Working paper

Impacts of the Regulatory Environment on Refugees’ and Asylum Seekers’ Ability to Use Formal Remittance Channels


Leon Isaacs, Sarah Hugo, Gemma Robson, Charlie Bush, Poppy Issacs and Iñigo Moré Martinez



This report uses seven sample countries as case studies to focus on how regulations and regulatory policies affect a refugee’s ability to send and receive formal, cross-border remittances. It identifies the main regulatory challenges and makes a series of recommendations to address them. Previous surveys and anecdotal evidence indicate that refugees and asylum seekers are senders and receivers of remittances. However, this group has received little attention to date. There is little understanding as to the challenges faced by refugees and asylum seekers in accessing formal, cross-border remittance services and whether these challenges differ from those faced by other migrants. The report finds that the main challenge refugees and asylum seekers experience when trying to send remittances is one of access. There is a clear conflict between the documentation that refugees and asylum seekers are provided and the documentation that they require according to anti-money laundering and counterterrorism financing regulations. Across the seven sample countries—Denmark, Ethiopia, Germany, Jordan, Saudi Arabia, the United Kingdom, and the United States—there are no regulations specifically focusing on these groups with respect to money transfers. Efforts to achieve “proportionate regulation” are compromised due to these groups’ specific circumstances, including their legal status, country of origin, and identification (or lack of it). There is a clear need for further guidance to stakeholders from the top down, from regulators and policy makers to remittance agents and bank branch managers. At all levels, the challenges of access are found to extend beyond direct access to remittance services, to include barriers to mainstream banking services.