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The emergence of technology-enabled financial services COMMONWEALTH FINTECH TOOLKIT (fintech) in the past two decades has profoundly impacted the production and delivery of financial services. The Commonwealth FinTech Toolkit provides technical guidance on fintech and fintech applications. It sets out a framework for creating enabling environments for fintech, through legislation, regulation, institutions and policies. It also aims to build fintech capacity among government staff. Part I considers the ways in which emerging technologies are transforming financial services. Part II explores how Commonwealth member countries can use those Helping Governments to technologies to achieve their development goals. Leverage Financial Innovation Commonwealth FinTech Toolkit Helping Governments to Leverage Financial Innovation © Commonwealth Secretariat 2020 All rights reserved. This publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic or mechanical, including photocopying, recording or otherwise provided it is used only for educational purposes and is not for resale, and provided full acknowledgement is given to the Commonwealth Secretariat as the original publisher. Views and opinions expressed in this publication are the responsibility of the author(s) and should in no way be attributed to the institutions to which they are affiliated or to the Commonwealth Secretariat. This project was part-financed by the Government of Australia, Department of Foreign Affairs and Trade and Australian Aid. Wherever possible, the Commonwealth Secretariat uses paper sourced from responsible forests or from sources that minimise a destructive impact on the environment. Printed and published by the Commonwealth Secretariat. iii Preface The Commonwealth Secretariat has developed the Commonwealth FinTech Toolkit in response to a specific request from the Commonwealth Central Bank Governors (CCBGs). Recognising the growth and impact of technology-enabled financial services (fintech) in the Commonwealth, the Governors endorsed the development of a Commonwealth FinTech Toolkit at a meeting in October 2018. The threefold aims of the Toolkit are to: • provide technical guidance on fintech and fintech applications, including using fintech to achieve development outcomes; • set out a framework for creating enabling environments for fintech, including with appropriate legislation, regulation, institutions and policies; and • build fintech capacity among government staff. With support from the Australian Government’s Department of Foreign Affairs and Trade, the Commonwealth Secretariat commissioned an expert group from Visionary Future LLC to help with this project. v Contents Preface iii Abbreviations and Acronyms ix Executive Summary xiii Introduction 1 PART1 TechTopics 3 1 DigitalFinancialServices 5 1.1 Introduction 6 1.2 Context 6 1.3 Description 7 1.4 Key Considerations for Future Development 12 Endnotes 15 2 ArtificialIntelligence 19 2.1 Introduction 20 2.2 Context 20 2.3 Description 20 2.4 Key Considerations for the Future 23 Endnote 24 3. BlockchainandFinancialServices 25 3.1 Introduction 26 3.2 Context 28 3.3 Description 29 3.4 Key Considerations for Future Development 32 Endnotes 33 4 DigitalIdentity 35 4.1 Introduction 36 4.2 Context 37 4.3 Description 39 4.4 Key Considerations for Future Development 41 Endnotes 43 vi Contents 5 BigData/BigDataAnalytics 45 5.1 Introduction 46 5.2 Context 46 5.3 Description 48 5.4 Key Considerations for Future Development 49 Endnotes 50 6 Cybersecurity 53 6.1 Introduction 54 6.2 Context 54 6.3 Description 56 6.4 Key Considerations for Future Development 57 Endnotes 57 PART2 ApplicationandAction 59 7 PolicyInterventionsandOutcomes 61 7.1 Introduction 62 7.2 Financial Inclusion 63 7.3 Improved Cross-border Transactions and Trade 70 7.4 Improved Economic Growth 71 Endnotes 73 8 Considerations 75 8.1 Introduction 76 8.2 Diversity among Commonwealth Nations 76 8.3 Small States: Opportunity and Challenge 77 8.4 Advanced Economies and Legacy Systems 78 8.5 Developing Economies 78 8.6 Regional Considerations 80 8.7 Conclusion 81 Endnotes 82 9 ActionFrameworkforCreatinganEnablingEnvironment forFintech 85 9.1 Introduction 86 9.2 Building an Effective Fintech Task Force 87 9.3 Creating an Enabling Environment for Fintech 89 9.4 Building on Success 99 Endnotes 100 vii 10 CaseStudies 101 Case Study 10.1 The Journey of Emerging Technologies: Blockchain in Papua New Guinea 102 Case Study 10.2 Pioneering Mobile Money in Kenya 106 Case Study 10.3 Digital Assets Businesses in Bermuda 108 Case Study 10.4 Malta’s Support for Virtual Financial Assets 111 Endnotes 114 Appendix1CommonwealthGovernmentInterviews 115 Appendix2Methodology 117 Appendix3Findings 119 ContributorsandAcknowledgements 121 ix Abbreviations and Acronyms 5AMLD Fifth Money Laundering Directive (EU) AAI applied artificial intelligence ADB Asian Development Bank AfDB African Development Bank AI artificial intelligence AML anti-money-laundering APEC Asia-Pacific Economic Cooperation ASEAN Association of Southeast Asian Nations ASIC Australian Securities and Investment Commission ATM automatic teller machine BATs Baidu, Ali Baba and Tencent BIS Bank for International Settlements BMA Bermuda Monetary Authority BPNG Bank of Papua New Guinea BSBD basic saving bank deposit CARICOM Caribbean Community CBB Central Bank of Bahrain CBDC central bank digital currency CBK Central Bank of Kenya CCBGs Commonwealth Central Bank Governors CCP central counterparty CDR consumer data right CFT countering the financing of terrorism CGAP Consultative Group to Assist the Poor CPMI Committee on Payments and Market Infrastructures (BIS) CSD central securities depository DABA Digital Assets Business Act 2018 (Bermuda) DFAT Department of Foreign Affairs (Australia) DfID Department for International Development (UK) DFS digital financial services DIT Department for International Trade (UK) DLT distributed ledger technology ECCB Eastern Caribbean Central Bank ECCU Eastern Caribbean Currency Union x Abbreviations and Acronyms EMI e-money issuer ESMA European Securities and Markets Authority EU European Union FCA Financial Conduct Authority (UK) FCP financial consumer protection FDC Foundation for Development Cooperation FIAU Financial Intelligence Analysis Unit (Malta) FMI financial market infrastructure forex foreign exchange FSB Financial Stability Board GAI generalised artificial intelligence GDP gross domestic product GDPR General Data Protection Regulation (EU) GFIN Global Financial Innovation Network GNP gross national product GPS Global Positioning System GPSDD Global Partnership for Sustainable Development Data GSMA Global System for Mobile Communications HFT high-frequency trading HKMA Hong Kong Monetary Authority HMRC Her Majesty’s Revenue and Customs (UK) IADB Inter-American Development Bank ICO initial coin offering ICT information and communications technology ID identity IDB Inter-American Development Bank IFC international finance corporation IMF International Monetary Fund IOSCO International Organization of Securities Commissions IP Internet Protocol ITAS innovative technology arrangements and services KYC know your customer KYCC know your customer’s customer LEI Legal Entity Identifier MAS Monetary Authority of Singapore MDIA Malta Digital Innovation Authority MFSA Malta Financial Services Authority xi NBFI non-bank financial institution NI National Insurance NMSE nano and micro sector enterprise NPS Net Promoter® Score OECD Organisation for Economic Co-operation and Development P2P peer-to-peer PBD privacy by design PCS payments, clearing and settlement PESTLE political, economic, social, technological, legal, environmental [analysis] PIN personal identification number PIRI Pacific Islands Regional Initiative PMJDY Pradhan Mantri Jan Dhan Yojana [National Mission for Financial Inclusion] (India) PMLFTR Prevention of Money Laundering and Funding of Terrorism Regulations 2018 (Malta) PNG Papua New Guinea PPP public–private partnership PRC People’s Republic of China PSD2 revised Payment Services Directive (EU) QOS quality of service SCI SEPA credit identifiers SDGs Sustainable Development Goals (UN) SEPA Single Euro Payments Area SMEs small and medium-sized enterprises SSS securities settlement system SWIFT Society for Worldwide Interbank Financial Telecommunication SWOT strengths, weaknesses, opportunities and threats UBO ultimate beneficial owner UN United Nations USAID US Agency for International Development VC virtual currency VFA virtual financial asset VFA Act Virtual Financial Assets Act 2018 (Malta) VFA Regulations Virtual Financial Assets Regulations 2018 (Malta) WEF World Economic Forum xiii Executive Summary Atthe2018meetingoftheCommonwealthCentralBankGovernors(CCBGs), membercountriesrecognisedthegrowthandimpactoftechnology-enabledfinancial services(fintech)onCommonwealthpopulations,andendorsedthedevelopmentofa CommonwealthFinTechToolkit. The Governors noted demand for PART I Tech Topics improved technical guidance regarding In Part I, we look at the ways in which the implementation of fintech—an area emerging technologies are transforming with which many member countries are financial services. grappling. Acknowledging that some states are more advanced in this area than Chapter 1 Digital Financial Services others, the Governors noted that it would • Digital financial services (DFS) can be extremely useful