On the occasion of the Arab Financial Inclusion Day 2020,
the Arab Monetary Fund, AMF, announced the publication on Digital Identity and
e-KYC Guidelines for the Arab Region issued by the Arab Regional Fintech
Working Group. This document aims to contribute to the existing dialogue at the
regional and global levels on the importance of digital identity, ID, and
electronic know your customer, e-KYC, and Customer Due Diligence, CDD, and
their impact on financial inclusion and the further steps going forward.
Inadequate access to financial services is a problem facing
a significant portion of the population across the world and the region. This
can be alleviated via the transformation to digital financial services and the
digital access to financial services. Given this fact, the Arab region’s
financial services industry and policymakers have taken over the past five
years significant steps to recognise and address challenges to meaningful
financial inclusion. It is estimated that 60 percent of world GDP will be
digitalised by 2022, while this growth in digital financial transactions
requires a better understanding of how individuals are being identified and
verified in the world of digital financial services.
Digital identity, ID, technologies are evolving rapidly,
giving rise to a variety of digital ID systems. Similarly, the ongoing
digitalisation of the economy represents a major challenge that requires a
balance between remote and digital onboarding for clients and ensuring
compliance with regulations aimed at tackling money laundering and the
financing of terrorism, AML/CFT regulations. Digital ID systems can offer new
possibilities for achieving sustainable development goals if they are inclusive
and trustworthy. When designed appropriately, Digital ID systems can be more
secure than analogue systems, with stronger, more intelligent, and more easily
monitorable data protection measures, which in turn offer better guarantees of
data privacy.
Taking advantage of these benefits, however, requires
purposeful preventative action and an ongoing commitment to identifying and
mitigating potential threats. Absence of such officially authenticated
identification may pose disadvantages and undermine the financial inclusion of
such individuals. The inability to credibly prove one’s identity does not only
hinder financial inclusion but may lead to an individual’s political and social
exclusion.
In the financial services domain, absence of a valid and
officially authenticated identification renders inaccessibility to the basic
yet most crucial facilities like loans, bank accounts, ATMs etc. National
governments play a primary role in enacting measures to facilitate the
recording of legal identity for its residents. With increasing digitisation,
national governments must now focus on implementing robust and digitally
enabled identification systems that can increase individual’s access to
financial services and more holistic representation in the digital world.
Therefore, it is incumbent that countries establish a
reliable supervisory model to introduce efficient Digital ID systems. However,
such implementation of systems on a nation-wide scale has its own challenges,
namely, the risk of exclusion, political concerns, cost implications, data
privacy, protection and security To foster financial inclusion, tiered and
electronic KYC regime may be utilized by the Financial Institutions to gain
foresight of their customer’s objectives, needs and circumstances or be
prepared to say that the client has refused to identify those objectives.
Developments in technology have brought about various
technology solutions, known as ‘KYC utilities’ which act as a single repository
of customer identity data which is utilized for facilitating easier KYC
process. By digitising processes through KYC utilities, the time required for
identity checks and verification can be shorten, CDD compliance costs can be
reduced and potentially the quality and reliability of customer data will be
improved. With the intention of understanding the development of Digital ID and
e-KYC programmes among the Arab countries, a questionnaire was circulated to
the Regulatory and Supervisory authorities in the Arab Countries. Based on the
findings of the survey, it is noted that Digital ID system are still in nascent
stages, though there are systems in most countries for a government issued
national identity system.
Most countries are still following physical KYC structure
with face-to-face interactions (or equivalent) and physical documents being the
basis for client on-boarding and verification models. Bahrain and UAE appear to
be the frontrunners in the implementation of an e-KYC model. Based on the
findings of the survey, a range of action items have been proposed to Arab
Countries: Establishment of a unique, legal, interoperable, Digital ID with an
‘identity first’ focus that collects minimal information for creation of an
identity.
Support the Digital ID framework by adoption of policies,
rules and regulations addressing the risks or concerns associated with the use
of Digital ID.
Establish a ‘risk-based’ CDD regime which balances between
the AML/CFT objective and financial inclusion objectives.
Prioritize integrity of user data and facilitate processes
and procedures for minimalistic sharing of the information during CDD.
Create benchmarks and standards for use of any
‘non-government’ backed identity systems.
Ensure complete, accurate and better integrated databases
that can be utilized for customer identification and verification purposes.
Implement a strong governance model to manage the Digital ID
and CDD regime.
Provide regulatory clarity, remove barriers and foster
enabling regulatory environment for innovation which may provide newer
solutions for CDD.
Collaborate with regional and international
bodies and regulators.