WHAT IS INCLUSIVE FINANCIAL INTEGRITY? 6

CONTENTS

EXECUTIVE SUMMARY 3

1 INTRODUCTION AND BACKGROUND

2 WHAT IS INCLUSIVE FINANCIAL INTEGRITY?

3 STATUS OF FINANCIAL INCLUSION AND AML-CFT/

CPF IN THE FOUR COUNTRIES 5

6

7

4 NATIONAL AND SECTORAL RISK ASSESSMENTS IN SUPPORT OF INCLUSIVE FINANCIAL INTEGRITY

5 ALIGNMENT OF AML/ CFT/CPF POLICIES AND NATIONAL FINANCIAL INCLUSION STRATEGIES

6 ALIGNMENT OF NATIONAL AML-CFT COORDINATION

AND INCLUSIVE FINANCIAL INTEGRITY 13

17

21

7 NATIONAL ID, DIGITAL ID, CDD AND E-KYC-CDD 24

8 SIMPLIFIED CUSTOMER DUE DILIGENCE 30

9 MOBILE MONEY AND INCLUSIVE FINANCIAL INTEGRITY 34

10 RISK-BASED SUPERVISION AND INCLUSIVE FINANCIAL

INTEGRITY 37

11 FINANCIAL INCLUSION AND THE MUTUAL EVALUATION

PROCESS 40

12 SUMMARY OF KEY TAKEAWAYS 43

ACRONYMS 45

BIBLIOGRAPHY 45

ACKNOWLEDGMENTS

This case study is a product of the Global Standards Proportionality Working Group (GSPWG) and its members. Contributors: The following AFI member institutions provided qualitative insights through in-depth interviews and written contributions: Banco Central del Paraguay, Bank of Namibia, Central Bank of Sri Lanka, and the Financial Regulatory Commission of Mongolia. From the AFI Management Unit: Mariam Zahari and Robin Newnham.

We would like to thank Lindsay Chan (consultant) for his outstanding support in conducting research and drafting the report. We would also like to thank AFI member institutions, partners and donors for generously contributing to development of this publication.