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Report

Emergency Disbursements During COVID 19: Regulatory Tools for Rapid Account Opening and Oversight

A white paper exploring the challenges in account opening, with a lense toward making it easier to provide cash transfers during COVID 19

The COVID-19 pandemic prompted an unprecedented wave of emergency disbursements, testing the ability of countries to reach unbanked and underserved populations quickly and safely. This white paper explores how enabling regulation—especially tiered KYC and simplified account opening—made digital emergency payments possible at scale.

Key Takeaways:

  • COVID Response – In markets with enabling regulation, tens of millions of accounts were opened during the pandemic—up to 60 million globally.
  • Barriers to Inclusion – Traditional Know Your Customer (KYC) requirements excluded millions without formal ID, especially women and low-income populations.
  • Tiered KYC and SDD – FATF-compliant approaches like simplified due diligence (SDD) enabled low-risk accounts with lighter onboarding requirements.
  • Regulatory Innovation – Countries like Brazil, India, Mexico, and West African states used digital IDs, remote onboarding, and deferred ID to expand access.

The report emphasizes the need to formalize these crisis-era innovations to support long-term financial resilience and inclusion.

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