3rd December marks the International Day of Persons with Disabilities. As part of our efforts to address the impact of financial crime programmes on inclusivity, we wanted to take this opportunity to reflect on how fincrime controls may impact those with a disability and how we can avoid creating barriers.
This is not a trivial issue. According to the World Health Organization, over one billion people (about 15 percent of the world’s population), have some form of disability. In the UK, the figure is 14.1 million people. The House of Lords’ Select Committee on Financial Exclusion has found disabled people are likely to be disproportionately affected by financial exclusion, even though UK financial institutions have a legal obligation under the Equality Act 2010 to make reasonable adjustments for disabled customers.
FinTechs can clearly help remove barriers for some customers, such as those with limited mobility or hearing or speech difficulties, who find it easier to access financial services via an app. However, along with actively considering accessibility and inclusive design for their products and processes, they need to be super aware of how their financial crime controls may inadvertently impact customers with disabilities, to ensure they’re not excluded or provided with poorer services.
Fraud controls represent a particular challenge. Many of the controls put in place to keep out fraudsters can also inadvertently block people with disabilities from accessing their own money. Certain means of confirming identity will be challenging with certain disabilities, and features such as accounts timing out may be a barrier. A good approach is to provide options. Different customers may need different methods for activating cards - e.g. ATM activation may not be suitable for those with limited mobility, and customers with visual or dexterity impairments may find using an app difficult and prefer to speak on the phone, which customers with hearing or speech impairments may not. Similarly, while using a pin for card payments is more secure than a signature, it may not work for customers who struggle to remember a pin or have restricted dexterity.
Authentication processes which rely on a cognitive function test (a task that requires a customer to remember, manipulate, or transcribe information) can also be an obstacle. Customers with dyslexia or memory difficulties may find it difficult to remember specific characters from a security password, for instance. Here again, providing alternatives for certain customers can help - ideally offering at least one alternative method such as biometric identification (e.g. fingerprint scanning).
While digital banking reduces most direct customer interaction, financial crime teams will sometimes need to contact customers, e.g. to ask for information at onboarding or in relation to an unusual transaction. Again, disabled customers should be offered suitable options to meet their specific needs. Customers with dexterity problems may prefer to speak to someone over the phone rather than use a chat function, but those with hearing or speech impairments may prefer to type. While providing different communication channels undoubtedly increases operational complexity, it is vital to find ways to facilitate customers with additional needs.
Another issue to consider is how to distinguish between customers whose accounts have been taken over or who are being coerced or manipulated by someone else, and those who require assistance to access their money. Staff should be made aware of this possibility, and given suitable guidance on how to differentiate. Alternatively, customers could choose to have this information recorded on their account. Some firms allow an authorised third party to take certain actions on an account, for instance some providers issue cards for carers who can make limited purchases on behalf of the card holder without gaining unrestricted access to their whole account.
Finally, we as anti-financial crime professionals need to look inwards and consider the composition of our teams. Are we being as inclusive as possible, and are we offering equal opportunities to those with disabilities to work in this sector? As with any issue of inclusion, a more diverse team which encompasses those with disabilities will likely be better at spotting potential barriers and unintended consequences of financial crime controls. Can we do more to make hiring inclusive, and to make sure working arrangements are flexible and accommodating?
In partnership with Tech Nation’s FinTech Delivery Panel, FINTRAIL has produced a set of “FinCrime Principles of Inclusion”, which aim to increase awareness of the tensions between financial crime prevention and financial inclusion, whilst offering practical considerations for those designing or assuring an anti-financial crime frameworks. Find out more and download the principles here.
There are many initiatives underway in the financial sector to support financial inclusion. Without an active effort to consider the inclusion of customers with disabilities, fincrime controls can sometimes unintentionally undermine these efforts. We need to ensure that anti-financial crime measures do not create unnecessary barriers and undermine the industry’s drive towards inclusivity.
Key takeaways:
Offer alternatives for customers with disabilities: e.g. how to communicate with staff or how to activate a card
Train staff on recognising the needs of customers with disabilities
Recognise the difference between third party assistance and account takeover / coercion
More inclusive fincrime teams are likely to create and operate more inclusive controls.
Consider adopting the FinCrime Principles of Inclusion to ensure inclusivity is a key part of your thinking on financial crime controls
If you’d like to learn more, please contact Maya Braine, Head of Insights or email us at: contact@fintrail.com.