In the course of my training AML staff in various countries moving in the direction of Financial Inclusion I have advocated a multi-pronged approach for KYC/CDD. With large sub-populations without any form of identification such as birth certificates, marriage certificates, national ID cards etc. a digital photograph taken at the bank does help together with some identification from an existing customer (e.g. those who go from door-to-door every morning to supply newspapers will come to know certain customers). Bank officials need to verify the address (often unauthorised or makeshift structures) by personally visiting the given address. A low threshold limit for the maximum amount to be kept in the account does help in the early years. Discretion has to be exercised prudently. Accounts have to be closely monitored.