Financial Action Task Force Standards and Financial Inclusion: What Should Be Done – and Not Done – to Improve the Alignment Between Integrity and Inclusion Policy Objectives?

The working paper was drafted to meet the 31 August 2020 deadline of the Financial Action Task Force’s public consultation process relating to the extension of the risk-based approach to proliferation financing. The paper draws primarily on recommendations made in our research papers over the past two decades to highlight the following: • Broaden FATF’s financial inclusion focus from access to financial services to actual usage of those services; • Require supervisory understanding of institutional decisions not to simplify CDD in lower risk scenarios; • Do not extend FATF’s risk-based measures to proliferation financing without considering its impact on financial inclusion; • Ensure that the FATF standards support collaborative Customer Due Diligence to increase the effectiveness and efficiency of AML/CFT control measures.