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Addressing Customer Due Diligence Obligations to Promote Rohingya Financial Inclusion

May 2018 — By Quentin Vassas, Noanne Laïda

This report seeks to demonstrate that viable solutions exist for undocumented refugees, and outlines successful examples in different contexts whereby alternative KYC approaches have been established for refugees. It further demonstrates that by identifying and assessing the risks and concerns around money laundering and financing of terrorism (ML/FT) in relation to the Rohingya population in Bangladesh, many of these perceived ‘risks’ can be managed and mitigated through customising the policies of financial service providers (FSP). The report finally highlights recommendations for the Bangladesh authorities and FSPs in relation to enabling access to financial services for the Rohingya population.