Displaced and Disconnected: East and Horn of Africa and Great Lakes Region (July 2022)

Executive Summary

Refugees and other forcibly displaced persons (FDPs) around the world face a number of challenges accessing basic services such as mobile phone connectivity and bank accounts. The East and Horn of Africa and Great Lakes Region is no exception. This report focuses on one such challenge: legal barriers that refugees and asylum-seekers face due to the proof of identity documentation required for SIM card registration mandated by the telecommunications sector and Know Your Customer (KYC)/Customer Due Diligence (CDD) procedures in the financial sector.

SIM registration is mandatory in all nine East African countries studied in this report. While every country’s legal framework differs slightly, they all require proof of identity documents to register a SIM card. In some countries, those requirements deny refugees and/or asylum-seekers legal access to SIM cards registered in their own name. KYC/CDD requirements – typically set forth in the country’s laws and regulations on anti-money laundering and countering the financing of terrorism – create legal barriers for refugees and asylum-seekers in accessing formal financial institutions, as well as mobile money and other digital financial services in many countries.

While formal and informal workarounds exist both in the context of mandatory SIM registration and for accessing financial services, including mobile money, these workarounds are inferior to having an open and inclusive legal framework. Workarounds carry risks and liabilities for humanitarian organizations engaged in cash assistance and promote close-looped systems which stymie true financial inclusion for the concerned populations. With this in mind, this report concludes by setting forth recommendations for both government and humanitarian actors in the focus countries with the aim of achieving a more inclusive legal landscape which affords refugees, asylum-seekers, and other FDPs greater access to digital and financial services.

Source: UN High Commissioner for Refugees

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