Assessed Intelligence | Your Secure and Responsible Technology Partner

Initiative | Financial Inclusion

Know Your
Community.

Intelligent Financial Inclusion

Bridging rigorous AML/CFT compliance and inclusive financial access through Federated Learning, the ARISE Framework, and community-grounded behavioral analytics. Sovereign. Private. Scalable.

Supported by
UNDP AI Trust and Safety Re-imagination Programme

Partners and Supporters

The Challenge

Compliance Systems Designed for One World Are Excluding People From Another.

Financial Service Providers must meet strict Anti-Money Laundering and Counter-Terrorist Financing standards. But automated systems calibrated for Western financial behavior routinely flag legitimate local transactions as suspicious, locking out the people they are meant to serve.

The result is a paradox: the more rigorously compliance is enforced, the more financial exclusion compounds. Seasonal income cycles, community savings groups, and informal trade patterns are not red flags. They are the financial reality of billions.

AML/CFT False Positives Exclude Legitimate Users

Automated fraud detection built for global markets systematically misclassifies local financial behavior, resulting in account closures and credit denials for individuals who pose no risk.

Thin-File Customers Are Invisible to Standard Models

Individuals without formal credit histories are excluded not because they are risky, but because existing systems have no vocabulary for their economic activity.

Data Sharing Creates Sovereignty and Privacy Risk

Traditional collaborative model training requires raw customer data to move between institutions, creating unacceptable privacy and regulatory exposure for all parties.

One-Size-Fits-All Products Fail Underserved Populations

Without localised behavioral data, Financial Service Providers cannot design the tailored credit, savings, and insurance products that would genuinely serve the unbanked and underbanked.

36% of Nigerian Adults Lack Formal Financial Access

In Africa’s largest economy, the gap between financial system capacity and community-level reality is widest precisely where inclusion would have the greatest development impact.

World Bank 2025*

1.4B

People worldwide excluded from formal financial services, the foundational barrier the KYC initiative is built to dismantle.

EFInA Nigeria 2023*

36%

Of Nigerian adults lack access to formal financial services, in Africa’s largest economy and primary focus of the initiative’s first operational phase.

PreCEFI / EFInA 2023*

<0.5%

Of rural Nigerian women with clear entrepreneurial goals had access to formal credit in 2023, despite 10.2 million reporting active business aspirations.

Federated Learning Design

0

Raw customer data shared between institutions. The Federated Learning architecture enables collaborative model training with complete data sovereignty and privacy by design.

Know Your Community

Compliance Does Not Have to Mean Exclusion. We Are Proving It.

By integrating local behavioral context into automated systems, the KYC initiative bridges regulatory compliance with financial inclusion, without compromising the data sovereignty of individuals or institutions.

The Persona Engine
P1
Small-Scale Trader
High-frequency low-value transfers. Irregular income cycles. Community credit participation. Misclassified under global defaults.
P2
Rural Entrepreneur
Seasonal income spikes. Informal savings group deposits. No formal credit history. Legitimate economic actor, invisible to standard models.
P3
Urban Migrant Worker
Remittance patterns across multiple corridors. Shared account usage. Inconsistent documentation. Community-based trust networks.
P4
Community Savings Group Member
Rotating credit contributions. Pooled family accounts. Non-standard transaction timing. Legal and traceable, but flagged by algorithmic defaults.
Architecture
Personalized Federated Learning. Models train locally. Only gradients are shared. Raw data never leaves the institution.
Zero raw data transfer

The Persona Engine

Behavioral Analytics Grounded in Local Financial Reality.

At the core of the KYC initiative is the Persona Engine, which classifies users based on behavioral analytics specific to their local context. Rather than treating customers as a monolith, these personas help AI systems and financial institutions understand the diverse ways communities interact with money.

The Persona Engine is trained through a Personalized Federated Learning framework that allows collaborative model improvement across multiple financial institutions without ever sharing or moving sensitive raw data. Models stay local. Insights are shared. Privacy and sovereignty are preserved by design.

Compliance is Smarter: Systems distinguish between high-risk activity and unique but legal financial behaviors.
Inclusion is Intentional: FSPs can better serve thin-file customers with consistent community-based economic activity.
Accuracy is Improved: Reducing false positives ensures more people maintain formal accounts to build long-term financial identities.

How It Works

Federated Learning. Sovereign Data. Shared Intelligence.

The architecture ensures that financial institutions can improve fraud detection and inclusion outcomes collaboratively, without any institution ever seeing another’s raw customer data.

Key Objectives

Supporting the UN Sustainable Development Goals.

01
SDG 1SDG 5SDG 8

Economic Empowerment

By ensuring automated systems recognise legitimate livelihood patterns, the initiative enables individuals to access the credit and capital required to achieve long-term economic mobility, with particular impact for women and informal sector workers.

02
SDG 1.5SDG 10

Financial Resilience

By reducing the risk of unintended account closures and algorithmic misclassification, the initiative ensures individuals can maintain stable access to financial tools through economic disruption, protecting the most financially vulnerable from systemic exclusion.

03
SDG 9SDG 17

Financial System Innovation

The data architecture enables pro-poor supply-side innovation by providing Financial Service Providers with the localised behavioral intelligence necessary to develop tailored insurance, savings, and credit products that reflect local financial realities.

Project Spotlight

Beginning in Nigeria. Building for the World.

As the home of Africa’s largest economy and population, Nigeria serves as the primary testing ground for the KYC initiative’s first operational phase, in strategic partnership with the Presidential Committee on Financial Inclusion.

Project Spotlight: Nigeria

Operationalising the ARISE Framework Through a National Mandate.

In Nigeria, the KYC initiative is being operationalised through a strategic partnership with the Presidential Committee on Financial Inclusion (PreCEFI), represented by the Office of the Vice President. PreCEFI provides the executive mandate necessary to align AI-driven financial systems with national development goals.

The Reality

36% of Adults Lack Formal Financial Access

In 2023, fewer than 0.5% of rural women with clear entrepreneurial goals had access to formal credit, despite 10.2 million reporting active business aspirations.

The Barrier

Systems Calibrated for Western Markets

Traditional AML/CFT and fraud detection systems frequently misclassify common Nigerian transactional behaviors, including seasonal income and community-based transfers, as high-risk activity.

The Goal

Inclusive Behavioral Personas at Scale

Through PreCEFI, the initiative builds behavioral personas that allow FSPs to move beyond one-size-fits-all models and create tailored products for the unbanked and underbanked.

Three Operational Pillars

01

Strengthen Compliance and Stability

Reduce False Positives
Calibrate AI/ML pipelines to recognise Nigerian financial realities, ensuring legitimate users are not incorrectly flagged by misaligned global defaults.
Align With Regulations
Support FSPs in meeting obligations including the Baseline Standards for Automated AML Solutions to safeguard national and regional financial stability.
02

Drive Innovation and Empowerment

Build Inclusive Personas
Leverage the PreCEFI partnership to develop personas allowing FSPs to better understand underserved populations beyond one-size-fits-all models.
Enable Tailored Products
Provide accurate, localised data to facilitate creation of pro-poor credit and insurance products for the economic advancement of the unbanked.
03

Foster Ethical Leadership

Capacity Building
Deliver tailored training in algorithmic ethics to senior leadership, ensuring technology remains aligned with human rights and organisational values.
Ethical Governance
Empower senior leadership to establish internal Ethics Officers, ensuring sustainable technology deployment and long-term institutional accountability.

ARISE Framework

Built on Assessed Intelligence’s Governance Standard.

The KYC initiative applies the ARISE Framework across all system design, model governance, and institutional deployment decisions, ensuring that every component is Accountable, Responsible, Inclusive, Secure, and Equitable.

From persona model design to regulatory alignment and ethical governance, the ARISE Framework provides the structured assurance layer that allows financial institutions and governments to deploy AI-driven financial inclusion with confidence.

GOVERN

Policy frameworks and executive mandate for responsible AI deployment in financial systems.

IDENTIFY

Behavioral persona classification and risk surface mapping across participating institutions.

PROTECT

Federated Learning architecture ensures data sovereignty and privacy by design at every layer.

VALIDATE

Independent audit and attestation of model fairness, bias metrics, and regulatory alignment.

Get Involved

Join the Initiative.

We are actively expanding our network of forward-thinking Financial Service Providers, government agencies, and development organisations. If you are interested in implementing the ARISE Framework, participating in our workshops, or partnering on the Nigeria rollout, we would like to hear from you.

¹ World Bank (2025). Financial inclusion overview. worldbank.org

² Committee on Payments and Market Infrastructures (2019). New correspondent banking data. bis.org

³ World Bank Group (2016). De-risking in the financial sector. worldbank.org

⁴ EFInA (2023). Access to Financial Services in Nigeria. a2f.ng

Forged by Experience  ·  Driven by Purpose  ·  Built to Endure