Coronavirus: Financial Inclusion Considerations for Risk-Based Supervision and the Virus’s Impact on the Risk-Based Approach

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This Briefing Paper explores how the financial services opportunities created by the coronavirus pandemic can be used to propel the global adoption of a genuinely risk-based approach to supervision and financial crime controls.

This Briefing Paper outlines how countries, supervisors and regulated entities can advance the adoption of a genuinely risk-based approach by considering four main areas.

1. The Financial Action Task Force must correct the imbalance between negative and positive incentives within the international anti-financial crime framework to promote risk-taking by supervisors and regulated entities.

2. Developing countries must be supported so that they can adopt the flexibility already offered by the system.

3. Once prepared to take more risks, all entities would benefit from performing risk assessments that take account of financial inclusion through impact assessments to reduce the occurrence of unintended consequences.

4. The experience of the coronavirus pandemic must be dissected so that lessons learned can be carried forward and built on to promote innovation as a matter of course within the system.

The views expressed in this publication are those of the authors, and do not reflect the views of RUSI or any other institution.

Correction Notice: A minor update to the title of this paper was made on 17 July 2020.


Isabella Chase

Associate Fellow

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Tom Keatinge

Director, CFCS

Centre for Financial Crime and Security Studies

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