The quest for inclusive financial markets is a challenge for both business and regulatory models as it requires new and largely unknown portions of the market to be served. This quest can at times be frustrated by regulatory barriers to inclusion that make it costly to provide financial services to low-income people. In South Africa, the regulator recognised this in so far as AML and CFT requirements were concerned, and allowed for some flexibility for low-risk customers.

This 2011 study investigated the reasons for the apparent lack of universal response by financial institutions to the flexibility allowed by South Africa’s anti-money laundering (AML) and combating of terrorist financing (CFT) regulatory requirements in relation to low-risk clients.