As we engage in cash programming we partner with financial institutions more and more to partner with us in the delivery of aid. This has many benefits including various efficiencies, but it also has unintended consequences.
The humanitarian principles are key principles that all humanitarian actors are expected, in some cases required, to adhere to. One of them is the humanitarian principle of Impartiality which requires us to give aid without bias:
Humanitarian action must be carried out on the basis of need alone, giving priority to the most urgent cases of distress and making no distinctions on the basis of nationality, race, gender, religious belief, class or political opinions.https://www.icrc.org/en/ihl-and-humanitarian-principles
On the other hand, KYC or Know Your Customer is a financial regulation requiring us to know who we are engaging with for a financial transaction.
KYC is the process whereby a business verifies the identity of its clients and assesses their suitability, along with the potential risks of illegal intentions towards the business relationship… [It is a process] of ensuring their proposed customers, agents, consultants, or distributors are anti-bribery compliant, and are actually who they claim to be.https://en.wikipedia.org/wiki/Know_your_customer
So one principle says to only consider need and the other says know who you are dealing with. On the face of it, there doesn’t seem to be any issues. However, this may change as we dig in.
KYC requires financial institutions to verify that I am who I say I am. In order to do this, they require validated documentation. For example, proof of address from specific type of organisation, government issued identity documents like a passports, national ID card, birth certificates and so on. All fairly standard.
The challenge is when you don’t have those types of documents because you have fled your home due to natural disaster or conflict, or you are refugee, or you have been living in poverty, and so on. The people who tend to need humanitarian aid tend to be the people who are least likely to have the documentation acceptable for completing KYC.
Secondly, as KYC requires us to prove who we are, which comes with the requirement of documentation. Therefore, if aid programmes move to the type of cash and voucher programming which require KYC adherence, then aid is not based on need alone. Are you then excluded, if you have need but do not have the KYC documentation?
It is a fine line. But fine lines are where the subtle and significant shifts happen, unintentionally. Fine lines are where the long term changes slip in.
Considering who it leaves out is a critical step. But also asking if this is a shift we want to make is also critical; make it a conscious choice, not a subtle, unconscious one.
And yes, we’ve collected data about who people are for years and in many projects. That is not the rub. The rub is when it, along with certain types of proof, becomes a requirement, a pre-requisite. And it is all done under the banner of our humanitarian principles.