In 2019, Jamaica introduced simplified customer due diligence (CDD) through amendments to its Proceeds of Crime Act, Anti-Money Laundering (POCA AML) regulations. Customer Due Diligence is the procedure that banks must use before opening bank accounts for their customers. The goal was clear: to reduce on-boarding barriers (when opening bank accounts) and expand access to the financial system by allowing lower verification requirements for low-risk customers.
But this came with a trade-off.
Instead of a rigid checklist, financial institutions now had to assess risk upfront, justify simplified onboarding, and maintain audit trails. In other words, compliance shifted from a documentation exercise to a judgment call—introducing operational complexity and regulatory risk if misapplied.
On paper, this enabled inclusion. In practice, the system still feels unchanged.
Most Jamaicans still believe opening an account requires:
- Government-issued ID (95%)
- TRN (88%)
- Proof of address (76%)
- Character reference (65%)
- Job letter (54%)
- Minimum deposit (60%)
This is effectively full CDD—not simplified.
Among those who found the process difficult:
- 35% cited long wait times
- 24% lacked a character reference
- 15% couldn’t access a JP
- 10% had no proof of address
- 6% had no job letter
Among the unbanked:
- 18% say it’s too much hassle
- 16% don’t trust financial institutions
- 16% don’t have enough money
- 12% lack required documents
These are the very barriers simplified CDD was meant to remove.
The issue is not just operational—it’s cognitive.
According to the Standard & Poor’s Global Financial Literacy Survey, a person is financially literate if they understand four concepts: numeracy, compound interest, inflation, and risk diversification. Only about 33% of Jamaicans meet this threshold.
So even where onboarding is simplified, many people:
- assume the process is complex
- don’t understand financial products
- hesitate to engage
At the same time, trust remains fragile. A meaningful share of the unbanked cite lack of trust as a reason for staying out of the system. Awareness of financial services is high, but usage is low.
Some of the biggest barriers have nothing to do with regulation at all:
- long wait times
- unclear requirements
- inconsistent communication
- poor customer experience
The result is a gap between law and lived experience.
Jamaica removed the legal barriers to financial inclusion in 2019. But the system still behaves as if those barriers exist.
Simplified CDD opened the door. The system just never made it easy to walk through.
References
- 2023 National Financial Inclusion Study by Hope Caribbean Company Limited
- S&P Global Financial Literacy Survey by Standard & Poor’s Rating Serice, Gallup Inc., the World Bank Development Research Group, and the Global Financial Literacy Excellence Center