March 2020 Digital Identities in Financial Services Part 3: The Business Opportunity for Digital Identity - Institute of ...
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March 2020
Digital Identities in Financial Services
Part 3: The Business Opportunity for Digital
Identity
Digital Identity is Changing the Way Financial Institutions Interact
with Customers
In this paper, we investigate how developments in digital identity and an evolving marketplace
are creating new business opportunities for financial service providers. Banks and insurers have
a long track record of responsible stewardship with personally identifiable data. In an emerging
digital identity ecosystem reliant on partnerships, this experience can be built on to help
responsibly and sustainably grow digital identities to better serve consumers, develop new
revenue streams, achieve operational efficiencies and mitigate risk.
In our primer to the three-part series “Digital Identity – Key Concepts”, as well as parts 1 & 2 of
our series, we had defined digital identity as a compilation of electronically captured and
developed attributes and credentials of a uniquely identifiable persona that can be linked to a
physical person.1
Digital attributes and characteristics that help verify and profile individuals are becoming
increasingly essential in the digital age. Institutions use digital data of existing or potential
customers to identify behavioral patterns thus helping them to more appropriately serve
customers, better mitigate risk, and improve operational efficiencies.
1Institute
of International Finance, Digital Identity: Key Concepts, July 2019,
https://www.iif.com/Portals/0/Files/content/Regulatory/iif_digital_id_07022019.pdf
As customer expectations are constantly increasing, financial service providers need to embrace
technological advancements to create better and more seamless relationships with their
customers. Traditionally, financial service providers have been internally structured to be
product-focused and as such might lose sight of the customer journey leading to subpar
relationship management.
In an increasingly competitive landscape, with new entrants daily trying to disrupt the financial
service space, the threat for customer acquisition and retention has never been greater. Having
an internal digital identity initiative in place refocuses the organization on one of its main
stakeholders: the customer.
However, to achieve a successful digital transformation refocused on the customer, the two
remaining stakeholders (namely investors and employees) need to be on board. In this paper,
we explore how financial service providers can best position themselves by leveraging their
strong suit and engaging all stakeholders in this changing ecosystem.
With only around 1-3% of money laundering activity being captured by financial institutions, the
Institute of International Finance (IIF) sought to focus the first paper on how digital identity can
improve the customer due diligence (CDD) process thorough a better reliance framework and
other initiatives.2 Another driver for digital identity adoption is sustainable digital financial
inclusion, which we delved into in detail in our second research paper “Responsible Digital
IDs”.3
Throughout our series, we have referenced many successful digital identity models currently
being implemented and the underlying technologies being used to address key issues the
financial service sector is facing. The IIF also published a response letter to the Financial Action
Task Force (FATF) digital identity guidance consultation with concrete recommendations on
how the guidance can be further developed.4
The IIF’s focus with this third paper is on how digital identity can help propel digital
transformation within the industry, leading to new business opportunities and better customer
engagement. We also discuss the multiple internal and external obstacles that need to be
addressed to fully leverage the business opportunity of digital identity.
2 Institute of International Finance, Digital IDs in Financial Services Part 1: Embedding in AML
Frameworks, August 2019,
https://www.iif.com/Portals/0/Files/content/Innovation/08272019_iif_digital_id_part_1.pdf
3 Institute of International Finance, Digital IDs in Financial Services Part 2: Responsible Digital ID,
October 2019, https://www.iif.com/Publications/ID/3596/Digital-Identities-in-Financial-Services-Part-
2-Responsible-Digital-IDs
4 Institute of International Finance, Digital IDs in Financial Services: IIF Response to FATF Digital
Identity Guidance, November 2019, https://www.iif.com/Publications/ID/3673/IIF-Response-to-FATF-
Digital-Identity-Guidance
2
Digital Transformation Focused on Customer Centricity
The current internal organizational structure of most financial service providers is a
departmental focus on the products and services the institutions provide. Concurrently,
financial institutions (FIs) are also structured to focus on segments, in which departmental
heads focus on a specific segment of customers, and by branch network.
In all these instances the focus is usually on achieving sales and profitability targets where
departmental heads are held responsible and incentivized for achieving these targets. This set up
usually creates departmental silos where one key area is missing: the focus on the customers.
The customer journey is seldom seen in whole by financial service providers; thus, creating a
meaningful personal relationship with the customer becomes increasingly difficult. Even though
metrics regarding customer satisfaction such as a net promoter score (NPS) could be applied by
institutions it solely captures a snapshot of how the customer was feeling towards a certain
interaction with the institution.
What is missing is a complete profiling of the customer: how frequently are they interacting with
the institution, through what channels, at what stage of their life, what kinds of products are
they and could they be interested in, where they live, which vendors they interact with on a
daily/weekly/monthly or annual basis, what are their potential current and future financing
needs etc. Even with customer relationship management systems in place, the information a
financial institution obtains is solely related to the customers' financial or non-financial
interaction with the institution.
With increasingly more customers migrating their daily activities to digital channels the digital
footprint left by these individuals acts as a gold mine for financial service providers. Proper
digital identity data analytics can have a profound impact on customer engagement/satisfaction
resulting in better bottom-line results and therefore on shareholders’ value.
Executives have been endorsing digital transformation in their respective financial institutions
for years now. This might be in the form of digitizing existing products and services in hopes of
migrating customers to the bank’s digital channels (such as internet-or mobile banking) and
automating back-end processes to streamline operations and cut down on operational costs.
Digitization of products and services can take several forms such as using chatbots or virtual
bank agents to answer customer inquiries. These initiatives usually require a fair amount of IT
investments and a return on investment that is harder to measure due to the difficulty of
identifying the actual increase in customer profitability (cost savings or increased revenue)
stemming from digitizing these processes. More importantly, the structure of the organization
stays the same (departmental silos focused on products and services rather than the customer).
With new technology companies trying to disrupt the financial services industry (a phenomenon
covered thoroughly in our series), we have seen a more fundamental shift - by forward-looking
executives and board members - towards digital transformation. Institutions are starting to
create digital platforms (usually separate entities) to leverage a customer-focused ecosystem
more efficiently by promoting interoperability between all ecosystem players to reach common
standards and more importantly refocus the organization on one of the main stakeholders: the
customer.
3
The following figure from our previous paper illustrates how a digital platform works:
Figure 1: Potential Ecosystem Interoperability
Third party
(Customer
Points of
Contact)
Digital Open
Platform
APIs
Financial
Service
Providers
Digital platforms are a means of agile direct to consumer servicing, based on an ecosystem
where many different companies come together to solve a business problem for a customer. The
digital platform strategy uses emerging technologies such as artificial intelligence, data
analytics, and cooperation with fintechs, correspondent banks, technology companies, and
traditional vendors to create a plug-and-play business model allowing multiple participants to
connect and interact with each other and create value to the consumer through a seamless
convenient experience. Digital platforms will help synthesize this into one relationship that
consumers don’t have to interact individually with a host of vendors and companies.
Digital identity lies at the heart of this customer-focused ecosystem in which trusted financial
service providers leverage their experience with risk management, gained through decades of
abiding by banking regulation, while utilizing the alternative data amassed by technology
companies and third-party vendors.
In this ecosystem, identities can be verified by multiple digital identity attributes (bill and tax
payment records, financial statements, call data records, etc.) that are issued by trusted entities
who have an established relationship with consumers. Financial service providers would act as
financial advisors while utilizing technology platforms’ large consumer bases to best help serve
customers.
Digital platforms would position themselves as data stewards, embracing innovation and
collaboration to make banking more affordable, accessible, tailored, and sustainable - a goal
4customers have been striving for. We will be talking about how this partnership model can have
an impact on customer engagement and how to set up successful partnerships in subsequent
sections but for now, we will aim to highlight the obvious operational efficiencies of such digital
transformation initiatives.
1. Decreased operational costs:
Digital identity verification is mainly an automated process, so people will no longer need to
have their identities verified in-person at a bank branch, thereby decreasing human capital costs
related to onboarding clients. The same applies when granting riskier products such as loans,
where a credit score needs to be obtained and financial history needs to be verified. The
platform approach, including the building of digital services on the platform, has also led to
tangible increases in efficiency. Bank of America’s management team estimated that they have
reduced deposit costs in consumer banking by almost 160 basis points (from 3.1% in 2010 to
1.51% in Q4 2019). Platforms can help drive market-creating innovation when they lead to profit
potential in areas of little or no competition.5
A standardized digital identity, based on direct access to various trusted sources issuing relevant
know your customer (KYC) attributes, not only saves the integration cost of myriad different
KYC solutions on the market, but also reduces interaction time, and therefore cost, for both
customers/prospects and financial institutions. Also, as CDD not only comprises basic
identification but also due diligence, it is obvious that the more comprehensive the digital
identity solution comprising relevant KYC attributes, the more automated – and therefore cost-
efficient – the CDD process for the major financial service use cases “payment services,”
“lending services” and “investment services” can be designed in the solution, even further
reducing interaction time/paper document requirements and exchanges on both sides.
The due diligence also covers high-risk situations where enhanced due diligence is required. The
digital identity solution is also capable of providing necessary additional attributes and/or
corroboration,6 which brings us to our second apparent efficiency: risk mitigation and avoiding
related costs.
2. Improved risk mitigation:
By using multiple records that have a high degree of authenticity with historical and physical
presence the confidence and assurance of a person being both unique and existing could be
distinctive. Apparent benefits are having a higher level of risk assurance, reducing fraud risk and
improving knowledge of customers which can be attained through:
• Increasing the number of reliable sources
• Verifying the attributes to the sources of information
• Including identity attributes in the monitoring and analytics programs by maintaining
traceability records
5
Donovan, D. (2020). “Platforms for Retail Banking Could Turn Rivals into Allies”. The Financial Brand
https://thefinancialbrand.com/92863/platforms-retail-banking-amazon-agile/
6 European Commission Expert Group (2020), “Assessing Portable KYC/CDD Solutions in the Banking
Sector”, https://ec.europa.eu/info/files/assessing-portable-kyc-cdd-solutions-in-the-banking-sector-
December2019_en
5• Considering, monitoring and testing all identification methods for pros and cons.7
Diminishing credit loss due to improved data analytics is another way digital identity will
contribute to better cost savings. Real-time analytics and credit scoring obtained from the data
will help institutions identify red flags early on and therefore be better prepared.
Active Customer Engagement
As mentioned earlier, by partnering with ecosystem players, financial service providers have an
opportunity to leverage data in unprecedented ways leading to higher customer engagement and
increased revenue. Acting as data stewards through successful partnerships would enable
financial service providers to gain financial as well as valuable non-financial data on existing
and potential customers. Financial service providers would more easily be able to verify a
person, analyze their behavioral patterns and decide how best to advise customers on their
financial well-being. Products and services offered by financial services would be tailored to the
needs and wants of customers and based on solving actual pain points. This is a fundamentally
different approach than offering a suite of standard products and services to all customers.
A key success factor here is realizing the opportunity to solve real-life customer problems and
finding the strategic partners that would enable you to better serve customers. Every person has
a unique digital footprint; being able to identify what these are and whether financial service
providers can make life easier through partnerships on an individual basis will be key. Some
individuals need to pay school fees, taxes, and utility bills, and for transportation, housing,
groceries etc. Identifying these payment needs of individuals and forming partnerships with
vendors to offer seamless contactless journeys will be a key competitive advantage. In collecting
and analyzing the digital payment and nonpayment data, financial service providers can more
effectively increase personalization and offer tailored products and services to new potential
customers.
1. Increased personalization and targeted revenues:
Analyzing the digital identity data set will enable financial service providers to be able to predict
future customer behavior and offer tailored products and services promoted through real-time
marketing improving the chances of commercial activity and differentiation amongst
competitors. The partnership model above offers precious opportunities to financial service
providers, as it enables them to gain insights through new data sources helping them create a
fuller picture of individuals and their respective digital identities.
Analyzing third party customer touchpoints, for example, can help financial service providers
know which life stage the customer is in. Analyzing data from e-commerce activity, internet
searches, digital demographic data, and digital behavioral patterns would facilitate targeted
offerings at exactly the right time the customer needs it. If a customer was looking to buy a new
car, a new house, or baby products, for example, and financial service providers analyzed the
historical financial transactional data - based on the customers' pre-determined credit score -
would be able to promote an mortgage or auto/personal loan instantly to their customer. Digital
identity could have the potential to instantly connect the customer with their desired financing
needs at the time of purchase. This is in comparison to the traditional approach of having to
apply for a loan, provide identity verification with the required documentation, wait for the
credit score to come through and for risk managers to assess the financial situation of the
7Eugenio (Gene) DiMira, “Digital Identity: The Integrity of Information”,
https://www.acamstoday.org/digital-identity-the-integrity-of-information/
6customer before finally receiving the loan. This is a process that can take weeks and multiple
visits to a branch. Creating a seamless interaction enables faster and more efficient commerce.
2. Serving new segments:
In addition to personalized selling to existing clients, alternative data derived from partnerships
offers an unprecedented opportunity to sustainably serve new customers. By analyzing
alternative data sets financial service providers can seamlessly onboard clients and create
alternative credit scores to individuals who do not have a financial track record. The IIF’s second
digital identity paper (which focused on financial inclusion) offers several case examples of such
scenarios.
The Role of Financial Service Providers
The difficulty of creating and maintaining a digital identity ecosystem is very high, as the
overarching principles of a successful digital identity ecosystem being trust, transparency, and
security. Key success characteristics are open source technology, interoperability across sectors
and geographies, and public/private collaboration with incentives to all stakeholders involved.
Financial services providers have a solid track record of ensuring client data is protected and
have built trust with customers over the years. Due to the nature of sensitive financial data,
investments in security and privacy have been substantial in the industry. Trust in financial
service providers is reinforced by the long track record of protecting sensitive data (real
payments), something which is differential for the industry. Thus, it makes sense that financial
service providers oversee digital platforms acting as data stewards. Financial service providers
are also risk managers at heart and are incentivized to lower non-performing loan ratios and are
regulated to ensure financial stability is maintained in the economy. Thus, it is in the
organization's best interest to not misuse digital identity data for overselling financial products
which can create an over-indebtedness issue in economies.
Risk and lending officers have traditionally served as gatekeepers and must tune their
institutions’ lending criteria based on credit records, risk appetites, regulatory tolerance, and the
economic outlook. And compliance officers worry about unintended consequences of any
behavior or policy that winds up causing illegal credit discrimination.8 These core values need to
stay at the heart of using alternative data relating to digital identity and as such carves an
important role for financial service providers in this emerging ecosystem.
Transparency will be key when transitioning platforms into data stewards as consumers (the
rightful owners of the data) will have the right to know and consent to how their data is being
used. Machine learning algorithms that ultimately decide on how customers are assessed should
be coded by local data scientists to address tailored problems for the relevant society. Women
and minorities need to be encouraged and trained by financial service to be part of the process of
writing these algorithms to ensure all segments of the society are served equally.
One important point to mention when discussing transparency is the use of data to fight
financial crime. The fight against financial crime often is challenged with a lack of traceability to
the source of funds to confirm their legitimacy. A digital identity can deliver traceability to fight
8
Cocheo, S. (2020). “Nontraditional Credit Data Could Bring Loans to More Consumers”. The Financial
Brand https://thefinancialbrand.com/91849/personal-loan-alternative-credit-data-consumer-
borrowing/?edigest .
7crime, without over-sharing in a fully transparent model addressing challenges with privacy
principles which are concerned with data oversharing and unapproved use.
Another key success factor for digital identity partnerships to work is having a framework that
rewards and incentivizes all participating entities. When choosing partners in the ecosystem
financial service providers should partner up with players that have similar values to ensure that
the long-term relationship can be maintained and can flourish while ensuring that reputational
risk be mitigated. Patience is needed to create the right revenue share model and create a
sustainable business model that will best serve the interest of everyone involved, including
customers. The ultimate end goal, through the portability and analysis of digital identity data
through efficient networks, is to lower transactional cost and bank customers more sustainably.
It is important that the partnership be agile enough to respond to customer needs and wants in
real-time, cutting through bureaucratic red tape.
Banking as a Service: The Case Study of Marcus by Goldman Sachs
Forward-looking financial institutions have recognized that the larger ecosystem includes
various niche services such as making payments, processing loans, offering credit, delivering
authentication and verification, underwriting insurance, and providing remittance solutions. As
a financial service provider, it will be very hard to perfect all of these offerings and there may be
various existing companies that already excel in providing these services. The digital platform
role could be to aggregate these services and deliver a superb customer experience which is
known as “banking as a service.”
Goldman Sachs introduced Marcus in 2016. Marcus is a digital platform that provides financial
services at highly competitive rates delivered without the branch and back-office infrastructure
that often stifles legacy financial institutions. Since its launch, Marcus has grown into a
noteworthy digital banking platform as evident by the growth figures below:
8Figure 2: Growth of Marcus from Goldman Sachs (2016-2019):
~5mm
$60bn
$12bn
0.2mm
Number of Customer Deposit Balances
2016 2019 2016 2019
~860mm
$7bn
$0.2bn $2mm
Loan/Card Balances Revenue
2016 2019 2016 2019
Goldman has plans to more than double consumer deposits to at least $125 billion and loan and
credit card balances by three-fold to over $20billion over the next five years. The institution has
substantially invested in engineers, developers, and R&D and has made partnerships a main
pillar of their digital platform strategy. Marcus has already partnered with Apple on a consumer
credit card (gaining access to Apple’s 100 million U.S. customers)and is using banking as a
service to offer products that offer value, simplicity, and transparency all while using the
Goldman brand to convey trust and security to the consumer.9
Leveraging the trust of consumers towards financial services to offer banking as a service is
becoming a trend with institutions such as Citi partnering up with Google and a consortium of
banks embarking on a digital trust project.
9
Marcus, J. (2020). “A Digital Bank That Should Keep Rivals Up At Night”. The Financial Brand
https://thefinancialbrand.com/92681/marcus-goldman-sachs-digital-banking-checking-
strategy/?edigest.
9The Creation of an Open Global Trust Framework
Financial services companies aim to help individuals and businesses to prosper. To prosper,
they need to trade which requires a certain degree of trust in counterparties. In the non-digital
space, financial services companies facilitate trade with payment, credit and insurance services.
In the digital space, in addition to payment, credit and insurance services, there are new
challenges. Counterparties often do not know each other. It becomes difficult for individuals and
small and medium enterprises to establish trust. Trust requires knowing the identity of the
person or entity on the other side of a trade. Trust also requires knowing whether a counterparty
is going to fulfill their obligations and whether the information they are sharing is correct.
This has led Banco Santander to develop an experimental open Digital Trust Protocol (DTP),
built as an extension of the widely adopted OpenID Connect. The proposed protocol has a
corresponding application programming interface (API) specification and software development
kit (SDK). The protocol solves the digital trust problem by creating the opportunity for real-time
verification of identity and digital trust information. The proposed protocol complements efforts
already underway in the OpenID Foundation’s workgroups.
The IIF and Santander are currently engaging other banks and payments and identity
companies to explore this initiative, with a view to potentially developing an open Global Trust
Framework. With assistance from the OpenID Foundation and other nonprofit, technology-
agnostic organizations, they are actively seeking other participants to help develop the proposed
standard. The objective is to create, adapt and deploy open global standards for exchanging
sensitive information. If adopted, the open standards aim to be interoperable with existing
platforms. It will be built upon open-source code and, as with the underpinnings of the internet
itself, it will be free to use. This can create a Global Trust Framework with a range of options,
services, and competing providers. It is designed to be an environment where market forces
drive innovation.
Example Use Case of DTP: Senior discount for train service
Citizens wanting to obtain discounted train services often need to prove that they are 1) over 65
years of age 2) are national residents of a given country. Using the digital trust protocol on the
train service website or app, the user is redirected to log in using their bank credentials. Once
logged in the user requests that their bank verify: 1) the user’s age and 2) their status as a
national resident. After verification, the bank confirms the details with the train service and the
end-users receive the senior discount.
Users can determine which financial institution they want to work with knowing that their
actual address and age are kept secret. DTP is designed to protect privacy. Consent is always
obtained because each transaction is initiated by the individual who holds the identity garnering
full control to the consumer while the train service (in this example) does not have to incur the
risk and expense of storing unnecessary personally identifying information.
10Realizing the Business Opportunity: Transitioning to Open Platforms
Two main pillars for any successful partnership are trust and communication.
Stakeholders need to be able to trust one another i.e., customers need to trust that their data is
being protected and that digital platforms (backed by financial service providers) can keep this
data secure, third parties and financial service providers need to trust the data quality being
shared and regulators need to trust that institutions are keeping the consumers’ best interest at
heart.
There also needs to be a constant feedback loop between ecosystem players where the private
sector needs to have an ongoing dialogue with the public sector to realize the potential of digital
identity in fighting financial crime and illicit behavior. These rights need to be balanced against
the legitimate interests of processing and sharing information to prevent illicit financial flows.
Communication between the third-party vendors and financial service providers is just as
important with products and services constantly updated to serve emerging/changing customer
demand; and finally, communication to the customer relating to relevant product/service
offerings and the implications of enrolling in them.
Another main aspect of the digital identity ecosystem to work is having data portability. There
needs to be a trusted reliance framework in place enforced through interoperability and
common standards. Having cross-sectoral and cross-jurisdictional data interoperability will be
extremely important to ensure stakeholders are receiving maximum value for the data; be that
consumers who want a seamless experience when traveling or dealing with different vendors in
different sectors, or regulators and law enforcement agencies who are trying to identify and
capture illicit money flows.
Setting up the Right External Framework
Creating a digital identity ecosystem is a complex matter with multiple stakeholders involved
close collaboration will be needed to create a functioning system that creates value for the
consumer.
Regulators and governments will have the main role to play. First off they need to ensure that
the proper infrastructure is in place when it comes to an internet connection and making sure
that data plans are affordable for all to use. When it comes to the network system governing the
digital identity ecosystem regulators need to enforce a set of best practice standards to ensure a
trustable reliance framework can be achieved.
Encouraging data portability and interoperability and moving away from localization will also be
very important to create the cross border and industry harmonization. We recently published
the IIF response to a FATF digital identity consultation, with our comment letter highlighting
critical issues such as:
1. Recognizing the value of multiple reliable sources of identification;
2. Emphasizing the need for interoperable digital identity systems;
3. Asserting the importance of consumer protection;
4. Reframing the reasoning of having a two-tiered CDD process for low-income
segments;
5. Highlighting the usefulness of a private to the public feedback loop and;
116. Revision of the reliance framework.
Having strong data privacy laws in place and enforcing ethical use of data is another important
aspect that will increase consumer trust and digital identity adaptability.
Internal Barriers for Financial Service Providers to Consider:
To be able to wholly realize the potential of digital identity data, organizations need to create a
culture that appreciates the importance and value of data. Usually, this is a top-down approach
supported by the board and senior management.
The use of data can be a double-edged sword within institutions as frontline employees can see
it as a valuable tool that creates insights and drives change, or as a tool that exposes the
shortcomings of their line of business. Keeping in mind that the end goal is serving customers
more efficiently, the use of data needs to be positioned as a change agent for the better.
Also, to prepare for the data revolution, companies need to have the proper infrastructure and
human capital in place. Infrastructure ensures the quality, portability, and security of the data
which allows for seamless integration with everyday business use. The infrastructure also needs
to be agile enough and built on open source technology for more seamless integration with
third-party vendors or governmental agencies. Finally, with vast amounts of data to be
processed, the infrastructure needs to be stored in a cost-efficient manner using technologies
such as cloud computing. For proper analysis and usage of data, acquisition, integration, and
retention of data scientist and data engineers will be needed to prepare the data and code
machine learning algorithms.
The IIF in partnership with Deloitte is currently undertaking a project that identifies the main
internal and external barriers to digital transformation which can serve as guidance for the
similar transformation needed with digital identity initiatives. 10
The Road Ahead
Digital identity is becoming a critical focal point as financial service providers have an important
and ever-increasing role in emerging digital identity ecosystems. Creating a functioning
ecosystem that brings value to the customer will take time, perseverance and patience in dealing
with the different ecosystem stakeholders. With this paper, we aimed to highlight the vision for
the future digital identity ecosystem and the commercial opportunities as well as some of the
barriers that must be overcome.
Financial institutions are well-positioned to act as trusted, regulated players that can provide
the building blocks for responsible digital identity initiatives by empowering individuals to
control and extract value from their digital identities securely and inclusively. Emerging data
platforms would act as trusted data custodians and are well-positioned to be at the forefront of
protecting client privacy.
10 Institute of International Finance, Realizing the Digital Promise: Part 1, February 2020,
https://www.iif.com/Publications/ID/3759/Realizing-the-Digital-Promise-Part-1
12Amin Khairy
Policy Advisor, Digital Finance
akhairy@iif.com
Other Contributors
Brad Carr
Managing Director, Digital Finance
bcarr@iif.com
Conan French
Senior Advisor, Digital Finance
cfrench@iif.com
Daniel Pujazon
Policy Advisor, Digital Finance
dpujazon@iif.com
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