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Influence the normative framework

What are the potential risks?

The concerns of affected people are not taken into consideration in the design of cash-based transfers, and this leads to imbalance of power at different stages of the user journey.

What standard do we want to achive?

When identifying risks of abuse of power in cash assistance, participation, inclusion and consultation are fundamental principles. Humanitarian agencies need to ensure that the views of cash recipients in their diversity are taken into consideration.

Key actions

Tools to influence the normative framework around access to financial services, data protection and customer protection

What are the potential risks? 

  • The national regulation prevents vulnerable groups from accessing formal financial services
  • Personal data is compromised by lacking regulation, poor enforcement of the regulation, or poor data protection measures.
  • The rights of clients are not protected because client protection regulation is lacking or poorly enforced.


What do we want to achieve?

  • Financial regulators define the Customer Due Diligence requirements, particularly Know-Your-Customer (KYC) requirements, which have to be met to access financial services. Tiered KYC requirements facilitate initial access to financial services for cash recipients who do not have the required national identification documents. Tiered KYC ensures that people facing these challenges are eligible for proportionately lower risk-based anti-money laundering and combating the financing of terrorism (AML/CFT) controls. Products and services available to cash recipients under tiered KYC requirements might be entry-level with limited functionality or with restricted use.


  • Regulators set standards for data protection and broader client protection. A national data protection framework will structure the conditions of and support for the mitigation of risks related to the collection, use, storage, disclosure and disposal of personably identifiable information on cash recipients. Humanitarian agencies should have adequate data protection policies in place to ensure cash recipient data is protected in the interactions with all stakeholders.


  • Regulators include client protection in the national legislation to ensure safe and dignified access to financial services, especially for the most vulnerable. Financial service providers follow ‘responsible finance practices’ including transparency on pricing and terms and conditions, ethical standards in the treatment of clients, privacy of client data and mechanisms for complaint resolution.

Advocate with regulators to increase access to financial services

Ensure affected communities have fair access to financial services. Privilege beneficiary owned full-fledged account and promote tiered KYC requirements for vulnerable groups.


Protecting cash recipients' personal data

Ensure that personal information is safeguarded. Advocate for the development/application of data protection frameworks that support lean collection of personal information and efficient processing and redress. Conduct data privacy impact assessments of your programmes when in doubt.


Advocate with regulators to strengthen client protection

Advocate for national client protection regulation which considers specific vulnerabilities.