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1 In principle, provision of same services should be subject to same know-your-customer and other AML/CFT requirements to ensure a level playing field. Policymakers, regulators and the private sector should take collective responsibility for the interpretation of low and high risks. Compared to cash, use of e-money increases certain money laundering (ML) and terrorist financing (TF) risks while reducing others. Compared to cash, e-money poses greater risks with respect to rapidity but lower risks with respect to anonymity, elusiveness, and oversight. Source: World Bank (2008) Anonymity: Customer's identity is unknown Mobile Money Medium Vulnerabilities Compensating factors Cash Higher Vulnerabilities Compensating factors Elusiveness: Ability to disguise amount, origin, and destination Mobile Money Medium Vulnerabilities Compensating factors Cash Higher Vulnerabilities Compensating factors Rapidity Mobile Money Higher Vulnerabilities Mobile money transactions typically occur in real time,allowing for rapid transaction layering (transferring fundsamong multiple accounts to obscure their origin). Compensating factors Telephone number (sending and receiving), time, and the amount of the transaction are known to the mobile operator. Cash Lower Vulnerabilities Compensating factors Lack of oversight or poor oversight Mobile Money Medium Vulnerabilities Compensating factors Cash Higher Vulnerabilities Compensating factors E-money raises specific ML/TF typologies that need to be properly mitigated. Source: GSMA (2015).PoC = Proceeds of Crime. Introducing monetary amount-based risk tiers and simplifying the KYC requirements for lower- risk tiers is a practical and widely used way of risk-based KYC. Ghana Read More Ghana GH¢S500 (OTC only, with Source: Close Liberia Read More Liberia Source: Close Nigeria Read More Nigeria N50,000 (US$137) N300,000 (US$822) N200,000 (US$548) N500,000 (US$1370) N5,000,000 (US$13700) Source: Close Source: Tools Designing appropriate SDD measures (PDF167.75 KB) Determining value limits for DFS subject to SDD (PDF70.45 KB) Source: AML/CFT obligations and regulatory expectations should also be risk based. Especially in the low-risk tiers, the AML/CFT controls can be simplified. In proven low-risk situations exemptions from some AML/CFT obligations can be considered (by the regulators). Two AML/CFT obligations are particularly important in e-money context: IT capacity to monitor, detect, and analyze unusual transactions, Due diligence and training of the agents. In the context of Recommendation 1, “proliferation financing risk” refers strictly and only to the potential breach, non-implementation or evasion of the targeted financial obligations referred to in Recommendation 7. These R.7 obligations apply to two country-specific regimes for the Democratic People’s Republic of Korea (DPRK) and Iran, require countries to freeze without delay the funds or other assets of, and to ensure that no funds and other assets are made available, directly or indirectly to or for the benefit of AML/CFT Requirements
Overview
Risk
Four key money laundering risks
E-MONEY VS. CASH
MONEY LAUNDERING / TERRORIST FINANCING RISK
Risk
Key e-money actors that may be involved in ML/TF
KEY E-MONEY ML/TF TYPOLOGIES AND MITIGANTS
Customers
Typology Mitigation Measures Fraudulent registration System controls, development of national ID Multiple registrations Central ID verification database, development of national ID, limit of number of accounts per person, SIM registration Transfer of service after registration ID requirement for certain transactions, geographic monitoring, PIN authentication. Loading with PoC Risk-based transaction and balance limits, transaction monitoring systems, PIN authentication, ability to locate mobile device via MSISDN and IMSI. Transfer of PoC to co-conspirators Risk-based transaction and balance limits, transaction monitoring systems to detect anomalous activity. Use of PoC to purchase from sellers Pooling PoC in single account Withdrawal of PoC Transfer to/from terrorists Use of international and domestic watchlists. Agents & Merchants
Typology Mitigation Measures Agent allows PoC to be cashed in or out from account Proper criteria for agent selection, ongoing agent due diligence (automated transaction monitoring, in-person mystery shopping), sharing of agent blacklists. Agent fails to fulfill due diligence obligations Agent allows customers to exceed cash-in or cash-out limits Proper automated system controls that may not be overridden by agents. Complicit merchant received PoC Sound criteria for merchant onboarding, proper ongoing due diligence (automated transaction monitoring, in-person mystery shopping). Fraudulent merchant misappropriates funds Employees
Typology Mitigation Measures Fraudulent registration of false accounts to facilitate ML/TF Theft of funds using internal access through, e.g., false transactions, creation of unbacked e-money, theft from dormant accounts Allowing PoC to be cashed in or out from account Allowing customers to exceed cash-in/out limits ACCOUNT TIERS AND MONETARY LIMITS FOR ELECTRONIC MONEY & SIMILAR DFS IN SELECT COUNTRIES
Tiered KYC
Account Type Single Transaction Limit Cumulative Daily Transaction Limit Cumulative Monthly Transaction Limit Maximum Account Balance All accounts
(US$102)
acceptable ID)Level 1: Minimum KYC account GH¢300
(US$61)GHS¢3,000
(US$612)GH¢1,000
(US$204)Level 2: MediumKYC account GH¢ 2,000
(US$408)GH¢20,000
(US$4,077)GH¢ 10,000
(US$2,039)Level 3: Enhanced KYC account GH¢5,000
(US$1,019)GH¢ 50,000
(US$10,193)GH¢ 20,000
(US$4,077)Account Type Single Transaction Limit Cumulative Daily Transaction Limit Cumulative Monthly Transaction Limit Maximum Account Balance All accounts US$100 (OTC only) Level 1: Entry level accounts US$250 US$2,000 US$1,000 Level 2: Accounts with full KYC US$1,000 US$8,000 US$4,000 Level 3: Accounts with enhanced KYC US$2,000 US$20,000 US$10,000 Account Type Cumulative Daily Transaction Limit Maximum Account Balance Other Restrictions Level 1: Low-value accounts International funds transfer prohibited Level 2: Medium-value accounts International funds transfer prohibited Level 3: High-value accounts Unlimited SIMPLIFIED DUE DILIGENCE REQUIREMENTS FOR LOW-VALUE DFS ACCOUNTS
Country and account Simplified due diligence requirements for low-value DFS accounts Full customer due diligence requirements for regular accounts Colombia (e-deposits) Full name, national ID number and issuance date (verified through access to biometric ID database). Full name, ID number, address, telephone, occupation, employer information. Honduras (e-wallets) Full name (as shown on ID card), address, phone number(s) (verified within 30 days through National Register of Persons). 21 requirements, including full name, place/date of birth, type of ID, nationality, sex, address, phone number, occupation, income, assets, marital statusand more. ELECTRONIC KYC (E-KYC) & SIM KYC FOR DFS ACCOUNTS
Country How e-KYC works India Customer provides fingerprint and Aadhaar (unique ID) number and authorization to conduct e-KYC. Provider sends information to Unique Identification Authority of India’s server; if it matches, account can be opened instantly. Colombia Banks have access to Registrar of Banks’ biometric ID database and can use this database to conduct e-KYC. Pakistan All SIMs are biometrically verified and linked to customer identity in National Database and Registration Authority (NADRA). Biometrically verified SIMs can then be used to remotely open entry-level branchless banking accounts in a few seconds. Kenya Banks are able to leverage KYC details obtained during SIM and e-money account registration to open entry-level mobile banking accounts remotely. Information obtained from the MNO/EMI is verified against information in the national ID database. Ghana E-money issuers that have collected and retained customer ID information previously, e.g., during registration of SIM cards or bank accounts, are allowed to use this information for CDD. The data needs to be validated against the database of the National Communications Authority within 2 days. Main AML/CFT Obligations of E-money institutions
Proliferation Financing (PF) Risks
Considerations
Considerations for Regulators
Considerations for Supervisors