Biometrics and Financial Inclusion a Roadmap for Implementing Biometric Identity Systems in Sub-Saharan Africa
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Biometrics and financial inclusion A roadmap for implementing biometric identity systems in sub-Saharan Africa March 2018 Authors Barry Cooper Masiiwa Rusare Albert van der Linden Matthew Ferreira Centre for Financial Regulation & Inclusion Tel. +27 21 913 9510 Email: [email protected] The Vineyards Office Estate Farm 1, Block A 99 Jip de Jager Drive Bellville, 7530 South Africa PO Box 5966 Tygervalley, 7535 South Africa www.cenfri.org Biometrics and financial inclusion | March 2018 1 Table of contents List of abbreviations 3 1. Introduction 4 2. Identity 6 The concept of identity and identity systems 6 The CDD barrier to financial inclusion 11 3. Biometrics 15 4. Biometric considerations 19 Use cases 19 Barriers 26 Regulation 32 Standards and interoperability 36 5. A roadmap for the implementation of biometrics 38 Pre-conditions 39 Implementation 44 Post-implementation 46 6. Conclusion 49 7. References 50 Annexure: List of stakeholder interviews 52 List of figures Figure 1: Rwandan national ID ecosystem 8 Figure 2: Percentage of population without legal proof of ID in SSA 10 Figure 3: Income categorisation of those without a legal identity 10 Figure 4: Identification and verification in biometrics 16 Figure 5: Legal framework 34 Figure 6: Summary of biometric roadmap 38 List of boxes Box 1: Types of biometrics that can be used for identification purposes 18 List of tables Table 1: Principles of privacy by design 33 Biometrics and financial inclusion | March 2018 2 List of abbreviations CDD customer due diligence eID electronic identity eKYC electronic Know-Your-Customer ESAAMLG Eastern and Southern Africa Anti-Money Laundering Group FATF Financial Action Task Force FSDA Financial Sector Deepening Africa FSP financial service provider G2P government to person GDPR General Data Protection Regulations GIABA The Inter-Governmental Action Group against Money Laundering in West Africa ID Identification ICT information and communication technologies ISO International Organisation for Standardization KYC Know-Your-Customer MAP Making Access Possible ML money laundering NADRA National Database and Registration Authority NIA National Identification Authority NPR national population register NRI national registration institution PoA proof of address RBA Risk-Based Approach SASSA South African Social Security Agency SDGs Sustainable Development Goals USD United States dollar Biometrics and financial inclusion | March 2018 3 1 Introduction In sub-Saharan Africa (SSA), only 34% of Lack of identity is a barrier to accessing a adults have access to a bank account, multitude of important services, particularly compared with 51% for the Europe and financial services. In response to Anti- Central Asia region (Findex, 2014). Financial money-laundering initiatives spearheaded inclusion is important for improving the by the Financial Action Task Force (FATF) livelihoods and wellbeing of individuals as (specifically Recommendation 10 on well as for broader financial-sector growth, customer due diligence [CDD]), banks are development and stability. Evidence required to have strong proof of identity of suggests that financial-sector development their customers in order to do business with (including assets, stock and bond market them. This varies but generally includes capitalisation, credit extension to the private identity documents and Proof of Address sector, and liquid liabilities of financial (PoA). Without such documents, consumers institutions) is linked to broader economic are excluded from accessing formal financial growth (Mohan, 2006). Given the role of a services. In Angola, 41% of individuals cited a functioning financial sector in uplifting lack of documents as the reason for being livelihoods and in spurring economic financially excluded, while in South Africa growth, it is an important development and Nigeria this figure was 14% and 12% agenda for Africa and SSA in particular. respectively. Lack of identity documentation varies in its severity as a barrier to exclusion The World Bank (2017) estimates that the depending on the country, but overall lives of 1.1 billion people who live without indicates a significant problem (Findex, proof of identity could be improved by if 2014). they gain access to digital identity. Identity can help vulnerable people to gain access to Biometrics pose a possible solution to the critical services, such as health services, identity problem in SSA and especially governments grants, education and financial financial exclusion due to lack of identity. services such as bank accounts. Lack of legal This is because biometrics are an inherent means of identification is a problem across part of the consumer, something that the SSA, with varying degrees of severity. In consumer does not have to carry around Nigeria, 78% of the population (149 million) (such as a piece of paper or document, do not have a legal means to prove their which is much easier to lose or damage). identity, while in South Africa 12 million Moreover, biometrics are more reliable as a individuals (22%) are excluded from the means of identification and significantly formal identity system of the country (World prevent crimes such as fraud and Bank, 2017). This translates to 454 million impersonation. This has clear benefits for the individuals (48% of the population) across many sectors within the economy the entire SSA. especially the financial sector, which will be able to reduce money laundering (ML) risk through greater certainty of the identity of Biometrics and financial inclusion | March 2018 4 its customers. However, across Africa, the engagement with select regulators and FSPs adoption of biometrics in identity systems within the GIABA and ESAAMLG regions. has been slow and haphazard. This has led to underwhelming results and Against the above background, this note implementation of systems that are not cost-effective, scalable or interoperable. of countries and financial service providers (FSPs) and to help them select and adopt Although a number of studies have explored biometric approaches that have a lasting the potential of biometrics in addressing impact on financial inclusion, financial identity challenges, the adoption and use of integrity and broader national development biometrics in Africa have been slow and objectives. The first section discusses the uncoordinated at best. This is confirmed by concept of identity and the link between the gap between the various approaches robust identity systems and financial and the current practices on identity and inclusion. It highlights the role that lack of biometrics. The challenge of navigating the identity plays in facilitating financial various biometric approaches and exclusion in SSA. The second section defines determining the most appropriate one biometrics, unpacking the role of biometrics (among the wide range that are around) in the identity space and how biometrics remains a key driver for slow and can be a strong identifier. The third section inappropriate adoption of biometrics discusses the use cases for biometrics as approaches in Africa. However, the urgent well as the barriers to the successful need to address financial exclusion as well implementation of biometric identity as poor financial integrity ratings (by FATF) schemes in SSA. The final section presents a opens up the possibility for countries to roadmap for implementing biometric adopt biometrics approaches that promote identity in Africa. It is informed by the financial inclusion, financial integrity and previous sections and serves as guidance to national development objectives in the long regulators, industry players and donors on how to best go about the process. Technical Assistance work as well as Biometrics and financial inclusion | March 2018 5 2 Identity The concept of identity and identity through personal or social connections. This systems has changed. The expansion of economic circles, the need to conduct long-distance An identity broadly accepted as a basic transactions and the ability to interact with human right. Article 71 of the Convention on those with whom we do not have personal relations have driven the need for more have the right to a legally registered name, sophisticated identity authentication and officially recognised by the government. verification mechanisms. article aims to ensure that all natural persons Identity: a collection of attributes3. At its have a legally recognised identity. Access to a core, identity is nothing more than a unique legal identity is also included in the set of attributes. The attributes themselves do Sustainable Development Goals (SDGs). not have to be unique, but the combination 2 Target 9 under Goal 16 thereof the set has to be unique. For provide legal identity for all, including birth example, the name John Smith is not particularly unique, but the name John Smith key to unlock access to formal political, combined with other attributes such as a economic and social participation. In the physical characteristic a biometric and a absence of a verifiable identity, an individual date of birth already increases the probability might be denied access to basic rights and of uniqueness. It is by means of these services. attributes that an individual can be uniquely identified by another individual or system. The authentication of identity an increased Through verification of identity, the individual need in an intermediated society. In ages gains access to services. This is because past, human interaction was, almost verification gives the service