Compliance by design
Translating complex financial regulation into a scalable ownership framework.
Client: Guideline
Role: Staff Product Designer
Date: Apr – Aug 2025
TL;DR
I led the design of an ownership verification experience to meet new FinCEN AML (anti-money laundering) requirements, balancing strict regulatory compliance with onboarding conversion through research-driven strategy and cross-functional alignment.
Overview
In 2024, updated FinCEN Customer Due Diligence (CDD) rules required broker-dealers to collect and verify beneficial ownership information for all entity customers. As Guideline looked to become a registered broker-dealer (a regulated entity authorized to buy and sell securities), we needed to implement enhanced Know Your Customer (KYC) standards across both new and existing retirement plan sponsors.
This required collecting:
All beneficial owners (25%+ ownership)
A designated control person
Personal identifying information (PII) for each individual
Recursive ownership details when entities owned other entities
Failure to collect this information would legally prevent accounts from being opened or maintained, creating both regulatory risk and operational impact.
The challenge: introduce legally mandated friction into one of the most conversion-sensitive parts of the product, plan onboarding, without meaningfully harming trust or completion rates.
The design process
Reframing the problem
This was not a simple form redesign — it was the introduction of a new compliance capability into a live onboarding funnel. Early in discovery, I needed to quickly build fluency in broker-dealer AML and FinCEN Customer Due Diligence requirements. To accelerate understanding, I leveraged AI-assisted synthesis tools to break down dense regulatory language into structured requirement maps, which I then validated in close partnership with Legal and Compliance.
Through that discovery process, an important structural insight emerged: while regulations support deeply nested ownership hierarchies, the majority of U.S. small businesses (over 80%) are directly owned by individuals. Designing primarily for the complex edge case would have imposed unnecessary cognitive load on most customers.
Instead, I reframed the system architecture around the most common ownership pattern, while safely supporting recursive entity structures when required. This systems-level decision reduced overwhelm without sacrificing regulatory completeness and became the foundation for the experience.
Concept A: Surface all owners upfront, add details later
Concept B: Progressively identify ownership as the need arises
Driving alignment through research
When I joined this initiative, the project manager already had a predefined solution direction in mind. Rather than positioning this as a conflict, I treated it as one viable hypothesis among several. To shift the conversation from preference to performance, I proposed structured usability testing across competing mental models.
I conducted 10 moderated sessions with small business owners, evaluating two fundamentally different approaches: a progressive branching workflow that dynamically revealed ownership complexity as needed, and a centralized ownership declaration model that surfaced all requirements upfront.
I assessed emotional response to sensitive PII requests, clarity of terminology such as “beneficial owner” and “control person,” cognitive load, error patterns, and confidence before submission. The results were decisive: 90% of participants preferred the progressive model, citing lower overwhelm and greater clarity. Participants consistently responded more positively when complexity was introduced incrementally rather than presented all at once.
By grounding the decision in observed behavior rather than opinion, I aligned stakeholders around the research findings and established the progressive model as the foundation for the final design. This shift from debate to evidence was pivotal in maintaining momentum within a tight three-month timeline.
Designing for trust in high-friction moments
Because we were requesting highly sensitive data including SSNs, dates of birth, and home addresses, the emotional layer of the experience was as important as the regulatory one. Legal language alone would not build trust.
We embedded repetitive, plain-language explanations at the moment information was requested, clarified why the data was legally required, reinforced security practices, and added structured review states before submission. In testing, these interventions increased perceived legitimacy and reduced hesitation when entering sensitive information.
Working within legacy constraints
The existing onboarding component was not built to support recursive ownership structures or complex navigation. Within a three-month delivery window, we extended legacy workflows without destabilizing the broader onboarding funnel. In parallel with Engineering, we defined a scalable ownership data model capable of supporting future regulatory evolution.
The outcome was not merely a compliant screen flow, but a reusable compliance framework capable of adapting to additional broker-dealer requirements over time.
Outcomes
The final workflow received full Legal and Compliance approval, along with executive and founder sign-off. It successfully completed pilot testing with an initial cohort of customers and established a scalable ownership verification architecture.
Although full release was paused following Guideline’s acquisition by Gusto in November 2025, the system remains strategically relevant to Gusto’s long-term KYC roadmap, with anticipated implementation in the next 1–2 years.
Compliance by design
Translating complex financial regulation into a scalable ownership framework.
Client: Guideline
Role: Staff Product Designer
Date: Apr – Aug 2025
TL;DR
I led the design of an ownership verification experience to meet new FinCEN AML (anti-money laundering) requirements, balancing strict regulatory compliance with onboarding conversion through research-driven strategy and cross-functional alignment.
Overview
In 2024, updated FinCEN Customer Due Diligence (CDD) rules required broker-dealers to collect and verify beneficial ownership information for all entity customers. As Guideline looked to become a registered broker-dealer (a regulated entity authorized to buy and sell securities), we needed to implement enhanced Know Your Customer (KYC) standards across both new and existing retirement plan sponsors.
This required collecting:
All beneficial owners (25%+ ownership)
A designated control person
Personal identifying information (PII) for each individual
Recursive ownership details when entities owned other entities
Failure to collect this information would legally prevent accounts from being opened or maintained, creating both regulatory risk and operational impact.
The challenge: introduce legally mandated friction into one of the most conversion-sensitive parts of the product, plan onboarding, without meaningfully harming trust or completion rates.
The design process
Reframing the problem
This was not a simple form redesign — it was the introduction of a new compliance capability into a live onboarding funnel. Early in discovery, I needed to quickly build fluency in broker-dealer AML and FinCEN Customer Due Diligence requirements. To accelerate understanding, I leveraged AI-assisted synthesis tools to break down dense regulatory language into structured requirement maps, which I then validated in close partnership with Legal and Compliance.
Through that discovery process, an important structural insight emerged: while regulations support deeply nested ownership hierarchies, the majority of U.S. small businesses (over 80%) are directly owned by individuals. Designing primarily for the complex edge case would have imposed unnecessary cognitive load on most customers.
Instead, I reframed the system architecture around the most common ownership pattern, while safely supporting recursive entity structures when required. This systems-level decision reduced overwhelm without sacrificing regulatory completeness and became the foundation for the experience.
Concept A: Surface all owners upfront, add details later
Concept B: Progressively identify ownership as the need arises
Driving alignment through research
When I joined this initiative, the project manager already had a predefined solution direction in mind. Rather than positioning this as a conflict, I treated it as one viable hypothesis among several. To shift the conversation from preference to performance, I proposed structured usability testing across competing mental models.
I conducted 10 moderated sessions with small business owners, evaluating two fundamentally different approaches: a progressive branching workflow that dynamically revealed ownership complexity as needed, and a centralized ownership declaration model that surfaced all requirements upfront.
I assessed emotional response to sensitive PII requests, clarity of terminology such as “beneficial owner” and “control person,” cognitive load, error patterns, and confidence before submission. The results were decisive: 90% of participants preferred the progressive model, citing lower overwhelm and greater clarity. Participants consistently responded more positively when complexity was introduced incrementally rather than presented all at once.
By grounding the decision in observed behavior rather than opinion, I aligned stakeholders around the research findings and established the progressive model as the foundation for the final design. This shift from debate to evidence was pivotal in maintaining momentum within a tight three-month timeline.
Designing for trust in high-friction moments
Because we were requesting highly sensitive data including SSNs, dates of birth, and home addresses, the emotional layer of the experience was as important as the regulatory one. Legal language alone would not build trust.
We embedded repetitive, plain-language explanations at the moment information was requested, clarified why the data was legally required, reinforced security practices, and added structured review states before submission. In testing, these interventions increased perceived legitimacy and reduced hesitation when entering sensitive information.
Working within legacy constraints
The existing onboarding component was not built to support recursive ownership structures or complex navigation. Within a three-month delivery window, we extended legacy workflows without destabilizing the broader onboarding funnel. In parallel with Engineering, we defined a scalable ownership data model capable of supporting future regulatory evolution.
The outcome was not merely a compliant screen flow, but a reusable compliance framework capable of adapting to additional broker-dealer requirements over time.
Outcomes
The final workflow received full Legal and Compliance approval, along with executive and founder sign-off. It successfully completed pilot testing with an initial cohort of customers and established a scalable ownership verification architecture.
Although full release was paused following Guideline’s acquisition by Gusto in November 2025, the system remains strategically relevant to Gusto’s long-term KYC roadmap, with anticipated implementation in the next 1–2 years.