Purpose – The purpose of this paper is to explore the relationship between anti-money laundering (“AML”) and combating of financing of terrorism (“CFT”) customer due diligence (“CDD”) measures in the financial services industry, and exclusion from financial services. Design/methodology/approach – An introduction to the concept of financial exclusion is provided as well as an overview of international AML/CFT CDD standards. The paper highlights a softening of national CDD measures in South Africa and the UK to lessen the impact on financial exclusion. Findings – Countries should consider the impact that CDD requirements may have on financial exclusion when they design their AML/CFT systems. Research limitations/implications – Multi-discilinary research is required to improve the understanding of the broader interaction between AML/CFT objectives, financial exclusion and economic development, especially in countries with a large informal economy. Practical implications – CDD requirements may unnecessarily exacerbate financial exclusion if they are not formulated with care to reflect the reality of the particular country setting. Originality/value – The paper offers insights into the international standards resulting to the identification of clients and the experiences in the UK and South Africa regarding the implementation of these standards on financial exclusion.

Purpose: The purpose of this paper is to investigate Financial Action Task Force (FATF)'s risk‐based guidance to combat money laundering and terrorist financing to determine its approach to the identification and management of low‐risk providers, products and transactions.Design/methodology/approach: The paper analyses the relevant FATF recommendations and its guidance notes and reflects on key questions for regulators and financial institutions.Findings: FATF has not defined “risk” for purposes of the risk‐based approach. The absence of a clear definition complicates the identification of low‐risk products. FATF do provide an example of a risk matrix that can be used to identify low‐risk banks, but the example is based on assumptions and generalisations that are not sustainable. In addition, it identifies certain low‐value transactions as “low risk” transactions. The paper reflects on the role of value as an indicator of risk and concludes with a number of suggestions to clarify the conceptual framework.Originality/value: Low‐risk products and transactions are often overlooked because the risk‐based approach focuses attention on high‐risk matters. Low‐risk products are however crucial to the efforts to increase financial inclusion. The paper identifies gaps in the current conceptual framework and indicates ways in which they can be addressed.

This study considers the impact of the FATF’s greylisting process from a market perspective. The results are intended to inform the development of public policy and improvement of market signalling. The study develops a theoretical market impact model and identifies the indicators which may impact banking operations and institutional decisions. It is explicitly market-oriented in that the model seeks to reflect how stakeholders in financial and non-financial markets typically respond to signals sent out by the FATF. The authors find that the FATF’s greylisting signalling has changed over time and distinguish four broad periods reflecting different messaging. The study uses financial, trade, and other variables derived from the World Bank’s ‘World Development Indicators’ databank to explore evidence of impact in each of the different phases of the FATF’s approach to greylisting. The study uses a pooled cross-section and time series approach with fixed effects, based on a sample of 177 countries and 3540 country-years of data from 2000 to 2020. The study examines impacts on net official development assistance, the banking environment (non-performing loans, risk premiums), net foreign assets, indebtedness, and market capitalisation. It finds significant correlations between many financial variables and FATF listing events, including an apparent reduction in development assistance during greylisting periods which endured after the country was delisted. This is of significant concern, as such reductions may impact disproportionately on developing economies.

Purpose – The purpose of this paper is to identify key questions that should be addressed to enable the Financial Action Task Force (FATF) to provide guidance regarding the alignment of anti-money laundering, combating of financing of terror and financial inclusion objectives. Design/methodology/approach – The paper draws on relevant research and documents of the FATF to identify questions that are relevant to consider when it formulates guidance regarding the alignment between financial integrity and financial inclusion objectives. Findings – The FATF advises that its risk-based approach enables countries and institutions to further financial inclusion. It is, however, not clear what the FATF means when its uses the terms “risk” and “low risk”. It is also unclear whether current proposals for financial inclusion regulatory models will necessarily limit money laundering as well as terror financing risks to levels that can be described as “low”. The FATF will need to clarify its own thinking regarding low money laundering and low terror financing risk before it will be able to provide clear guidance to national regulators and financial institutions. Originality/value – This paper was drafted to inform current FATF discussions regarding guidance on financial inclusion. The questions are relevant to all stakeholders in financial regulation.