Threading a Needle of Strategy, Technology, and Compliance

If you’ve ever looked for a new place to live, you may have come across these two types of homes: the one the landlord’s repainted so many times that the windows barely open, and the one that still smells like new carpet.

It’s unlikely that this is what leaders at a 100+ year-old global bank were thinking about when they decided to expand their offerings into digital services, but it is likely they sorted through similar considerations: Build on top of legacy infrastructure, or create something net-new?

The bankers wanted, specifically, to provide their customers with a retail banking experience for mobile devices. They’d successfully deployed the product in Europe and now wanted to bring this tested solution to their branches in other countries. The thinking went like this: If they started with a mature and comprehensive regulatory environment like the United States, then they’d be well prepared to handle regulatory challenges in Latin America and beyond.

Sounds simple enough. But to do so, bank leaders would need to thread a needle—give their US customers the simple, useful mobile experience they expected while, on the back end, navigating that thicket of requirements.

Requirements like those set by the Federal Reserve, the Securities and Exchange Commission (SEC), the Office of the Comptroller of the Currency (OCC), and the Consumer Financial Protection Bureau (CFPB).

Requirements, such as complying with the Dodd-Frank Act, the Bank Secrecy Act, and the Gramm-Leach-Bliley Act, which presume a thorough understanding of data privacy and localization, anti-money laundering (AML) practices, and consumer protection regulations, as well as technical considerations like robust cybersecurity measures to manage and protect sensitive financial data.

(But wait! For a foreign solution expanding into new markets, there were also more garden-variety considerations, like support for multiple languages, and adapting the product to local market practices and customer expectations, including the ability to download the offering as a mobile application or through a browser link.)

Complicated? You bet. And in the face of this, the bank leaders made a bold choice: opting to build their digital solution on a net-new, cloud-native platform—one they’d build and launch first in the United States, then roll out to other territories.

It was a bold choice because what the bankers were avoiding in ongoing legacy technology headaches, they were front-loading with a digital transformation. The choice meant significant challenges and layers of complexity that together could make the deployment both resource-intensive and time-consuming.

So, confident as they were in the path they’d chosen, the leaders were just as confident that they’d need an assist to get it all done. And not just in one area (like technology), but several (like strategy, policy, and compliance too). To make their vision a reality—and thread that needle—they called Deloitte.