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KYC Practices in Indonesia and the Opportunity for Implementing E-KYC to Accelerate Financial Inclusion

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KYC Practices in Indonesia and the Opportunity for Implementing E-KYC to Accelerate Financial Inclusion MSC Policy brief #24 KYC practices in Indonesia and the opportunity for implementing e-KYC to accelerate financial inclusion Agnes Salyanty, Arshi Aadil, Rahmatika Febrianti, Raunak Kapoor, and Sneha Sampath KYC practices in Indonesia and the opportunity for implementing e-KYC to accelerate financial inclusion Introduction and background In response to the COVID-19 pandemic, the Public infrastructure for electronic Know Your Government of India provided emergency Customer (e-KYC) has been critical to financial digital cash transfers to more than 300 million inclusion initiatives in many developing people within a month by utilizing the payment countries. E-KYC provides multiple benefits over system backed by Aadhaar, the foundational traditional paper-based KYC. It enables efficiency digital ID in the country. This included a total gains in terms of time, cost, and resource transfer of USD 3.8 billion (INR 280 billion) to requirements involved in the verification of the farmers, senior citizens, and women who were identity of an individual or entity. This ensures a identified quickly as they were beneficiaries of near real-time onboarding of a customer for any social protection programs. The digital payment financial product or service. Since an efficient infrastructure built around Aadhaar provides an KYC process is one of the most important and interoperable, cost-effective, quick, and secure costly aspects of any customer due diligence, payment solution using the digital ID to verify making it easy and cost-effective is the priority beneficiaries and authenticate transactions and of financial services providers. In addition, withdrawals. inefficiencies in the customer onboarding process can have a significant impact on the trust Countries have built robust architecture around of a potential customer in the financial service foundational identity systems that enable provider and consequently on the adoption and different stakeholders to access the identity uptake of its products and services. database and develop services. For financial sector players alone, access to a digital-ID- backed authentication and verification service allows seamless customer identity verification, onboarding, and authentication of transactions. Provided below are some examples from across the globe that highlight how the transition from traditional KYC to e-KYC reduces the time and cost involved in onboarding customers. India United Kingdom Estonia The adoption of e-KYC in Reports estimate that a digital Smart-ID in Estonia enables India decreased the cost of identity infrastructure could the secure online delivery of customer verification from help the country save USD 99% of public services. This USD 15 to USD 0.50 and the 13.2 billion. This would include digital identity system enables time spent from five days to a direct savings of up to USD 2 Estonians to complete KYC few seconds. More than 8.04 billion through improvement checks much faster, vote billion e-KYC transactions have in the current inefficient KYC online, pay taxes digitally, and been conducted in India so processes and up to USD 11.3 buy cryptocurrencies, among far. Providers like banks and billion in savings on identity others. The government mobile network operators fraud. estimates that its e-Estonia are projected to save USD systems contribute around 2% 1.3 billion in KYC-related of the GDP per year in savings. administrative costs by 2021 2 KYC practices in Indonesia and the opportunity for implementing e-KYC to accelerate financial inclusion More than 98% of the adult population of FinTechs have adopted in Indonesia. The study Indonesia already has a Kartu Tanda Penduduk provides insights into the challenges, costs, (e-KTP), the Indonesian identity card. The and time taken by service providers to conduct Ministry of Home Affairs maintains a secure the KYC process. It further provides actionable database with the digital identities of citizens, policy recommendations to promote a public which includes their biometrics. By the end of infrastructure for e-KYC to accelerate digital 2020, around 2,819 government and private inclusion. The detailed report is available here. institutions, including 1,177 banks, had access to demographic data of citizens from this database. These stakeholders range from Regulatory landscape banks to FinTechs and hospitals to educational institutions. These institutions are granted for KYC for banks and access through an MoU signed with Dukcapil for the “right to access.” This gives a stakeholder FinTechs the right to view the demographic details of the citizens under the terms of the MoU. Dukcapil Several laws and governing bodies regulate the has also granted licenses to two private entities, KYC process for the financial services industry together known as the Platform Bersama or “our in Indonesia. Depending on the type of prod- platform,” to act as intermediaries for providing uct and service and the level of risk involved, B2B solutions to the industry. While these the requirements and levels of assurance vary positive developments have eased some of the when it comes to the verification process for challenges around KYC, access to the biometric customers. Law No. 8 (2010) on the Preven- database of citizens remains restricted. Certain tion of Crime and Money Laundering requires selected use-cases related to law enforcement financial service providers to implement a KYC agencies are the exception to this, such as process and report to the Indonesian Finan- access to the data for the police department and cial Transaction Reports and Analysis Centre the immigration office. (PPATK) regarding any suspicious transaction The Anti-Money Laundering/Combating the In the past few years, Dewan Nasional Keuangan Financing of Terrorism (AML-CTF) regulations Inklusif (DNKI), in collaboration with various of Otoritas Jasa Keuangan1 for banks and peer- partners including government departments to-peer (P2P) lenders and Bank Indonesia2 for and private institutions like banks and e-money players define the overall framework consulting firms, has been championing efforts within which the service providers can design to inform policies for the implementation of their KYC processes. They lay down the rules robust national identity infrastructure. This for customer due diligence for different types will facilitate the inclusive delivery of financial of accounts and risk profiles, which include services and help Indonesia achieve its vision of options for using electronic verification of cus- providing access to bank accounts to 90% of its tomer identity. In addition, government regula- adult population by 2024. tion as stated in Permandagri No. 102 provides an overarching framework for access to and use An enabling infrastructure and policy framework of national citizenship data. The table below on e-KYC would help the country achieve its provides a snapshot of the existing regulatory vision of financial inclusion. This policy brief framework for KYC and its implications for dif- is based on a study conducted by MicroSave ferent categories of service providers. Consulting (MSC) in collaboration with DNKI to assess the existing KYC processes banks and 1 OJK: Financial Services Authority of Indonesia is a government agency in Indonesia that regulates and supervises the financial services sector. 2 BI: Central bank of the Republic of Indonesia 3 KYC practices in Indonesia and the opportunity for implementing e-KYC to accelerate financial inclusion Service providers Regulations on AML-CTF in the financial (financial Laws on citizenship database and access Presidential Regulation on Social Assistance Draft law on Personal Data Protection sector instrument) Bank POJK No. 23 /POJK.01/20193 defines the rules The Population Administration Law No. 24 The draft law bestows several rights to financial (Basic savings for the implementation of AML CFT in the Year 2013 states that the biometric data held service users regarding personal data with some account) financial service sector. It comprises rules on in the NIK5 (SIAK) database needs protection. exceptions. tiered customer due diligence (simplified CDD4, However, it does not provide details on the basic CDD, and enhanced DD), as well as both treatment of “protected data.” (Article 54) The users have the following rights: face-to-face and non-face-to-face verification. Permendagri No.102 Year 2019 states that: 1. Right to delete and destroy personal data as The later verification can be done by using at well withdraw consent to the processing of data; least two-factor authentication (what you are/ 1. Legal entities can only access the Dukcapil have/know). database and receive a yes or no response after 2. Right to choose or not to choose the (Article 17) matching for verification. The types of database processing 6 include NIK, family card number, biometrics G2P – Himbara POJK 23/2019 relaxes the identification and Perpres 63 Year 2017 states that: personal data through a pseudonymous Banks verification requirement for government- (fingerprint, iris, photo), and a combination of mechanism for specific purposes; (Delivery of social related institutions. On the other hand, low-risk the population data elements. (Article 29) 1. Bank partners shall conduct G2P account registration and opening based on the 3. Right to delay or limit the processing of data; assistance) customer profiles, such as G2P beneficiaries 2. MoHA offers three methods to access data: DTKS database. This account must be can open accounts by utilizing simplified CDD. Using a card reader, through a web service, and 4. Right to use and transmit data. used to receive benefits under other social (explanation of POJK No. 12 /POJK.01/2017, through a web portal. (Article 21) page 3) assistance programs. (Article 6) 3. Access to the Dukcapil database is limited to 2. To ensure interoperability and the MoHA staff and users (including business interconnectivity, the payment services entities) who have the mandate under an MoU. should be owned, managed, or both, by Users need to establish an SOP on the technical state-owned commercial banks. (Article 11) implementation of data access (Article 13) 3. All costs associated with the 4.
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