Various FATF Recommendations are considered in order to provide the context for the analysis set out below, specifically in respect of the following: money or value transfer services (Recommendation 14), new technologies (Recommendation 15) and wire transfers (Recommendation 16).
It is recognised that new technology opportunities and mobile services offer solutions that will, to a far greater extent than in the past, provide opportunities to deliver financial services to the underserved or excluded market. Technology advances enable broad-based, remote off-line, non-face-to-face, lower cost, secure delivery that should be appropriately regulated and supervised. While it is acknowledged that they may represent new ML/TF risks, and it is accepted that appropriate measures must be in place to address these in institutions, they may also bring with them new opportunities for financial inclusion as well as new opportunities for ML/TF risk mitigation. This should be seen holistically from an AML/CFT perspective and should specifically consider the risk of financial exclusion. The degree to which these can be leveraged to offer financial inclusion opportunities will, to a large extent, depend on the AML/CFT regulatory requirements that are in place in a jurisdiction.
The ability to move money or value, domestically or cross border, from one person to another, is central to financial inclusion objectives. It is increasingly recognised that financial service delivery channels must address challenges that are evident in reaching the geographical spread of populations in the SADC region in a manner that is cost effective. This should, in the interests of financial inclusion, be enabled in the AML/CFT regulatory frameworks of the countries in question.