Overview
Access Bank Group operates across 13+ African countries through subsidiary banks. Each subsidiary had its own loan approval process; some manual, some partially automated, but none consistent with the Group standard. This created compliance exposure at Group level, inconsistent customer experience, and delays in FX reconciliation when interbank transfers were involved in multi-country loan structures. I was engaged to lead the requirements work for cross-border loan approval RPA; standardising the workflow while accommodating each market's regulatory requirements.
Challenge
The complexity was not technical; it was regulatory and organisational. Each African country has its own banking regulator, its own KYC requirements, its own credit bureau landscape, and its own documentation standards for loan applications. A bot that worked for Nigeria would not work for Rwanda without adaptation. The challenge was to design a "core plus local variant" architecture where the automation framework was standardised but each market's regulatory specifics were handled through configurable rules.
Markets covered included Congo (DRC), Rwanda, Gambia, Cameroon, and Kenya; each with distinct regulatory frameworks, currency considerations, and local language requirements.
My Approach
- Conducted requirements workshops with subsidiary operations teams in each market (remote and on-site where possible)
- Mapped the Group-standard loan approval workflow and identified the 8 stages where local regulatory rules diverged
- Designed a "core plus local variant" RPA architecture; documenting the standard bot specification and a per-market configuration guide
- Authored local regulatory compliance appendices for each market: Congo (BCC requirements), Rwanda (NBR standards), Gambia (CBG framework), Cameroon (COBAC rules), Kenya (CBK regulations)
- Coordinated Group Compliance, subsidiary operations, and Group IT alignment on the final specification
- Led UAT sessions with each subsidiary team before market-specific deployment
- Produced post-deployment handover documentation and training materials for subsidiary BA teams
Market Regulatory Highlights
- Congo (DRC): BCC-compliant KYC documentation, French-language output requirements
- Rwanda: NBR credit bureau integration, RWF currency handling
- Gambia: CBG simplified KYC tier system for retail loans
- Cameroon: COBAC dual-currency (XAF/USD) loan structuring rules; 60% faster KYC achieved
- Kenya: CBK consumer credit regulation, CRB integration requirement