Skip to content

FEC Platform — Requirements Inventory

Synthesized from 4 client documents (3,748 lines, 231 sections across business concept, ecosystem blueprint, onboarding spec, and engineering spec). This document feeds the PRD. It extracts, categorizes, and prioritizes — it does not make final scope decisions. Those belong to the PRD.


1. Business Goals & Strategic Objectives

1.1 Primary Goals (from Business Concept + Blueprint)

Goal Rationale
Prevent onboarding of prohibited entities Regulatory non-negotiable
Comply with AML/CTF obligations Legal requirement for any FI
Comply with sanctions regulations OFAC, EU, UN, local lists
Establish accurate customer master data Foundation for all downstream controls
Assign risk-based controls proportionally Risk-based approach required by FATF
Ensure consistency of decision-making One customer, one risk view
Support auditability and regulatory review Must reconstruct any decision from 5+ years ago

1.2 Secondary Goals

Goal Source
Reduce onboarding cycle time Business Concept, Onboarding Spec
Reduce analyst inefficiency Business Concept
Improve customer experience (low-risk = low friction) Business Concept
Minimize false escalations Engineering Spec
Standardize enterprise workflows Blueprint
Reduce duplicated customer reviews Business Concept
Better management visibility through MI/KPIs Blueprint

1.3 Strategic Vision

"Move from siloed compliance tooling to enterprise financial crime orchestration." "A Financial Crime Operating System — not an AML application, not a sanctions tool, not a workflow product."

  • Shared customer intelligence across all FEC processes
  • Consistent governance
  • Reusable decision capabilities (modules)
  • Configurable business-line workflows
  • Modular operational expansion

2. MVP Boundary Recommendation (from Engineering Spec)

2.1 In MVP

Domain P0 Priority Source
Customer Onboarding workflow P0 All 4 docs
Name Screening P0 All 4 docs
Customer Risk Rating P0 All 4 docs
Basic Network Analysis (ownership graph, linked entities) P0 Engineering Spec
Case Management (analyst workspace) P0 All 4 docs
Configuration Engine (workflows, thresholds, rules without code) P0 Blueprint + Engineering Spec
Audit Trail (immutable, append-only) P0 Blueprint + Engineering Spec
RBAC P0 Engineering Spec
Escalation workflow P0 All 4 docs

2.2 Explicitly Excluded from MVP

Domain Priority Reason
Transaction Monitoring P1 Complexity; needs event ingestion pipeline first
Transaction Screening P1 Real-time payment controls; separate infrastructure
SAR/STR Filing Automation P1 Needs transaction monitoring foundation
Fraud Modules P2 Separate domain; architecturally supported not built
Advanced ML Pipelines P2 Premature without data and baseline rules
Multi-jurisdiction Regulatory Engines P2 Start with one jurisdiction, generalize later
AI Copilots P2 Aspirational; needs stable platform first
Adverse Media NLP P2 Depends on external data sources

2.3 Process Scope in MVP

From the onboarding specification — Customer Onboarding is the primary MVP process:

Supported Variants In MVP
Retail Individual Yes
SME Yes
Corporate Yes
Correspondent Banking Yes
Private Banking Yes
Leasing / Specialized Configurable template

Other lifecycle processes (periodic review, event-driven review, offboarding) are P1 — defined after MVP.


3. Functional Requirements by Domain

3.1 Workflow Orchestration

ID Requirement Priority Source
WF-01 Configurable workflow templates (no code deployment required) P0 Blueprint §7, Eng Spec §3.1
WF-02 Dynamic branching based on risk scores P0 Onboarding §9
WF-03 Parallel task execution (e.g., screening + risk rating simultaneously) P0 Onboarding §9.2
WF-04 Human task creation (manual approvals, reviews) P0 Onboarding §4.1
WF-05 SLA timers with breach actions (reminder → escalation → reroute) P0 Onboarding §11
WF-06 Retry policies for failed module executions P0 Eng Spec §7
WF-07 Compensation/rollback logic P1 Eng Spec §7
WF-08 Subprocess insertion P1 Onboarding §12
WF-09 Workflow versioning (running instances continue on old version) P1 Blueprint §7

3.2 Customer Onboarding (Primary MVP Process)

ID Requirement Priority Source
ON-01 Application intake with customer classification P0 Onboarding §6, §8
ON-02 Data capture: identity, legal entity, ownership, business purpose P0 Onboarding §7
ON-03 Document collection with mandatory/optional logic per customer type P0 Onboarding §8
ON-04 Identity validation (individual + legal entity) P0 Onboarding §9
ON-05 UBO identification and ownership capture P0 Onboarding §9
ON-06 State machine: NEW → INTAKE → DATA_COLLECTION → … → APPROVED/REJECTED P0 Onboarding §8
ON-07 Configurable document requirements per customer type and jurisdiction P0 Onboarding §12
ON-08 Fast-track path for low-risk customers P0 Onboarding §9.2
ON-09 Remediation loop for incomplete documentation P0 Onboarding §9.2
ON-10 Customer status: approved, approved with restrictions, rejected, withdrawn, prohibited P0 Onboarding §2.1, §6.2

3.3 Name Screening

ID Requirement Priority Source
NS-01 Match customer identity against sanctions lists P0 Blueprint §3.2
NS-02 Match against PEP lists P0 Blueprint §3.2
NS-03 Match against internal watchlists P0 Blueprint §3.2
NS-04 Exact match and fuzzy match P0 Eng Spec §9
NS-05 Alias matching P0 Eng Spec §9
NS-06 Transliteration support P1 Eng Spec §9
NS-07 Match disposition: no-match, potential-match, confirmed-match P0 Blueprint §3.2
NS-08 Auto-disambiguation for obvious false positives P1 Blueprint §3.2
NS-09 Analyst triage and adjudication workflow P0 Blueprint §3.2
NS-10 Integration with external sanctions data providers P0 Onboarding §13

3.4 Customer Risk Rating

ID Requirement Priority Source
RR-01 Configurable rules engine (not hardcoded) P0 Eng Spec §10
RR-02 Risk factors: geography, customer type, ownership complexity, PEP exposure, product exposure P0 Eng Spec §10, Business Concept §7
RR-03 Output: Low / Medium / High risk bands P0 All docs
RR-04 Rationale trace — every contributing factor explainable P0 Eng Spec §10
RR-05 Methodology versioning P0 Blueprint §7
RR-06 No ML initially (rules-based only for MVP) P0 Eng Spec §10
RR-07 Risk reassessment on data change P1 Blueprint §3.1

3.5 Case Management

ID Requirement Priority Source
CM-01 Case creation from workflows (onboarding review, screening escalation, etc.) P0 Blueprint §3.4
CM-02 Queue management with assignment and reassignment P0 Onboarding §4.1, §12
CM-03 Case lifecycle: created → assigned → investigating → escalated → decided → closed P0 Blueprint §3.4
CM-04 Evidence aggregation and attachments P0 Blueprint §6
CM-05 Case notes (timeline, not overwrite) P0 Blueprint §6
CM-06 Escalation routing within case (Level 1-5) P0 Onboarding §10
CM-07 Decision logging with rationale and actor P0 Blueprint §3.4
CM-08 SLA tracking and breach notifications P0 Onboarding §11
CM-09 Single-pane analyst workspace (customer profile + alerts + evidence + decisions) P0 Blueprint §11
CM-10 Case types: onboarding review, sanctions investigation, customer review, EDD review, QA review P0 Business Concept §9

3.6 Network Analysis (MVP Scope)

ID Requirement Priority Source
NA-01 Ownership graph visualization (parent → child → subsidiaries) P0 Eng Spec §11
NA-02 Linked entity discovery (shared addresses, directors, identifiers) P0 Eng Spec §11
NA-03 Relationship traversal (who owns what and through whom) P0 Eng Spec §11
NA-04 Do NOT build advanced graph intelligence in MVP P0 (constraint) Eng Spec §11

3.7 Configuration Engine

ID Requirement Priority Source
CF-01 Workflow definitions configurable without code P0 Blueprint §7, Eng Spec §3.1
CF-02 Threshold management (risk score cutoffs, SLA timers) P0 Blueprint §7
CF-03 Approval matrices (who approves what, at what level) P0 Blueprint §7
CF-04 Document requirement rules (by customer type, jurisdiction, product) P0 Blueprint §7
CF-05 Routing rules (who gets which case, based on what criteria) P0 Blueprint §7
CF-06 Configuration versioning with promotion pipeline (dev → test → prod) P0 Blueprint §7
CF-07 Rollback capability P0 Eng Spec §13
CF-08 Configuration change audit trail P0 Eng Spec §13
CF-09 Impact analysis before promotion P1 Blueprint §7

3.8 Escalation

ID Requirement Priority Source
ES-01 5-level escalation model (analyst → senior → EDD → compliance → executive) P0 Onboarding §10, Blueprint §4
ES-02 Configurable escalation triggers (risk score, sanctions hit, PEP, missing docs, etc.) P0 Onboarding §10
ES-03 Routing by business line, jurisdiction, alert type, risk score, workload, analyst skill P0 Blueprint §4
ES-04 Escalation deadline management with breach actions P0 Onboarding §11
ES-05 Segregation of duties enforcement in escalation chain P0 Blueprint §4

3.9 Audit & Governance

ID Requirement Priority Source
AU-01 Immutable, append-only audit log P0 Eng Spec §15, Blueprint §8
AU-02 Track: who, what, when, why, source inputs, config version, module outputs P0 Eng Spec §3.4
AU-03 Every workflow state transition logged P0 Onboarding §15
AU-04 Every decision logged with rationale P0 Onboarding §15
AU-05 Every module invocation logged (request + response) P0 Blueprint §5
AU-06 Every configuration change logged P0 Eng Spec §15
AU-07 Deterministic replay — reconstruct any decision from N years ago P0 Eng Spec §16, Blueprint §8
AU-08 Segregation of duties enforced (analyst ≠ approver ≠ auditor) P0 Business Concept §10, Onboarding §14
AU-09 Four-eyes principle for high-risk decisions P0 Business Concept §10
AU-10 Override governance — every override logged with justification P0 Onboarding §12
AU-11 Policy version traceability — which policy version was active at time of decision P1 Onboarding §3

4. Non-Functional Requirements

4.1 Performance

ID Requirement Source
NF-01 Responsive UI — analyst workflows must not block Onboarding §16
NF-02 Screening response within seconds Onboarding §11 (30min SLA for analyst review implies near-real-time screening)
NF-03 Concurrent workflow execution — multiple analysts processing simultaneously Onboarding §16

4.2 Security

ID Requirement Source
NF-04 Role-Based Access Control (RBAC) All docs
NF-05 Multi-Factor Authentication (MFA) Onboarding §14, Blueprint §9
NF-06 Encryption in transit (TLS) Onboarding §14, Blueprint §9
NF-07 Encryption at rest Onboarding §14, Blueprint §9
NF-08 Field-level access control for sensitive data Onboarding §14
NF-09 Privileged access monitoring Onboarding §14
NF-10 SSO readiness Eng Spec §14

4.3 Reliability

ID Requirement Source
NF-11 Retry logic for failed module executions Eng Spec §7
NF-12 Graceful degradation when external services unavailable Onboarding §16
NF-13 High availability — platform remains operational during failures Blueprint §13

4.4 Observability

ID Requirement Source
NF-14 Structured logging Blueprint §13
NF-15 Metrics (workflow throughput, SLA breaches, decision volumes) Blueprint §13
NF-16 Distributed tracing for request correlation Blueprint §13

4.5 Maintainability

ID Requirement Source
NF-17 Modular architecture — each capability independently deployable Onboarding §16, Blueprint §13
NF-18 Configuration changes must not require code deployment Eng Spec §3.1
NF-19 Versioned APIs Eng Spec §16

4.6 Usability

ID Requirement Source
NF-20 Low click count for analyst tasks Onboarding §16, Blueprint §13
NF-21 Intuitive workflows — analysts should not need training for basic tasks Blueprint §13
NF-22 Single-pane investigation view (customer + alerts + evidence + decisions in one place) Blueprint §11

4.7 Compliance & Retention

ID Requirement Source
NF-23 Audit records retained per regulatory minimum (5-10 years depending on jurisdiction) Onboarding §3, Blueprint §8
NF-24 Evidence preservation — documents linked to decisions Onboarding §3.2
NF-25 Data privacy compliance (GDPR, local equivalents) Blueprint §8

5. Integration Surface

5.1 Internal Integrations (within FEC platform)

From To Purpose
Onboarding workflow Name Screening Screen customer at onboarding
Onboarding workflow Risk Rating Calculate customer risk score
Onboarding workflow Network Analysis Map ownership structure
Case Management Audit Service Log all case actions
Configuration Engine All modules Supply active config version

5.2 External Integrations

Integration Purpose Priority
Sanctions list providers (OFAC, EU, UN) Name screening data source P0
PEP list providers PEP detection P0
Corporate registries Legal entity verification P0
Identity verification providers Individual identity validation P0
CRM Customer relationship context P1
Customer Master Existing customer records P1
IAM / SSO Authentication and authorization P1
Document repository Secure document storage P1

6. User & System Actors

6.1 Human Roles (from Onboarding Spec §4.1 + Blueprint)

Role Primary Responsibility
Relationship Manager Commercial initiation; provides business context
Onboarding Specialist Intake review; workflow initiation; document coordination
KYC Analyst Customer verification; document validation; ownership review
Sanctions Analyst Screening adjudication; true hit confirmation
EDD Analyst Deep due diligence; ownership complexity; source of wealth
FCC Reviewer High-risk approvals; policy exceptions; sanctions governance
Supervisor Workload balancing; SLA monitoring; escalation handling
Audit Reviewer Process verification; control assurance; reconstruction

6.2 System Actors (from Onboarding Spec §4.2 + Blueprint §5)

System Actor Function
Workflow Orchestration Engine Drives process state transitions
Customer Classification Engine Determines customer archetype and template
Document Validation Engine Validates mandatory/optional documents
Identity Verification Service Validates individual and entity identity
Name Screening Engine Matches against watchlists
PEP Screening Engine Detects politically exposed persons
Customer Risk Rating Engine Calculates risk score and band
Entity Resolution Engine Links related entities
Network Analysis Service Maps ownership and relationships
Notification Engine Sends reminders, escalations, customer comms
Audit Service Records all events immutably
Policy Validation Engine Enforces config version compliance
Configuration Engine Serves active config to all modules

7. Domain Model — Canonical Entities

From the Onboarding Spec §7 and Blueprint §6, the following entities recur across all documents:

Entity Core Purpose In MVP
Customer Top-level party (individual or organization) P0
Individual Natural person (officers, UBOs, retail customers) P0
LegalEntity Registered organization P0
OwnershipRelationship Parent → child with ownership % and control type P0
Account Financial account linked to customer P0
Document Identity docs, incorporation certs, etc. P0
ScreeningResult Output of name/sanctions screening P0
RiskAssessment Risk score, band, factors, methodology version P0
WorkflowInstance Running instance of a workflow template P0
Task Work item assigned to a human or system P0
Decision Formal decision (approve, reject, escalate) with rationale P0
Case Investigation container linking tasks, evidence, decisions P0
Alert Generated by monitoring/screening modules (P1 — post-MVP) P1
Transaction Financial transaction (P1 — needed for tx monitoring) P1
RegulatoryFiling SAR/STR filing record (P1) P1

8. Key Terminology

Term Definition Source
FEC Financial Economic Crime All docs
KYC Know Your Customer All docs
CDD Customer Due Diligence Onboarding §3
EDD Enhanced Due Diligence (deep investigation for high-risk) Onboarding §3
UBO Ultimate Beneficial Owner All docs
PEP Politically Exposed Person All docs
SAR / STR Suspicious Activity Report / Suspicious Transaction Report Blueprint §3.5
SoD Segregation of Duties Onboarding §3.2
AML / CTF Anti-Money Laundering / Counter-Terrorist Financing All docs
Bounded Context DDD term: a logical boundary within which a domain model applies Eng Spec §3.6
Decision Module A pluggable analytical capability with a standard contract Blueprint §5
Configuration over Code Business rules changeable without software deployment Eng Spec §3.1

9. Open Questions & Ambiguities (from Client Docs)

These need resolution in the PRD or architecture phase:

# Question Why It Matters
1 Is this a single-tenant or multi-tenant platform? The docs mention "multi-institution deployment capability" (Blueprint §1.2) but also suggest a single institution context. Drives data isolation, deployment model, and RBAC design
2 Which jurisdiction's regulations apply first? The docs reference multiple jurisdictions but don't specify a starting point. Determines onboarding rules, retention periods, reporting obligations
3 What's the expected volume? (customers/day, concurrent analysts, screening requests/sec) Sizing for infrastructure and performance targets
4 How deeply should the "network analysis" go? Docs say "basic" for MVP but don't define the cutoff. Risks scope creep
5 Is there an existing customer master system to integrate with, or is this greenfield? Drives data migration and integration complexity
6 The escalation model has 5 levels — are all 5 needed in MVP or are levels 4-5 P1? Simplifies first delivery
7 What's the deployment target? Cloud? On-prem? Both? The Eng Spec says "cloud-agnostic" and "on-prem" — these are very different operational models. Drives infrastructure choices and CI/CD design
8 Should the MVP support only customer onboarding as a process, or should periodic review be included? Defines the minimum viable process surface
9 Real-time screening vs. batch? The onboarding process uses near-real-time, but transaction screening (post-MVP) is real-time. Temporal vs. streaming architecture decisions

10. Summary of What Feeds the PRD

PRD Section Informed By
Executive Summary §1 — Business Goals, §1.3 — Strategic Vision
Product Scope & MVP §2 — MVP Boundary, §9 — Open Questions
User Personas §6 — Human & System Actors
Functional Requirements §3 — Requirements by Domain
Non-Functional Requirements §4 — NFRs
Domain Model §7 — Canonical Entities
Integrations §5 — Integration Surface
Compliance Requirements §4.7 — Compliance & Retention
Risks & Open Items §9 — Open Questions

Inventory compiled from: - FecEcosystemBusinessConceptDocument.md (734 lines) - EnterpriseFecEcosystemBlueprint.md (1,040 lines) - CustomerOnboardingEnterpriseSpecification.md (1,062 lines) - EnterpriseFecPlatformEngineeringSpec.md (912 lines)

Total source: 3,748 lines / 231 sections across 4 documents.