8. Thematic risks and areas of concern, policy responses and next steps
While the Monitor has addressed risks from different perspectives (including sectors, sources of risk, etc.), this final chapter aims to synthesise concerns across sectors and products to highlight thematic risks and areas of concerns that emerged from jurisdictions’ responses to the reporting template.
8.1.1. Increasing incidence and complexity of scams and frauds
As the financial landscape evolves with increased remote access and increasing adoption of digital products and services, jurisdictions around the globe noted that financial scams and frauds were becoming more frequent and more complex. The majority of jurisdictions reported an increased incidence of scams and frauds in 2022. Even though financial scams have always loomed as a threat to consumers – even in analogue environments – jurisdictions agree that the increased use of mobile and digital services was accompanied by an attendant rise in scams and frauds. The greater use of digital tools has also affected the types of scams.
This trend threatens to undermine recent gains made in expanding access to financial services, as consumers may understandably withdraw from digital services that expose them to harm. It also damages the financial well-being of consumers and households, at a time when they are buffeted by various crises and threats, adding to overall vulnerability.
8.1.2. Emergence of new credit products and risk of over-indebtedness
Over the course of 2022, inflation and increases in interest rates all contributed to a cost-of-living crisis that put a strain on household finances around the world. In some jurisdictions, new credit products that had emerged in recent years (such as Buy Now Pay Later) offered consumers novel ways to manage their finances. However, jurisdictions are concerned that these same products could increase the risk of over-indebtedness among financial consumers, especially those experiencing acute financial hardship. Inadequate creditworthiness assessments and opaque fee schedules could lead to consumers taking on unsustainable debt and devoting too much of their income to unexpected fees and charges. Jurisdictions are also actively monitoring how interest rate hikes have affected households’ overall debt burdens.
8.1.3. Innovation in digital technology and business models
Innovation in the financial sector can help widen opportunities for financial consumers and help drive financial inclusion. The rapid pace of innovation, however, could also lead to consumer harm. The Central Bank of Nigeria (CBN), for example, noted that digital financial services have exacerbated existing consumer risks and continued to introduce new and ever-evolving risks, given the dynamic nature of financial technology. CBN cautioned that these risks could undermine the delivery of digital financial services to underserved and low-income consumers and, if ignored, were likely to erode consumer trust in digital services.
Decentralised finance (DeFi), which uses distributed ledger/blockchain technology, as does crypto-assets, was cited by authorities in Canada and Italy, who highlighted how various firms have entered these spaces to act as intermediaries between DeFi and traditional financial markets, presenting new risks with potential implications for financial stability given the possible interconnections between DeFi and traditional markets (OECD, 2022[1]).
The use of artificial intelligence (AI) and machine learning has also emerged as a source of innovation and potential concern for authorities. While AI and machine learning has the potential to improve financial services, e.g. through risk assessments and personalised recommendations, these technologies also present potential risks, including through the perpetuation of biases and discrimination that already exist in financial systems (OECD, 2021[2]).
Firms are also innovating in terms of their business models, which can bring benefits to consumers but also introduce new risks. Brazil referenced risks arising from the emerging “Bank-as-a-Service” (BaaS) business model, including a lack of clarity over how responsibility is shared between regulated entities and the new providers contracting their services and the legal nature of the new providers (i.e. whether they are operating without required authorisation). Malaysia noted that evolving business models and rapid product innovation were outpacing regulatory developments and could result in lack of consumer protection and leave consumers vulnerable to unfair treatment. For example, an increasing trend of unregulated e-commerce providers partnering with insurers to distribute insurance products may heighten the risk of mis-selling or product pushing. Jurisdictions also described how digital innovation is coinciding with and, in some cases, accelerating the disappearance of physical bank branches.
8.1.4. Increasing access to crypto-assets
While not entirely novel, authorities continue to have concerns about crypto-assets. Their anonymity can facilitate fraud, according to respondents, and they are useful for facilitating money laundering. The lack of regulation over crypto-exchanges and/or noncompliance by crypto-exchanges with applicable domestic regulations was also cited as a risk factor. The involvement of regulated entities in crypto-asset-related activities was a concern from some authorities; one respondent noted that “financial services providers were eager to join the cryptocurrency craze despite its drastically volatile nature which made it inappropriate for the masses.” Research from the United States demonstrated that the crypto-asset-owning population is younger, more financially vulnerable and diverse than the general population. Research from the Competition and Consumer Protection Commission of Ireland similarly revealed that 25- to 34-year-olds were twice as likely as the general population to hold crypto-assets in some form.
Jurisdictions noted that crypto-assets have become significantly more accessible in recent years, despite their high risk and speculative nature. In Luxembourg, for example, more and more consumers are regularly exposed to promotion campaigns for “easy” investments in crypto-assets by user-friendly exchange programmes. Authorities in Ireland also noted the availability and ease of purchasing crypto-assets, which is a cause for concern given that the products are unregulated or in non-compliance with applicable regulations, and extremely volatile.
8.1.5. Alternative sources of financial advice (e.g. “finfluencers”)
Increasing access to crypto-assets, which may be unregulated in some jurisdictions or issued and/or traded in non-compliance with applicable domestic regulations in others, is related to another emerging trend concerning the confluence of a) self-directed investors, b) online “zero commission” trading platforms and c) financial influencers (i.e. “finfluencers”) who provide advice over social media, in some cases encouraging the purchase of virtual assets. As authorities in Canada reported, retail investor participation in capital markets saw rapid growth during the pandemic years, particularly in terms of self-directed investors. For some, the desire for returns in the face of challenging economic conditions may have led to more speculative investments, such as crypto-assets. Authorities in Portugal similarly noted that younger investors who have entered the market through digital channels (mostly investment platforms and apps) seem to be keener to make investment decisions on their own, or to follow financial advice from self-proclaimed experts on the internet.
Meanwhile, online influencers encourage their followers to make certain financial decisions, leading investors to allocate resources to products and services that may not be suitable for them. A 2023 study conducted by FINRA Investor Education Foundation and CFA Institute found that social media was the top information source for Generation Z investors in the United States, Canada and the United Kingdom (FINRA Investor Education Foundation and CFA Institute, 2023[3]). Slovak Republic noted the significant impact of influencers, who often give misleading information or fail to provide risk warnings. The Monetary Authority of Singapore (MAS) cited misleading financial services advertisements posted on social media that highlight unsubstantiated high returns without mentioning any specific products. MAS noted that consumers may not know the identity of the person posting the advertisement and whether the person is licensed by MAS.
Authorities in Brazil are especially concerned by instances of “finfluencers” being hired by regulated entities without due transparency, leading consumers to take unnecessary and misinformed risks. Furthermore, due to a lack of in-depth knowledge about financial products and services pushed to their audience or even in bad faith, influencers can contribute to the spread of financial crimes and fraud, with significant financial losses. As noted in Section 5.4 in Chapter 5, a survey carried out in Brazil showed that three-quarters of surveyed investors (average of 32) began making investments based on information they received from YouTube channels and influencers. The CVM (Securities and Exchange Commission of Brazil) is closely monitoring this trend and is studying a possible regulation on the subject to bring more transparency to digital Influencers hired by regulated entities.
In a related development, a warning to consumers about the risks of crypto-assets, issued by the Central Bank of Ireland in March 2022, emphasised that people needed to be alert to the risks of misleading advertisements, particularly on social media, where influencers were being paid to advertise crypto-assets. Bank of Spain has also highlighted trends related to the increasing number of advertisements using novel means of communication, such as social media or digital banners, as well as new ways of advertising, for instance using influencers on social media such as TikTok, Instagram or Facebook. These new trends required the Bank of Spain to adapt its banking advertising regulation. New regulation was enacted in October 2020, requiring financial institutions to comply with specific rules depending on the media in which the advertisement is going to be broadcast.
International co-ordination on this subject may be particularly relevant, given the global reach of online social networks. Indeed, a 2022 Report by the International Organization of Securities Commissions (IOSCO) details policy and regulatory guidance to help supervisors and regulators address emerging risks from the rise of “finfluencers” and online marketing (International Organization of Securities Commissions, 2022[4]). Among the report’s policy considerations, it notes that IOSCO members should mandate that firms take responsibility for the accuracy of information provided over social media channels, including through influencers. IOSCO members should also require the appropriate disclosure of information, including risks and conflicts of interest. In the European Union, the European Commission proposed a new package of measures in May 2023 related to retail investment; among other things, the proposals aim to address misleading marketing, including on social media (European Commission, 2023[5]).
8.1.6. Greenwashing and risks related to sustainable finance
As noted in Sections 4.2.1 and 4.5.1 in Chapter 4, authorities are concerned about risks related to ESG, sustainable finance and greenwashing. Authorities in Canada noted that while the interest of institutional and retail investors in ESG finance continues, reporting practices are still nascent. Securities regulators in Canada continue to focus on efforts that promote confidence in corporate disclosures, including advancing ESG disclosure standards and compliance monitoring that support informed decisions by investors and market participants. CONSOB reported that some product manufacturers in Italy have begun to assign "green" labels to certificates issued and offered to retail investors. The offering documents of such investments specify the pursuit of sustainability targets and the compliance with rules dictated by codes of conduct, which are published by trade associations in the absence of a specific legislation. The business segment is also developing quickly in Germany, where authorities are alert to possible consumer risks and detriment. Legal and practical aspects of the regulatory response are still subject to discussion and development in the country; therefore, closely monitoring the market for risk is necessary, at least initially. Authorities in Portugal also recognised that the potential lack of knowledge of ESG financial instruments (among consumers and financial intermediaries), combined with incomparability of information could place investors at risk of potential detriment and possibly generate financial losses. In line with these concerns, the CMVM described plans to conduct more robust supervision on sustainable finance in the second half of 2023. In Chile, the Funds Supervision Department of the Financial Markets Commission developed a survey on ESG issues, which was incorporated into the department’s risk matrix. The Financial Sector Supervisory Commission of Luxembourg similarly identified sustainable finance as a key topic in 2023 and beyond. In April 2023, the CSSF published its supervisory priorities in the area of sustainable finance (Commission de Surveillance du Secteur Financier, 2023[6]).
Jurisdictions have undertaken and planned a range of initiatives to address current and emerging risks. The following section highlights promising and effective approaches.
8.2.1. Implementing and improving comprehensive financial consumer protection frameworks
A key response to help protect financial consumers from potential detriment is to strengthen or implement a comprehensive policy framework for financial consumer protection. As the leading international standard for effective and comprehensive financial consumer protection frameworks, the G20/OECD High-Level Principles set out the components that jurisdictions should consider when first developing a financial consumer protection regulatory framework. They also offer a roadmap for jurisdictions with established frameworks to improve upon their existing policies and regulations. Jurisdictions that have yet to implement the Principles (or have only partially implemented them) should prioritise the full implementation of all 12 Principles.
Many authorities described plans to review or issue new regulations to strengthen financial consumer protection frameworks. Indonesia will issue new or enhanced regulations to improve several areas, including rights and obligations for consumers. Nigeria and Portugal will revise regulations regarding disclosure. Nigeria will review the Consumer Protection Regulation to incorporate detailed disclosures for digital products and services. Portugal will extend the array of payment services included in Banco de Portugal’s Fees Comparison Website, to include instant credit transfers and operations performed through payment applications operated by third parties.
Building on its updated complaints-handling regulatory framework, Peru described plans to enhance market conduct requirements for digital financial products and services, introduce new rules for eliminating dark patterns and expand requirements in product design and distribution. Finland amended its Consumer Protection Act in early 2023 and thereby introduced stricter provisions on good lending and marketing practices, lower interest rate caps and stronger authentication requirements.
In New Zealand, the Conduct of Financial Institutions [Amendment] Act (CoFI) will become law in 2025. This will require deposit takers, banks and insurers to implement a fair conduct principle, which would mean: paying due regard to consumers' interests; acting ethically, transparently, and in good faith; assisting consumers to make informed decisions; ensuring the products and services the financial institution provides are likely to meet the requirements and objectives of likely consumers (when viewed as a group); and not subjecting consumers to unfair pressure or tactics, or undue influence.
Bank of Thailand cited plans to issue new regulation on Responsible Lending by the end of 2023, and in May 2023 the Government of Australia announced its intention to regulate Buy Now Pay Later products under the National Consumer Credit Protection Act (2009). In addition to the July 2023 introduction of the new Consumer Duty, which sets higher and clearer standards of consumer protection across financial services and requires firms to put their customers’ needs first, the United Kingdom is also developing regulatory regimes for Buy Now Pay Later and crypto-assets.
In Bulgaria, the Bulgarian National Bank has introduced more detailed reporting of payments and fraud given the new Payments Statistics Regulation in Europe, which establishes new reporting requirements in relation to innovative payment services and channels, payment schemes and fraudulent payment transactions.
8.2.2. Strengthening supervisory capacity
Second, jurisdictions described a range of initiatives aimed at strengthening supervisory capacity, including new activities, investments and approaches.
National Bank of Rwanda cited mystery shopping, while Banco de Moçambique and Brunei Darussalam Central Bank described plans to develop their first risk-based frameworks for market conduct supervision. The Financial Markets Commission (CMF) of Chile noted work underway to define market conduct standards to be met by CMF’s supervised institutions. Bank of Spain also noted intentions to develop and improve the implementation of a risk assessment framework focusing on conduct oversight, building on market conduct reporting requirements introduced in 2022. The FCAC in Canada created a dedicated supervisory team that will plan and conduct thematic reviews. OJK, the Financial Services Authority of Indonesia, is developing an internal task force to serve as a quick response team and investigate potential problems based on early warning signs.
In Peru, the Superintendency of Banking, Insurance and Private Pension Funds (SBS) described the process of implementing a transformational project to enhance their supervisory model and identify potential gaps in its regulatory framework. The enhanced model started with an internal reorganisation of SBS’s market conduct supervision structure, which since 2022 has comprised three specialised departments and a general head. These departments supervise market conduct management as well as interest rates, analyse different sources of user complaints (including those posted on social networks), and apply corrective action. As a result of the reorganisation and the new functions assigned to the team, SBS increased the number of market conduct supervisors. In addition, SBS is improving their supervisory guides, building risk dashboards and exploring other SupTech tools to monitor conduct risks.
The Financial Sector Conduct Authority (FSCA) of South Africa similarly described plans to enhance supervisory engagement models (including at Board and senior leadership level) and increase the sophistication of supervisory models for assessing the fairness and nature of customer service in the banking system. FSCA also plans to enhance and refine conduct risk indicators to strengthen reporting and analytics on identified conduct risks across financial institutions. In New Zealand, regulatory Returns will be introduced in 2024 to provide additional insights into provider behaviour, while in Spain, the DGSFP (Dirección General de Seguros y Fondos de Pensiones) plans to develop and improve the implementation of a risk assessment framework focusing on conduct oversight.
…with a focus on culture
Three jurisdictions described a focus on culture as part of efforts to address conduct risks and improve outcomes for consumers.
In Australia, the Government is establishing the Financial Accountability Regime (FAR) to improve the operating culture of entities in the banking, insurance and superannuation industries and to increase transparency and accountability across these industries. The FAR aims to deter poor behaviour and ensure that financial institutions and their senior executives are held to account when they fail to meet their obligations. The enforcement powers of the FAR are designed to combat serious regulatory issues such as prudential risk to the Australian financial system or significant and systemic consumer harms. Legislation to establish the FAR was reintroduced into Parliament in March 2023 and as of August 2023 remained subject to Parliamentary consideration.
In Hong Kong (China) the Insurance Authority is building on its existing risk-based supervisory approach and focusing more on insurers’ business conduct to ensure they have sufficient controls in place to get the basics right. As such, IA is allocating more supervisory attention to the insurers’ governance culture and their control functions, including dedicating more resources to on-site inspections to insurers focusing on their business conduct and collecting additional data to assess culture.
The FSCA of South Africa described similar plans to interrogate and assess the extent to which financial institutions have embedded good conduct in their cultures. Specific indicators and information gathering questions have been built into the new conduct returns to assist in measuring fair outcomes and assessing a firm’s culture. Supervisors have also started attending operational meetings of the banks and insurers, (e.g. complaints handling meetings, product approval meetings and claims meetings) to observe firm culture.
8.2.3. Protecting consumers at heightened risk of vulnerability
As part of a comprehensive financial consumer protection framework, it is important to also protect consumers who may be at heightened risk of experiencing vulnerability.
While jurisdictions define vulnerability differently depending on the context, a general definition states that: vulnerable consumers are consumers who are “susceptible to detriment at a particular point in time, owing to the characteristics of the market for a particular product, the product’s qualities, the nature of a transaction or the consumer’s attributes or circumstances” [OECD/LEGAL/0403]. The wide range of contexts in which financial vulnerability can occur demonstrates how financial shocks can cause anyone to experience financial vulnerability, regardless of their prior circumstances.
One way to address consumers experiencing vulnerability is through access to consumer protection hardship arrangements. A key insight from jurisdiction’s experiences with the COVID-19 pandemic was the importance of appropriate hardship arrangements for consumers experiencing financial difficulty. These hardship measures were most effective when implemented quickly and with a high degree of flexibility to provide short-term relief to mitigate the impact of emergency measures.
Given the challenging macroeconomic conditions in 2022, jurisdictions described targeted initiatives aimed at consumers who may be more likely to experience vulnerability or who are already in financial difficulty.
The Securities Commission Malaysia described targeted outreach efforts to vulnerable populations, which include consumers who are living in rural areas, elderly, and those in a low-income bracket.
Similarly in Canada, the Ontario Securities Commission reported plans to continue outreach focused on multicultural and diverse communities. Taking vulnerable customers into account is a subject of interest for all Canadian regulatory authorities, in the context of an aging population combined with the increase in the digital service offer and the associated risk of fraud. For example, data from the Autorité des marchés financiers (AMF) indicated that financial institutions in Québec met only 54% of the AMF's expectations in terms of taking into account the needs of vulnerable clients. Vulnerable clients have an increased risk of fraud and abuse caused in part by the decline of faculties (loss of memory, difficulty filling out forms, confusion, etc.). Canadian authorities are concerned that the current economic climate could result in greater fraud and criminal activity, as well as increased affordability issues, which would disproportionately affect vulnerable consumers.
In Colombia, the Financial Superintendency (SFC) decided to develop a regional supervisory strategy consisting of traveling to municipalities far from the main cities to know how financial consumers are treated and to evaluate the policies and guidelines that financial entities implement regarding fair treatment.
In Peru, access to the financial system by immigrants and refugees is made complicated due to barriers related to the different types of ID involved (both permanent and temporary) and the lack of knowledge from financial institutions’ personnel on how to validate those IDs for KYC purposes. As a result, in co-ordination with both national and international organisations, SBS published guidance on the financial inclusion of immigrants and refugees, which covers, among other things, the main ID documents used by this group and their characteristics and validation mechanisms (SBS et al., 2023[7]). SBS also launched a cycle of seminars with associations of financial institutions to disseminate the guidance and reduce this knowledge barrier among financial institutions.
The National Bank of Poland referenced a “cash protection scheme” that ensures that digitally excluded (usually older) consumers can pay with cash whenever they like. In addition, many Ukrainian refugees were successfully integrated within Polish financial system, due to combined efforts of the public administration and the financial sector.
The Bank of Italy described plans to focus on situations of customer distress and mitigating risks of over-indebtedness. The initial analysis will aim to increase the Bank’s understanding of the procedures adopted by intermediaries for the prevention, detection and management of cases of consumers in financial difficulties. The Bank of Italy is committed to ensuring that debt collection procedures, which are often outsourced to third parties, duly take into account the situation of the consumer and are not overly invasive.
In France, the Lemoine Law passed in 2022 reduced to five years the right for applicants formerly suffering from cancer, hepatitis C and other chronic disease not to declare their disease. It also abolished medical questionnaires for housing loans below EUR 200 000 and whose repayment due date falls before the borrower’s 60th birthday.
Regarding consumers who have already been the victims of harm, the Government of Australia is establishing a Compensation Scheme of Last Resort (CSLR) to support ongoing confidence in the financial services external dispute resolution framework. Subject to the passage of legislation, the CSLR would facilitate the provision of up to AUD 150 000 in compensation to eligible consumers who have suffered misconduct by their financial services provider as determined by the financial system dispute resolution ombudsman, the Australian Financial Complaints Authority (AFCA).
8.2.4. Empowering financial consumers
… with digital tools
Another channel through which authorities can complement financial consumer protection policies is by promoting consumer empowerment. To reach this goal, jurisdictions described the use of price comparison tools, calculators and certifications aimed at consumers to help them make informed financial decisions and support healthy competition in the market. In Poland, the Consumer Protection Office developed an online mortgage calculator, which allowed consumers to check how payments would change with the rise of interest rates and how much they could save on interest with early repayments. The introduction of this tool was very timely, and it quickly became popular among online users. National Bank of Rwanda also launched a price comparison tool that aggregates information on interest rates and tariffs on loans, deposit accounts, cards and e-banking. The Central Bank of Hungary (MNB) referenced two consumer-facing platforms that aim to support transparency, comparability, public awareness and through this product innovation. First, a Consumer-Friendly certification framework that accounts for competitiveness, financial stability and consumer protection is available for three product types: housing loans, home insurance and personal loans. The MNB operates an online comparison site that allows consumers to compare such products in a standardised, easily comparable and transparent way, providing them with information on the main parameters of the products offered by the institutions. Second, a Green Financial Product Finder was launched in April 2023 focusing on green investment funds, green unit-linked life insurance and green voluntary pension funds. The Competition and Consumer Protection Commission of Ireland similarly runs public awareness campaigns to encourage consumers to use their comparison tools and calculators to see how much money they can save by switching financial products.
… and through financial literacy
Another strategy that can complement financial consumer protection is to support consumers’ capabilities to make informed financial decisions by improving financial literacy levels in line with the OECD Recommendation on Financial Literacy (OECD, 2022[8]) . Many jurisdictions aim to improve consumers’ financial literacy through financial education and/or public awareness campaigns. Ireland has carried out market research and PR campaigns to inform and educate consumers, particularly young consumers ages 18-35, on BNPL and crypto-assets. To help consumers better understand investment risks linked to crypto-assets, Bank of Greece issued a Q&A on bitcoin on its website. Nigeria introduced a new e-learning platform. Ontario (Canada) redeveloped the OSC’s investor website “GetSmarterAboutMoney.ca”. Germany is working on a national financial literacy strategy and plans to launch a central platform for financial literacy in 2024. In addition, Germany also plans to develop a finance-themed board game as part of its strategy to improve financial literacy levels. The Financial Supervision Commission of Bulgaria launched an innovative mobile app for filling complaints in real time, which improved consumer awareness. Promoting financial literacy has been a top priority for the Banco de Portugal, which has its own financial education initiatives and also co-ordinates the Portuguese National Plan for Financial Education together with other financial supervisors. Financial education initiatives in Portugal include reaching target audiences through digital channels and e-learning platforms, as well as hosting training sessions and developing financial education materials.
The Monitor describes how financial consumers are exposed to risk and underlines the need for appropriate mechanisms to address information and market power asymmetries that can lead to consumer detriment. Findings in this report also support the importance of holistic and comprehensive financial consumer protection frameworks to respond to such risks and minimise harm. In combination with the G20/OECD High-Level Principles on Financial Consumer Protection, the Monitor can also provide a useful template for country reviews of financial consumer protection policies and to identify areas that require additional scrutiny.
At the outset of this initiative, the objectives for the Monitor were to:
3. elevate the perspective of financial consumer protection policymakers and authorities in international policy debates by contributing to the available evidence base.
In line with these objectives, the next steps building from this publication include the following:
Draw upon the findings to inform the Programme of Work for the G20/OECD Task Force on Financial Consumer Protection, including future areas of research, subjects of roundtable discussions and seminars, and the development of policy guidance.
Disseminate the Monitor and its findings to policymakers, public authorities and other stakeholders who can draw upon it to inform law and regulatory reform to enhance financial consumer protection where required, guide market monitoring and effectively address consumer detriment.
Evaluate the reporting template and data collection process to identify areas for improvement, with an eye toward future iterations of the Monitor and any lessons for responding jurisdictions regarding their data collection capabilities.
References
[6] Commission de Surveillance du Secteur Financier (2023), The CSSF’s supervisory priorities in the area of sustainable finance, https://www.cssf.lu/en/2023/04/the-cssfs-supervisory-priorities-in-the-area-of-sustainable-finance/ (accessed on 23 August 2023).
[5] European Commission (2023), Retail investment strategy, https://finance.ec.europa.eu/publications/retail-investment-strategy_en (accessed on 20 September 2023).
[3] FINRA Investor Education Foundation and CFA Institute (2023), Gen Z and Investing: Social Media, Crypto, FOMO, and Family, https://www.finrafoundation.org/sites/finrafoundation/files/Gen-Z-and-Investing.pdf (accessed on 20 September 2023).
[4] International Organization of Securities Commissions (2022), “Report on Retail Distribution and Digitalisation”, https://www.iosco.org/library/pubdocs/pdf/IOSCOPD715.pdf (accessed on 25 August 2023).
[1] OECD (2022), “Institutionalisation of crypto-assets and DeFi–TradFi interconnectedness”, OECD Business and Finance Policy Papers, No. 01, OECD Publishing, Paris, https://doi.org/10.1787/5d9dddbe-en.
[8] OECD (2022), “Recommendation of the Council on Financial Literacy”, OECD Legal Instruments, OECD/LEGAL/0449, OECD, Paris, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0449.
[2] OECD (2021), Artificial Intelligence, Machine Learning and Big Data in Finance: Opportunities, Challenges and Implications for Policymakers, OECD, Paris, https://www.oecd.org/finance/financial-markets/Artificial-intelligence-machine-learning-big-data-in-finance.pdf (accessed on 21 November 2023).
[7] SBS et al. (2023), Guía Práctica para la Inclusión Financiera de Población Fefugiada y Migrante, https://www.sbs.gob.pe/Portals/3/jer/Materiales_EF/2023/GuiaPracticaPoblacionRefugiadaMigranteDigital.pdf (accessed on 20 September 2023).