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Global Standards Proportionality
Working Group (GSPWG)

Global Standards Proportionality
Working Group (GSPWG)

The adoption of appropriate global standards for financial stability and integrity is of great importance to ensure that financial inclusion is pursued in tandem with safe and sound financial systems.

Standard-setting bodies recognize that the implementation of global standards should be proportionate, risk-based and without unintended consequences for the promotion of financial inclusion. Nonetheless, achieving proportionality at the national level can be challenging for a variety of reasons. These include:

• capacity challenges in effective implementation of a risk based approach;
• inter-agency coordination and data challenges; and
• insufficient tools to monitor the impact of standards on sectors which may have important roles in financial inclusion.

The Financial Stability Board (FSB) acts as a coordinating body of SSBs with respect to financial stability. In addition, six SSBs engage in work relevant to financial inclusion: The Basel Committee for Banking Supervision (BCBS), the Committee on Payments and Market Infrastructures (CPMI), the Financial Action Task Force (FATF), the International Association of Deposit Insurers (IADI), the International Association of Insurance Supervisors (IAIS), and the International Organization of Securities Commissions (IOSCO).

In 2010, the G20 Principles for Innovative Financial Inclusion were developed with the aim of creating an enabling policy and regulatory environment for innovative financial inclusion. The eighth principle, which relates to ‘Proportionality’, calls for the building of a policy and regulatory framework that is proportionate to the risks and benefits involved in such innovative products and services, and is based on an understanding of the gaps and barriers in existing regulation.

In July 2014, the members of the Alliance for Financial Inclusion (AFI) created the Global Standards Proportionality (GSP) Working Group. This serves as a platform to facilitate peer learning among policymakers and regulators in achieving a balance between financial inclusion, integrity and stability, as well as to examine the proportionate implementation of standards set by global Standard-Setting Bodies (SSBs).

In May 2015, the Global Symposium “Towards Proportionality in Practice: Financial Inclusion and Implementation of Global Standards” was held in Kuala Lumpur, co-hosted by Bank Negara Malaysia, the Toronto Centre, and AFI. The adopted KL Resolution of Proportionality in Practice, calls for the gathering of data and evidence on the impact on implementing global financial stability standards in developing countries, highlighting the costs of unintended consequences and the benefits of proportionate approaches. It also calls for the documentation of successful regulatory and supervisory approaches to implementing proportionality, and the continuation of peer learning for successful approaches to implementing proportionality globally.

Within the global standards proportionality (GSP) thematic area, AFI members have pioneered and implemented a number of approaches to achieve effective policy approaches which balance financial inclusion, stability and integrity considerations. They are also advancing peer learning and capacity building with respect to the opportunities and risks presented by innovative technologies, mitigating the impact of global bank ‘de-risking’ on affected jurisdictions and ensuring that global standards are implemented with consideration for the financial inclusion of disadvantaged groups, including women, youth, forcibly displaced persons and populations living in rural areas.

While financial integrity and stability are the key mandates of financial regulators globally, financial inclusion plays a key role in crisis mitigation, economic recovery and resilience building. The implementation of global standards for financial integrity and stability may have unintended adverse consequences on financial inclusion of women and other disadvantaged groups. For instance, women are less likely to hold the requisite documents for customer identification.

In addition, most women may not have access to collateral that is sufficient to secure a loan. It is therefore crucial that global standards are implemented proportionately while considering the inherent risks and being attentive to gender considerations.

GSP, as a thematic area, covers a total of 18 Maya Declaration targets, including those related to the proportionate implementation of both financial integrity and financial stability standards.

Primary thematic area 2012 2013 2014 2015 2016 2017 2018 2019 2020 2023

Global standards proportionality

  • Financial integrity
  • Financial identity
  • Financial stability
Maya Declaration targets 3 3 5 5 6 8 10 18 18 27
Completed 1 1 1 1 1 3 3 4 4 10
In progress 2 2 4 4 5 5 7 14 13 17
Completion rate 33% 33% 20% 20% 17% 38% 30% 22% 22% 37.04%


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AFI’s Global Standards Proportionality Working Group (GSPWG)

GSPWG is a platform that provides technical support to developing and emerging country policymakers to implement global standards for financial stability (e.g. the Basel Framework) and financial integrity (e.g. Financial Action Task Force [FATF] 40 Recommendations) proportionately and without unintended negative consequences for financial inclusion.

The working group supports AFI’s Global Standards and Policy Committee with respect to strategic engagements with global standard-setting bodies and leverages on AFI’s partnership with the FATF-Style Regional Bodies and the International Association of Deposit Insurers.

Members also exchange information on the opportunities and risks associated with new technologies, such as digital identity innovations, regulatory technology solutions, and the growing use of virtual assets, which could potentially impact the effectiveness of global standards and regulatory compliance.

The working group has four thematic subgroups and one taskforce:

•Digital Identity and E-KYC
•Virtual Assets Regulation
•Stress Testing & Crisis Resolution for E-Money Providers
•Climate Change, Sustainable Finance, and Financial Stability
•RegTech Taskforce (Jointly with DFSWG and FIDWG)



Jacinta Anyinge, Bank Uganda

Co-Chair I

Joseph Munyoro, Bank of Zambia

Co-Chair II

Phepile Dlamini, Central Bank of Eswatini

Gender Focal Point

Mariama Sillah, Bank of Gambia

  • Create policy guidance and knowledge products on the proportionate implementation of global standards to strengthen and align financial integrity, financial stability and financial inclusion.
  • Disseminate key insights, learnings and best practices on proportionality to the broader AFI membership.
  • Conduct peer-reviews of policies and regulations, which aim to promote proportionality in practice.
  • Provide technical support to the AFI Global Standards and Policy Committee (GSPC)
  • Engage in in-country implementation issues with SSB regional bodies.

Inclusive Financial Integrity

Objective:  To develop an M&E framework to monitor progress and challenges in implementing Inclusive Financial Integrity across the AFI network.

Deliverable:  M&E framework for Inclusive Financial Integrity

Inclusive Financial Stability

Objective: To support members in aligning the goals of financial stability and financial inclusion, with practical guidance on the incorporation of proportionality, financial inclusion considerations, and climate risk considerations into financial stability frameworks and policies.

Deliverable: Inclusive Financial Stability Toolkit

Virtual Assets Policy/VASP & Regulation

Objective: To support the AFI network with policy guidance and approaches to:

(1) financial inclusion use cases for VAs and VASPs particularly from experiences and proven pilots led in the private and humanitarian sectors whereby there have been concrete instances or evidence of the advancement of financial inclusion; and

(2) policy and regulatory approaches to VAs and VASPs, including how the balance between financial inclusion, financial integrity, financial stability and consumer protection can be achieved.

Deliverable:  Guideline on Regulation of Virtual Assets

Financial Inclusion Country Assessment

Objective: To assist members impartially self-evaluate their current state of progress in advancing financial inclusion in their jurisdiction and receive review inputs from peers from within the network, as well as identify forward priorities and policy recommendations to support members’ financial inclusion strategies.

Deliverable: AFI’s 2024 Pilot Financial Inclusion Country Assessment









  • In 2020, the AFI-Cenfri Inclusive Financial Integrity Toolkit was launched in a virtual webinar, and AFI attained observer status at the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA).
  • In 2019, 10 members of IADI joined the GSPWG as technical advisors to support its work to protect customer funds held in e-money products
  • In 2018, AFI attained observer status at three FSRBs namely the Asia/Pacific Group on Money Laundering (APG), Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG), and Grupo de Acción Financiera de Latinoamérica (GAFILAT)
  • Results of the AFI Members Survey on Financial Technology (FinTech) and Regulatory Technology (RegTech) were presented at the 2017 meeting of FSB’s FinTech Issue Group
  • AFI & G-24 Special Report “Stemming the Tide of De-Risking through Innovative Technologies and Partnerships” was published in 2016 and presented to the members
  • GSPWG strategic plan for 2016-2020 was adopted
  • AFI’s Global Standards & Policy Committee (GSPC) Chairman Governor Muhammad Ibrahim presented “The Risks of Financial Exclusion” to SSBs’ 2016 meeting
  • The 2016 Bali Outcome Statement on the Linkages between Financial Inclusion and Financial Stability
  • The KL Resolution on Proportionality in Practice, as well as The Moscow Resolution on Financial Inclusion & Shadow Banking were adopted in 2015
  • The AFI Paper “Potential Impacts of Global Standards on National Financial Inclusion Policies” was presented in 2014 at the Basel meeting of H.M. Queen Maxima and Heads of SSBs (currently updating the Paper)
  • Banco Central de Reserva de El Salvador
  • Banco Central del Paraguay
  • Banco de Moçambique
  • Banco Central de São Tomé e Príncipe
  • Banco Nacional de Angola
  • Bangko Sentral ng Pilipinas
  • Bangladesh Bank
  • Bank Al-Maghrib
  • Bank Negara Malaysia
  • Bank of Ghana
  • Bank of Namibia
  • Bank of Papua New Guinea
  • Bank of Sierra Leone
  • Bank of Tanzania
  • Bank of Uganda
  • Bank of Zambia
  • Banque Centrale de Madagascar
  • Banque Centrale de Mauritanie
  • Banque Centrale de Tunisie
  • Banque Centrale des Etats de l’Afrique de l’Ouest (BCEAO)
  • Banque de la République du Burundi
  • Central Bank of Armenia
  • Central Bank of Egypt
  • Central Bank of Eswatini
  • Central Bank of Jordan
  • Central Bank of Kenya
  • Central Bank of Lesotho
  • Central Bank of Liberia
  • Central Bank of Nigeria
  • Central Bank of Solomon Islands
  • Central Bank of Sri Lanka
  • Central Bank of the Bahamas
  • Central Bank of The Gambia
  • Central Bank of the Republic of Uzbekistan
  • Centrale Bank van Suriname
  • Central Bank of Sudan
  • Comisión Nacional Bancaria y de Valores de México (CNBV)
  • Financial Regulatory Commission of Mongolia
  • Comisión Nacional de Bancos y Seguros de Honduras
  • Maldives Monetary Authority
  • Ministère de l’Economie, des Finances et du Budget du Sénégal
  • Ministry of Finance – Eswatini
  • Ministry of Finance and Economic Development Zimbabwe
  • Ministry of Finance Zambia
  • National Bank of Cambodia
  • National Bank of Rwanda
  • National Bank of Tajikistan
  • Nepal Rastra Bank
  • Palestine Monetary Authority
  • People’s Bank of China
  • Reserve Bank of Fiji
  • Reserve Bank of Malawi
  • Reserve Bank of Vanuatu
  • Reserve Bank of Zimbabwe
  • South African Reserve Bank
  • Superintendencia de la Economía Popular y Solidaria de Ecuador
  • Superintendencia General de Entidades Financieras de Costa Rica (SUGEF)
  • Superintendencia de Bancos de la República Dominicana
  2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
1st: Bali, Indonesia
2nd: Lima, Peru
3rd: Riviera Maya, Mexico
54th: Lilongwe, Malawi
5th: Cape Town, South Africa
6th: Kuala Lumpur, Malaysia 7th: Frankfurt, Germany GSPWG
1st: Port of Spain, Trinidad % Tobago
2nd: Kuala Lumpur, Malaysia
3rd: Maputo, Mozambique
4th: Moscow, Russia
5th: Nadi, Fiji
6th: Accra, Ghana
7th: Sharm El Sheikh, Egypt
8th: Siem Reap, Cambodia
9th: Sochi, Russia
10th: Cairo, Egypt
11th: Kigali, Rwanda
12th: Virtual Meeting 13th: Virtual Meeting 
14th: Virtual Meeting
Member Institutions N/A N/A 18 20 32 38 47 45 44 48 53 53
Knowledge Products
0 5 5 6 6 6 7 7 11 11 12 19
Policy Changes
0 0 1 2 14 15 15 26 28 42 57 TBD
Peer Reviews
0 0 8 8 8 8 8 8 8 8 8 TBD


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