Objectives:

• Analyze the core conflict between strict AML/CFT compliance and the goal of maximizing **financial inclusion**.
• Interpret the relevant **FATF Recommendations** and Guidance that permit and promote a **Risk-Based Approach (RBA)** for lower-risk customers.
• Apply the principles of **proportionality** to design simplified customer due diligence (**SDD**) procedures for the unbanked.
• Evaluate the specific money laundering and terrorism financing risks associated with various **financial inclusion products** (e.g., mobile money, agent banking).
• Develop operational strategies for using alternative forms of identification (e.g., digital ID, community verification) in an AML/CFT-compliant manner.
• Design effective, risk-appropriate transaction monitoring and suspicious activity reporting (**SAR**) processes for low-value accounts.
• Understand the role of national identity systems and regulatory collaboration in facilitating inclusion while maintaining integrity.
• Assess the regulatory and policy changes required to safely and successfully onboard the financially excluded.

• AML/CFT Compliance Officers and Managers in Financial Institutions
• Financial Intelligence Unit (FIU) Analysts and Officers
• Regulators from Central Banks and AML/CFT Supervisory Bodies
• Financial Inclusion Policy Makers and Development Specialists
• FinTech and Mobile Money Operators (MMOs) Compliance Teams
• Heads of Financial Crime Risk and Internal Audit
• International Development Bank Staff focused on Governance and Inclusion

• Case Studies on FATF Mutual Evaluation Reports and RBA application.
• Group Activities on designing a compliant SDD procedure for a mobile money product.
• Discussions on the ethics of de-risking vs. inclusion and the need for a national policy.
• Individual Exercises on performing a mini-risk assessment for a new inclusion product.
• Role-playing a dialogue between a regulator and a bank seeking to use alternative ID.
• Workshop on drafting policy guidelines for agent network AML/CFT controls.

Unit 1: The Regulatory Landscape and the Conflict

• Rationale and core requirements of global AML/CFT standards (FATF, UN).
• Defining **De-risking** and its negative impact on financial inclusion.
• The imperative to comply with both AML/CFT and national inclusion mandates.
• Case studies on where overly strict AML/CFT has excluded populations.

• Analyzing **FATF Recommendation 1** and the RBA principle.
• FATF Guidance on Financial Inclusion and the RBA: Key takeaways.
• Defining **Low-Risk** scenarios and criteria for the financially excluded.
• The requirement for a national AML/CFT risk assessment that considers inclusion.

Unit 2: Simplified Customer Due Diligence (SDD)

• Legal and operational design of **Simplified Customer Due Diligence (SDD)** procedures.
• Setting appropriate thresholds for SDD (account balance, transaction limits).
• Acceptable forms of **non-traditional identification** and verification methods.
• Mitigation strategies for the remaining risks associated with SDD accounts.

• Leveraging **Digital Identity (ID)** systems for remote and secure onboarding.
• Using biometrics and geospatial data for enhanced, low-cost verification.
• The role of **Agent Networks** in performing client due diligence and verification.
• Regulatory sandboxes and innovative approaches to AML/CFT for FinTech.

Unit 3: Product-Specific Risk Mitigation

• AML/CFT risk profile for **Mobile Money Services (MMS)** and e-wallets.
• Managing risks in agent banking, P2P payments, and informal networks.
• Designing risk-appropriate transaction monitoring for low-value/high-volume flows.
• The regulatory approach to AML/CFT for microfinance institutions and cooperatives.

Unit 4: Monitoring, Enforcement, and Policy Alignment

• Tailoring AML/CFT supervision to assess the adequacy of RBA application.
• Effective **Suspicious Activity Report (SAR)** filing for inclusion products.
• Policy coordination between the Financial Intelligence Unit (FIU) and Financial Sector Regulators.
• Addressing the challenges of cross-border financial inclusion and AML/CFT.