Conversely, there are challenges posed by AML-CFT requirements to the goal of achieving financial inclusion and, hence, the FATF Guidance states there is a need to “take account of the nexus between financial integrity and financial inclusion and the cross-reinforcement between these two objectives”.
Fifth, outsourcing of activities by banks, including for financial inclusion, also poses reputational, financial and fidelity risks which may impact the health of the institution and of the financial system9. In particular, the reputation risks associated with outsourcing may impact the activities of the entire bank and not just the outsourced activities in case of any mishap or misdemeanour by the outsourced agents.