AML/CFT Regulation : Implications for Financial Service Providers that Serve Low-Income People
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Washington, DC
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This report on anti-money laundering
(AML) and combating the financing of terrorism (CFT)
regulation addresses the consequences of these regulations
on low-income people. The introduction of new or tightened
AML/CFT regulations may have the unintended and undesirable
consequence of reducing the access of low-income individuals
to formal financial services. As a means to avoid this
outcome, this paper argues in favor of gradual
implementation of new measures; the adoption of a risk-based
approach to regulation; and the use of exemptions for
low-risk categories of transactions.
Palabras clave
ACCESS TO FINANCIAL SERVICES, ACCESS TO SERVICES, ACCOUNT HOLDERS, ACTS OF TERRORISM, ADVERSE EFFECTS, AGRICULTURAL BANKS, ALTERNATIVE FINANCIAL INSTITUTIONS, ANTI-MONEY LAUNDERING, AUDITS, BANK ACCOUNTS, BANKING RELATIONSHIP, BANKING SERVICES, BANKS, BOND, BUSINESS RELATIONSHIPS, BUSINESS TRANSACTIONS, BUSINESSES, CAPITAL FLOWS, CERTIFICATES, CHARITABLE SECTOR, CLIENT BASE, CLIENT IDENTIFICATION, CLIENT INFORMATION, COLLATERAL, COMMERCIAL BANK, COMMERCIAL BANKS, COMMERCIAL FUNDING, COMMERCIAL TRANSACTIONS, COMMODITY, COMMUNITY BANKS, COMPLIANCE COSTS, CONSUMER CREDIT, CONVENTIONAL BANKS, COOPERATIVES, CORRUPTION, CREDIT INSTITUTIONS, CREDIT UNIONS, CRIMINAL LIABILITY, CRIMINAL PURPOSES, CURRENCY, CURRENT LAWS, CUSTOMER IDENTIFICATION, DEBIT CARDS, DENIAL OF ACCESS, DEPOSIT, DEPOSITORY, DEPOSITORY INSTITUTIONS, DEPOSITS, DEVELOPING COUNTRIES, DEVELOPMENT BANK, DEVELOPMENT BANKS, DONOR FUNDING, DOUBLE BOTTOM LINE, DRUG TRAFFICKING, DUE DILIGENCE, DUE DILIGENCE REQUIREMENTS, ECONOMIC DEVELOPMENT, ELECTRONIC MONEY, EMPLOYER, EQUIPMENT, EXCHANGE RATES, EXPOSURE, EXTERNAL AUDITS, FINANCIAL ACTIVITY, FINANCIAL CRIMES, FINANCIAL INSTITUTION, FINANCIAL INSTITUTIONS, FINANCIAL INSTRUMENTS, FINANCIAL INTELLIGENCE, FINANCIAL INTERMEDIARIES, FINANCIAL MARKET, FINANCIAL MARKETS, FINANCIAL PRODUCTS, FINANCIAL REGULATION, FINANCIAL SECTOR DEVELOPMENT, FINANCIAL SERVICE, FINANCIAL SERVICE PROVIDER, FINANCIAL SERVICE PROVIDERS, FINANCIAL SERVICES PROVIDERS, FINANCIAL SUPPORT, FINANCIAL SYSTEM, FINANCIAL SYSTEMS, FINANCIAL TRANSACTIONS, FOREIGN DIRECT INVESTMENT, FOREIGN EXCHANGE, FORMAL FINANCIAL SECTOR, FORMAL FINANCIAL SERVICES, FUNDS TRANSFERS, FUTURES, GENERAL PUBLIC, GLOBAL PAYMENTS, GRAPHICS, GREATER ACCESS, GROUP LENDING, HOUSEHOLDS, HUMAN RESOURCE, HUMAN RESOURCE CAPACITY, HUMAN RESOURCE POLICIES, ID, IDENTIFICATION REQUIREMENTS, IDENTITY CARD, ILLICIT ACTIVITIES, ILLICIT ACTIVITY, INCOME, INCOME TAX, INFORMATION EXCHANGE, INFORMATION SHARING, INFORMATION SYSTEMS, INSTITUTIONAL CAPACITY, INSURANCE COMPANY, INTEREST RATE, INTERNAL AUDITOR, INTERNAL CONTROL, INTERNAL CONTROLS, INTERNATIONAL BEST PRACTICE, INTERNATIONAL COOPERATION, INTERNATIONAL FINANCIAL MARKETS, INTERNATIONAL STANDARDS, INVESTMENT CAPITAL, JURISDICTION, JURISDICTIONS, LAW ENFORCEMENT, LEGAL PROTECTION, LEVEL OF SECURITY, LICENSE, LIFE INSURANCE, LIQUID SECURITIES, LOAN INSTITUTIONS, LOAN OFFICERS, LOAN SIZES, LOCAL BANKS, MFI, MFIS, MICROCREDIT, MICROFINANCE, MICROFINANCE INSTITUTION, MICROFINANCE INSTITUTIONS, MICROINSURANCE, MIDDLE-INCOME ECONOMIES, MONEY LAUNDERERS, MONEY LAUNDERING, MONEY LAUNDERING ACTIVITY, MONEY MARKET, MONEY ORDERS, MONEY TRANSFERS, MORTGAGE, MORTGAGE CREDIT, NEW TECHNOLOGIES, NEW TECHNOLOGY, NONPROFIT ORGANIZATIONS, OPERATIONAL COST, OUTSTANDING BALANCE, OWNERSHIP STRUCTURES, PAYMENT SYSTEM, PAYMENTS NETWORK, PAYMENTS SYSTEM, PDF, PHOTO, PHOTO ID, POOR CLIENTS, PORTFOLIO, PORTFOLIO MANAGEMENT, POSTAL BANK, POSTAL BANKS, POSTAL SAVINGS, PRIVATE BANKING, PUBLIC POLICY, PUBLIC RECORD, REAL ESTATE, RECORD KEEPING, REGULATORS, REGULATORY REGIMES, REMITTANCE, REMITTANCES, REPUTATION, REPUTATION RISKS, REPUTATIONS, RESULT, RESULTS, RISK ANALYSIS, RISK MANAGER, RISK OF FRAUD, RISK OF MONEY LAUNDERING, RURAL BANKS, RURAL CREDIT, RURAL CREDIT COOPERATIVES, SAVINGS ACCOUNTS, SAVINGS BANK, SAVINGS BANKS, SECURITIES, SECURITIES ISSUES, SERVICES TO CLIENTS, SHAREHOLDERS, SIGNATURE, SMALL LOAN, SMALL LOANS, STATE BANK, SUPERVISION, SUSPICIOUS ACTIVITIES, TECHNICAL ASSISTANCE, TERRORISM, TERRORIST, TERRORIST ATTACK, TERRORIST ORGANIZATIONS, TRANSACTION, TRANSACTION REPORTING, TRANSFERABLE SECURITIES, TRANSPARENCY, TREASURY, USES, VERIFICATION, VILLAGE, VILLAGES, VOLATILITY, VOLUNTARY DEPOSIT, WEAK ENFORCEMENT, WEB, WEB SITE, WIRE TRANSFERS, WORKING CAPITAL