In both the Federal Government of Somalia and the Somaliland administration, there are no explicit legal provisions that prohibit refugees and asylum seekers from accessing basic financial services. The existing financial regulatory frameworks do not contain formal restrictions that exclude displaced persons from engaging with banks, microfinance institutions, or mobile money platforms. In principle, this creates an open space for financial inclusion, allowing refugees and asylum seekers to access essential services such as savings accounts, remittance systems, and basic credit products. However, in practice, significant barriers remain due to the widespread lack of officially recognized identification documents and formal legal status among displaced populations.

Financial institutions in both Somalia and Somaliland generally require documentation such as national identity cards, proof of legal residence, or other verifiable credentials to meet Know Your Customer (KYC) requirements and comply with anti-money laundering regulations. Refugees and asylum seekers often lack these documents, which limits their ability to open bank accounts, apply for loans, or obtain mobile money services. Additionally, the absence of a documented income history or credit profile further restricts access to financial products that could support livelihoods and economic integration. Despite these practical challenges, the legal environment itself does not impose direct prohibitions, and there is growing interest among financial service providers and humanitarian actors to develop inclusive financial mechanisms tailored to the needs of forcibly displaced populations. These include simplified KYC procedures, biometric registration, and partnerships with mobile money platforms to facilitate access to digital financial services. Such initiatives, aligned with global best practices on financial inclusion, offer a pathway for improving the financial resilience and self-reliance of refugees and asylum seekers in both Somalia and Somaliland.