普惠金融联盟《利用数字金融服务应对全球紧急情况的政策框架——以COVID-19为例》.pdf

POLICY FRAMEWORK FOR LEVERAGING DIGITAL FINANCIAL SERVICES TO RESPOND TO GLOBAL EMERGENCIES – CASE OF COVID-19 FRAMEWORK 2 POLICY FRAMEWORK FOR LEVERAGING DIGITAL FINANCIAL SERVICES TO RESPOND TO GLOBAL EMERGENCIES - CASE OF COVID-19 INTRODUCTION 3 I. PROMOTION OF DIGITAL PAYMENTS 4 II. SECURE AND RESILIENT DIGITAL PAYMENTS AFI members are encouraged to use the policy framework as relevant to their respective jurisdictions in response to the global emergency. Regulatory authorities should view the policy framework as an evolving document they can build on as they share experiences and best practices. INTRODUCTION The global pandemic COVID-19 and the ensuing emergencies have reinforced the urgency of using Digital Financial Services DFS to preserve the functioning of financial systems and the security of people during the period of declining demand, reduced supplies, and tightening credit terms. Digital payments, particularly when accompanied by digital financial infrastructure interoperable payments, unique digital IDs, etc. and enabling regulations e-KYC, fees, etc., help governments quickly and securely make cash transfers and other socio-economic benefits in the of financial support. They enable businesses with urgent flow of funds and allow individuals to send money cross borders and to pay for purchases at a market or a store from the safety of their homes. But its potential is much greater than what we know today. This global emergency has highlighted the benefits of DFS in building resilience to withstand economic and financial shocks. In the short term, DFS have helped accelerate the response to health emergency and support economic recovery. In the longer term, they have the potential to play a considerable role in economic development and the eradication of poverty. During the DFSWG virtual meeting held in April 2020, members noted the need to initiate work on DFS and respond to the global pandemic. This was also reflected in the joint working group global webinar on “Regulatory capacity of existing infrastructure to handle any changes in transaction volumes; safety and security of the employees, in accordance with national/international health guidance; internal and external communication plan; etc. From the preparedness of regulatory authorities’ perspective, the development of a contingency and business continuity plan should be ensured. This should at minimum include the implementation of health and hygiene measures, in accordance with national/international guidance; identification of critical functions; and governance and oversight plans and measures to protect critical technology/ digital infrastructure, such as retail payment systems, ination systems for supervision, data storage systems, etc. Bank of Italy 2020. In the medium term, both regulatory authorities and DFS providers should develop and calibrate contingency plans to address pandemic risks and identify practical actions with swift cution, in proportionate to the severity of the potential pandemic scenarios, whilst considering the operational risks and the ability to serve customers with limited functions, split teams and/or remote teams. Further, authorities should provide in-depth guidance on disaster recovery and national switches’ disaster recovery plans and server mirroring techniques. Business continuity management should include identifying core business processes and fetching alternatives to sustain operations during emergencies e.g. offline solutions/ integrations. II. SECURE AND RESILIENT DIGITAL PAYMENTS b to simplify logistics of providing payments and; c to enhance the current health measures that are put in place. As the emergency demands working remotely from home, authorities need to ensure additional security mechanisms to protect servers and end-user devices their own as well as that of the DFS providers, such as computers, laptops, mobile phones and other digital devices that connect to a corporate network. . Authorities to ensure the establishment of a focal point in order to effectively communicate critical issues during emergencies. Among other things, authorities to implement data security measures, such as appropriate technical and organizational safeguards to protect data from unauthorized access and processing which may amount to abuse, accidental damage, and loss. 8 POLICY FRAMEWORK FOR LEVERAGING DIGITAL FINANCIAL SERVICES TO RESPOND TO GLOBAL EMERGENCIES - CASE OF COVID-19 III. ENABLING REGULATIONS Regulation is not a one-size-fits-all approach and can be reviewed under critical periods to suit the prevailing circumstances by regulatory and supervisory authorities. Though most countries have existing regulatory frameworks on agent banking, mobile money, payment systems, etc., there may be a need to modify existing provisions or come up with new guidance specifically to deal with the emergency. These measures could either be temporary or long term in nature. Further, these measures could be issued either as a simple directive, letter of no objective, or as part of a regulatory sandbox/innovation hub initiative. The following are the guiding principles around enabling regulations ANTI-MONEY LAUNDERING/COMBATING THE FINANCING OF TERRORISM With so much turbulence and disruption caused by COVID-19, its health risks and the resulting mortalities, population behaviors in general have been affected; those avoiding infection - whether individuals, striving businesses or governments - highly prefer remote, digitized interactions. At the same time, the situation also offers opportunities for scammers and money launderers to exploit. As such, special focus and perspective are required from AML/CFT Policymakers. Some of the increased risks concerning AML/CFT are listed below a. Donation scammers Scams of donation that target kind-hearted people who donate to support others facing hard times due to unemployment. b. Money laundering Money launderers that exploit vulnerable companies facing financial difficulties and further abuse mules people who agree to receive the laundered cash before transferring out to the launderers. The following are specific guidance Authorities to enforce robust communication and ongoing reporting for a proactive detection of scamming and behaviors. DFS providers should keep records and maintain ongoing risk checks on customers, apply enhanced due diligence or expediting the reporting of suspicious behaviors to authorities, and authorities to educate providers on suspicious behavior for proactive future detection. Authorities to work with DFS providers to enhance customer awareness/education through relevant communication channels to be broadcast on how to avoid scammers and instead, send cash to trusted/ verified donation collection entities. Leverage on the benefits of machine learning algorithms for ML/FT smart detection. - For smarter and faster detection of suspicious behavior, with less labour and higher coping mechanisms with the robust nature of digital payments. Amplify application use of risk-based approach, utilizing simplified due diligence/tiered Know Your Customer KYC, where applicable, to provide safe services to the population, with payments made the easiest way possible, and encourage DFS adoption at a time where it is much more safe than dealing with cash and its related human interactions. Enable e-KYC and digital identification and verification solutions to enable more remote digitized on-boarding. Ongoing contact and collaboration to include AML/ CFT authorities and service providers for continuous alignments on recent potential risks, along with ensuring logical risk-based AML/CFT approach that does not impede the adoption of DFS. KYC AND CUSTOMER DUE DILIGENCE KYC is a critical step for providing financial services that sometimes might cause an impediment and obstacle to reach the underserved. In this time of COVID-19, where social distancing is key, eKYC and digital identities play a critical role in enabling digital services, along with simplified due diligence, to offset the risk of the offered services and the current situation. The following are specific guidance Apply simplified KYCs where there is assessed lower ML/TF risk, in keeping with FATF standards. III ENABLING REGULATIONS 9 POLICY FRAMEWORK FOR LEVERAGING DIGITAL FINANCIAL SERVICES TO RESPOND TO GLOBAL EMERGENCIES - CASE OF COVID-19 Adopt digital identities and e-KYC solutions and regulate it as part of the financial services ecosystem. Reduce the requirements on non-face-to-face account opening to include either two or more documents digitally for authentication. Use video calls/ID with interview for proper facial screening and voice authentication. Apply proportionate KYC requirements for merchants and smaller merchant on-boarding. Request providers to enhance security for eKYC customers with advanced verification authentication. CONSUMER PROTECTION AND MARKET CONDUCT Consumer Protection plays a more obvious role in ensuring sustainability than jump-starting DFS markets. One important aspect is trust building to be widely recognized. Given the complexity in the use of digital payments, it is essential to have an effective and robust financial consumer protection framework that will address risks associated with consumers, especially the vulnerable segment. This global emergency will nudge, rather force, users from vulnerable segments, such as inal workers, women, elderly and small businesses, to jump on to the digital bandwagon. This will certainly pose consumer protection risks and will entail appropriate regulatory interventions, including enhancing digital financial capability. The following are guidance to consider DFS providers should ensure consumers receive timely and easy access to ination through multiple channels. Evolve the disclosure of terms and conditions; prevent misleading ination regarding terms and conditions, and fees by applying sanction and rules against provisions in the regulatory framework. Implement measures and education initiatives to protect consumers from loss due to fraud. Ensure that providers create an ethical corporate culture with fair treatment for customers and recognize that all customers are not the same; provide processes and flexibility of treatment for vulnerable customers. Establish interactive voice response, text-based content and potential chat-box mechanisms to deliver key ination on terms and conditions. Establish or segregate call centre staff from consumer protection hotline. Regulators should ensure that products are not bundled but clearly labelled and visible for consumers to make their choices. DFS providers should ensure consumer data is protected and not shared with third parties. Under extraordinary circumstances if customer data must be extracted for contact tracing and containment of transmission, it must be done in a voluntary manner. Further, such measures should be temporary in nature. REMOTE SUPERVISION Technology is evolving and the use of the Internet connectivity and plats can enable regulators to easily access and receive data from various providers. Regulators can leverage on SupTech and RegTech as a technology compliance solution to effectively conduct remote supervision and analyze the risks posed on the various innovative models under a lockdown situation or during an emergency. To ensure that the knowledge, skills and tools of the staff are effective in conducting remote supervision, Standard Operating Procedures SOPs should be established with the following guidance Collaborate with Internal Management Ination System of regulatory authority and providers to access transactional data with a remote supervisor. Secure and encrypt system using a virtual private network; remote supervision will not be done on the staff’s personal laptop and/or personal email. Regulator to use innovative technologies, such as AI/ ML/advanced data analytics, DLT, cloud computing and APIs to enhance existing and remote supervisory functions. Provide staff with a laptop that has dual authentication and log in controls that can be restricted by the regulatory authority. Provide staff with Wi-Fi and ensure firewalls are blocked from accessing emails. Analyze data only on off-site supervision during this period; but to be used to provide judgments by regulatory authority. Online complaints mechanisms can be monitored by supervisory authority to understand agent’s behavior and utilize the website and Internet to carry out financial literacy and awareness. Conduct surveys on cell phones to obtain customers’ feedback on services offered. Conduct remote meetings using Skype, Zoom and other relevant apps with providers and ensure meetings are recorded. 10 POLICY FRAMEWORK FOR LEVERAGING DIGITAL FINANCIAL SERVICES TO RESPOND TO GLOBAL EMERGENCIES - CASE OF COVID-19 Providers to send regular updates to agents and customers reminding them to maintain social distancing and personal hygiene. Authorities to work with DFS providers to facilitate effective liquidity management and rebalancing facilities to agents. This can be done by partnering with additional stakeholders, such as post offices, microfinance institutions, commercial banks and other locally relevant agencies. Further, where possible, agents can be provided with credit/ working capital facilities to manage their liquidity needs. These initiatives can be undertaken as public- private partnerships or through private sector driven initiatives, with active support from regulatory authorities. Agents and merchant outlets are frontline workers providing essential services to the customers, often vulnerable segments. This is despite the dip in revenues and increased health risk. In this regard, authorities could work with DFS providers and other relevant stakeholders to come up with social protection measures, such as health insurance, income support programs for agent and merchant outlets. Provide dedicated services for the vulnerable customers, especially disabled, women and the elderly. Consideration should be given for dedicated resources to be allocated to the vulnerable. This could be in the of dedicated timings and staff, so that their financial needs are addressed efficiently and promptly in an effort to minimize long queues and further delays. In the medium to long term, authorities to collaborate with diverse stakeholders to create a cash-lite economy by creating additional use cases and multiple access channels through interoperable arrangements. In the medium to long term, consider promotion of gender diversity in agent networks, which is a significant barrier for women’s access in a number of markets. IV. AGENT AND MERCHANT OPERATIONS The ability to transfer funds are deemed crucial for financial inclusion, as most of the developing economies