Shaping how the bank operates from MiFID II

Three movements at once: translate and implement the regulation carefully, strengthen client trust and adjust the operational way of working. Every domain touched another, and every choice in one domain caused adjustments in another. On top of that lay a temptation that surfaces in every compliance project: tick everything off so it is formally in order, without anything getting better for the client. That looks like the fastest route, but it delivers an extra layer that then has to be staffed every day: procedures and controls that exist only to show that the bank is in order.

See clearly first, only then build. Instead of going straight into execution mode, a qualitative analysis came of the difference between the existing way of working and what the directive asked, domain by domain and process by process. Three questions ran through it each time: what do we deliberately keep in place, what do we change fundamentally, and where does it threaten to be formally in order without becoming better?

The Belgian work happened in close coordination with the foreign head office, while every country ran its own rollout, tailored to the national transposition of the directive. In the later phases, the bank-wide rollout in Belgium followed, divided over three workstreams: products, services, and transactions and registration.

The analysis delivered more than a list of differences: it gave the local team a sharp picture of what really had to shift. The central team forwarded the completed questionnaires to the other countries as an example of a thorough approach. From that moment the tone of the project changed. No longer something that had to happen, but something the organisation itself gave shape to.

The Belgian bank was in order with the directive on time. Just as valuable was what happened along the way: systems, processes, collaboration, roles and client focus were sharpened again, because the introduction of MiFID II was used as an occasion to look at how work is done. Regulation thus became a lever instead of an obligation.