iRace Digital (FundBank) · Client Onboarding and KYC

HST is rebuilding client on boarding
and KYC for iRace Digital (FundBank)

iRace Digital onboards institutional clients across three jurisdictions and several entity types. HST works across that whole estate: the shared data model everything sits on, the regulatory forms that run on top of it, and the move of the existing journeys onto the same foundation. This page sets out the onboarding workflows involved and what each one needs from the platform underneath.

The engagement

What HST is doing

iRace Digital, trading as FundBank, provides banking and fund services to institutional investors, fund structures and asset managers. Client entities sit in the United States, Luxembourg and the Cayman Islands, so onboarding has to satisfy three supervisory regimes at once.

Onboarding is where a bank’s financial crime obligations turn into software. Customer due diligence, beneficial ownership, sanctions and politically exposed person screening, source of funds, tax transparency and client categorisation are all asked of the same client at the same time, and evidenced on the same record.

HST works across the estate rather than on one deliverable. That covers the shared data and portal foundation, the digitisation of each regulatory form, keeping the existing live journeys running while the work happens, and leaving the bank’s own team a pattern they can extend themselves.

The approach is to treat onboarding as a family of related workflows rather than a set of separate forms. Once the shared parts exist, adding a new workflow is mostly configuration.

Onboarding workflows we build

The eight types of onboarding workflow in this estate

These look similar on a requirements document. They behave very differently once real clients use them, which is why they are worth separating.

Workflow typeWhat makes this one hardHow it is built
Institutional and fund entity onboarding
  • The number of parties,
  • and the roles they hold,
  • varies by client.
  • Jurisdictional routes overlap but not completely.
One record per party and role instead of numbered slots. Directors, beneficial owners, controllers, signatories and politically exposed persons are limited by the client's structure, not by the schema. Jurisdictional variation is handled with conditional steps on a shared journey rather than a separate front end per route.
Service provider and delegate capture
  • One organisation often holds two roles,
  • and each role carries its own regulatory registration and oversight evidence.
The same party model with a provider flag, covering administrator, auditor, custodian, prime broker, investment adviser, manager and legal counsel. Where one firm holds two roles, two role records point at the same organisation rather than copying its details onto the application.
Mandate, authority and approval rules
  • Every bank expresses payment authority differently,
  • and the rules change more often than the software.
Approval rules are held as records: transaction type, value band, approval condition and sequence, with authorised persons and their access rights alongside. New bands and approver combinations do not need a schema change, and the business can maintain the condition list itself.
Regulatory categorisation by assessment
  • The outcome has to be worked out from evidenced tests rather than picked by the client,
  • and the reasoning has to stand up years later.
A conditional questionnaire captures the qualifying tests and criteria and calculates the category. Any opt-up is stored as a separate confirmation. The conditional logic uses the platform's own rules rather than custom code.
Declaration and self-certification
  • One early answer changes the rest of the journey,
  • and the deepest branch nests repeating people inside repeating people.
Classification drives the flow. A passive entity opens the controlling persons branch, and the same tax residence component is reused for the account holder and for each controlling person, so the nesting reuses a module instead of needing new screens.
Documentary evidence and review
  • Documents expire,
  • get rejected,
  • get rejected,
  • get reissued and get reviewed again.
  • A single field holding the current file loses the history behind the decision.
A requirement record states what is needed and why it applies. Document records hold each version with its issue and expiry dates, review status, reviewer and comments. A reissued certificate does not overwrite the previous review.
Internal review, decision and escalation
  • The client-facing journey is only half the workflow.
  • Operations and Compliance need queues,
  • outcomes and an audit trail.
Review and decision records with assigned teams, outcomes, comments and dates, shown through the internal views the business already uses. Where automation fails it raises a visible exception instead of reporting success.
Remediating a live estate
  • The model is changing underneath journeys that are already running,
  • and feeding reports and flows that were never fully inventoried.
Legacy and modular routes run side by side in one environment. Active applications are not switched mid-journey. Domains move one route at a time and keep their legacy reference for traceability. Old structures come out only once forms, flows, reports and integrations no longer use them.
The number of parties and the roles they hold, varies by client.
Jurisdictional routes overlap but not completely

One record per party and role instead of numbered slots. Directors, beneficial owners, controllers, signatories and politically exposed persons are limited by the client’s structure, not by the schema. Jurisdictional variation is handled with conditional steps on a shared journey rather than a separate front end per route.

One organisation often holds two roles, and each role carries its own regulatory registration and oversight evidence.
The same party model with a provider flag, covering administrator, auditor, custodian, prime broker, investment adviser, manager and legal counsel. Where one firm holds two roles, two role records point at the same organisation rather than copying its details onto the application.
Every bank expresses payment authority differently, and the rules change more often than the software.
Approval rules are held as records: transaction type, value band, approval condition and sequence, with authorised persons and their access rights alongside. New bands and approver combinations do not need a schema change, and the business can maintain the condition list itself.
The outcome has to be worked out from evidenced tests rather than picked by the client, and the reasoning has to stand up years later.
A conditional questionnaire captures the qualifying tests and criteria and calculates the category. Any opt-up is stored as a separate confirmation. The conditional logic uses the platform’s own rules rather than custom code.
One early answer changes the rest of the journey, and the deepest branch nests repeating people inside repeating people.
Classification drives the flow. A passive entity opens the controlling persons branch, and the same tax residence component is reused for the account holder and for each controlling person, so the nesting reuses a module instead of needing new screens.
Documents expire, get rejected, get rejected, get reissued and get reviewed again.
A single field holding the current file loses the history behind the decision.
A requirement record states what is needed and why it applies. Document records hold each version with its issue and expiry dates, review status, reviewer and comments. A reissued certificate does not overwrite the previous review.
The client-facing journey is only half the workflow. Operations and Compliance need queues, outcomes and an audit trail.
Review and decision records with assigned teams, outcomes, comments and dates, shown through the internal views the business already uses. Where automation fails it raises a visible exception instead of reporting success.
The model is changing underneath journeys that are already running, and feeding reports and flows that were never fully inventoried.
Legacy and modular routes run side by side in one environment. Active applications are not switched mid-journey. Domains move one route at a time and keep their legacy reference for traceability. Old structures come out only once forms, flows, reports and integrations no longer use them.

Why we separate them. A team that has only built the first type tends to model the fifth the same way. The branching, the nesting and the audit requirements then turn up part-way through the build. Working out which type you are dealing with before the data model is written avoids most of that.

The shared foundation

One model and every workflow sits on it

The application record stays narrow and holds the journey. Everything that repeats (parties, addresses, identifiers, activity profiles, documents, form answers) is held as related records. Adding a workflow adds records rather than columns.

What we test the design against. 

A new form, or a newly migrated domain, should be deliverable by adding one small typed table and standard configuration, reusing the existing submission, security and review patterns. No new question columns on the application record, and no custom front end.

Domain expertise applied

What each regulatory discipline needs from the model

Onboarding architecture only holds up if each structure traces back to the obligation it serves. This is the mapping the design works to.

Ownership and control percentages, party type and screening status held per party and role, with no ceiling on how many of them a structure can have.

A record per direction, channel, currency and period, covering wires, ACH and digital asset movements, with expected volumes and counterparty countries. This is the baseline monitoring is later calibrated against.

Classification, registration number or the reason none is held, and the declaration, over unlimited tax residence and controlling person records with their own residences and indicia.

A category reached by evidenced test rather than by assertion, with any opt-up stored as an explicit confirmation.

Value bands, approval conditions and approver combinations held as data, so a change to the bank’s mandate policy is a configuration change rather than a release.

Strategy, asset class, geography and allocation held as structured records, so jurisdictional exposure can be queried rather than parsed out of free text.

Issuing country and authority, validity dates and status per identifier, with field-level security where the data is sensitive.

Deletion restricted on application-scoped records, with rows deactivated or superseded instead. Migrated records keep their legacy reference so their history survives the migration.

How the work is sequenced

Reversible at every step, because the estate is live

Changing onboarding while clients are mid-application is mostly a sequencing problem. This order keeps each step reversible.

Classify before moving anything

01
database
Every existing field is classified as keep, move, derive, retire or defer. The forms, flows, views, reports and integrations that use it are identified first, so nothing moves before its dependencies are known.

Build the foundation without touching the journey

02
datatbase_license_renewal
Related tables, relationships, ownership behaviour, security roles and portal permissions are deployed and tested while the existing routes carry on unchanged.

Prove it on new workflows first

03
Search
New regulatory forms launch on the shared foundation, so the pattern is tested against real submissions before any existing data moves.

Migrate one domain, one route at a time

04
Search
A single domain moves for a single route and is checked against real onboarding data before being extended in business priority order. Legacy structures go read-only for an agreed period and are removed only after dependency, audit and retention checks.

Hand over a repeatable pattern

05
Search
A build checklist covering naming, form creation, permissions, submission states and reusable modules, so the bank's own team can add the next workflow with standard platform skills.

Where it goes next

What the same foundation is built to carry

Building for the family rather than the form is what makes the next workflow cheap. These are the ones the existing patterns already support.

Each is a small typed record plus standard configuration on the shared submission, security and review patterns. No custom front end, and no regression risk to the forms already live.

A review cycle has the same structure as an onboarding one: a submission, changed child records, evidence and a decision. Because history is kept rather than overwritten, a refresh can show what actually changed since the last one.

Enhanced measures attach to the party or relationship that triggered them rather than to one flag on the application, so a higher-risk party carries its own evidence requirements and review path.

Missing or expired evidence across a book of clients becomes a queue of requirement records with owners and due dates, rather than a spreadsheet somebody maintains by hand.

A new supervisory regime becomes conditional steps and jurisdiction-specific requirement rules on the shared journey, rather than a fourth parallel front end to keep in sync with the other three.

No custom questionnaire engine and no plug-in-heavy application, so the bank’s makers can extend the solution with standard Power Platform skills.

The vocabulary we work in

Onboarding terms, and what the model has to do about them

person

UBO

Ultimate beneficial owner. The natural persons who ultimately own or control the client. The number varies by structure, so the model cannot cap it.
solution-raod-map-icon

PEP

Politically exposed person. A status held against a party, with its own screening history, rather than one flag on the application.
cloud-1

CDD / EDD

Customer and enhanced due diligence. Enhanced measures apply to a particular relationship or party, so the model has to express them at that level.
companies

FATCA / CRS

The US and OECD tax transparency regimes. Both need tax residences, plural, for the account holder and for each controlling person.
Vector-1-1

Passive NFE

A passive non-financial entity. Choosing it opens the controlling persons branch, which is the largest source of nested repeating data in a self-certification.
iso

MiFID II professional client

A category worked out from evidenced tests rather than declared by the client. The tests and the resulting category both have to be stored.
al-opport-icon

Elective professional

A retail client opting up and giving up some protections. The opt-up has to be confirmed explicitly and kept.
sla

LEI / GIIN

Entity and financial institution identifiers. Each has its own issuing authority, validity dates and status, so they are held as records rather than text fields.
trams

Four-eyes

No one person can both raise and approve. In onboarding this comes out as approval rules and authorised person records.
Insurance

Periodic review

The scheduled re-check of an existing relationship. Structurally it is onboarding again, for clients already on the book.

Financial services domain expertise

The disciplines behind this work
Our financial services work is organised around the regulated disciplines below rather than around a technology stack. The highlighted ones are used directly on this engagement.
01

Client onboarding &
financial crime

KYC / CDD
Enhanced due diligence
Beneficial ownership
PEP & sanctions screening
AML
Transaction monitoring
KYT / blockchain analytics
Travel Rule
Client lifecycle management
02

Regulatory & tax

FATCA
OECD CRS
MiFID II client categorisation
Record keeping & retention
Audit evidence
Regulatory data architecture
03

Banking operations &
control

Books & records
Position keeping & valuation
End-of-day close
Reconciliation
Four-eyes / maker-checker
Mandate & payment authority
Settlement orchestration
04

Custody & platform
engineering

Custody operating model
Vault & wallet lifecycle
Address whitelisting
Deposit quarantine
Key custody & MPC
Threshold cryptography ops
Cloud landing zone & SRE
Highlighted disciplines are used on this engagement. This page covers the custody infrastructure part of that list. The onboarding, financial crime and banking operations work sits in the same practice, with the same team.

Looking at your own onboarding estate?

If the model is limiting how many beneficial owners you can record, or how long a new regulatory form takes to launch, the problem is usually underneath the form. We have spent a long time in that layer.
COMMON QUESTIONS

Frequently asked questions

Client onboarding and KYC involve collecting and validating information about institutional clients, including customer due diligence, beneficial ownership, sanctions and PEP screening, source of funds, tax transparency and client categorisation.

iRace Digital provides a client onboarding and KYC foundation for institutional clients, covering shared data, regulatory forms, onboarding workflows, review processes and the migration of existing client journeys.

The onboarding estate supports institutional clients across the United States, Luxembourg and the Cayman Islands, with jurisdiction-specific requirements handled within shared onboarding journeys.

The platform supports institutional and fund entity onboarding, service provider and delegate capture, mandate and approval rules, regulatory categorisation, declaration and self-certification, documentary evidence and review, internal review and escalation, and remediation of existing live workflows.

The data model records parties and their roles, including directors, beneficial owners, controllers and signatories. It is designed to support varying numbers of parties based on the client’s structure rather than using a fixed number of fields.

Requirements are stored according to what is needed and why it applies. Document records maintain versions, issue and expiry dates, review status, reviewer information and comments, allowing previous reviews to remain traceable when documents are reissued.

The model covers areas including KYC/CDD, enhanced due diligence, beneficial ownership, AML, FATCA, OECD CRS, MiFID II client categorisation, mandate control, record keeping and regulatory data architecture.

The shared platform foundation uses Microsoft Dataverse, Power Pages, Power Automate and Dynamics 365, with a no-code-first approach.

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