Risk-Based Supervision in Low-Capacity Environments

Considerations for enabling financial inclusion
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This paper is a supplement to the official and peer reviewed CGAP Technical Guide: A Guide to Supervising E-Money Issuers (EMIs), (December 2018).

It aims to provide general guidance to supervisors designing proportional approaches to EMI supervision and drafting or improving EMI supervision manuals, while highlighting that a risk-based methodology would help EMI supervisors develop a proportional approach.  This paper summarizes the findings of our research on available guidance and challenges observed in emerging markets regarding the implementation of risk-based supervisory approaches that aim to support responsible financial inclusion, especially in the context of digital financial innovations. The paper also includes an illustrative case study on the Philippines and recommendations on areas for future work by the international community. 


This work was funded in whole or in part by CGAP. Unlike CGAP's official publications, it has not been peer reviewed or edited by CGAP, and any conclusions or viewpoints expressed are those of the authors, and they may or may not reflect the views of CGAP staff.

About this Publication

By Laura Brix Newbury and Juan Carlos Izaguirre