El pasado mes de marzo venció el plazo para recibir comentarios al nuevo Proyecto de Circular publicado por la Superintendencia Financiera de Colombia, que busca impartir instrucciones relativas a la administración del riesgo de lavado de activos y de financiación del terrorismo.

Innovación e inclusión financiera

El proyecto tiene como fin que las entidades supervisadas lleven a cabo un mejoramiento continuo, promover la innovación y la inclusión financiera, desarrollando nuevas tecnologías que hagan más robusta la administración del riesgo de lavado de activos y de financiación del terrorismo.

Entre los aspectos más destacados se encuentran la posibilidad de que las entidades vigiladas puedan realizar los procedimientos de conocimiento del cliente de manera presencial o no presencial a través del uso de canales digitales o electrónicos y procedimientos simplificados de conocimiento de clientes, entre otros aspectos.

Major progress in technologies is helping banks to design increasingly more viable business models to serve unbanked sections of the population. On this issue, the  Institute of International Finance (IIF) and the Center for Financial Inclusion at Accion (CFI) interviewed executives at 24 banks operating in emerging markets (mainly commercial, public, credit cooperatives and private banks) to learn about their strategies for driving forward financial inclusion using technology, alliances and banking agencies, among others. They also addressed the challenges and opportunities they are facing in the areas of corporate responsibility, regulation, financial literacy and customer protection.

The report summarises the findings of this survey and analyses the role played by banks to encourage financial inclusion in an increasingly digital world. It ends with some recommendations to guide banks in promoting financial inclusion, eg:

• Exchanging good practice: information, models, KYC -Know Your Customer- policies, partnerships with Fintech companies, data analysis, among others.
• Cooperation between banks and national government bodies, incentivising digital payments and inclusive banking (financing for micro, small and medium enterprises (MSMEs), subsidies, etc), building technology infrastructures, implementing pro-inclusion policies, coordination and support among all government bodies (regulators, insurers, governments, etc) and greater commitment to customers.

This document from the Center for Global Development focuses on the role of regulation in the process of financial inclusion. It highlights the major milestones achieved, thanks mainly to the digital revolution – which has allowed new financial services and channels to be developed –and the adoption of appropriate regulation in line with the characteristics and needs of each country (along with other factors). Furthermore, it suggests that inadequate regulation is one of the major obstacles to financial inclusion.

The object of the report is to analyse regulatory factors that impact the effectiveness of inclusive financial regulation and it recommends certain practises for designing this.

The report considers that public policies and regulations have to be flexible enough to ensure that, on the one hand, the financial system is efficient, and on the other, that it protects the consumer. Designing effective regulation, especially for digital finances, is a challenge.

Three commonly-used guiding principles for designing inclusive regulation are the starting point for the recommendations:

1. “The same regulation for the same functions”, in other words, financial services with the same functions are treated the same, irrespective of the legal form of the service provider.
2. “Risk-based regulation”, in other words, the rigidity of legal requirements depends on the risk that it intends to covered, both for individuals and for the stability and integrity of the financial system.
3. “Balance between ex-ante and ex-post regulation”, in other words, there has to be a balance between setting out certain rules beforehand (ex-ante) and resorting to regulating a given problem or market failure after the fact (ex-post).

26 recommendations come out of these principles, which are divided into the following three categories:

1. Foster competition: A market open to competition promotes a variety of products and services, greater efficiency, reduced costs, etc., which facilitates financial inclusion. The object of policies that regulate competition is to allow and provide incentive for new players to come into the market.  
2. Levelling the playing field in financial services, in other words, financial services with the same functions are regulated in the same way, provided that they represent a similar risk for consumers or for the financial system. A level playing field is essential to ensure that all providers compete under equal conditions.  
3. “Know Your Customer” rules (KYC): are necessary to preserve the integrity of the financial system and in particular to fight money laundering and financing of terrorism. KYC standards are important for financial inclusion because when institutions know who their customers are, they can adapt the products and services they offer them to their characteristics and needs.

Finally, the report makes 5 other recommendations that concern new payment systems for paying small amounts, such as mobile money for instance.