Customer due diligence for maximal financial inclusion
How To Identify
& Assess Customers
While Achieving Maximum Financial Inclusion
Maximizing Financial Inclusion
Accept as many deserving
applicants as possible
(“CIP”) with maximum
prices as low as
Contain fraud to
Legally excluded On SDN/Blocked List?
Impersonator Stolen identity?
Prior fraudster /abuser On CHEX list? Other negative list?
Likely to defraud/abuse Anonymized email? Device with malware or on dark web?
Commercially un-suitable Un-scoreable or low score or with senior liens on assets?
(for “borrow” only)
Lists (simple matches)
• Bureaus, CHEX …
• OFAC …
• Banks & networks
• Device Identity
• IP address/Geo-location
• Scan of ID docs
• Prior addresses/ assets
• Digital footprints
• References from peers
What’s Keeping Us Up at Night
Staying ahead in the arm’s race against fraudsters
• Use of new technology: fraudsters are early adopters
• Shorten reaction times: fraudsters can jump quickly from one service to another
Fairness and privacy concerns
• New instances of discrimination against:
• People with no/ few digital footprints
• Protected classes which happen to have specific data patterns
• Possible contribution to the proliferation of online data
Implementing strong CIP and KYC is economically crucial, in order to achieve low
priced services for a large audience. It is not just for compliance.
Technology keeps improving. But fraudsters are always a moving target.
We are aware of potential fairness and privacy pitfalls. New policies will need to
be carefully crafted to protect both consumers and service providers.