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How a Know-Your-Customer Utility Could Increase Access to Financial Services in Emerging Markets

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How a Know-Your-Customer Utility Could Increase Access to Financial Services in Emerging Markets www.ifc.org/thoughtleadership NOTE 59 • OCT 2018 How a Know-Your-Customer Utility Could Increase Access to Financial Services in Emerging Markets Global efforts to counter terrorism financing and money laundering have led banks to terminate relationships with some communities, businesses, and individuals around the world. When a financial institution or intermediary cannot easily judge the identity and associated risks of a customer, it is often more efficient to avoid transacting with that customer altogether. This may disproportionately affect small banks, small firms, and low-income individuals in emerging and developing economies. This Compass Note explores an innovative solution that could help improve customer due diligence through a Know-Your-Customer (KYC) utility. Knowledge of a customer is central to providing financial governments could work together to develop KYC utilities. services, so effective and efficient customer due diligence These could help improve CDD in smaller or more difficult (CDD) is critical to enabling financial intermediaries to emerging markets and have the ultimate goal of improving serve their customers. Over the last 20 years, financial integration and financial inclusion. intermediaries have also been expected to monitor for, and report on, potential financial crimes. Failure to do so can What is KYC? result in large fines or termination of operations. The Financial Action Task Force (FATF) is an independent The increasing complexity of this law enforcement role, inter-governmental body that develops and promotes and associated reporting and monitoring requirements and policies to protect the global financial system against costs, have caused some financial intermediaries (FIs) to pull money laundering, terrorist financing, and the proliferation back from cross-border investment, trade, and clearing and of weapons of mass destruction. FATF has developed the settlement activities. When correspondent banks withdraw following basic principles for customer due diligence that from relationships with respondent banks and other FIs, this are required to “Know a Customer.” is collectively referred to as de-risking. This usually implies that the correspondent was unable to cost effectively assess Who is the customer? – Establish Identity. For individuals, the quality of a counterparty’s CDD processes, and therefore identify the customer and verify his or her identity cannot assess the risks. As a result, the FI often terminates using reliable, independent source documents, data, or the relationship with that counterparty. This has had information. For companies, identify the name, legal form, systemic impacts in some smaller countries, and particularly existence, and beneficial owner(s), and verify their identities. in those countries without a global correspondent bank What are customers doing? – Transaction Monitoring and willing to clear and settle U.S. dollar transactions. Ongoing Customer Due Diligence. Understand the purpose Know-Your-Customer (KYC) utilities may be a solution. and intended nature of relationships between individuals This note explores how International Financial Institutions and businesses. Where is the money coming from into the (IFIs), Multilateral Banks (MDBs), private firms, and institution and how is it being used? 1 This publication may be reused for noncommercial purposes if the source is cited as IFC, a member of the World Bank Group. Conduct ongoing customer due diligence to ensure that global financial system is critical to their recovery. Know- customer transactions match customer profiles.Ongoing Your-Customer utilities could help resolve this problem. CDD involves tracking mergers and acquisitions; reviewing What is a Know-Your-Customer Utility? new lines of business; investigating changes in governance, directors, and management; and being sure that customer There are three types of KYC utilities operating today: profiles are up-to-date. Industry Collaboration Utilities, Jurisdictional Utilities, and Utility Service Providers. Two subcategories of In many countries, if these transaction monitoring processes utility service providers are: a) Utility Services, which are or ongoing customer due diligence processes reveal any primarily data services and identification (ID) information suspicious transactions or activities, then the FI is legally storage; and b) Managed Services, which are basically obligated to report this to the national law enforcement outsourced utility services, plus transaction tracking and authorities for further investigation. Failure to report can CDD. Examples of each type of utility are as follows: result in fines and/or loss of the FI’s operating license. Industry Collaboration Utility: SWIFT CDD Risks and De-risking CDD requires records of where customer payments For individuals or firms to receive formal financial services, originate and terminate. This explains why one of they must have a verifiable identity and valid transaction the first successful KYC utilities was introduced by records. Transactions must conform to customer profiles, SWIFT, the Society for Worldwide Interbank Financial and when they do not, the customer must explain the Telecommunications. transaction or it will be rejected. For any suspicious transaction, a report must be filed with the authorities. Essentially, SWIFT deals in electronic messages between banks, and these messages provide a transaction trail, Correspondent banks must be able to verify that respondent documenting where money originates and terminates. banks are doing sound CDD and are reporting possible SWIFT does not clear or settle transactions, and holds crimes to avoid the inadvertent processing of criminal no accounts, but does pass information about payments transactions. In many cases, if a correspondent bank through its highly secure messaging system. SWIFT has cannot easily and affordably assess the legitimacy and risks a successful shared data repository that holds profile data of a respondent bank’s transactions, it will simply terminate for hundreds of respondent and correspondent banks. the relationship. Unfortunately, small banks, small money The SWIFT KYC utility, available to SWIFT members, transfer organizations, charitable organizations, small is useful for member correspondent/respondent banking firms, and poor people are often disproportionately relationships, and reduces correspondents’ risk when affected by CDD requirements. Their transactions are dealing with respondent banks in high-risk or sanctioned often cash-based or cannot be traced, and the returns jurisdictions because the SWIFT utility validates where the from transacting with them are small, making the risks money goes, and that the recipient is acceptable. The utility, of dealing with these entities larger than the rewards. which is used by major correspondent and respondent Similarly, respondent banks will feel pressure to terminate banks, is used primarily for the larger payments of larger relationships with low-income individuals and small firms if corporations. There are around 11,000 SWIFT users today, validating transactions with them is prohibitively expensive. which makes SWIFT a significant player in international The consequences of this have been reductions in trade, corporate payments; however, many smaller banks and FIs remittances, and credit availability, as well as diminished in emerging markets are not SWIFT members. financial performance and job losses. Thus, an unintended consequence of Anti-Money Jurisdictional Utility: Monetary Authority of Laundering/Combating the Financing of Terrorism (AML/ Singapore KYC Utility CFT) regulations has been that global correspondent banks The Monetary Authority of Singapore has introduced have withdrawn operations in smaller markets and no longer a National KYC utility that covers all individuals with collaborate with local banks that serve smaller customers. accounts in Singapore. The “MyInfo” service, a personal The knock-on effect of this de-risking is reduced services to data platform that contains government verified personal some of the poorest and most stressed countries exactly when details for every account holder, is the foundation for this their integration into global trade and supply chains and the utility. Residents provide their data to the government once, 2 This publication may be reused for noncommercial purposes if the source is cited as IFC, a member of the World Bank Group. 3rd party case management Command and Control Dashboards and KPIs On boarding and Ongoing detection and prevention Investigate and data collection respond Risk Entity-centric Social network Watch list scoring analysis management AML transaction Payments fraud 1st party / Fraud monitoring bust out fraud EIM alert and Online fraud case management KYC/CDD Account takeover Composite Check and Alert triage and optimisation risk score Transaction filtering deposit fraud Staff / collusion / Compliance insider fraud Alert and case management Application fraud Sanctions / Debit card fraud PEP screening Secured lending / Financial management KYC CPP / MAC fraud mortgage fraud EDD/ODD Market abuse / Disclosure management operational risk Real time or batch Outcome capture Bank systems data 3rd party risk, Analytical workbench–configure and tune models and rules Customers Employees fraud or Applications Online data compliance Transactions 3rd party data engines Financial crime repository FIGURE 1 BAE’s KYC Utility Product Offering—The NetReveal risk, fraud, and compliance solution
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