DNB Carnegie wanted to move beyond traditional compliance to work smarter, faster, and in a way that benefits a customer-friendly experience. Here's how Trapets helps them.
DNB Carnegie is the leading Nordic Investment Bank with a strong international platform and is recognised for its client focus and commitment to service excellence.
Its Group Financial Crime Prevention (GFCP) organisation is both agile and thorough, ensuring regulatory compliance while maintaining a high-quality experience that customers expect.
Leading the bank’s GFCP organisation is Sophie Bahgat, an experienced leader in the Financial Crime Prevention area.
Her organisation handles all aspects of financial crime prevention, including AML/CTF, transaction monitoring, KYC, Market Surveillance, Financial Sanctions, and Anti-Bribery & Corruption controls, as well as providing advice and training to the Bank’s employees.
Operating with a lean structure, DNB Carnegie’s GFCP organisation must cover a broad scope, from strategic model development to operational investigations and management reporting to the Board.
“We’re a smaller bank, which means our GFCP organisation needs to be staffed with skilled and versatile expertise. Everyone needs to know a lot about a lot in the FCP area,” says Sophie.
The bank wanted to move beyond traditional compliance, not only to meet regulatory requirements but also to work smarter, faster, and in a way that benefits a customer-friendly experience.
"We always challenge our KYC-model setup: Can we fetch more KYC information from open sources or authorities and ask the customers a couple of fewer questions? At DNB Carnegie, we have a high-performing culture which is also reflected in our FCP work in the sense that we always encourage innovation and building smarter models."
DNB Carnegie has relied on Trapets for over a decade as its core platform for AML/CTF, screening, KYC, transaction monitoring, and market and trade surveillance.
When Sophie joined in November 2024, she immediately saw its potential and knew where to refine and optimise the setup.
“Trapets is at the centre of everything we do in Financial Crime Prevention. The beauty of having everything in one system is that when one risk factor changes, all parts update automatically. It all works in a risk-based harmony.”
During her first year, Sophie and her team restructured many modules and improved integrations, paving the way for a more dynamic, proactive compliance approach. They also visualised many aspects of the FCP work in Power BI dashboards, enabling the team to prioritise better, staff areas correctly, and track trends in their FCP models daily.
Trapets serves as the team’s central hub, “the sun everything else revolves around,” as Sophie puts it.
The system automatically sorts and prioritises cases based on a wide range of predefined high-risk factors, ensuring analysts spend time where it matters most.
“The KYC model does the groundwork when it comes to case prioritisation. The system’s many KYC triggers let the Bank use specific KYC data in its transaction monitoring as opposed to only revisiting it when it’s time for ODD. It’s efficient and in line with the purpose of the regulation.”
A wide range of KYC parameters is built directly into the Transaction Monitoring, improving precision, reducing false positives, and enriching the “scenario development toolbox”.
Trapets also supports DNB Carnegie’s surveillance of trading activity to help ensure compliance with the Market Abuse Regulation (MAR). DNB Carnegie utilises many synergies by including Market Surveillance in the GFCP organisation. There are a lot of synergies with the AML/CTF Transaction Monitoring.
“Having one vendor for the full suite is a huge advantage. Trapets has a holistic mindset, and so do we.”
The ability to build dynamic KYC forms and workflows allows DNB Carnegie to tailor the system to their processes.
“It’s customisable and flexible. We can take a new transaction monitoring scenario from the drawing board to up and running in an hour if we wanted to. We in the GFCP organisation execute many ongoing model changes by ourselves, which is a real strength. That gives us a good chance to keep up with the ever-changing risk environment.”
Sophie and her team are now working to complement the ongoing periodic due diligence (ODD) with more automated Perpetual KYC, providing continuous monitoring and real-time risk awareness powered by verified external data.
“Perpetual KYC is a good complement to the traditional ODD cycle. Financial institutions can no longer afford not to have always up-to-date customer information. There are no excuses, especially when there are plenty of KYC data sources available. We want to know immediately when certain red flags appear and quickly mitigate that newly emerged risk. That’s the future - fast-paced and proactive compliance.”
They are also exploring more API integrations with government and other open data sources to further automate and enrich KYC with verified real-time information.
“Authentic, verified data, beyond what the customer themselves state, is a prerequisite for future-proofing your compliance and taking responsibility for having good data to work with.”
Sophie sums up Trapets in a couple of words:
“Full circle. It’s a comprehensive workspace that's visually clear, easy to navigate, and designed to make information accessible. And it’s customisable, we can shape it to fit our exact needs.”
When asked what guidance she would give to other financial institutions considering a similar solution, Sophie emphasises the importance of preparation, particularly around data and structure, before implementation.
“Do your data groundwork properly,” she advises. “Structure your input data before you start, evaluate which data you want to use and how, because the system will only ever be as good as the data you feed it.”
She recommends that organisations map out their data and workflows before migrating to a new compliance platform:
“If you do this upfront, you’ll get much more value from the system from day one. The better your data foundation, the more powerful your compliance setup will be.”
DNB Carnegie’s partnership with Trapets shows how a smaller bank can leverage technology to achieve big-bank compliance capability, all while keeping the customer experience front and centre.
“We’re building for the future - automation, digitalisation, and smarter ways of working,” Sophie concludes.
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