More than 100 countries have launched emergency cash disbursement programs to alleviate financial hardships for individuals and households in light of the COVID-19 pandemic. Many of these programs are based in digital payments; however, a lack of official identification, mobile data services and the difficulties in face-to-face interactions restrict potential users from a standard customer due diligence process. Guidance from the Financial Action Task Force (FATF), the global anti-money laundering standards-setting body, encourage the use of innovative solutions for customer onboarding, specifically the risk-based approach and simplified due diligence (SDD). This paper summarizes the range of practice across jurisdictions that have employed a combination of SDD (also known as tiered CDD), licensing of non-bank financial institutions, and digital identification to enroll unbanked individuals into financial accounts so that they could receive COVID-19-related relief cash transfers. As this note concludes, jurisdictions that had adopted such practices were able to quickly ramp-up disbursement programs, bringing tens of millions of beneficiaries into the formal financial system.

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