Practice

Simplified Customer Due Diligence

Regulations support the implementation of Simplified Customer Due Diligence (CDD) by DFSPs. Simplified CDD allows for a consumer with very limited or no formal proof of identification to open a basic transaction account with controlled limits. Regulations also support digital or remote account opening methods that allow a customer to easily self-issue a basic transaction account. Ongoing, risk-based CDD approaches enable customers with more identification and established transaction history to gain higher transaction limits and expanded services commensurate with their risk profile.

Safe Payments

Scheme ensures that users can conduct their transactions safely

How to Implement

Guidance

Allow and encourage the application of simplified CDD.

Regulators should allow and encourage the use of simplified CDD by DFSPs for lower risk customers that allows them to easily open basic transaction accounts in line with their assessed risks (based on FATF recommendations). (The process of identifying the customer and verifying their information at account opening is often referred to as know-your-customer or KYC process). Basic transaction accounts that are subject to lower identification requirements and transaction value limits, ensure the Inclusive IPS remains accessible and useful to a broader set of customers, including those new to formal financial services.

Reiterate simplified CDD in Scheme rules.

The Scheme rules reiterate that DFSPs should implement internal policies and procedures that are in line with regulations that allow and encourage the use of simplified CDD for basic transaction accounts.

Communicate features and controls on transaction accounts: DFSPs should clearly disclose the functionalities that customers get with open basic transaction accounts, and the limits and controls they are subject to.

They should also communicate the features of more advanced accounts that customers can have access to with more identification and established transaction history, based on risk-based CDD approaches that align functionalities to customer risk profiles.

Balance customer account controls with fraud controls.

The Scheme requires DFSPs to apply transaction account controls appropriate for each customer risk profile, in line with regulations and relying on simplified CDD, that allow customers to open and use basic transaction accounts while also enabling DFSPs in mitigating the incidence of fraud through ongoing monitoring and application of additional controls as appropriate.

Require multiple sender authentication methods.

The Scheme requires DFSPs to utilize multiple tools and controls to authenticate an account holder. Multifactor authentication is a common approach that requires an account holder to confirm their identity with a combination of something they have (e.g., a mobile phone), something they are (e.g., their fingerprint or iris scan), or something they know (e.g., a PIN or password). Use of multiple methods, including ones that work with feature phones to authenticate senders will more effectively prevent fraud.

Maintain simplified CDD requirements for cross-border transfers.

Low-value, cross-border transfers are available to end users with basic identification.

Why It Matters

This makes the Inclusive IPS more accessible and useful for underserved communities while supporting management of risk as transaction limits grow.

Seeing More Clearly

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Women’s Inclusion

Low-income women are less likely to have formal identification and have higher mobility constraints, thus benefiting from the availability of basic transaction accounts that have simplified due diligence requirements do not require excessive documentation and a burdensome process, and that can be opened remotely.

Fraud Mitigation

Simplified CDD protocols consider the risk of the end user as they become onboarded to digital accounts and apply the appropriate controls to match that profile. The protocols aim to achieve the right balance simple easy account opening and enabling DFSPs in mitigating the incidence of fraud through ongoing monitoring and application of additional controls as appropriate.

Cross-Border

End users’ payment needs across key use cases extend to cross-border transactions. Applying simplified CDD processes in the cross-border context, and ensuring that low-value cross-border transfers can be made by end users with basic identification (as in the domestic context), supports end users’ need for convenience and usefulness.

A woman purchases a necklace using mobile money in Rwanda.

Tools

Design Guides

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Related Resources

From the Community

Helpful resources from other organizations on implementing this practice.

    PDF | FATF

    Guidance on Financial Inclusion and Anti-Money Laundering and Terrorist Financing Measures

    Overview of FATF’s AML/CFT guidance, the benefits of simplified CDD

    Blog | AfricaNenda

    From Policy to People: Key Takeaways from Our Webinar on eKYC and Inclusive Instant Payments Systems in Africa

    Webinar on benefits of eKYC and practical considerations on balancing risk and innovation

    Report | AfricaNenda

    The State of Inclusive Instant Payment Systems in Africa 2024

    Report on Inclusive IPSs in Africa, including a section on KYC innovation

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A woman uses mobile money to purchase fruit at a market in Rwanda.