Overview
When MUFG Bank Ltd needed to remediate its customer base across both its London branch and MUFG Securities EMEA PLC, it required genuine KYC expertise - not generalist compliance support. The added complexity: the programme ran under remote working conditions, with limited scope for traditional knowledge transfer. emagine assembled a specialist SME team, onboarded them through a structured remote process, and embedded them directly into the bank's KYC function. The full programme, covering both Bank and Securities populations, completed on time and to FCA compliance standards throughout.
The Challenge
For financial institutions operating in the UK, FCA requirements on KYC and anti-money laundering create a continuous compliance obligation. Customer files need periodic review. High-risk relationships require enhanced due diligence. And when a remediation programme is triggered (whether by a regulatory directive, an internal audit finding, or a change in risk appetite) the workload is significant, the timeline is fixed, and the accuracy bar doesn't move.
MUFG Bank Ltd faced exactly this situation. Operating through a London branch and its securities subsidiary MUFG Securities EMEA PLC, the bank needed to review and renew its customer base — covering both high-risk and medium/low-risk populations to meet FCA requirements. The programme called for specialist KYC SME capability, not generalist compliance support.
One further complication: the programme ran during a period when in-person working remained restricted. The team needed to be assembled, onboarded to the bank's systems, and operationally productive under remote working conditions, with limited scope for traditional knowledge transfer.
The Solution
emagine was appointed under a formal Statement of Work to supply an SME KYC team covering both MUFG Bank Ltd and MUFG Securities EMEA PLC. The dual-entity scope meant the team needed analysts with the range to work across both entities, rather than specialists focused on one.
Phase 1: Assembling the team
The team was recruited specifically for the engagement, assessed against the technical requirements of FCA-standard KYC renewals and the ability to handle the dual-entity scope. The hiring process prioritised depth over speed: the bank needed analysts who could work independently with limited oversight, not a team that needed close management to reach the required standard.
Phase 2: Knowledge transfer under constraints
With remote working in place, the usual approach of sitting alongside existing team members wasn't available. The consultants worked through a structured remote knowledge transfer instead: reviewing the bank's systems and processes, documenting findings, identifying risks, and building working familiarity with the bank's procedures before taking on live cases.
Treating knowledge transfer as an active review rather than passive onboarding meant the team went into production with a good understanding of where the process risks sat and how to handle the edge cases that tend to slow remediation programmes down.
Phase 3: Delivery and governance
The team operated as part of the bank's KYC function, handling the full case review process: customer identification and verification, due diligence assessment, documentation review, and case completion to the FCA compliance standard. Quality governance followed emagine's standard framework — risk-weighted sampling, error classification by severity, and rework within 24 hours of identification.
The programme ran from February to August 2022, covering both the Bank and Securities populations within the contracted scope.
Transformation timeline
Phase 1
Assembling the team
Phase 2
Knowledge transfer under constraints
Phase 3
Delivery and governance
The Results
The remediation programme completed within the contracted timeline. The quality governance framework kept accuracy at the level required for FCA compliance throughout. The dual-entity scope (covering both MUFG Bank Ltd and MUFG Securities EMEA PLC) was managed within a single team structure, avoiding the overhead of running two separate workstreams. Likewise, the remote delivery model worked. The structured knowledge transfer approach and the seniority of the analysts placed meant the team could operate at the level of independence the programme required, flagging issues through the right channels rather than waiting for direction.
Real KYC Depth
Proven SME expertise across Bank and Securities — ready to deliver from day one.
Independent by design
Fully capable of operating independently and effectively, even in remote conditions.
FCA standards maintained
FCA-compliant quality upheld consistently and rigorously, from first day to last.
Delivered on time
The programme completed in full and on schedule. Exactly as planned, no exceptions.