Anyone who has been to my AML introductory training for new staff will have seen my slide showing a Serbian photographic driving licence offered as proof of identity by a lady of Iraqi origin. The problem with it is that the photograph is of her face completely covered by a rather lovely peacock-blue veil. It was accepted at a bank that shall remain nameless, because they were chary of causing offence by stating the bleeding obvious, which is that a photograph that shows no features at all is rather worthless as proof of identity. Now, we’re all nice people, keen to tolerate other cultural preferences and norms, but perhaps we need to make the rather valid and important point that access to financial services is a privilege and not a right. And if you want to avail yourself of that privilege, you need to comply with the entry requirements. (In case you’re thinking about financial exclusion, yes, everyone needs to be able to use the most basic of financial services – somewhere safe to save their money – and such accounts can be provided with minimal entry requirements, mainly because there is very little criminal scope to them. But even these require some due diligence.)
I was thinking about this recently because a blog reader who works in AML in Jersey very kindly sent me this article from a blog about mobile money. It tells the story of a low-income Indian woman who wants to open a savings account at a bank in Bangalore. To quote what happened next: “Being Muslim, Mubeena is wearing her burqa, as she always does when outside of her home. This was unacceptable to the bank branch staff because they could not verify photographs and KYC documentation. So she began to remove her burqa (being completely clothed and nicely dressed underneath), yet what embarrassment for all the men staff at the branch!” In the end, she was sent home, account-less. Can you see me rolling my eyes? If the men in the branch were so outraged by seeing Mubeena’s uncovered head, could she not have been dealt with by a female member of staff? If, on the other hand, Mubeena had refused to reveal her face to anyone, then quite rightly she should have been refused the account.
In short, we do what we can – and we use our noggins to work our way around little challenges like veiled ladies. As my reader in Jersey says in her email: “Sometimes we fall over ourselves to be culturally appropriate, when as far as KYC/CDD/ECDD is concerned, sometimes the actual following of the rules can get in the way of ‘knowing’ your client, and thank goodness for a risk based approach that involves ‘thinking’ – as long as we actually think …”