Mobile Financial Services Risk Matrix

Developed in partnership between

Kenya School of Monetary Studies, Nairobi, Kenya
United States Agency for International Development, Washington, DC, USA
Booz | Allen | Hamilton, McLean, VA, USA

July 23, 2010

This document hopefully contributes some clarity to the systemic and consumer risks involved in mobile financial
services and the options most commonly available for addressing those risks. The authors welcome feed back on
errors or omissions that could materially improve the usefulness of this document in policy discussions.
The risks and response options identified in this Matrix do not represent the official position of the KSMS, USAID,
BAH or any of those who have generously contributed their time and expertise to this project.
 Mobile Financial Services Risk Matrix

Introduction in the regulated financial intermediaries. However, it has also converted widely
distributed consumer risk into a concentrated systemic risk, where the value of the
Mobile Financial Services offer significant opportunities for improving the efficiency items in transit on deposit through trustee accounts is no longer insignificant.
of financial services by expanding access and lowering transaction costs. The rapid But this is not only an issue for Kenya (one that is being actively addressed) but is of
public acceptance of these services in countries such as the Philippines, Brazil, India, concern to regulators in many other countries that are responsible for balancing the
and Kenya has demonstrated that the technology is mature and brings real benefits assurance of an enabling environment that is conducive to innovation and economic
to people who previously could not access financial products or services. development against consumer protection concerns. Given that there is no common
The Consultative Group to Assist the Poor (CGAP) has recognized this development standard for the enabling environment, different regulators have responded in
with their seminal work on the impact that this technology is having on access to different ways, leading to a proliferation of inconsistent operating environments for
finance for the poor and in their Branchless Banking Diagnostic Template. account providers, and in some cases, limitations on the range of services that can be
provided based on factors other than the underlying risks. This lack of consistency
On September 25, 2009, the G-20 Leaders committed to improving access to financial
was lamented at the February 2009 Mobile World Congress in Barcelona.
services for the poor and directed the establishment of a G-20 Financial Inclusion
Experts Group (FIEG) to support the safe and sound spread of new modes of The United States Agency for International Development felt that it could play a
financial service delivery capable of reaching the poor. The FIEG is identifying catalytic role in helping to harmonize legal and regulatory environments for mobile
lessons learned on innovative approaches to providing financial services to these financial services through partnering with one of the leading international
groups; promoting successful regulatory and policy approaches; and elaborating consulting firms, Booz Allen Hamilton, to undertake a detailed analysis of the
standards on financial access, financial literacy, and consumer protection. various risks involved in the different models of mobile financial services, as viewed
from each of the key stakeholders involved in these transactions. The research was
Seminal work has been done in this area in Africa by the Central Bank of Kenya,
undertaken in collaboration with the Kenya School of Monetary Studies, the policy
which authorized Vodafone/Safaricom to introduce the M-PESA mobile payment
research and training arm of the Central Bank of Kenya, and involved discussions
system, with startling results. Some 25 percent of the population of Kenya is now
with stakeholders in Ghana, Kenya, Malawi, Nigeria, Rwanda, South Africa,
using the service to make over 24 million transactions by May of 2010. The logic
Tanzania, Uganda, and Zambia as well as with CGAP, the U.S. Treasury, the U.S.
was that using a cell phone system to transmit and receive domestic remittances was
Federal Reserve in Atlanta, and the GSM Association.
a lower risk for the general population than the previous options available to make
informal transfers back to villages. This service has just been expanded to include The analysis produced consists of three parts: 1) the Mobile Financial Services Risk
savings, loans and insurance in collaboration with Equity Bank. The explosive Matrix, 2) transaction flow mapping of some of the key transactions to show where
growth of use of mobile money has had the unintended benefit of increasing public these risks occur, and how these may differ depending on the service model, and 3)
involvement in the formal financial system, including expansion of savings accounts

Mobile Financial Services Risk Matrix 1 July 23, 2010

 Mobile Financial Services Risk Matrix

an analysis of how various jurisdictions have already responded to these risks, enabling some routine transactions to be done without visiting a bank branch, which
based on analysis provided by CGAP. saves time and costs for both the client and for the bank while enabling bank
branches to serve a larger number of clients due to the reduced branch traffic. All
This analysis is not intended to be all inclusive or prescriptive. Indeed, this would
cash in and cash out transactions require access to a bank branch or ATM.
not have been possible since the topic of mobile banking is a rapidly evolving issue.
Moreover, the flow charts are representative, since each account provider will have Banks may expand access through use of agents to represent the bank for account
its own business model. And the options found for each risk are not necessarily opening and cash in or out services. Transactions initiated through the bank's
mutually exclusive, since more than one policy option may be appropriate. agents are relayed back to the bank and pass over the client's account, and the bank
assumes responsibility for the actions of its agents.
USAID sees this matrix as a living document that will undergo modification as our
collective understanding of the risk factors and responses to these risk factors 2. MNO (Mobile Network Operator) Model: A pure cell phone company (MNO)
continues to develop. We invite you to participate in this process by reviewing this service extends the wireless network messaging functionality to provide payment
document and providing us with any material feedback that you believe would services that enable customers to remit funds to each other that can be settled
improve its contribution to the development of a sound, balanced regulatory through the MNO's established agent network. Individual payment transactions
framework for mobile financial services. occur entirely within the MNO and do not require the service user to have a bank
account. The funds in transit - paid in by the remitter but not yet withdrawn by the
Comments/suggestions should be sent to Mr. Jeffrey Jackson, Senior Private Sector
recipient, are in principle on deposit in a segregated account with one or more banks
Advisor, USAID at [email protected].
(trust account if under common law), so are within the formal financial system.
Since the service provider is only executing client payment instructions and is not
Mobile Financial Services Model Definitions
performing the credit evaluation and risk management function of a bank, these
1. Bank Model: In a pure bank model the bank (or other formal deposit taking services arguably do not constitute "banking" and do not require the level of
institution) holds the license. Each client is required to have an established account regulatory oversight needed for deposits that are used to fund lending. The
with the bank. The service provides mobile access to normal banking services, such depository bank has no involvement in or responsibility for payments through the
as balance inquiry, transfers between accounts, and payments. Access can be MNO system. Given the relatively high cost of a bank account (minimum balance,
through the Internet or through a cell phone based system where the cell phone service charges, full KYC requirements, and travel time to a branch) and the easy,
company provides a menu based communications services in partnership with a low cost and increasingly universal access to cell phone services, the MNO model
bank, but is not involved in any underlying financial transactions, all of which pass arguably is highly effective in brining informal cash transactions into a form of
through the client's bank account and for which the bank assumes responsibility. formal financial system, expanding access to financial services.
This service provides convenience to existing bank clients and to the bank itself by

Mobile Financial Services Risk Matrix 2 July 23, 2010

 Mobile Financial Services Risk Matrix

3. Hybrid Model: A combination of a bank, MNO or other third party that offers 3. Reputation: A risk that damages the image of one of the stakeholders, the mobile
communications and financial transaction services that combine characteristics of system, the financial system, or of a specific product
both the pure bank and pure MNO models. Such combination hybrid models 4. Legal: A risk which could result in unforeseeable lawsuits, judgment or contracts
include but are not limited to: that could disrupt or affect MFS business practices
• MNO/Bank Model: Cell phone company based payment services that handle 5. Liquidity: A risk that lessens the ability of a bank or MFS provider/agent to meet
payments internally with cash in/out through the MNO's agent network, yet link cash obligations upon demand
to formal banking services such as savings, loans and insurance in partnership
with a regulated financial institution by enabling communications with the bank 6. International: A systemic risk (as defined above) that could have cross-border
and transfers between the user's cell phone payment account and accounts at the contagion effect
bank. Most mobile financial services are hybrid, drawing on the relative
strengths of the partners involved.
TABLE OF CONTENTS
• Government Provider/Bank Model: A government sponsored interbank
Part I - Risk Matrix
clearing system includes consumer access functionality, either using smart cards
1. Consumers .................................................................................................................................... 4
or smart cell phone Sims that temporarily act as a store of value and synchronize
2. Merchants ....................................................................................................................................22
with a formal bank account. The cell phone company, if involved, provides
3. Agents ...........................................................................................................................................24
communications services while the government operates the payment switch
4. Account Providers .....................................................................................................................30
between banks and between accounts within banks.
5. Trust Account Holding Financial Institutions....................................................................... 40
6. Payment Systems ........................................................................................................................42
Risk Definitions
7. National Regulators ...................................................................................................................43
1. Systemic: A risk that could cause collapse of, or significant damage to, the 8. International Regulatory Issues ............................................................................................... 61
financial system or a risk which results in adverse public perception, possibly Part II – Sample Transaction Flow Charts ..................................................................................... 64
leading to lack of confidence and worse case scenario, a "run" on the system Part III - Risk Response Details ........................................................................................................ 77
2. Operational: A risk which damages the ability of one of the stakeholders to Bibliography.........................................................................................................................................175
effectively operate their business or a risk which results in a direct or indirect loss Contributors .......................................................................................................................................189
from failed internal processes, people, systems or external events

Mobile Financial Services Risk Matrix 3 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
1.1 Potential customers cannot When initially registering for Know Your Customer 1.National ID system: • Universality removes potential for X X X X X X
access mobile payment mobile financial services (MFS), (KYC)/Customer Due Diligence Authorities issue universal IDs, which are exclusion of those desiring service.
services due to inability to the inability of the account (CDD) guidelines to be set used for access to financial services • Burden on national authorities to
prove his/her identity. provider or its agents to commensurate with the risk of the institute universal ID program may
adequately verify the identity and service. be unaffordable or beyond the
personal information of applicants Subject to regulatory approval and existing infrastructure's legal,
may block approval or access to verification of implementation. technical or political capacity to
mobile payment services. enforce.

2. Financial ID system: • With no universal national ID, the

In the absence of universal ID, financial financial sector must rely on other
account providers (as a consortia) offer a forms of identity, which all
financial ID with similar characteristics as customers may not have access to;
a universal ID, but only issued to however, they can set risk-based
customers after meeting standard sector tiers to ensure access.
KYC requirements (e.g. a customer’s • Coordination of various private
phone # and SIM could be used as basic actors in the financial sector could
form of identification) work through the bankers
Could link in with an industry ID system association and/or MFI association,
established for ensuring certainty of possibly with leadership from the
identity in credit bureaus, or with a tax central bank.
ID system.

3. Regulated KYC Requirements which • Each institution can interpret the

leave implementation to institutions requirements, which may allow
various combinations of
identification. Banks can set risk-
based tiers to ensure access.
• Each individual bank must establish a
policy that meets regulatory
requirement.
• Reliance on existing forms of
identification keeps cost low, but
difference in policies across
institutions creates some risk

Mobile Financial Services Risk Matrix 4 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
4. No regulatory KYC requirements • Each institution will determine
requirements for account opening
based on their perception of risk.
Lack of regulatory requirement
should keep barriers to access low.
• Lack of requirement opens cross-
organization risk for criminal activity.

1.2 Existing customer cannot Verifying identity and personal Transaction size and KYC/CDD 1. Restrict access to mobile financial • Requiring that agents repeat the
access mobile payment information to protect customers levels commensurate with the user's services to those who can meet the same same KYC requirements at the X X X X X X
services due to inability to when using mobile payment ability to self identify through PIN, KYC requirement as account opening transaction level that are required at
prove his/her identity. services may block access if the photo attached to the account, account opening is not practical. It
customer is not able to national ID or biometric ID system. would place an enormous time
adequately prove his/her identity. Easily accessible process for replacing requirement on agents, and should
lost SIM or PIN. not be necessary if the account
opening procedure is implemented.
Subject to regulatory approval and
(This would be the equivalent of
verification of implementation.
requiring a photo ID check at the
ATM.)
• Regulatory authorities would not be
able to effectively police such a
requirement.

2. Ensure that appropriate risk based • Strict KYC requirement for agent
service access requirements are transactions will create
established at account opening inconveniences for customers and
create more bureaucracy for agents.
• Expecting agents to conduct this due
diligence for transactions of existing
customers, especially during busy
times is impractical.
• Risk-based allowances ensure
customers still have some access
even without full KYC; yet the limits
protect against fraud. (Option

Mobile Financial Services Risk Matrix 5 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
enables customers who have lost
their ID to maintain some access)
• Lower requirements for small, or
low risk, transactions reduce
regulatory burden for agents

3. Require that funds transferred to • Risks unwarranted returns if agents

recipients who do not have established do not want to complete pay-outs
KYC credentials are returned to sender for non-KYC reasons

4. Require that account providers have • Balance protection of customers

acceptable procedures in place for against theft of funds against
replacing PIN and other provider ID inconvenience of denial of service for
legitimate transactions

1.3 Customer’s identity is stolen The risk of stolen identity can Protect service users against results 1. Biometric national ID, or financial ID, • Though biometric ID and validation X X X X X
and used to open a mobile have multiple ramifications, of identity theft system with biometric validation required reduces the possibility that a stolen
payment account including: Subject to regulatory approval and for account opening. ID could be used to fraudulently
fraudulently. • Customer’s identity could be verification of implementation. open an account in a customer’s
used to access other services name, the cost of implementing such
a program can be high.
• Customer is held accountable
for fraudulent transactions • Different biometric options have
made in his/her name varying cost associated with them
(e.g. voice tends to be less expensive
• Customer is unable to access as it can occur over the phone,
mobile services because an whereas fingerprinting and retinal
account using his/her scans are more costly)
name/identity has already been
established fraudulently. • Biometric ID program may be
beyond the technical capacity of a
regulator to implement and maintain,
as the infrastructure for capture and
validation will require maintenance.
• Costs will likely decline as the
technology improves – in the interim
other and possibly multiple forms of

Mobile Financial Services Risk Matrix 6 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
ID may be required, such as birth
certificates or passports where
available.

2. Account providers provide an effective • Requiring a rapid alert system to

process for alerting users of unusual advise users that their accounts may
activity, and blocking accounts when be compromised and block
notified of fraudulent activity. procedure to stop fraudulent activity
once recognized is a simple and
pragmatic way to deal with stolen
identity.
• The procedure can be easily
validated by regulators.

3. Develop of best practices for • KYC mechanisms, which could

enhancement of fraud detection systems. include point-based multiple ID
Provider reports suspicious or fraudulent requirement, limits potential for
activity to central authorities (Central fraudulent account opening.
Bank/Financial Intelligence Unit or FIU). • Reporting helps target systemic
fraud, thus reducing risk.
• Enforcement mechanisms for
reported illicit activity may not exist
or may be weak. Creating or
enhancing such mechanisms will
require investment.

4. With adequate account opening • Consumer protections embedded in

protections, including adoption of policies contracts will reduce barriers to
above, providers can limit the liability of adoption, and should not be terribly
fraudulent activity in account agreement. costly with adequate fraud controls.
Periodic account validation would protect • Contract enforcement could be
the integrity of these protections. required to ensure customer
protection which would require an
effective court system.

Mobile Financial Services Risk Matrix 7 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
5. No regulatory KYC/CDD • Lack of KYC/CDD requirements
requirements or provider-based open financial system to fraud risk,
consumer protection against fraudulent whether through ID theft or ID
account opening. fraud.
• Lack of protection represents a
potential cost for consumers and
thus a barrier to entry.

1.4 Customer’s account security If a customer’s account Account providers maintain a rapid 1. Strong privacy legislation / regulation • Regulatory requirement reduces X X X X X X X
credentials and / or account credentials, account information account block process for customers requires institutions to institute controls likelihood for improper release.
information and transaction and transaction history are not if customer/MNO believes the to reduce the likelihood for unauthorized Standard requirements for all
history are improperly adequately protected, the account has been compromised. release, or theft, of personal information. institutions limit criminal targeting of
released (e.g., PIN customer’s account can be Development of best practices for weak institution policies.
biometrics, and stolen illegally accessed to steal funds or enhancement of fraud detection • Burden on national authorities to
phone/subscriber identity to process illicit activities. systems. institute and enforce; may be
module [SIM]). Customers may also be subject to unaffordable or beyond the existing
identity theft or blackmail. MNOs mitigate risk of unauthorized/
inappropriate access to customer infrastructure's legal, technical or
Some models, particularly the transaction data. political capacity, or authority, to
hybrid, may share customer data implement and enforce.
as a means to mitigate fraud by To mitigate the risk of customer
account credentials, information, and • Requirement will impose a cost on
enabling a clear audit trail of the
transaction history being providers.
financial transaction.
compromised, implement best
practices for data security 2. Provider led controls instituted to • Institutional policies reduce
maintenance, including data sharing mitigate the likelihood of unauthorized likelihood for improper release.
between service providers and other release or theft of customer information. Lack of standard requirements for all
business entities. institutions allows for criminal
Subject to regulatory review and targeting of institutions with weaker
verification of implementation. policies.
• Institutional programs will impose a
cost on providers; however, lack of a
regulatory requirement allows
institutions to determine the level of
mitigation.

3. Providers institute a “disaster plan” to • Can result in denial of access to

Mobile Financial Services Risk Matrix 8 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
notify customers impacted by breach, services, resulting in hardship for
Plan could include procedures to block funds recipients until problem
transactions on all impacted accounts and resolved.
to issue new credentials to customers. • Quick action can limit operational,
systemic, and reputation risk.

4. No formal regulatory requirement or • Lack of policy raises the systemic

provider policies for customer protection fraud risk.
or disaster recovery plan • Ineffective response to a breach of
privacy could undermine public
confidence in the financial system
and its regulators.

1.5 Customer is unable to Customers are not able to MNOs provide an efficient dispute 1. Regulatory oversight authority refers • Licensing authority needs to set an X X X X X X
efficiently dispute a resolve disputes with an account resolution process. disputes back to the account provider but "acceptable level of disputes" above
transaction or account provider and recourse to a Clear, published service standards to verifies account provider dispute which continuation of the account
charge. government body or regulatory minimize the cause of disputes. resolution process. provider's license may be put in
authority to arbitrate disputes is question.
weak or non-existent. Regulatory domain able to define
consumer protection for error • Implies regulatory monitoring of the
Note: The dispute requiring resolution, in terms of account provider’s error resolution
resolution could be a transaction responsibilities, time frames, and program, not just complaints.
that is initiated by a customer on liabilities. • Regulatory authority may not have
the customer’s phone, as well as
Subject to regulatory review and capacity to handle complaints of
a transaction that an agent makes
verification of implementation. disputes
on behalf of a customer who
does not have his/her own phone.
2. Association of providers, or NGO, • Association ownership could be
provides dispute resolution process. perceived as biased toward
providers, but less biased than a
provider run system. An NGO
focused on consumer protection
could be preferable.
• Allowing other providers in the
association (or NGOs with other
motivations) to interact with
customers could create provider

Mobile Financial Services Risk Matrix 9 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
animosity
• Association may not have capacity to
support, or the budget to develop,
this function.

3. Individual providers provide dispute • Provider management could be

resolution process biased toward provider; however,
competition should enhance
customer position.

4. Independent alternative dispute • Existence of an independent ADR

resolution (ADR) function developed to function provides consumer
handle appeals to other processes. protection against industry bias in
other processes.

5. No dispute resolution process • Lack of consumer protection raises

cost for consumers, thus creating a
barrier to adoption.
• The only incentive for resolving
customer disputes will be customer
retention and reputation, which will
be stronger in competitive
environments, and environments
with an active business press corps.

1.6 Customer is charged Agent may overcharge or have a Account providers use clear 1. Regulatory authority requires full • Full disclosure of all fees limits X X X X X X
unauthorized fees by agent. side transaction fee that is not contracts that fully disclose all fees to disclosure of all fees in account potential for consumer exploitation
authorized that they impose on be charged, tailored for various agreement. by providers.
the consumer. customer situations, including • Regulators may lack the
Customers may not understand different languages and illiteracy (i.e. capacity/budget to monitor and
the complexity of the contract pictogram-based contracts). enforce the requirement, especially
signed, making it possible for Service charges clearly posted at each considering the abuse is more likely
him/her to face additional agent's location. Disclosures to happen at the agent level than the
fees/services without being aware reasonably comprehendible to all corporate level.

Mobile Financial Services Risk Matrix 10 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
of it. The lack of clarity of customer groups (i.e. major language 2. Account providers required to ensure • Account provider disclosure
contract could be further disclosures and potentially fee structure is posted in all service mitigates potential for consumer
exacerbated by language barriers pictograms) locations in a format understandable to exploitation,
or illiteracy. Subject to regulatory review and the broad population. (i.e. major language • Account providers may have
Additional government charges, verification of implementation. disclosures and potentially pictograms) difficulty ensuring reasonable
such as VAT, may complicate the Account providers required to discipline compliance throughout their agent
disclosure of true costs and or expel consistently non-compliant network.
tariffs. agents.

3. No fee disclosure policy • Account providers may not fully

disclose fees, and/or agents may
violate terms of service, undermining
public satisfaction with the service,
potentially resulting in complaints to
the regulator.

1.7 Customer cannot access Insufficient numbers/availability of Providers responsible for market 1. Regulatory authority mandates minimal • Requirement raises the cost for X X X X X X
cash from mobile money mobile money and/or bank coverage geographic coverage as part of financial account providers so that the service
account due to lack of agent correspondent agents in a given No unreasonable regulatory access/inclusion interests. may not be profitable. Also, the
availability. geography results in consumers constraints on expansion of agent requirement raises barriers to entry
not being able to access cash or networks for smaller players.
incurring excessive travel costs • Account providers may agree to
and inconvenience. collaborate in areas where
population density does not justify
multiple service access points.

2. Regulatory authority mandates • Coverage would improve in rural

community reinvestment by account areas
providers to extend agent coverage • Requirement is a cost for providers;
however, it has positive reputation
benefits and could be scaled based
on network size.

Mobile Financial Services Risk Matrix 11 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
3. Regulatory authority requires • Customer expectations are set at
disclosure of agent network coverage in account opening.
service-level agreements (SLAs) • Cost of compliance is low for
providers and the cost of oversight
is minimal.
• Agent network will expand with
market demand.

4. Regulatory authority allows account • Allowing account providers to

providers to appoint agents at their determine the type and distribution
discretion, but with registration at the of its agent network maximizes
regulatory authority and subject to market efficiency.
inspection as deemed necessary. • The registration of agents and
potential to inspect them provides
the regulatory authority with a
degree of oversight.
• Agent network will expand with
market demand.

5. Treat as internal account provider • Customer expectations may not be

issue - no regulatory oversight of extent reasonable due to lack of
of agent network or required disclosure. transparency regarding network
coverage and SLAs. Customer
complaints may rise.
• The reputation of the service may
suffer.
• Agent network will expand with
market demand.

1.8 Agent unwilling to perform The agent may be unwilling to Adoption of payment services best 1. Regulatory authority establishes anti- • Motivates account providers to X X X X X X
transaction for customer. perform a transaction because of practices including optimization of discriminatory policies with verification of encourage agents to serve the
liquidity management concerns. agent and super-agent compensation compliance. “customer in front of them”
Agent may wish to conserve cash models for cash distribution, cash • Regulatory authority may lack
by restricting large transactions pick up, and deposits. capacity and/or authority for

Mobile Financial Services Risk Matrix 12 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
to more profitably service a Standards for agents barring consumer protection oversight;
larger number of smaller discriminatory practices, with Discrimination complaints are the
transactions. regulatory review and verification of task of other agencies
Agent is unwilling to serve compliance.
customer due to discrimination 2. Regulatory authority provides • Regulatory authority may lack the
(race, tribe, religion, sex, etc). oversight to ensure agents and other capacity to perform this role with
service providers perform transactions in sufficient credibility to deter abuse.
Agent is instructed by super agent
compliance with account agreements.
not to perform transactions
during specific hours of the day
3. Account providers set institutional • Institutional policies mitigate
due to cash pickup and deposit
anti-discrimination policies and monitor discrimination likelihood by setting
burdens.
agent behavior/compliance up a disincentive for agents.
• Providers may be more reactive in
preventing discrimination if there is
no regulatory cost.
• Providers may lack the capacity to
monitor and enforce policy.

4. No regulatory requirement or provider • Relies on existing general anti-

policies requiring agents to complete discrimination statutes and practices.
transactions

1.9 Customer cannot access Customer cannot perform cash- Account providers are responsible to 1. Monitor complaints of unavailability of • Forecasting and management X X X X X X
cash from mobile money out transaction because the agent customers for providing cash-out cash - factor the level of instances into capabilities are similar for ATM and
account due to lack of agent does not have sufficient cash on services in a timely manner, including license extension discussions/decisions. Branch cash forecasting/
Refer liquidity hand to perform the transaction. contingency plans to deal with management.
to 4.7 liquidity crises,
Agent may be experiencing • Only a regulatory issue if account
unusually high cash-out requests Subject to regulatory review and provider performance egregious -
due to special events, including verification of implementation. impact on license extension.
public events, public disturbances,
• Account providers face a reputation
or loss of public confidence.
risk if they cannot manage liquidity
Super agents providing physical well.
cash distribution to individual
agents are not able to manage 2. Account providers forecast and • Requirement ensures customers
cash stocks effectively. manage liquidity of agent network to access to cash within a reasonable

Mobile Financial Services Risk Matrix 13 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
optimize service for consumers. amount of time.
• Forecasting and management
capabilities are similar for ATM and
Branch cash forecasting/
management.
• Market forces will improve liquidity
management over time as providers
keep reliable agents, take on some
agent responsibilities, or partner
with other institutions as agents of
last resort.

1.10 Customer cannot access Customer cannot receive cash Customer’s responsibilities and 1. Provider ensures alternative access • Customers responsible for X X X X X X
cash from mobile money from agent or perform cash-out process for regaining access to cash procedures in the event of customer maintaining their access. But failure
account due to lack of transaction during regular spelled out in contracts and in notification of access failure; terms and to resolve access problems could
personal access. “business hours” due to one of account provider’s operating conditions of each party’s responsibilities undermine public acceptance by
the following situations: procedures. outlined in account agreement. increasing the user's risk.
• Customer has exhausted Simple remedies to each situation
his/her pre-paid minutes. spelled out and available to users. 2. No alternative access measures exist • Customer must pursue through
dispute resolution if they can not
• Customer’s cell phone battery
reestablish connectivity.
is dead.
• Customer has lost his/her cell
phone.

1.11 Customer cannot access Customer cannot receive cash Providers are responsible to 1. Regulatory authority requires system • Required service levels and X X X X X X X X X
cash from mobile money from agent or perform cash-out customers for providing cash-out availability service levels. Business continuity plans mitigate system
account due to lack of transaction during regular services in a timely manner. continuity plans must be clearly stipulated availability risk.
system availability. “business hours” because of one Account providers post realistic in terms and conditions of customer • High system availability requirement
of the following situations: access standards and area coverage agreements. will impose a cost to some providers
• Cell phone service is not to ensure appropriate client service Significant complaint levels will impact and raise a barrier to entry for
available in that location. expectations. license extension. potential providers.
• The account provider is Subject to regulatory review and • Regulatory authority
experiencing a temporary verification of compliance. capacity/authority to regulate and
enforce system availability may not

Mobile Financial Services Risk Matrix 14 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
system outage. be practical. (Whether the
A record of complaints may regulatory authority in this situation
indicate questionable business is financial or telecommunication is
practices, or a lack of complaints debatable.)
could mean there is no
established avenue for consumer 2. Regulatory authority establishes a • Requires careful balancing of the
remediation. Unscrupulous comprehensive licensing and registration enabling environment to prevent bad
businesses or business may process for service providers to mitigate practices while not inhibiting market
change names and locations to risk exposure from migration of weak entry of new players and innovation.
hide complaint histories once the business practices. • Risk of stifling initiative through
business ceases operations. over regulation.

3. Regulatory authority monitors system • Any new market entrant is likely to

availability service levels. take time to fully roll out its service,
Significant complaint levels could impact particularly if competition is
license extension. entrenched. Failure to do so within
a reasonable time could lead to
failure of the service, resulting in the
regulator having to ensure an
orderly withdrawal.
• Regulatory capacity to monitor
system availability may be limited.
• Lack of a regulatory requirement
keeps barriers to entry low, relative
to this issue.

4. No system availability requirement by • Adoption rates will be low if

regulators or commitment by providers customers cannot depend on system
availability.

1.12 Lack of network Closed loop networks with no No protectionist barriers to transfer 1. National regulators require • Requirement of interoperability may X X X X X
interoperability prevents capability to transfer funds funds between systems. interoperability of payment networks raise a barrier to entry as the
consumer from transacting between account holders of Intra- account provider transfers (through inter-account provider links or technology requirements could be
Refer with desired party. different account providers’ through a switch)
conducted within the account more challenging than a simple
to payment networks due to lack of provider’s system. closed network. Further, the
5.13 interoperability. Among requirement may stifle innovation in

Mobile Financial Services Risk Matrix 15 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
providers or their non- Inter-account provider transfers a new technology through keeping
participation on a national conducted through a national switch, new entrants out.
payment platform block payments either directly or through • Consumers might benefit as there
outside of the account provider's correspondent clearing accounts, would be no network limitations on
network. The first player to without unreasonable usage fees or sending mobile money.
enter the market can gain penalties.
monopoly power, limiting • Account providers might be forced
competition, but can help justify to compete on cost, products, and
initial market entry into virgin service, rather than size of network.
markets. • Limits first mover advantage,
potentially discouraging initial market
entry.

2. Competition agency empowered to • Requires a competition agency with

investigate non-competitive behavior the capacity to investigate and
enforce non-competitive behavior,
such as predatory pricing.

3. No regulatory action • Predatory pricing and expanded

monopoly power are possible;
however, experience with
networked technologies (cell
phones/ATMs) suggests that the
market will move toward
interoperability without regulatory
action.

1.13 Customer loses balance due Trustee impaired: Should the Trust funds holding the value of items 1. Law / Regulation relating to bank • Requires trust law - normal in X X X X X X X X
to failure of a bank holding trustee fail or become insolvent, in transit are legally segregated from failure or insolvency segregates assets common law systems but typically
trust fund, or a similar trust accounts that are not legally the trustee's own assets in held in trust accounts from the general difficult in statute law systems.
situation where trust fund is segregated from the general pool bankruptcy. pool of assets of a trustee in the • Requires a court system that both
compromised. of bank assets available to satisfy Trust accounts are divisible (to bankruptcy process. understands trust law and is
creditors may be pulled into the spread risk) and transferable (in case empowered to enforce it.
bankruptcy process, with access of failure of the trustee to perform).
blocked.
Management and investment of trust 2. Law / Regulation on trust funds that • Diversification of trust accounts
The trust account may be funds regulated similarly to insurance provides for: spreads risk across multiple financial

Mobile Financial Services Risk Matrix 16 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
technically segregated, but no company loss reserves to limit risk of • Transferability of the trust to another institutions thus reducing the
rapid procedure for transferring impairment of value. trustee in case of non-performance or exposure of providers. Holding
funds held in trust to another failure of the trustee. across multiple institutions will
trustee may exist, preventing • Investment guidelines for trust funds create a bit more complexity for
access to the funds that limit risk concentrations for funds payment providers in managing
not invested in marketable or short several bank relationships.
maturity government securities. • Monitoring and enforcement of trust
• Clear segregation of trust funds account diversification should be
covering customer funds from the possible through periodic reporting.
operating funds of the account
provider.
• Periodic regulatory verification of the
adequacy of trust funds

3. No regulatory action • Deficiencies in the trust account, if

leading to the inability of an account
provider to cash out for clients,
could have systemic impact through
weakening of public confidence in
the financial system.

1.14 Pooled deposits within a Trust impaired: Trust funds Trust funds holding the value of items 1. Law / Regulation relating to bank • Requires trust law - normal in X X X X X X X X
trust account can create a deposited by the trustee in an in transit are legally segregated from failure or insolvency segregates assets common law systems but typically
funding concentration risk account with the trustee bank or the trustee's own assets in held in trust accounts from the general difficult in statute law systems.
which would not protect other banks are pooled deposits bankruptcy. pool of assets of a trustee in the • Requires a court system that both
individual customers if trust that may be significant compared Trust accounts are divisible (to bankruptcy process. understands trust law and is
is impaired. to the size of the bank, spread risk) and transferable (in case empowered to enforce it.
representing a funding of failure of the trustee to perform).
concentration risk, and may not
Trust fund investment policy to 2. Law / Regulation on trust funds that • Diversification of trust accounts
be fully protected under bank
provide liquidity for cash-out needs provides for: spreads risk across multiple financial
closing/insolvency/ deposit
and to protect against impairment of • Transferability of the trust to another institutions thus reducing the
insurance rules.
value. trustee in case of non-performance or exposure of providers. Adds
• Even if available, deposit complexity for payment providers in
failure of the trustee.
insurance is at the account managing several bank relationships.
level, and if the trust account is • Investment guidelines for trust funds
that limit risk concentrations for funds • Monitoring and enforcement of trust

Mobile Financial Services Risk Matrix 17 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
viewed as a single account, not invested in marketable or short account diversification should be
rather than many, the cap maturity government securities. possible through periodic reporting.
would be insignificant • Clear segregation of trust funds • Excessive risk concentrations in a
compared to the size of the covering customer funds from the trust fund could heighten systemic
trust account. operating funds of the account vulnerability should a loss of public
• The value of trust funds provider. confidence in the account provider
invested in other financial • Periodic regulatory verification of the result in disintermediation with
instruments or institutions may adequacy of trust funds consequent demand to liquidate
be impaired by a decline in investments by the trust.
market value of the
investments. 3. No regulatory action • Deficiencies in the trust account, if
• Significant and unusual outflows leading to the inability of an account
could present the trust with provider to cash out for clients,
liquidity difficulties if could have systemic impact through
investments cannot be weakening of public confidence in
unwound. the financial system.

1.15 Customer loses balance due If the financial services provider Prevent co-mingling of account 1. 1:1 trust account balance requirement. • Requires periodic reporting by X X X X X X
to bank/provider not or bank holding the trust fund provider company operating funds banks/providers to regulators.
maintaining a 1:1 coverage does not maintain a balance equal and customer funds in transit. • Reporting requirements Regulators
requirement in the payment to the total value of all payments The sum of the lower of cost or will need the capacity to effectively
account trust fund. in transit, the customer may not market value of trust funds in account monitor and verify reports.
be able to recover his/her funds if provider trust accounts must at least
the service were to be fully cover the value of all transfer 2. No regulatory action • Failure to ensure that items in transit
terminated. items in transit or funds stored in are fully covered by corresponding
The risk is particularly severe if mobile phone accounts that are funds held in trust could result in a
the account provider is defined as funds paid in by customers messy winding up of a failed account
experiencing operating losses or into payment accounts and not yet provider, with systemic impact on
cash flow strains due to network withdrawn. financial markets.
expansion or other operating or Subject to regulatory supervision (this
investment costs and may see is probably the dominant systemic
client funds in transit as a source risk issue).
of operating funding.

1.16 Consumers may respond to Increasing the ease with which Public awareness of the risks of over 1. Regulatory authority prohibits use of • Not implementable since money is X X X X X X
social pressures by drawing funds may be transferred to indebtedness. credit facilities for funding mobile money fungible.

Mobile Financial Services Risk Matrix 18 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
on credit lines to fund family members may increase Lender policies and procedures that accounts. • Financial institutions will reject
payments, risking over social pressures for such protect against over indebtedness. regulators limiting how credit
indebtedness. transfers, possibly leading This is a general (not cell phone facilities can be used on a situational
remitters to tap credit lines to specific) consumer protection and basis.
supplement payments. This may portfolio quality issue that should be
increase the risk of remitters already under regulatory oversight, 2. Regulatory authority may provide • Requires support from the on-site
increasing their debts to although may not be in place in many general consumer protection guidelines examination of regulated institutions’
unsustainable levels. countries. for over indebtedness, but otherwise take lending policies and procedures, as a
no action normal part of market supervision.

1.17 Customer’s family is unable If account providers have not Escheatment guidelines to mimic the 1. Regulatory authority mandates • Account opening complicated, X X X X X
to access account funds if the established escheatment guidelines for demand deposits establishing beneficial owners for stored increasing operating costs and
customer dies. guidelines for customer mobile accounts. value fund balances payable on death of potentially deterring usage.
payment accounts in case of Subject to regulatory oversight and the owner • Regulation implies enforcement
death, customer’s families will be verification of compliance. capacity and costs.
unable to access the balances and
the account will remain dormant
2. No regulation, but account providers • Account opening complicated,
on the provider’s system.
establish beneficial owners for stored increasing operating costs and
value fund balances in the event of death potentially deterring usage.
or incapacity of the owner

3. Service users protect themselves by • Could result in miss-allocation of

sharing access codes with trusted family funds by overly trusted family
member(s) member(s)

4. Institute “abandoned property” • Requires an accounting process for

regulations that transfer unclaimed funds abandoned funds and may require a
to the state after a prescribed period. process for responding to claims
received after the prescribed period.

1.18 The beneficial owner(s) of Single accounts opened in the Responsibility for any transaction 1. Law / Regulation prohibits group • The law cannot realistically prevent X X X X X X
stored value and name of a group or a member of passing through a mobile account registration for transactional accounts. informal group use of accounts –
transactional accounts (e.g., a group for shared usage. For clearly defined. individual associated with the SIM
mobile money) cannot be example an individual within a card bears responsibility for any
determined by authorities in village establishes an account to issues.
the event of illicit account be used to receive remittances • Enforcement will focus on provider

Mobile Financial Services Risk Matrix 19 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
activity when group accounts for anyone in the village, or a policy and investigation when
are used village based solidarity or small criminal activity is suspected –
group lending program jointly implies enforcement costs
opens a mobile money account,
making regular deposits with an 2. Law / Regulation limits group • Corporate restriction limits
intention to “share out” funds to registration for transactional accounts to flexibility for micro-finance group
individual group members as corporate entities; enforced by account accounts.
micro-loans. provider and or regulatory authorities • The law cannot prevent group use of
As the account is associated with accounts – individual associated with
multiple individuals, authorities the SIM bears responsibility for any
have difficulty identifying specific issues.
actor when illicit activity occurs.
• Enforcement will focus on provider
Use of shared accounts is not policy and investigation when
permitted under FATF due to criminal activity is suspected –
AML/CFT concerns, since such implies enforcement costs.
accounts effectively permit
anonymity of most of the 3. Law / Regulations permits group • Increases documentation
beneficial owners of the account. registration with designated “signatory” requirements and transaction costs,
The FATF framework generally SIM authority acknowledged by all motivating for avoidance.
requires the beneficial owner(s) members in written agreement. • Ability to identify which actor within
of an account to be known to the the group made a given transaction
financial institution so using one would require collaboration from
person to send/receive money on the “signatory”.
behalf of a community is not
permitted.
4. No regulatory action • Account providers determine group
use policy.
• SIM card holder held accountable for
transactions over the account
motivating the SIM card holder to
block illicit transactions by shared
users.
• Regulatory authority’s ability to
identify members of a group and
which member of an informal group
is the source/beneficiary of an illicit

Mobile Financial Services Risk Matrix 20 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Consumers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
transaction will depend on
collaboration by the SIM card holder
whose account was used.

1.19 Government decides to tax Governments in need of revenues Keep the marginal transaction cost to 1. Government imposes a transaction tax • Any transaction tax will reduce X X X X
transactions to raise funds may see the high transaction a minimum. volume of the system. The
increasing the marginal cost volume mobile payment system as consumers that leave the system will
of each transaction. an opportunity. If governments be the poorest, as they are the most
decide to institute a transaction price-sensitive. Thus, any
tax on mobile payment system transaction tax would be viewed by
transactions, they would raise the the public as anti-poor.
marginal cost of each transaction • A transaction tax would complicate
to consumers (as account operations and accounting for
providers would pass this cost account providers.
along), thus pricing out many of
the consumers that the system • Some funds would inevitably be
most benefits. The high adoption raised; but offset by the negative
rate of mobile payments in most societal impact of decreased usage.
communities, and the benefits for
expanding access to financial 2. Government does not impose a • Mobile payment adoption rate, and
services, are driven largely by the transaction tax. expanded access to financial services,
low cost. not inhibited by taxation.

Mobile Financial Services Risk Matrix 21 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Merchant

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
2.1 Merchants are unable to Merchants accepting mobile Merchants able to cash out as needed 1. Regulatory authority requires account • Such regulation likely unenforceable, X X X X
easily convert mobile money money may not be able to rely on for liquidity management. providers to maintain an “agent of last since cannot dictate the composition
into cash, limiting their regular, flexible, and consistent resort” within specific geographic areas of account providers’ networks or
flexibility to run their methods to exchange electronic to ensure liquidity for consumers. related contracts.
business / store. money into cash or use electronic • It is in the interest of account
money to trade with their providers to provide an efficient
suppliers. If they take in mobile agent network to ensure market
money, but their suppliers do not penetration, regulatory intervention
accept mobile money, their ability is likely unnecessary.
to restock efficiently may be
limited.
2. No regulatory action • Merchants will adopt mobile
Merchants may refuse to accept payment capabilities into their
mobile money in payment for business model when they can either
goods and services if their ability use mobile money balances with
to cash out is limited. suppliers, or when they can depend
on agents to maintain liquidity.
• It is in the interest of account
providers to ensure an efficient
agent network. Monitoring of
complaints of inadequate access
could feed into license
considerations.

2.2 Merchant could be restricted Merchants locked into exclusivity Balanced exclusivity agreements that 1. Exclusivity agreements restricted by • Allowing or not disallowing X X X X X
by a contract with an agreements may be precluded facilitate market entry economies of law or regulation to balance short term exclusivity agreements may
account provider from from offering their clients better scale yet prevent unreasonable market entry facilitation against longer encourage market entry, but then
accepting payments for or and/or less costly services from restrictions on competition. term market competition, possibly block longer term competition.
from another account other account providers. through time limitations. • Blocking all exclusivity agreements
provider. Exclusivity agreements may could discourage first mover market
provide economic justification for entry.
market entry of the first provider,
• Requires regulatory monitoring of
but then may perpetuate a
account provider agreements with
monopoly.
agents and associated regulatory
costs.

Mobile Financial Services Risk Matrix 22 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Merchant

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
2. Regulatory authority requires • Requirement of interoperability
interoperability of payment networks would lessen the inconvenience of
(through inter-provider links or switch) any exclusivity agreements with
merchants as they would still be able
to make a purchase, though a fee
may be involved.
• Requirement of interoperability
would raise the cost for new
entrants.

3. Competition agency empowered to • Requires a competition agency with

investigate non-competitive behavior the capacity to investigate and
enforce non-competitive behavior.
This is not a unique issue to mobile
financial services.
• Actions to restrict exclusivity
agreements that harm consumers
will discourage their use in mobile
financial services too.

4. No regulatory action • Exclusivity agreements are possible;

however, experience with
networked technologies (cell
phones/ATMs) suggests that the
market will move toward
interoperability without regulatory
action.

Mobile Financial Services Risk Matrix 23 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Agents

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
3.1 Agent is unable to easily Agents that voluntarily or Cash out procedures are covered in 1. Regulatory authority requires • Requirement mitigates agent liquidity X X X X X X X X X
liquidate e-money inventory involuntarily lose their agent the agency agreement. providers to facilitate agent cash-out risk in case of termination.
when the agency relationship status must be able to convert Contractual disputes between upon termination. • Requirement removes a potential
is terminated. their e-money inventory to cash account provider and agents subject barrier for entry of new agents, if
or deposit in a bank account. to court resolution. they are uncertain of the market or
the account provider.
• Enforcement may be limited to
review of agent agreement
templates.

2. Provider sets contractual agent • Provisions set expectation for agents

termination provisions with guidance upon contract initiation. (Provisions
from the regulatory authority. should enable liquidation within a
timely manner.)
• If provisions do not ensure a timely
liquidation, this may constitute a
barrier to entry for new agents.

3. No regulatory guidance • Account provider has a commercial

interest in enabling existing agents to
exit: to reduce barriers to new
agents.
• Account provider sets own
contractual obligations to liquidate
agent’s e-money inventory in a
timely manner.
• Agent may liquidate balances via
other agents.
• Lack of clear exit strategy at
termination may constitute a barrier
to entry for new agents.

3.2 Agent receives cash from Agent receives funds from a Effectively constrain diversion of 1. Require that service users receive, and • Public confidence issue - in the X X X X X X
client but fails to service user but misdirects funds know they have a right to receive, clear account provider's interest to ensure

Mobile Financial Services Risk Matrix 24 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Agents

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
provide/transfer the e-money to the agent's own benefit. This funds. confirmation that funds have been that clients are not defrauded.
situation could arise in one of received and where they have been • Police may need training on dealing
two ways: directed. This may include a paper with complaints of abuse.
The consumer could be an receipt, if the customer does not have a
phone, or if the individual is not a • Agents require protection from
existing customer without their spurious claims of non-receipt.
phone with them, so they would customer.
not receive the transaction
confirmation while with the 2. Require that service users receive, and • Public confidence issue - in the
agent. know they have a right to receive, clear account provider's interest to ensure
confirmation that funds have been that clients are not defrauded.
The consumer may not be a
received and where they have been • Police may need training on dealing
customer but requests that the
directed. This may include a paper with complaints of abuse.
agent sends money to an existing
receipt, if the customer does not have a
customer, so does not receive • Agents require protection from
phone, but would not apply to non-
independent phone confirmation spurious claims of non-receipt.
customers requesting ‘informal
of the transaction.
remittance’ service from an agent, (i.e. • Non-customers receive no more
when the service is not formally offered protection in this situation, than if
by the provider). they asked any user on the network
to provide the same service.

3. Require account providers establish a • In the account provider’s own

control environment that establishes interest to protect its network and
some dual control feature or other clients from fraud.
mitigant to fraudulent practices by agents. • Implies regulatory review of account
providers’ control policies and
procedures.

4. Raise public awareness that users • Reduces the need for potentially
should have their cell phone available to costly and unenforceable rules to
ensure receipt of transaction ensure agents are crediting the
confirmations. proper accounts.

5. No confirmation requirement • Customers requesting cash-in or

remittance service without their
phone present are at risk of losing
cash if the agent decides to misdirect

Mobile Financial Services Risk Matrix 25 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Agents

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
the money, or not process the
transaction.

3.3 Agent is robbed. Agents that hold both cash and e- Agent responsibility for cash security 1. Regulatory authority requires agents to • Insurance provides protection in X X X X X
money face a risk of robbery. The should be clearly outlined in the be insured (whether by provider or self- case of theft.
risk may be heightened if the contract with the account provider. provided) • Insurance requirement may
volume of cash/e-money required • If the payment system is e-money, constitute a barrier to entry for
follows a predictable remittance cash is owned by its bearer so cash providers and /or agents.
cycle, requiring a higher than security is the responsibility of the
normal cash on hand position. bearer agent. 2. Provider informally agrees to make the • Agents will not view theft as a
Agent may be forced to transfer • If the agent is deposit-collecting, the agent whole based on sufficient evidence barrier to entry, as they will bear the
all or part of its e-money cash in the till may be the of robbery. theft losses.
inventory to the robber or other customers’, in which case greater
party. • Creates moral hazard that may
security measures may be encourage thefts.
However, agents that are also necessary.
merchants may find that accepting 3. No account provider or regulatory • Agents bear liability for theft losses.
e-money as payment for goods action - local police matter
and services sold reduces the • Agent liability may create a barrier
need of cash on hand, and the to entry.
risk of robbery.

3.4 Agent threatened with Agent unable to perform cash out Market access issue between account 1. Account agreement or regulatory • Account agreement or regulatory X X X X X X X
individual customer demands transactions due to KYC/CDD provider and its customers, impacting requirement stipulates access requirement mitigates unreasonable
or potentially larger group policies, insufficient cash on hand the account provider's market requirements and service levels. (see 1.2, expectations.
Refer protests due to inability to to meet occasional heightened reputation. 1.7, 1.8 and 1.9)
to 1.9 • If inability to meet service levels
perform cash-out demand, and/or system/network Only becomes a regulatory issue if becomes a problem, customer’s can
transactions. outages. customers cannot reasonably retrieve take legal action. More likely,
For example, the account their funds through other agents. customers would simply switch
provider’s system may be down, Otherwise, police/public orders issue. providers.
preventing KYC/CDD and
transaction verification. 2. No regulatory action • Local police relied upon to handle
Customer may have lost ID, pin civil disorder issues.
code or phone; an updated
account provider policy may
prevent agent from resetting pin
without sufficient credentials,

Mobile Financial Services Risk Matrix 26 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Agents

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
thus excluding the cash-out
transaction.

3.5 Agent takes in cash that Counterfeiter manufactures false Responsibility for accepting 1. Regulatory authority provides • May incentivize agent to report X X X X X X
proves to be counterfeit. notes to pass through agent and counterfeit currency for transfers the mechanism for reporting, retrieval, and counterfeit activity.
to integrate into the money same as for sale of goods - with the criminal investigation of suspect • Reporting facilitates identification of
Refer supply. agent. counterfeit notes.
to issues, investigation, and
5.17 Agent training on counterfeits, and Regulatory authority sets parameters for apprehension of counterfeiters.
other illicit financial instruments, to training material for use by account
• Regulatory authority requires
be modeled on bank teller training providers with their agents.
capacity/budget to support anti-
and provided commensurate to the
counterfeiting training and
perceived risk.
enforcement.
Account provider training program
for agents subject to regulatory 2. Account providers required, as part of • Training facilitates identification of
assistance/verification. AML/CFT/Fraud training programs, to issues, investigation, and
institute and monitor agent compliance apprehension of counterfeiters.
commensurate with perceived risk. • Active program will deter use of
agents to pass counterfeit notes.

3. No regulatory response to counterfeit • Increasing circulation of counterfeit

currency in circulation. currency.
• However, agents have a vested
interest in identifying and rejecting
counterfeit notes since these would
be rejected if deposited in the
agent's bank account.

3.6 Agent pays out cash that Agent may pay out counterfeit Passing counterfeit currency, whether 1. Regulatory authorities should provide • Reporting facilitates identification of X X X X X X X
proves to be counterfeit. currency received from as cash outs to e-payments or as mechanism for reporting, retrieval, and issues, investigation, and
customers without realizing it is change on trade purchases, is a criminal investigation of suspect apprehension of counterfeiters.
Refer counterfeit. criminal issue for the police, not a counterfeit notes.
to • Regulatory authority requires
Agent may use cash-out payments regulatory issue. capacity/budget to support anti-
5.18
to distribute counterfeit However, account providers should counterfeiting training and
currency. provide agent training on enforcement.

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Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Agents

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
Agents may "get rid of" counterfeits, as for 3.4. 2. Regulatory authorities to provide an • Financial incentives can increase
counterfeit currency they realize incentive, or reward, system for reporting cooperation of agent network in
they have taken in by passing it and retrieving counterfeit currency, identifying and pursuing
on. possibly including cash payments. counterfeiters.
• Regulatory authority requires budget
to support incentive program.
• Financial rewards may encourage
agents to collaborate with
counterfeiters; however, authorities
will monitor agents more closely
that consistently turn in counterfeits
for reward.

3. Account providers required, as part of • Training facilitates identification of

AML/CFT/Fraud training programs, to counterfeit currency and deters
institute and monitor agent compliance acceptance/distribution.
commensurate with perceived risk. • Agents may recirculate counterfeit
currency if not incentivized or
required to report it.

4. Regulatory authority or account • Reward could provide the incentive

provider could reward agents for for identification and the disincentive
identifying counterfeit currency or for passing the currency along.
providing information on counterfeiters. • Agents with frequent identification
would need monitoring to ensure
they were not involved in a
counterfeit scheme.
• Cost/capacity to implement such a
scheme would need to be evaluated.

5. No regulatory oversight or training by • Increased circulation of counterfeit

account provider of agent currency.
• However, account providers and
agents have a reputational interest in

Mobile Financial Services Risk Matrix 28 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Agents

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
preventing counterfeit cash
distribution.
• Burdening account providers with
probably unenforceable counterfeit
note regulation could reduce the
incentives for market entry.

3.7 Provision of credit to agents Network models allow super Liquidity needs of account providers 1. No regulatory action • Agents and super-agents will manage X X X X
by non-bank actors. agents/master agents to extend should be balanced with consumer their own credit needs and
liquidity in the form of e-money protection for agents so that indebtedness, as any small business.
directly to agents, possibly with extension of credit does not become Note: Agent liquidity requirements or service
limited or no controls or a vicious cycle. levels may lead providers to play a more
oversight. proactive role in liquidity management, which
could result in their providing credit to super-
agents; employing super-agents and providing
them with budget for liquidity
management—see 1.9 for more on agent
liquidity issues.

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Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Account Providers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
4.1 Provider employee An insider with access to financial Account providers responsible for 2. Regulatory authority requires • Insurance will mitigate the risk of X X X X X X X X X
manipulates agent credit systems manipulates balances for their own internal security as a cost providers to providers and the financial system
allowances, agent e-money his/her own financial gain. of doing business. Not a regulatory • Obtain fraud insurance to protect against significant fraud risks.
Refer balances, or customer e- issue unless a) defalcations threaten
to against insider threats and • Legal system must have the authority
money balances for financial the financial viability of the service, to arrest and prosecute those who
7.10 gain. possibly providing a systemic impact, • Maintain 1:1 e-money reserve
requirement in trust account. committed the fraud.
and or b) service providers’ customers
7.11 are impacted, in which case the Depending on the liability loss, enlist law • Fraud insurance may not be available
regulator has a consumer protection enforcement. or may price providers out of
interest. entrance into the market

3. Providers implement institution specific • Fraud detection allows for issue

fraud detection systems identification, investigation and
prosecution.
• Variance across institutions may let
criminals target weak systems;
however, competition will allow for
innovation.

4. No required regulatory response to • Small-scale insider manipulation is

insider employee provider fraud. unlikely to have much impact
• Systemic fraud by insiders could
damage the stability of the financial
system and will significantly damage
the reputation of the mobile system.

4.2 Provider fails to adequately Agents acting on behalf of an Account provider agent selection, 1. Regulatory authority trains and licenses • Training and licensing can help to X X X X X
select, train and supervise account provider can damage the training and supervision policies and agents to ensure capacity. ensure a base capacity among agents.
agents and super agents. account provider's business procedures are acceptable to the • Regulatory ownership or training
reputation, both with the public regulator, subject to verification of licensing is high cost and requires
and with the regulator if they act compliance. capacity that the regulator is unlikely
improperly. However, this is primarily a business to have.
management issue rather than a
regulatory issue unless agent 2. Regulatory authority requires provider • Training helps to ensure greater
performance problems become to institute an AML/CFT/anti-Fraud competence among the agent
flagrant. Regulator may mandate training program which incorporates

Mobile Financial Services Risk Matrix 30 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Account Providers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
KYC/CDD as a component of sound KYC/CDD guidelines. Training, network, and thus a stronger, more
AML/CFT programs. compliance monitoring, and registration stable mobile payment system.
of agents is required by account provider. • The agent may not have sufficient
training, resources or motivation to
follow prescribed guidelines without
threat of penalty or termination of
agent relationship for non-
compliance.
• Regularity verification of training
program is low cost and requires
low capacity.

3. Provider institutes training program • Training helps to ensure greater

that certifies an agent according to competence among the agent
policies and procedures of the company network, and thus a stronger, more
for KYC/CDD; may encourage agents to stable mobile payment system.
adopt sound business practices and follow • The agent may not have sufficient
government guidelines for KYC/CDD. training, resources or motivation to
follow prescribed guidelines without
threat of penalty or termination of
agent relationship for non-
compliance.
• No regulatory oversight of training
program may allow sub-optimal
programs.

4. No required training or licensing • Agent selection entirely up to the

process for agents account provider.
• Lax screening and/or inadequate
training could result in service
quality problems.

4.3 Account provider or Depending on the division of Account providers complying with 1. Require account providers to institute • Primary responsibility for compliance X X X X X X X X
provider’s agent does not responsibilities, some AML such regulatory oversight as provided appropriate due diligence of agents to with AML requirements within the
meet required regulatory procedures could be carried out in law and regulation, including ensure compliance with AML account provider’s network rests

Mobile Financial Services Risk Matrix 31 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Account Providers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
responsibilities for AML. by agents. Agents are generally effective suspicious transaction requirements. with the account provider.
not employees of the account reporting. • Implies regulatory review of account
provider and thus are related Predictable and enforceable penalties provider’s due diligence process.
only through contractual for non-compliance sufficient to
arrangements. If roles are not motivate routine compliance. 2. Regulatory non-compliance results in • Penalties will create disincentive for
clearly stipulated and enforced, corrective action and fine. Repeated non- non-compliance.
compliance can be difficult. compliance or significant instances of • Implies that the regulatory authority
non-compliance will lead to a cease and has sufficient staffing and financial
desist order to the account provider. resources available to demonstrate
effective enforcement.

3. Provider’s agent agreement allows for • Termination threat will create a

termination for non-compliance. disincentive for agent non-
compliance.
• Despite contractual obligations of
the agents, ML/TF risks will remain if
not appropriately monitored by
account provider and enforced by
regulatory authorities.

4. No civil or criminal penalties for • Enforcement of AML problematic,

provider or provider’s agent for non- increasing risk of FATF censure.
compliance

4.4 Trust fund is inadequately The account provider fails to Trust funds are regulated and 1. Regulatory authority requires • Reporting requirements allow X X X X X X X
funded. adequately fund the trust account, supervised similar to insurance minimum1:1 reserve requirement which banks/providers to demonstrate to
possibly through reserve accounts to ensure adequate is monitored through daily/weekly regulators and consumers their
• A breakdown in the funding coverage of trust liabilities. reporting with tiered enforcement stability and soundness by meeting
process or options, including fines for non- their requirement. The frequency of
compliance. the reporting creates greater
• Intentional diversion of funds assurance, and thus lower risk.
received in transit to cover the
provider’s operating costs. • Reporting requirements will impose
a cost on banks/account providers.
A trustee’s fund investment
strategy fails to conserve the • Frequent reporting requirements
could create a capacity issue for

Mobile Financial Services Risk Matrix 32 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Account Providers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
fund’s value. regulators that do not have the staff
to review reports and monitor
compliance.

2. Regulator requires trustee to be • Bonding will diversify the exposure

bonded to cover the performance risk. of stakeholders; however, the cost
could create a barrier to entry. If
the cost is passed on to customers,
the adoption/usage rate might slow.
• Bonding costs could be covered by
the interest that the trust accounts
generate.
• Monitoring and enforcement will
focus on the acceptability of the
bonding (insurance) company and
the coverage provided.

3. Regulatory agency creates a new type • Not needed for bank account
of deposit insurance at the payment providers, since funds already on
account holder level. deposit in covered bank accounts.
• For cell-phone based account
providers with pooled trust funds,
this would substantially expand
deposit insurance beyond current
global practices and dilute the
incentive for service users to open a
formal bank account.

4. No regulatory action. • Customers may lose mobile money

balances if account provider is not
managing trust accounts
appropriately.

4.5 Agent fraud untraceable due Lax or non-existent record Agents able to document their mobile 1. Regulatory authority requires agents to • Audit trail requirements will X X X X X X X
to poor records. keeping of transactions by agents financial transactions. maintain paper records for a time period discourage fraud, but may increase
creates challenges for account (consistent with other financial records) operating expenses and may not be

Mobile Financial Services Risk Matrix 33 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Account Providers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
Refer providers trying to research fraud Account providers able to support to support account provider’s electronic complied with, particularly if fraud is
to issues. Payment transactions may police investigation of complaints of records for investigation purposes. involved.
7.2, be commingled with other fraud. • Account provider’s electronic
7.4, merchant transactions, masking Regulatory involvement only in cases records may be sufficient and more
and any irregularities in the payment of systematic failure of account reliable.
7.5 service. provider to ensure its agent network
operates within reasonable bounds. 2. Account provider operating and record • Generally in account provider’s own
keeping procedures developed, in concert interests to ensure transaction audit
with regulators, to support investigation trails.
in case of agent fraud. • Providers will determine the degree
of fraud protection on an institution
by institution basis.

3. Require account providers to institute • Primary responsibility for compliance

appropriate record keeping by f agents to with record keeping requirements
ensure verifiable audit trails. within the account provider’s
network rests with the account
provider.
• Agent records may well be provided
through transaction records within
the account provider’s system.
• Implies regulatory review of account
provider’s agent record keeping
process.

4.6 System availability not System users may be denied Account provider’s services 1. Regulatory authority mandates system • Redundancy and continuity will X X X X X X
maintained by account access to their funds if the reasonably consistently available redundancy requirements and disaster mitigate the risk of system availability
provider. account provider is unable to during normal business hours. recovery to ensure continued financial and limit the duration when a failure
Refer consistently maintain access to its system access, particularly for significant
Continuation of operating license occurs.
to 7.9 services. contingent on maintaining reasonable account providers. • Documented alternative access
and service. procedures in the event of system
7.15
failures for providers.
• Regulations that focus on achieving
the objective rather than prescribing
specific procedures will enable

Mobile Financial Services Risk Matrix 34 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Account Providers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
account providers to innovate to
provide the least cost solution.
• Implies the regulator has, or can
procure, the technical expertise to
validate account providers'
contingency plans.

2. Regulatory authorities permit off-shore • In some jurisdictions where the

data hosting and/or backup. infrastructure is weak, hosting data
records in a more developed
jurisdiction may be necessary to
ensure adequate data security and
integrity.
• Can reduce operating expenses (and
service fees) by facilitating
economies of scale.
• May require availability of fiber optic
connections to ensure adequate
band width.
• May require agreement with hosting
country regulator to verify
compliance with data safety and
security requirements.

3. Providers establish their own • Redundancy and continuity planning

redundancy requirements and disaster will mitigate the risk of failure in
recovery to ensure continued financial system availability and limit the
system access. duration when a failure occurs.
• Should be supported by documented
alternative access procedures in the
event of system failures for
providers.
• Lack of regulatory requirement will
allow each institution to define the
extent of their contingency planning,

Mobile Financial Services Risk Matrix 35 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Account Providers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
which may leave some less protected
than may be appropriate for a
payment system. However, it will
also allow individual institutions to
innovate.

4.7 Agents are consistently out Without effective cash forecasting Agents have sufficient cash on hand 1. Regulator mandates liquidity • Requirement may enhance access to X X X X X X X X
of cash. mechanisms, agents may have to support most cash-out requests. requirements for providers. (by agent or cash within a reasonable amount of
difficulty managing their cash Account providers support agents by geographic region) The provider time.
Refer needs. could be required to appoint an “agent of
to 1.9 with cash management and • Consistent shortages decrease
Cyclical or unexpected demands forecasting. last resort” to ensure customer access. confidence in a provider’s system.
may complicate cash flow
• Requirement could raise a cost
forecasting.
barrier to entry as small players may
Agents may be too far removed not have cash forecasting/cash
from a cash supply point to management capabilities.
respond quickly to an increase in
• Providers may decide to hire some
cash demands.
agents as employees, as independent
agents in high-volume areas may not
be able to maintain balances or deal
with security issues.
• Forecasting and management
capabilities are similar for ATM and
Branch cash forecasting/
management.
• Regulation implies monitoring and
enforcement capacity.

2. Providers forecast and manage liquidity • Enhances customer access to cash

of agent network to optimize service for within a reasonable amount of time,
consumers. improving public perception of
service.
• Account providers may decide to
hire some agents as employees, as
independent agents in high-volume
areas may not be able to maintain

Mobile Financial Services Risk Matrix 36 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Account Providers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
balances or deal with security issues.
• Forecasting and management
capabilities are similar for ATM and
Branch cash forecasting/
management.

3. Require account providers establish a • Account providers have a vested

contingency funding plan in case cash-out interest in minimizing cash shortages.
needs are inconsistent with liquidity • Implies regulatory review of
forecasts. contingency plans.

4. No oversight for agent liquidity • Customers may be unable to

withdraw cash from mobile money
accounts from time to time, when
agents run out of cash.
• Market forces will improve liquidity
management over time, as account
providers keep reliable agents, take
on some agent responsibilities, or
partner with other institutions as
agents of last resort.

4.8 Agent contracted to multiple When an agent contracts with Account providers to hold agents 1. Regulatory authority prohibits agents • Restricting multiple agent relations X X X X X X X
account providers (i.e. a cell more than one account provider responsible for their individual from representing multiple account may limit competition, particularly if
phone provider and a bank) with differing regulatory contractual agreements, whether providers. the first mover has locked in the
with different regulatory requirements, the agent may exclusive or not. most suitable agents.
requirements (e.g. KYC) confuse its responsibilities, meet • Agents may not achieve adequate
does not meet its the lower regulatory burden volumes to justify being a paying
responsibilities for one or between the two, or not meet agent is not able to link to multiple
more. the regulatory requirements for account providers.
either.
• Difficult and expensive to monitor.

2. Providers do not permit agents to • Helps first mover justify market

enter into contractual obligations with entry.
other account providers without prior

Mobile Financial Services Risk Matrix 37 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Account Providers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
consent. • Limits subsequent competition by
locking in the most suitable agents.
• May limit agent profitability below
breakeven point, limiting service
expansion.

3. No action is taken by regulatory • Agents may link to multiple account

authorities or account providers restrict providers.
agents to a single account provider. • Ensures competition based on
service quality.
• May reduce incentive for first mover.

4.9 Individual poses as agent to If an individual poses as an agent Consumers able to avoid fraud 1. Regulatory authority requires all • Increased public information of X X X X X X
collect deposits or payments for an account provider, they through spurious agents. account provider agents to be registered. registered agents allows consumers
from unsuspecting could accept deposits or This list of registered agents published, to protect themselves by only
customers. payments from customers and and all registered agents post evidence of frequenting registered agents.
pocket the funds. The risk is registration. • Implies regulatory capacity for agent
likely higher in remote areas registration and the public
where oversight is limited, and information campaign.
where financial literacy is lower.
• Requires that account providers
require each agent to post
registration at its place of business.
• Most susceptible consumers, those
who are financially illiterate, will be
the most difficult to reach with an
information campaign.

2. Regulatory authority requires • Account provider assumes

providers to publish a list of official agents responsibility for distributing and
on a periodic basis to limit the potential advertising list of its agents.
for fraud. • Increased public information of
official agents allows consumers to
protect themselves by only
frequenting official agents.

Mobile Financial Services Risk Matrix 38 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Account Providers

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
• Most susceptible consumers, those
who are financially illiterate, will be
the most difficult to reach with an
information campaign.

3. Rely on the significant consumer • During cash in, the agent will have to
protection built into the system through have enough e-money available to
electronic receipts and account limits to initiate the transaction and resulting
mitigate fraud. confirmation to the service user.
• Transaction limits inhibit service
users from acting as informal agents.
• Monitoring systems flag suspicious
behaviour, enabling the account
provider to shut down informal
agents.

4. No regulatory action • Public may not understand that

Account providers are not
accountable for actions of these bad
actors.
• Instances of fraud subject to normal
police investigation.

Mobile Financial Services Risk Matrix 39 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Trust Account Holding Financial Institutions

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
5.1 Liability concentration risk Trust funds of a successful Trustee banks limit the size of trust 1. Bank regulators limit risk • Concerns with managing risk
caused by an expanding trust account provider could become accounts they manage to what is concentrations as a normal part of their concentrations may restrict bank
account that may have a significant to the point of reasonably manageable for that supervisory activities - this process interest in providing trust services.
Refer material impact on the representing a funding institution. should include funds held in trust, so off-
to • Trust funds need investment
trustee institution's balance concentration risk for the trustee balance sheet unless held in deposit opportunities that provide adequate
7.12 sheet, particularly for those bank - liquidity risk - should there accounts. liquidity in case of rapid
trust funds on deposit with be a sudden reduction in the disintermediation.
the trustee bank. volume of items in transit through
the account provider's system.
This could be due to new
competition, changes in
regulation, account provider
decision to diversify its own risks,
or civil disturbances that cause a
flight to cash.

5.2 The reputation of the The financial institution which Preserve the value of the trust funds 1. Regulatory requirements govern the • Conservative investment strategies X X X X X X
financial institution which holds the trust fund for the through prudent investment investment instruments in which trust for the trust funds will preserve
holds the trust account for account provider takes on management, subject to regulatory account holding financial institutions may asset values but limit investment
the mobile financial account reputational risk. If the trust oversight (as for insurance company invest funds. income which might otherwise be
provider is damaged due to funds are invested in instruments reserves) applied to offset account provider
its mismanagement of the that do not conserve their value, The affiliation risk will be managed by costs and keep transaction fees low.
trust account. the liability coverage provided by the market. Banks should not enter
the trust assets may become into agreements with mobile financial 2. Regulators evaluate reputational risk of • Adverse selection may come into
inadequate, potentially leading to account providers with which they major trust relationships. play - those banks most qualified to
a crisis in confidence in the have concerns. act as trustees may be the most
service. reluctant to take on the risks of
doing so.

5.3 The reputation of the The financial institution which Preserve the value of the trust funds 1. Regulatory requirements govern the • Conservative investment strategies
financial institution which holds the trust fund for the through prudent investment investment instruments in which trust for the trust funds will preserve
holds the trust account for account provider takes on management, subject to regulatory account holding financial institutions may asset values but limit investment
the mobile financial account reputational risk. If the account oversight (as for insurance company invest funds. income which might otherwise be
provider is damaged due to provider is poorly managed, the reserves) applied to offset account provider
its association with an trustee’s affiliation with an The affiliation risk will be managed by costs and keep transaction fees low.

Mobile Financial Services Risk Matrix 40 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Trust Account Holding Financial Institutions

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
account provider whose institution that loses the public the market. Banks should not enter 2. Regulators evaluate reputational risk of • Adverse selection may come into
payment system is poorly trust could damage its own into agreements with mobile financial major trust relationships. play - those banks most qualified to
run. reputation. account providers with which they act as trustees may be the most
have concerns. reluctant to take on the risks of
doing so.

Mobile Financial Services Risk Matrix 41 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: Payment Systems

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
6.1 Government mandated usage Government may have invested in Limit government involvement in 1. Government ownership of the • Interoperability creates benefits to X X X X
of government owned a national payment system payment systems to a) interbank payment switch effectively requiring any consumers, as they can transfer to
payment utility to process designed not just for inter-bank settlements, and b) establishing an existing and new account provider to any other consumer regardless of
and clear all payment settlements but to reach down to enabling environment for retail connect to and use the system for its network.
transactions regardless of the retail level, and may seek to payments that encourages payment services. • If government perceives a profit
type. protect its investment by blocking competition and innovation within opportunity, rather than a public
development or use of other accepted security standards. good, monopolistic pricing of the
payment systems. This risks transaction could ensue.
blocking innovation to improve
efficiency and lower payment • There is no incentive for a new
costs. technology innovations since the
government requires all transactions
to be processed through the system

2. Mobile financial account providers • Market pricing

allowed to use whatever payment system • Incentive to innovate processing
best serves the needs of their clients. systems and reduce transaction costs
• Interoperability will be market
driven.

Mobile Financial Services Risk Matrix 42 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
7.1 Illicit financial activities If the AML/CFT requirements do Risk-based supervision and 1. Regulatory authority implements and • Point-based AML/CFT system allows X X X X X X X
enabled by weak KYC/CDD not apply to mobile financial enforcement of AML/CFT safeguards enforces a point –based (stepped based flexibility for consumers with various
requirements/enforcement. services, illicit actors could to enable authorities to focus on the on risk) AML/CFT system. forms of identification; however,
leverage the mobile network for highest priority risks. limits risk by embedding a standard
illicit means. If the party due diligence requirement industry-
providing the financial service is wide.
held to these standards, but its • Regulatory authority to
ability to comply/enforce them is implement/monitor/enforce can be
limited, the risk still remains. costly, considering that agents are
(The ability to enforce AML/CFT the implementers.
among a disparate agent
population is a critical element.)
2. Account providers elect to have • Account providers can hedge risk by
account opening conducted by employees controlling account opening process.
rather than agents, so as to maintain • Potential customers inconvenienced
stricter AML/CFT controls. as account provider has limited
footprint relative to agent network.
• Cost of building a network to
support would be costly.

3. Account providers institute institution • Point-based AML/CFT system allows

specific KYC/CDD policy for agents, flexibility for consumers with various
which should comport with sound forms of identification; while limiting
AML/CFT standards. risk by embedding a standard due
diligence requirement network-wide.
• Lack of regulatory guidelines will
lead to variance in system strength
which can allow for exploitation.
• Implies regulatory capacity to
monitor individual account provider
policies and procedures, but allows
for innovation in achieving the
objective.

4. No regulatory action for mobile on • Illicit actors leverage mobile

Mobile Financial Services Risk Matrix 43 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
AML/CFT. networks for illegitimate financial
purposes; illicit activity flourishes in
economically disadvantaged
regions/zones where provider
enforcement mechanisms are weak

7.2 Identification of illicit financial Reporting of large or suspicious Risk-based supervision and 1. Financial regulatory authority includes • Standardized reporting, in line with X X X X X X
activities hampered by transactions to appropriate enforcement of AML/CFT safeguards mobile providers in AML/CFT reporting financial institutions, mitigates
insufficient reporting authorities and/or the Financial to enable authorities to focus on the requirements to appropriate authorities potential for illicit activities and
Refer requirements. Intelligence Units (FIUs) provides highest priority risks. and/or the FIUs. Account providers file facilitates investigation.
to information on mobile financial Suspicious Transaction Reports (STR) for
4.5, • Reporting requirements impose a
transactions that exceed or are transactions meeting specified criteria. cost on the account provider, which
7.4, structured to avoid reporting
and 2. STRs for all reporting entities indicate would be reflected in usage fees.
requirements, as well as on the channel used, including mobile.
7.5 trends and patterns of unusual • Account provider may not have the
mobile financial activity. technology to identify suspicious
transactions, resulting in a dump of
all transactions on the FIU.
• FIU may not have the capacity or
budget to analyze reports for mobile
sector.

3. Account providers are not included in • Mobile financial services could be

STR reporting requirement. used to channel large quantities of
small payments in support of illicit
activities.

7.3 Illicit financial activities As agents are a critical Risk-based supervision and 1. Regulatory authority trains and licenses • Training and licensing can help to X X X X X X
facilitated by unlicensed/ component of the mobile enforcement of AML/CFT safeguards agents to ensure capacity. ensure a base capacity among agents.
unmonitored agent network. payment network, may facilitate to enable authorities to focus on the • Regulatory ownership or training
Refer fraud or criminal activity (e.g. if highest priority risks.
to 4.2 licensing is high cost and requires
they do not comply with capacity that the regulator is unlikely
AML/CFT requirements, to have.
customers could conceivably set
up accounts under false
2. Regulatory authority requires account • Training helps to ensure greater
identities).
provider to institute an AML/CFT/anti- competence among the agent

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
fraud training program which network, and thus a stronger, more
incorporates AML/CFT guidelines. stable mobile payment system.
Training, compliance monitoring of, and • Motivating agents o follow
registration of agents is required by prescribed guidelines may be
account provider. challenging.
• Implies regulatory support for and
verification of training program.

3. Provider institutes training program • Training helps to ensure greater

that certifies an agent according to competence among the agent
policies and procedures of the company network, and thus a stronger, more
for AML/CFT; may encourage agents to stable mobile payment system
adopt sound business practices and follow • Motivating agents to follow
government guidelines for AML/CFT. prescribed guidelines may be
challenging.
• No regulatory enforcement of
training program may allow sub-
optimal programs.

4. No required training or licensing • Least direct costs for account

process. providers and regulators.
• May result in indirect costs through
use of mobile financial services to
support illicit activities.

7.4 Inadequate transaction Full transaction audit trails are Regulatory framework follows 1. All service users required to maintain • Cell phone company role limited to X X X X
records impair investigation essential to investigations to international standards for financial an individual bank account through which messaging - actual transactions occur
Refer of fraud or criminal activity follow the money trail. Records records retention to mitigate risks, all transactions flow. in the bank.
to retention should permit which sets 5 years to enable • Ensures that full transaction records
4.5, reconstruction of transaction information requests from competent exist within the formal banking
7.2, details, including the identity of authorities. system.
and the transaction parties.
• Acceptable to users who already
7.5
have bank accounts, but represents a
high cost barrier to users who have

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
no need for a full banking
relationship.
• Would substantially restrict
expanding access to financial services
to the unbanked.

2. Regulator requires transaction level • Internal systems facilitate

reporting and implements internal investigation
suspicious transaction identification • Lowers account provider costs by
process. enabling a raw data dump on the
FIU, without the need for analysis.
• Implies FIU capacity to absorb and
analyze large volumes of transaction
data, essentially all of which will be
routine.

3. Regulatory authority requires the • Record retention requirements will

account provider to maintain all payment facilitate investigation.
transaction records for 5 years following • Records retention responsibilities
the completion of the transaction. may be tiered to transaction
(Should mimic financial requirements) amounts and type of services
provided (e-money issuer,
remittance services, Telco)
• Retention requirements will impose
a cost on providers, which would be
passed on to service users.
• Differs from normal cell phone call
records, which may be subject to
shorter record retention.

4. Provider sets internal policies and • Record retention requirements will

procedures for maintaining all records facilitate investigation.
obtained through the CDD process and • If the standards for retention are
transaction records (Customer Detail low, authorities may not be able to

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
Records-CDRs) for a specified period trace transactions within a payment
following the completion of the chain from one provider to another
transaction, failure of the account or reconstruct sender/receiver
provider, and/or termination of customer identities in the prosecution of
relationship. financial crimes.

5. No mandatory or implied records • Ability to reconstruct audit trail is

retention policies for mobile financial dependent on business practices for
services records retention and retrieval
capability of account providers and
others in the account provider's
network.

7.5 National regulators and/or Investigative officials are unlikely Risk based regulatory framework that 1. Establish an FIU with sufficient • Would enable the country to comply X X X X X X X
law enforcement authorities to have the human capacity to minimizes the role of the regulator resources to credibly investigate with FATF guidelines and
unable to effectively effectively regulate the network while providing an enabling suspicious transactions and initiate participation in the Egmont group.
Refer investigate fraud or criminal of providers, agents, trust environment that mitigates against prosecution of illicit activity.
to • Would extend activities already in
activity due to lack of accounts and customers risks to the customer, account Establish specialized investigative, principle required for banking and
4.5, operational support systems necessary to mitigate the known provider network and the financial
7.2, prosecutorial and judicial expertise within insurance to mobile financial
and human capacity. risks. If the regulatory system. the legal system. services.
and framework entailed
7.4 Regulatory capacity sufficient to
licensing/supervising agents, as • Has cost implications - may require a
provide a deterrent to illicit use of
well as providers and banks, the fee regime on account providers,
mobile financial services through
number of regulators required for which would be passed on to users,
heightened risk of discovery and
this activity would likely be well reducing the financial incentives to
prosecution.
beyond that on staff for the use mobile financial services.
regulatory authorities.
2. Establish a risk-based framework that • The regulatory authority can
shifts the responsibility for monitoring leverage the transactional level
compliance on behalf of the agent to the compliance efforts of the account
account provider. provider by focusing on the control
mechanisms and risk management
programs from a system level.

3. FIU established but not adequately • No direct cost incurred, but

resourced, or no FIU established. • Not in compliance with FATF

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

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Legal
# Risk Description Objective(s) Policy Options Policy Implications
guidelines, potentially risking
inclusion in the list of non-compliant
countries, leading to restrictions of
access to international financial
markets.

7.6 National regulators and/or In many country contexts, the Clearly defined centralized regulatory 1. Empower through law/regulation either • Sole authority limits confusion X X X X X X
law enforcement authorities regulatory framework for mobile authority for mobile payment the financial regulator or regarding investigative authority.
unable to effectively payment service provision has not networks. telecommunications regulator as the sole • However, different issues may
investigate fraud or criminal been established. Thus, it is Clearly defined authority to refer regulatory authority over mobile payment require different subject matter
activity due to lack of unclear whether the financial breaches of public trust or illicit system. expertise which may not be resident
authority. regulators have the authority to activities to law enforcement in the sole regulator.
oversee the payment network, or authorities for prosecution.
if it is the responsibility of the • Capacity/Budget of sole regulator
telecommunications regulators, may need to be adjusted to
or if anyone has the requisite accommodate increased
authority. responsibility.
Jurisdictional concerns may be
2. Harmonize enforcement and penalty • Harmonization process defines
exaggerated, since the service
authority framework across which regulator is responsible for
functions are distinct. For
Communications and Financial Services which tasks, mitigating risks of issues
instance, in the United States,
regulatory authorities. “falling between the cracks” or of
many grocery stores provide
access to financial services (credit overlapping or contradictory
unions, etc) but their core activities.
business is selling groceries. Their • However, emerging risks may create
financial activities are easily confusion regarding responsibility.
overseen by financial authorities • Authorities may lack capacity to
and their core business is implement across institutional silos.
overseen by state food safety
regulators. 3. No Formal System (Ad hoc – on a • Lack of defined responsibility
case-by-case basis as determined). regarding specific risks will create
confusion and uncovered areas,
creating risk for the financial sector.

7.7 Account provider may fail to Mobile financial services are a Regulators to ensure account 1. Regulatory authority, or financial • Emerging risk monitoring will help X X X X X X
institute appropriate dynamically growing market with providers monitor evolving new risks, intelligence unit (FIU), monitors emerging the providers be vigilant with regards

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
safeguards against newly new account providers, new and institute appropriate risk risk for financial sector, including mobile to emerging risk, so they can
emerging risks. services and new vulnerabilities mitigation. payment systems. develop mitigation strategies early.
developing rapidly. Ensuring that Regulators routinely disseminating • Would benefit from integration into
information on the risk factors is warnings of new risks as these are the global FIU network.
disseminated and understood, and identified.
appropriate safeguards instituted, • FIU may not have the skills / capacity
is a significant challenge. necessary to analyze risks associated
with this new channel.
• FIU may not have the budget to
cover this area.

2. Association of account providers • Emerging risk monitoring will help

monitors emerging risk for financial the account providers be vigilant
sector, including mobile payment systems. with regards to emerging risk, so
they can develop mitigation
strategies early.
• Individual account providers
generally linked to international
institutions operating in multiple
countries, allowing for cross
fertilization.
• There may be no association at the
country level - but account providers
linked to the GSM Association.

3. No oversight of emerging risks • Emerging risks may not be spotted

until the risk is has become a
significant problem.

7.8 The ability to Criminal elements can utilize the Minimum standard audit trail for 1. Regulatory authority mandates • Implies regulatory involvement in X X X X X X
track/investigate illicit lack of standard processes in SMS/USSD (Unstructured Support inclusion of accurate and meaningful data standards and oversight over
transactions is made difficult conducting transactions, Service Data) transactions to enable information with transfer or related account provider data transmission
by the number of financial particularly in commingled investigation through account message through the payment chain. and retention policies and
intermediaries (e.g. agents, accounts and instances where it is providers’ payment transaction procedures.
super agents, providers, difficult to identify the beneficial processing system consistent with
banks managing the trust owner. This risk may be international standards, with accurate 2. Regulatory authorities prohibit mobile • Would limit the complexity of

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
accounts); and as these heightened with remote and non- and meaningful information that financial services outside of the same transactions.
various actors are not face-to-face transactions, travels with each transaction. account providers or bank. • Prohibits the expansion of low cost
vertically integrated, the lack particularly in the cross-border Contracts clearly identify the mobile financial services and would
of transparency between context of some mobile financial responsibilities of each party in the inhibit service innovation and
them exacerbates the service business segments. transaction and provide clear outreach.
challenge for regulators. channels for sharing information.
3. No regulatory action • Regulatory authorities would rely on
account provider records.

7.9 Account provider suspends Temporary or permanent failure Contingency response policies and 1. Regulatory authority mandates system • Redundancy and continuity will X X X X X X X X X
operations or collapses, of a systemically important procedures to ensure continuity of redundancy requirements and disaster mitigate the risk of system availability
disrupting service. account provider could trigger operations and rapid recovery in case recovery policies and procedures to and limit the duration when a failure
Refer loss of public confidence that of failure. ensure continued public access. occurs.
to 4.6 could spread beyond the account
and • Documented alternative access
provider, causing a general crisis procedures in the event of system
7.15 of confidence among the public. failures for providers
As communication networks are
relied upon for financial services, 2. For cell phone based systems, • Implies an orderly liquidation
performance risk becomes regulator requires off-site storage of process or transfer to an alternate
concentrated in critical systems backup data in a format that would enable account provider similar to that used
whose failure for technical or an orderly liquidation of the trust for a failed financial institution.
business reasons could impact a account(s) through repayment to system
significant portion of the users.
population.
For bank based systems based on
individual bank accounts, normal bank
processes required.

3. Providers establish their own • Redundancy and continuity will

redundancy requirements and disaster mitigate the risk of loss of system
recovery to ensure continued financial availability and limit the duration
system access. when a failure occurs.
• Documented alternative access
procedures in the event of system
failures for providers.
• Lack of regulatory requirement will

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Capitalizing on the Opportunity by Ensuring Sustainability

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Hybrid Model
International

MNO Model
Operational

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Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
allow each institution to define the
extent of their contingency plans,
which will leave some less protected
than may be appropriate for the
payment system. However, it will
also allow individual institutions to
innovate.

7.10 Account provider's Generally, when a customer sets Account providers ensure sufficient 1. Regulatory authority requires account • Insurance will mitigate the risk to X X X X X X X
employee sets up accounts up a prepaid mobile payment internal controls and monitoring of providers to conduct due diligence account providers and the financial
on the system with balances account, they make a deposit of the trust balances against the amount screening on key employees and obtain system of fraud.
Refer not backed by receipt of real currency for an equivalent in transit to discourage such fraud insurance (bonding) to protect
to 4.1 • Fraud insurance may not be available
currency and funding of the balance of mobile money. defalcations and rapidly identify them against insider fraud. or be expensive.
and trust account(s). Such an act However, an employee of the should they occur.
7.11 would create a liability and account provider with access to • Bonding costs lower if the legal
Subject to regulatory oversight.
related losses for the the backend systems could set up system has the capacity to arrest,
account provider fraudulent new accounts that prosecute and convict those who
were not backed by currency. commit fraud.
The employee could then either
cash-out or spend their mobile 2. Providers implement institution specific • Account providers have a vested
money, depleting the trust funds, fraud detection systems. interest in protecting themselves
which could go unnoticed from internal fraud and in
without proper internal implementing appropriate internal
safeguards. controls.
Since e-money is backed by real • Fraud detection allows for issue
money deposited in the trust identification, investigation and
account (or the capital of the prosecution.
account provider, if deficient), • Variance across institutions may let
creation of e-money may increase criminals target weak systems;
the velocity of money, but not however, competition will allow for
the volume. innovation.

3. No required regulatory response to • Small-scale insider manipulation is

insider employee fraud. unlikely to have much impact.
• Systemic fraud by insiders could
damage the stability of the financial

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
system and will significantly damage
the reputation of the mobile system.

7.11 In economies where minutes In some economies, mobile The account provider's business 1. No regulatory action • Hopefully cell phone company "sales" X X X X X X
are exchanged like currency, minutes have been used as a model will determine the extent of that reduce the cost of airtime will
and could be cashed-out for means of exchange. Generally, an service discounts they wish to result in increased business rather
Refer currency, distributor of account provider will provide provide to their customers. Not a than losses.
to 4.1 airtime vouchers or mobile minutes as a service for a regulatory issue.
and distributor employee could specific price. However, an
7.10 increase the amount of account provider could increase
airtime on the market. the number of minutes on the
market without compensation for
various reasons, such as extra
minutes to reward customer
loyalty. The effect would be to
discount the price of the cell
phone company's service, just as
any other product discount
results in an increase in the
product or service provided
without an offsetting increase in
revenue. If the additional minutes
are cashed out at the original
price, the cell phone company is
in effect paying its clients a cash
rebate.

7.12 Increasing reliance on mobile Rather than having funds Application of prudential guidelines 1. Law/Regulation that limits the size of a • Diversification of trust accounts X X
financial services may result dispersed across the financial on risk concentrations/dependencies trust account or group of trust accounts holdings across multiple financial
in a concentration of system, or outside of the financial to account provider trust accounts. from any account provider in any one institutions reduces risk
Refer deposits in one or a few system entirely, the uptake of trustee institution to a percentage of the
Expansion of larger financial concentrations.
to 5.1 trustee financial institutions, mobile payment services will trustee's risk weighted capital.
institutions down-market as the • Spreading trust funds across multiple
leading to disintermediation concentrate payment account technology lowers transaction costs financial institutions will add
from smaller institutions and funds in the trust funds held in and service break even points. complexity for account providers,
reductions in access to only a few institutions. increasing operating costs.
finance from those The financial institutions where
• Implies regulatory oversight to

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

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Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
institutions. some of these funds would have ensure compliance.
been deposited will have fewer
resources with which to make 2. No regulatory action • Account providers hedge their risk
loans. relating to concentration of deposits
The institutions holding these based on profit motive, which may
funds could be restricted by not align with what is best for the
regulations, or their own credit market as a whole.
policy decisions, from using these
funds for lending, thus reducing
the level of loan funding available
to the economy.
This could lead to consolidation
within the financial system
resulting from those institutions
that are not able to keep up with
the technology having increasing
difficulty competing.
However, the conversion of cash
in circulation to deposits in the
trust accounts would increase the
resources of the banking system
as a whole.

7.13 Single dominant player in a A single telecom company can Fair competition among providers on 1. Regulators require interoperability of • Requirement of interoperability X X X X
closed-loop environment dominate the market in the products/services. payment networks (through inter- could raise a barrier to entry as the
abuses market power absence of adequate competition. No unreasonable barriers to the flow provider links or through a switch) technology requirements could be
Refer (predatory pricing). The first player to enter the of funds between account providers. more challenging than a simple
to market can create a monopoly, closed network. Further, the
1.12 which can potentially lead to anti- Predictable market entry for qualified
requirement could stifle innovation
competitive pricing and restricted applicants to ensure that the prospect
in a new technology through keeping
services/innovation. of competition discourages predatory
new entrants out.
pricing.
• Customers would benefit as there
National and regional payment
would be no network limitations on
systems able to transmit payments
sending mobile money.
between account providers and
• Providers would be forced to

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
between countries. compete on cost, products, and
service, rather than size of network
which could represent a first mover
advantage.
• By reducing the first mover
advantage, could discourage
potential first movers from entering
the market.

2. Competition agency empowered to • Implies a competition agency with

investigate non-competitive behavior the capacity to investigate and
enforce non-competitive behavior,
such as predatory pricing, to
counteract the incentive for
monopoly pricing, thus protecting
the consumer.
• However, may impede development
of cross network transaction
capability.

3. No regulatory action • Predatory pricing and expanded

monopoly power are possible.
However, experience with
networked technologies (cell
phones/ATMs) suggests that the
market will move toward
interoperability without regulatory
action.
• Provided that account providers are
given consistent market entry
requirements, abuse of the first
mover advantage will encourage
competition to enter the market.

7.14 Illicit actors conduct high Because of the speed of the Account providers flag and limit 1. Account providers required to flag and • Monitoring systems implemented by X X X X
volume transactions using payment process using a mobile opening multiple accounts based on block multiple accounts with similar KYC/

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
multiple accounts, bypassing system, it is possible to make similar KYC/ CDD data. CDD data. the account provider can deter most
monitoring systems before multiple transactions quickly, in a Subject to regulatory oversight. illicit activity.
regulators can step in. near real-time transaction • Implies regulatory verification of
environment. With reasonable account provider systems, policies,
preparation, large sums could be procedures and its capacity to
transferred simultaneously using comply.
multiple accounts.
2. Rely on account monitoring as • Multiple accounts of the same owner
another alternative to KYC. can be identified via pattern
identification systems that recognize
activity similarities (e.g. several
account all sending money to the
same place/agent/customer or e.g. an
unusual level of transactions from
one place to another in a given
timeframe.)
• Enables expanded access where
national ID systems may be weak.

3. No regulatory action. • Providers will institute risk

mitigation systems in line with their
perceived risk to abuse of their
system.

7.15 Financial terrorists target Financial terrorists hack into Mobile payment networks’ security 1. Regulatory authority mandates system • Redundancy and continuity will X X X X X X X X X
payment network to disrupt mobile payment network to requirements, including possible redundancy requirements and disaster mitigate the risk of impaired system
financial system. disrupt the economy. The mobile redundancy, to be commensurate recovery to ensure continued financial availability and limit the duration
Refer payment network may be with the proportionate systemic system access, particularly for significant when a failure occurs.
to 4.6 targeted, as the security is importance of the account provider. account providers.
and • Documented alternative data access
perceived as less than that of the and recovery procedures in the
7.9 financial system. event of system failures for account
Alternatively, terrorists may providers
target the data center of the
account provider to damage or 2. Providers establish their own • Redundancy and continuity will
destroy service capacity. redundancy requirements and disaster mitigate the risk of impaired system

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
recovery to ensure continued financial availability and limit the duration
system access. when a failure occurs.
• Documented alternative data access
and recovery procedures in the
event of system failures for
providers
• Lack of regulatory requirement will
allow each institution to define the
extent of its contingency plans,
which will leave some less protected
than may be appropriate for the
payment system. However, it will
also allow individual institutions to
innovate.

7.16 Account provider fails / Mobile payment account Mobile payment account providers’ 1. Incorporate winding up provisions in • Protection of payment system assets X X X X X X X X X
enters insolvency limiting providers, like other companies, insolvency procedures should mimic the Law / Regulation covering mobile and records in case of insolvency
customer access to funds may fail / enter insolvency for a those of financial institutions. financial account providers, particularly would minimize the systemic impact
and potentially destabilizing variety of reasons. However, Established process for obtaining on assuring regulatory access to of a mobile payment system failure.
financial system. unlike normal companies, their records of items in transit and transaction records and trust funds that • Assets of clients, as in customer
service provision is a component enabling rapid cash out liquidation or back items in transit. funds in transit or temporary
of the financial system and their transfer to another account provider storage, should be kept out of the
insolvency can destabilize the using the trust funds. general pool of assets available to
economy if not properly satisfy creditors. This is particularly
managed. Clear regulatory policies and
procedures to manage such events. important in countries under statute
law that does not accommodate
separation of assets into trusts.

2. Insolvency handled like any other • Financial system stability would be at

business. risk depending on the size of the
network.
• Consumer protection for payment
account holders would be a
significant issue if the insolvency
process did not protect these

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Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

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Operational

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Legal
# Risk Description Objective(s) Policy Options Policy Implications
accounts differently from the general
assets of the account provider.

7.17 Counterfeit funds accepted Agents will be targeted as an Agent training on counterfeits to be 1. Regulatory authority provides • May incentivize agent to report X X X X X X X
by an agent. entry point for counterfeiters to modeled on bank teller training and mechanism for reporting, retrieval, and counterfeit activity.
unload money into the system. provided by account providers criminal investigation of suspect • Reporting facilitates identification of
Refer Counterfeiters will perceive commensurate to the perceived risk. counterfeit notes.
to 3.5 issues, investigation, and
agents as less knowledgeable than Regulatory authority sets parameters for apprehension of counterfeiters.
bank employees, the training material for use by account
security/monitoring of agents to • Regulatory authority requires
providers with their agents.
be less than banks, and yet still capacity/budget to support anti-
have a high enough transaction counterfeiting training and
volume that they would be enforcement.
difficult to identify.
2. Account providers required, as part of • Training facilitates identification of
AML/CFT/Fraud training programs, to issues, investigation, and
institute and monitor agent compliance apprehension of counterfeiters.
commensurate with perceived risk. • Active program will deter use of
agents to pass counterfeit notes.

No regulatory response to counterfeit • Increasing circulation of counterfeit

currency in circulation. currency.

7.18 Counterfeit funds distributed Counterfeiters may try to recruit MNOs responsible for supervision of 1. Regulatory authorities should provide • Reporting facilitates identification of X X X X X X X X
by an agent. agents into their networks to agents and collaborate with law mechanism for reporting, retrieval, and issues, investigation, and
distribute counterfeit currency enforcement authorities on criminal investigation of suspect apprehension of counterfeiters.
Refer into the economy. investigation of counterfeit currency counterfeit notes.
to 3.6 • Regulatory authority requires
to enable criminal prosecution of capacity/budget to support anti-
agents. counterfeiting training and
enforcement.

2. Regulatory authorities to provide an • Financial incentives can increase

incentive, or reward, system for reporting cooperation of agent network in
and retrieving counterfeit currency, identifying and pursuing
possibly including cash payments. counterfeiters.
• Regulatory authority requires budget

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Capitalizing on the Opportunity by Ensuring Sustainability

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Hybrid Model
International

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Operational

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Legal
# Risk Description Objective(s) Policy Options Policy Implications
to support incentive program.
• Financial rewards may encourage
agents to collaborate with
counterfeiters; however, authorities
will monitor agents more closely
that consistently turn in counterfeits
for reward.

3. Account providers required, as part of • Training facilitates identification of

AML/CFT/Fraud training programs, to counterfeit currency and deters
institute and monitor agent compliance acceptance/distribution.
commensurate with perceived risk • Agents may recirculate counterfeit
currency if not incentivized or
required to report it.

4. Regulatory authority or account • Reward could provide the incentive

provider could reward agents for for identification and the disincentive
identifying counterfeit currency or for passing the currency along.
providing information on counterfeiters. • Agents with frequent identification
would need monitoring to ensure
they were not involved in a
counterfeit scheme.
• Cost/capacity to implement such a
scheme would need to be evaluated.

5. No regulatory oversight or training by • Increased circulation of counterfeit

account provider of agent currency.

7.19 Currency redenominated When a country redenominates Treat items in transit in the same was 1. Financial regulators include mobile • Implies account provider capacity to X X X X
while in transit. its currency, often after a period as deposits in the banking system are payment system in any implementation adjust the nominal value of items in
of high inflation, service users treated in case of redenomination of plans for currency redenomination and transit during a redenomination.
should be paid out in the new the currency. handle them as they do deposits in the • Regulatory requirements mandating
units, adjusted for the banking system. that capacity may send a message to
redenomination. the market that redenomination is
likely, possibly undermining

Mobile Financial Services Risk Matrix 58 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
confidence in the national currency.
• May complicate the public education
process during redenomination by
bunching the impact for people who
may be less financially sophisticated.

2. No regulatory action • An incentive is created for moving

money into or out of the mobile
payment system around
redenomination to benefit from
arbitrage opportunity - could
bankrupt the account provider and
deplete the trust funds so that only
the first to cash out could be paid.

7.20 Regulator unreasonably The extraordinary success of Enable all proven business models 1. Limit mobile financial services to bank • Restricts usage to those who have X X X X X X X
202 blocks a particular service some cell phone based systems within a predictable legal and based models requiring users to pass all reason to have a full bank account,
0 model. have raised concerns in other regulatory environment. transactions over individual bank effectively excluding the poor.
countries based on “loss of accounts • Little or no developmental impact.
control” over uncertain risks or
resistance to competition with
2. Allow both cell phone company and • Opens access to financial services to
exiting formal financial
bank based services. the poor through low cost payment
institutions.
services that do not require a full
bank account – significant
developmental impact.
• Acts as a catalyst for building
confidence in the financial system
and in using formal financial services
rather than dependence on cash.

7.21 Interest income on service The trustee will invest the trust Ensure that the benefit of income 1. Require that interest income be • Adds an additional level of X X X X
users’ trust funds is funds in interest bearing generated by the trust funds is most credited back to individual service user’s complexity to the account provider’s
improperly allocated to the instruments, such as government efficiently allocated back to the accounts, based on the average amounts service by requiring calculation of
detriment of service users. securities or interest bearing benefit of service users, based on the in transit during the period. the interest and crediting back to the
deposit or savings accounts with service users’ individual accounts,

Mobile Financial Services Risk Matrix 59 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Mobile Financial Services Risk Matrix: National Regulators

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
financial intermediaries. So either account provider's business model adding to the cost of providing the
the trustee, the account provider service.
or the service users will benefit • Complicates account reconciliation
from this interest. for service users by adding
transactions not originated by
service users.
• Could encourage service users to
leave funds “on deposit” in lieu of
opening a formal savings account,
reducing incentives to move savings
into the formal financial sector.

2. Allocate some or all of the interest • Motivates trustees to provide the

income to the trustee to cover trustee trustee services.
fees for managing the trust account. • Eliminates pass back of trustee fees
to the account provider.
• Implies monitoring by the account
provider to avoid over-charging by
the trustee.
• May motivate trustee to reach for
higher yield, higher risk investments,
implying a need for regulatory
oversight of investments.

3. Allocate some or all of the interest • Augments the revenue stream for
income to the account provider as the account provider, in principle
additional revenue. enabling lower direct service fees to
service users.
• Benefit will vary with market interest
rates.

Mobile Financial Services Risk Matrix 60 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

International Regulatory Issues

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
8.1 Heightened difficulty tracking Illicit financial activities, such as Regional harmonization of the legal 1. Regulatory authority harmonizes • Harmonization with FATF standards X X X X X X X
and prosecuting illicit cross- money laundering and the and regulatory framework for mobile mobile financial service definitions in the facilitates tracking and prosecution.
border transactions given the financing of terrorist activities, financial services, context of FATF Special • New requirement imposes a new
new cross border payment can be facilitated (and more Recommendation VII (SRVII) within their cost on stakeholders
capability with a national difficult to prevent) when cross- own AML/CFT regimes.
regulatory framework and border transactions are allowed
enforcement mechanism. where different regulatory 2. Harmonize information sharing among • In order to track illicit cross-border
systems are in place. regulatory authorities. transactions as geographic borders
Incompatible regulation can diminish in importance, the ability
prevent, or make more for law enforcement entities and
complicated, identifying suspicious regulators to work collaboratively is
transactions, investigating the critical.
transactions, as well as
prosecuting and convicting those 3. No regulatory action • Continued, or possibly, increased
involved in illicit transactions. ability of terrorist and/or criminal
This risk applies to any cross elements to leverage mobile
border payment system, not just payment network and avoid
those using mobile financial prosecution for illicit cross-border
services. financial crimes.
• However, transaction size and
volume limits mitigate this risk,
particularly versus other payment
systems that can handle larger
amounts.

8.2 Small-scale traders face a Currently, in-country and Enable traders to use mobile 1. Regulatory authorities prevent the • Regulatory authorities limit mobile X
theft risk due to their ‘cash & regional traders conduct a cash payments to settle trade transactions larger transactions needed for traders or payment system to small-scale
carry’ business. and carry business that relies on involving larger amounts than are businesses via mobile payments. personal transactions, limiting its
cash settlement of trade appropriate for personal remittances usefulness for commerce.
transactions outside of any to reduce the theft risk and bring • Risk of mobile system use for ML/TF
financial institution, with no audit these trade transactions into the is limited by the small scale of
trails and with theft risk to the financial system. transactions.
traders. Enable the use of mobile payments
• Traders continue to use cash for
for cross-border transactions.
commerce and the risk of theft and
lack of audit trails persists.

Mobile Financial Services Risk Matrix 61 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

International Regulatory Issues

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
2. Regulatory authorities to allow for a • Regulatory authorities enable traders
separate user category for traders that and businesses to use mobile
allow for larger scale transactions. payments through stepped user
categories.
• Implies higher level of KYC/CDD to
contain the risk of mobile system use
for ML/TF.
• Risk of theft reduced by access to
non-cash, mobile channel.

3. Regulatory authorities do not restrict • Regulatory authorities enable traders

transaction size. and businesses to use mobile
payments as transaction limits do
not restrict their capacity.
• Risk of mobile system use for ML/TF
increases, as large transactions
enabled without segregated from
general consumer transactions.
• Risk of theft reduced by access to
non-cash, mobile channel.

8.3 Cross-border payments Convenience and safety may Enable use of mobile financial services 1. Regulatory authorities prohibit foreign • Cross border traders limited to X X X X X X X X
through a mobile financial encourage cross-border traders in cross border trade transactions exchange conversion using mobile using cash or a currency both buyer
service could be seen as to tap into a neighboring without unreasonable foreign financial services. and seller can use.
bypassing a country’s foreign country’s mobile payment system exchange restrictions. • May encourage use of a larger
exchange restrictions. to settle trade payments. neighboring country’s currency, as
If both buyer and seller use the for cash transactions, lowering
same system, then the funds will acceptance of the domestic
remain in the country hosting the currency.
buyer’s system. The seller will
either have to buy goods or 2. Regulatory authorities specifically allow • Facilitates monitoring of foreign
services using the e-money from foreign exchange conversion using mobile exchange flows.
the system host country, or cash financial services.
out through an exchange office • Implies development of linkages
between neighboring services that

Mobile Financial Services Risk Matrix 62 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

International Regulatory Issues

Hybrid Model
International

MNO Model
Operational

Bank Model
Reputation
Systemic

Liquidity
Legal
# Risk Description Objective(s) Policy Options Policy Implications
that can use the buyer’s currency enable currency conversion.
of origin.
If a foreign exchange conversion 3. No Regulatory Action • Market for mobile financial services
facility is built into the service, across borders may be impeded by
then transactions that otherwise lack of clarity on the potential
would be settled in cash move regulatory response.
into electronic form.

Mobile Financial Services Risk Matrix 63 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Part III – Sample Transaction Flow Charts

This Part II provides twelve sample transaction flows representing the most commonly used transactions in mobile financial services. The objective is not to be
prescriptive on how these flows should be structured, since each account provider will have its own business model and its own transaction processing methodology.
Rather, the intent of these samples is to show where in the most common transaction types the risks examined in Part I are likely to occur.
The samples provided are not exhaustive, nor do they necessarily reflect every risk involved - our understanding of the nature of these services and their implications to
the regulator's risk management process is still evolving, and will continue to do so as the technology and the breadth of service offerings expands. The samples are:
1. Account Setup - MNO Model. This involves an individual with a cell phone applying through an agent for a payment account with a cell phone company that is
providing payment services, such as Safaricom's M-PESA service in Kenya.
2. Cash In - MNO Model. This transaction flow represents an individual account holder buying e-money - depositing funds into his/her cell phone company based
payment account - through the intermediary of a cell phone company agent.
3. Agent Cash In - MNO Model. Agents will typically have both sales and purchases transactions of e-money with cell phone clients, with corresponding cash
transactions. This transaction flow represents an agent depositing the net surplus cash in the cell phone company trust account against purchase (re-stocking) of
additional e-money to enable future sales to clients. The reverse transaction would be Agent Cash Out, where an agent sells back e-money to the cell phone company,
in the process receiving the cash equivalent.
4. Cash Out - MNO Model, covers the situation where an account holder has received e-money, possibly as a gift from a relative, a salary payment, or a social subsidy
payment from the government, and wishes to withdraw some or all of the funds through a cell phone company agent.
5. P2P In Network - MNO Model, shows how a payment from one cell phone account holder to another might work - for example from a family member working in a
large town sending funds back to a family member in a rural area.
6. P2P in Network - Bank Model, demonstrates an account to account payment in a bank based system, where the cell phone is serving purely as a communications
devise to transmit instructions and advices, but where the cell phone company is not involved in the execution of the underlying transaction. This example requires
that both sender and recipient have established account relations with the same banking institution.
7. P2P Out of Network - MNO Model, shows how a payment would flow from a cell phone company client to a beneficiary who is a client of a competing cell phone
company.

8. P2P Out of Network, No Account - MNO Model. In this example, an account holder of a cell phone company account provider initiates a payment to a beneficiary
who does not have his/her own account, but can cash out through a cell phone company agent based on the cash out code provided.

The following four examples illustrate possible hybrid variations on some of the main transaction types in which a cell phone company serves as the communications
vehicle, while a bank based agent network, including dedicated agents, retailers and/or branches of the bank, provide the customer interface.

Mobile Financial Services Risk Matrix 64 July 23, 2010

Account Setup – MNO Model

2
Consumer

Complete Receive
Want Account Receive
Confirmation of
Account? Application and Rejection Notice
Account
Provides ID

No
Yes
Transaction
Complete
1
Receive and 3
Yes verify New Application Receive
Available? Account and ID Enter Customer Receive Notice
Agent

Rejection Notice
Application and Verified? Application of Account
ID Advise Customer
Advise Customer
of Rejection
No
No
Yes Yes

4 5 6 Create Account
NOT on STR to
Account 7
Network AML/TF Yes Yes Advise Agent Regulatory
Acceptable?
Available?
Network

List? Authority
Advise Customer
Yes
AML/TF
Unable to No No Trigger?
Complete No Reject Account
Application Advise Agent
No No Action
Bank

Flow chart is for illustrative purposes

only – actual flows will depend on
Service Provider’s business practices.

Risk Legend
1 1.8 Agent unwilling to perform transaction for customer/Including 6 4.1/4.5/7.10/7.11 Including, service provider employee sets up accounts on the system with
4 4.6/7.9/7.15/7.16 System availability cannot be maintained by provider./Privately managed
balances not backed by receipt of currency and funding of trust account.
payment network suspends operations or collapses, disrupting service.
1.18 Beneficial owners of stored value accounts cannot be determined in the event of illicit account activity when
2
group accounts are used. 1.3 Customer’s identity is stolen and used to conduct fraudulent transactions 7 4.5/7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or
5 criminal activity.
4.2/4.3/7.1/7.3 Including, provider fails to adequately select, train, and supervise agents and super
1.1 Potential customer cannot access mobile payment services due to inability to prove his/her identity.
agents/Provider or agent failing to meet regulatory requirements/Illicit financial activities enabled by
1.6 Customer is charged unauthorized fee by agent.
weak KYC/CDD requirements/enforcement.
3 1.18 Beneficial owners of stored value accounts cannot be determined in the event of illicit account activity when
1.18 Beneficial owners of stored value accounts cannot be determined in the event of illicit account
group accounts are allowed.
activity when group accounts are used..
4.2/4.3/5.1/7.3 Including, provider fails to adequately select, train and supervise agents and superagents.

Mobile Financial Services Risk Matrix 65 July 23, 2010

Cash in – MNO Model

7 11
1 Provide
Consumer

Required
Has Receives
Buy mobile Credentials
Yes Personal Confirmation
money? and Cash
Access? of Credit
Yes
No No

Transaction
Complete
2 4 6
3 Willing to Credentials Account 9
Available? Agent 8 Is
Yes process? Verified?
Yes unavailable, Yes Yes Active? Receives
Yes
Agent

e-Money in Request ID Currency not Initiate Mobile

unable or Confirmation
Inventory? Yes and Cash Counterfeit? Money Purchase
unwilling to of Debit
No No process No No
No No

10 Yes
Debit agent’s Mobile
5 Money Account
Yes 12 STR to Regulatory
Network

Credit Consumer’s Authority

Suspicious
Network Mobile Money Account
Transaction?
Available? (subtracting Tx fee, if
No applicable)
No No Action
Advise Each

Flow chart is for illustrative purposes

Bank

only – actual flows will depend on

Service Provider’s business practices.

Risk Legend
1 5 1.11/4.6/7.9/7.15/7.16 Including, customer cannot access account due to System availability cannot be maintained 9 1.16 Customer is charged unauthorized fees by agent.
1.10 Customer cannot purchase mobile money due to lack of personal access by provider/Privately managed payment network suspends operations or collapses, disrupting services.
2 1.7 Customer cannot purchase mobile money due to lack of agent availability. 1.2 Existing customer cannot access mobile payment services due to inability to prove his/her identity. 1.18/1.19 Including, government decides to tax transactions to raise funds, increasing the cost.
6 10
1.6 Customer is charged unauthorized fee by agent. 4.1/ 4.5/7.10/7.11 Provider employee manipulates customer e-money balances for financial gain.
3 1.9/4.7 Including, customer can’t purchase mobile money due to lack of agent inventory of m-money. 4.2/4.3/7.1/5.3 Including, provider fails to adequately select, train, and supervise agents and super agents/Illicit 4.5/7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
3.3 Agent is robbed. financial activities enabled by weak KYC/CDD requirements/enforcement.
3.7 Provision of credit to agents by non-bank actors. 11 3.2 Agent receives cash from client but fails to provide/transfer the e-money
7 1.16 Consumers have the ability to fund the transaction using a credit facility which will increase their debt.
4 1.8/4.2 Including, agent unwilling to perform transaction for customer. 8 12 7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
3.5/7.17 Including, agent takes in cash that proves to be counterfeit.

Mobile Financial Services Risk Matrix 66 July 23, 2010

Agent Cash In – MNO Model
Consumer

1
Has Receive
Agent

Buy mobile Request Receive Receive

Yes Personal Confirmation
money? Mobile Money Notice of Bank Debit
Access? of Mobile
Yes Rejection Advice
Money Credit
No No

Transaction
3 Complete
2 4 Initiate Mobile 5 7
Within Money Sale
Credentials Credit Agent’s
Network Transaction Yes
Yes Verified? Yes Draw on Agent’s Mobile Money
Available? Receive Yes Account is Limits? Receive
Network

Bank Account Account

Mobile Money Active? Credit Advice
Request to Trust Debit Mobile
No No Reject Purchase Account Money Inventory
No No Request
Advise Agent
Advise Agent

6 Debit Agent’s Bank

Receive Within Account (subtracting Tx 8
Credentials
Drawing Transaction fee, if applicable) STR to Regulatory
Verified? Yes Suspicious
Flow chart is for illustrative purposes Request Yes Accounts are Limits? Yes Yes Authority
Bank

Credit Network’s Trust Transaction?

only – actual flows will depend on Active?
Account
Service Provider’s business practices.
No No Advise Both
No Reject Drawing No No Action
Advise Network

Risk Legend
1.19 Government decides to tax transactions to raise funds, increasing the cost.
7,14 Illicit actors conduct high volume transactions using multiple accounts, bypassing monitoring systems before
1 1.10 Agent cannot purchase mobile money due to lack of personal access 4 7 4.1/ 4.5/7.10/7.11 Provider employee manipulates customer e-money balances for financial gain.
regulators step in.
4.5/7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.

2 1.11/4.6/7.9/7.15/7.16 Including, agent cannot access account due to system availability. 5 3.7 Provision of credit to agents by non-bank actors. 8 7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.

7,14 Illicit actors conduct high volume transactions using multiple accounts, bypassing monitoring systems before
3 1.2 Existing agent cannot access mobile payment services due to inability to prove his/her identity. 6
regulators step in.

Mobile Financial Services Risk Matrix 67 July 23, 2010

Cash Out – MNO Model

8
Currency not Transaction
Yes
1 Counterfeit? Complete
Consumer

Have Provide
Sell Mobile
Yes Personal Required
Money?
Access? Credentials No
Receive
Confirmation
No No of Debit

Yes
2 3 4 6
Agent
Has Initiate Receives Agent
Willing to unavailable, Credentials Account
Agent

Available? Yes Sufficient Yes Yes Yes Mobile Money Confirmation Provides
Process? unable or Request ID Verified? Active?
Cash? Sale of Credit Currency
unwilling to
process
No No No No No
Yes

7
5 Debit Consumer’s Mobile Money
Yes
Network Account (subtracting fee, if 9 STR to
Available? applicable)
Network

AML/TF Regulatory
Yes
Credit Agent’s Mobile Money Trigger? Authority
Account
No
Advise Both No
No Action

Flow chart is for illustrative purposes

Bank

only – actual flows will depend on

Service Provider’s business practices.

Risk Legend
1.8 Agent unwilling to perform transaction for customer.
4 1.4 Customer’s account credentials are improperly released.
1 1.10 Customer cannot access cash from mobile money account due to lack of personal access. 2.1 Merchants unable to easily convert mobile money into cash, limiting their flexibility to run their bus. 7 1.13/1.14/1.15/1.16 Including, customer loses balance due to failure of a bank holding trust fund, or a similar situation
4.2 Provider fails to adequately train and supervise agents and super agents.
where trust fund is compromised.
2 1.7 Customer cannot access cash from mobile money account due to lack of agent availability. 1.6/1.19 Including, customer is charged unauthorized fee by agent
1.11/4.6/7.9/7.15/7.16 Including, customer cannot access account due to System availability cannot be maintained
5 4.5/7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
by provider/Privately managed payment network suspends operations or collapses, disrupting services.
1.9/4.7/5.2/5.3 Including, customer cannot access cash from mobile money account due to lack of agent 8
1.2 3.6/7.18 Agent pays out cash that proves to be counterfeit.
3 liquidity (in mobile money). 6 . Existing customer cannot access mobile payment services due to inability to prove his/her identity.
3.3/3.4 Including, agent is robbed. 1.3 Customer’s identity is stolen and used to conduct fraudulent transactions
3.7 Provision of credit to agents by non-bank actors. 4.2/4.3/7.1/7.3 Including, provider fails to adequately select, train, and supervise agents and super agents/Illicit 9 7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
financial activities enabled by weak KYC/CDD requirements/enforcement

Mobile Financial Services Risk Matrix 68 July 23, 2010

P2P – MNO Model, In Network

2
1 Sender Receives
Sender initiates “Send Confirmation of
Consumer

Have Sender receives Debit

Send Money Money” transaction using
Yes Personal Advice of Non-
to Receiver? Receiver’s phone
Access? Payment
number Recipient
Receives
No No Advice
Yes Of Credit
Yes
Agent

No

3 4 5 6 Debit Sender Account 7

Receive (inc. fee, if applicable) STR to Regulatory
Network Sender Within Sufficient Receiver Trigger
Payment Yes Yes Yes Yes Yes Authority
Available? Validated? Limits? Funds? Account? Credit Receiver Account STR?
Network

Instructions
Advise both

No No No No No
Reject Payment
Advise Sender No Action

Flow chart is for illustrative purposes

Bank

only – actual flows will depend on

Service Provider’s business practices.

Risk Legend
1 1.10 Customer can not access cash from mobile money account due to lack of personal access. 1.13 / 1.14/1.15 Including, customer loses balance due to failure of a bank holding trust fund, or a similar 6 7.14 Illicit actors conduct high volume transactions using multiple accounts, bypassing monitoring systems,
4
situation where trust fund is compromised before regulators intervene
1.16/8.2 Consumers may be pressured into drawing on credit lines to fund payments to relatives. Small-scale
2 traders face a theft risk due to their ‘cash & carry’ business4.6/7.9/7.15/7.16 Including, customer cannot
access account due to System availability cannot be maintained 5 1.4 Customer’s account security credentials are released improperly 7 7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
by provider/Privately managed payment network suspends operations or collapses, disrupting services.
4.6/7.9/7.15/7.16 Including, customer cannot access account due to system failure, system availability cannot be
3 maintained by provider, or privately managed payment network suspends operations or collapses, disrupting
services.

Mobile Financial Services Risk Matrix 69 July 23, 2010

P2P – Bank Model, In Network

2
Sender Receives
1
Confirmation of
Consumer

Have Initiate Payment Sender receives Debit

Send Money
Yes Personal Instructions to Notice of Non- Transaction
to Receiver?
Access? Beneficiary’s Bank Payment Completed
Account Beneficiary
Receives
No No
Advice
Yes Of Credit
Agent

No

Yes

Network
Forward
Available? Forward
Network

Debit and
Notice of
Forward Credit
Non-Payment
Payment Advices
Instructions

4 Debit Sender Account 7

5 6
(inc. fee, if applicable) STR to Regulatory
Receive
Sender Within Sufficient Receiver Trigger Authority
Payment Yes Yes Yes Yes Credit Beneficiary Yes
Validated? Limits? Funds? account? STR?
Instructions Account
Bank

Advise Both
Flow chart is for illustrative purposes No No No No No
only – actual flows will depend on Reject Payment
Service Provider’s business practices. Advise Sender No Action

Risk Legend
1 1.10 Customer can not access cash from mobile money account due to lack of personal access. 1.13 / 1.14/1.15/1.16 Including, customer loses balance due to failure of a bank holding trust fund, or a 6 7.14 Illicit actors conduct high volume transactions using multiple accounts, bypassing monitoring systems,
4
similar situation where trust fund is compromised before regulators intervene
4.6/7.9/7.15/7.16 Including, customer cannot access account due to System availability cannot be maintained
2
by provider/Privately managed payment network suspends operations or collapses, disrupting services. 5 1.4 Customer’s account security credentials are released improperly 7 7.2/5.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.

3 8.2 Small-scale traders face a theft risk due to their ‘cash & carry’ business.

Mobile Financial Services Risk Matrix 70 July 23, 2010

P2P – MNO Model, In Network Consumer to Out-of-Network Consumer

2 Sender receives
Transaction
1 Advice of
Completed
Consumer

Have Sender Initiates Payment

Send Money
Yes Personal “Send Money”
to Receiver? Recipient
Access? Transaction using Sender receives
Receiver’s Phone receives Credit
Yes Advice of Non-
Number Advice
Payment (uses Cash-Out to
receive funds)
Agent

Yes

3 4 5 6 Debit Sender Account 7

Recipient’s
Receive Credit Recipient
Network Sender Within Sufficient Send Payment to Network Account
Payment Yes Yes Yes Yes
Available? Validated? Limits? Funds? Clearing Bank/Switch receives Valid?
Network

Instructions Advise Recipient

Advice
Advise Sender

No No No
Reject Payment Reject Payment Return Item
No
Return Funds Process
Advise Sender

8
9
Receive Instructions STR to Regulatory
Trigger
Debit Account of Yes Authority
Flow chart is for illustrative purposes STR?
Bank

only – actual flows will depend on Sender’s Network

Service Provider’s business practices. Credit Account of
Recipient’s Network No
Advise both Networks
No Action

Risk Legend
1.12/5.13 Lack of network interoperability prevents consumers from transacting with desired party.
1 1.10 Customer cannot access cash from mobile money due to lack of personal access. 4 1.4 Customer’s account credentials are released improperly 7
7.2/5.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal
activity.
7.19 Including, currency redenominated while in transit.
7.14 Illicit actors conduct high volume transactions using multiple accounts, bypassing monitoring
2 8.2 Small-scale traders face a theft risk due to their ‘cash & carry’ business. 5
systems before regulators can step in. 1.6/1.19 Government decides to tax transactions to raise funds increasing the marginal cost.
8
7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
1.11/4.6/7.9/7.15/7.16 Including, system availability cannot be maintained by provider / privately 5.19 Currency redenominated while in transit.
3 1.13/ 1.14/1.15/1.16 Including, customer loses balance due to failure of a bank holding trust fund, or
managed payment network suspends operations or collapses, disrupting services. 6
a similar situation where trust fund is compromised. 9 7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.

Mobile Financial Services Risk Matrix 71 July 23, 2010

P2P – MNO Model, In Network Consumer to Out-of-Network Consumer – No Account

2
1 Sender Receives
Transaction
Confirmation of
Sender Initiates “Send Sender Completed
Debit
Consumer

Have
Send Money Money” Transaction Receives 8
Yes Personal
to Receiver? using Receiver’s Phone Advice of Non-
Access? Recipient Recipient Uses Payment
Number Payment
Yes Receives Code to Cash Out through
No No Payment Code Agent or Purchase Goods

Use Payment Code to

Agent

Transfer Stored Value to

own Account against Cash
and/or Sale of Goods
No
Yes

3 4 5 6 Debit Sender Account 7

9
Receive (inc. fee, if applicable) STR to Regulatory
Network Sender Within Sufficient Receiver Trigger
Payment Yes Yes Yes Yes Yes Authority
Available? Validated? Limits? Funds? Phone Valid? Establish Payment Code STR?
Network

Instructions
Advise both

No No No No No
Reject Payment
Advise Sender No Action
Bank

Flow chart is for illustrative purposes

only – actual flows will depend on
Service Provider’s business practices.

Risk Legend
1 7.14 Illicit actors conduct high volume transactions using multiple accounts, bypassing monitoring 1.7 Customer cannot access mobile money account due to lack of agent availability
1.10 Customer cannot access cash from mobile money due to lack of personal access. 5 8
systems before regulators can step in. 1.9/4.4//4.7/5.2/5.3 Customer cannot access cash from mobile money account due to lack of agent liquitdity.
3.7 Provision of credit to agents by non-bank actors
2 8.2 Small-scale traders face a theft risk due to their ‘cash & carry’ business. 1.13/ 1.14/1.15/1.16 Including, customer loses balance due to failure of a bank holding trust fund, or 3.3/3.4 Including, agent is robbed.
6
a similar situation where trust fund is compromised. 1.8/4.2 Including, agent unwilling to perform transaction for customer.
1.11/4.6/7.9/7.15/7.16 Including, customer cannot access account due to personal access issues/ 7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity. 4.2/4.3/7.1/7.3 Including, provider fails to adequately select, train, and supervise agents and super agents/Illicit financial
3 System availability cannot be maintained by provider/Privately managed payment network 7
5.19Including, currency redenominated while in transit. activities enabled by weak KYC/CDD requirements/enforcement.
suspends operations or collapses, disrupting services. 1.6/1.19 Government decides to tax transactions to raise funds increasing the marginal cost. 3.6/7.18 Agent pays out cash that proves to be counterfeit.
7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
4 1.4 Customer’s account credentials are released improperly 9 7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
7.19 Currency redenominated while in transit.

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Account Setup – Hybrid Model

2
Consumer

Complete Receive
Want Account Receive
Confirmation of
Account? Application and Rejection Notice
Account
Provides ID

No
Yes
Transaction
Complete
1
Receive and 3
Verify New Application Receive
Yes Rejection Notice Receive Notice
Available? Account and ID Enter Customer
Agent

Application and Verified? Application of Account

Advise
ID Consumer of Advise Customer
Rejection
No
No

Yes Yes

4
Network

Network
Forward Forward Forward
Available?
Application Advice Advice
Unable to
Complete
Application No

5 6
Create Account STR to
NOT 7
Account a Regulatory
On AML/TF Yes Yes Advise Agent
Acceptable? Authority
List?
Bank

Flow chart is for illustrative purposes Advise Customer Yes

only – actual flows will depend on AML/TF
Service Provider’s business practices. Trigger?
Reject Account
No No
Advise Agent
No No Action

Risk Legend
1 1.8 Agent not available or unwilling to perform transaction for customer. 6 4.1/4.5/7.10/7.11 Including, service provider employee sets up accounts on the system with
4 4.6/7.9/7.15/7.16 System availability cannot be maintained by provider./Privately managed
balances not backed by receipt of currency and funding of trust account.
payment network suspends operations or collapses, disrupting service.
1.18 Beneficial owners of stored value accounts cannot be determined in the event of illicit account activity when
2
group accounts are used. 1.3 Customer’s identity is stolen and used to conduct fraudulent transactions 7 4.5/7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or
5 criminal activity.
4.2/4.3/7.1/7.3 Including, provider fails to adequately select, train, and supervise agents and super
1.1 Potential customer cannot access mobile payment services due to inability to prove his/her identity.
3 agents/Provider or agent failing to meet regulatory requirements/Illicit financial activities enabled by
1.6 Customer is charged unauthorized fee by agent.
weak KYC/CDD requirements/enforcement.
1.18 Beneficial owners of stored value accounts cannot be determined in the event of illicit account activity when
1.18 Beneficial owners of stored value accounts cannot be determined in the event of illicit account
group accounts are allowed.
activity when group accounts are used..
4.2/4.3/5.1/7.3 Including, provider fails to adequately select, train and supervise agents and superagents.

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6 10
1 Provide
Consumer

Required
Make Has Receive Receive
Credentials
Deposit to Yes Personal Funds back Confirmation
and Cash
Account Access? from Agent of Credit
Yes
No No

Transaction
Complete
2 3 5

Willing to Credentials 8
Available? Yes Agent 7 Receive Rejection
Process? Verified?
unavailable, Receive
Agent

Request ID Yes Currency not Initiate Advise Customer

unable or Yes Confirmation
Yes and Cash Counterfeit? Deposit Unable to Complete
unwilling to of Debit
Deposit
No No process No
Return Funds
No

4
Yes
Network

Forward
Forward Forward
Network Deposit
Advice Advice
Available? Request
No

Yes
9
Debit Agent’s Deposit 11
Receive Both Agent’s Account
Deposit Accounts Yes Account Yes STR to Regulatory
Request Active? Funded? Credit Consumer’s
Bank

Flow chart is for illustrative purposes Suspicious Authority

Deposit Account
only – actual flows will depend on Transaction?
(subtracting Tx fee, if
Service Provider’s business practices. Reject applicable)
Deposit
Request Advise Each No No Action

Risk Legend
8 1.16 Customer is charged unauthorized fees by agent.
1 1.10 Customer cannot purchse mobile money due to lack of personal access 1.2 Existing customer cannot access mobile payment services due to inability to prove his/her identity.
5
1.6 Customer is charged unauthorized fee by agent.
2 1.7 Customer cannot purchase mobile money due to lack of agent’s availability. 4.2/4.3/7.1/5.3 Including, provider fails to adequately select, train, and supervise agents and super agents/ 9 1.18/1.19 Including, government decides to tax transactions to raise funds, increasing the cost.
Illicit financial activities enabled by weak KYC/CDD requirements/enforcement. 4.1/ 4.5/7.10/7.11 Provider employee manipulates customer e-money balances for financial gain.
4.5/7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
1.8/4.2 Including, agent unwilling to perform transaction for customer.
3 6
Agent may know it does not have sufficient funds on deposit or credit line with the bank 1.16 Consumers have the ability to fund the transaction using a credit facility which will increase their debt. 10 3.2 Agent receives cash from client but fails to provide/transfer the e-money
1.11/4.6/7.9/7.15/7.16 Including, customer cannot access account due to System availability
4 cannot be maintained by provider/Privately managed payment network suspends operations or 7 3.5/7.17 Including, agent takes in cash that proves to be counterfeit. 7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
11
collapses, disrupting services.

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Agent Cash In – Hybrid Model
Consumer

Receive
Bank Credit
Advice

Transaction
Complete

Customer Make up
Agent

Branch open Receive Receive

Funds to Yes Aggregate
or ATM? Notice of Confirmation
Deposit? Deposit
Discrepancy of Deposit
Yes
No No
Network

Forward Forward Forward

Advice Advice Advice

3
1 2
Debit Branch/ATM
Receive Deposit Within Account (in aggregate)
Credentials 4
Transaction Yes
Disaggregate by Verified? Yes Credit Depositor’s STR to Regulatory
Yes Accounts are Limits? Suspicious
Bank

Flow chart is for illustrative purposes Individual Depositor Accounts (subtracting Tx Yes Authority
Active? Transaction?
only – actual flows will depend on fee, if applicable)
Then for each Depositor No Generate
Service Provider’s business practices.
(Consumer): Reconciliation Advise Agent and
No No Notice Customers
No No Action
Advise Agent

Risk Legend
1 1.2 Existing agent cannot access mobile payment services due to inability to prove his/her identity. 3 1.19 Government decides to tax transactions to raise funds, increasing the cost. 4 7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
4.1/ 4.5/7.10/7.11 Provider employee manipulates customer e-money balances for financial gain.
4.5/7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
7,14 Illicit actors conduct high volume transactions using multiple accounts, bypassing
2
monitoring systems before regulators step in.

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7
Currency not Transaction
1 Yes
counterfeit? Complete
Consumer

Provide
Agent
Need Cash? Yes Required
Available?
Credentials No
Receive
Yes Confirmation
No No Of Debit

2 3 5
Has Initiate Receives Provides
Willing to Agent unable or Credentials
Agent

Sufficient Yes Yes Authorization Confirmation Currency to

Process? unwilling to Request ID Verified?
Cash? Request of Credit Consumer
process

No No No
Yes

4
Yes
Network
Available? Forward
Network

Forward
Authorization Forward
Authorization
and Credit Debit Advice
Request
Advice
No

Verify Consumer’s Account

Balance 8
Debit Consumer’s Account STR to
Flow chart is for illustrative purposes
Bank

(subtracting fee, if applicable) AML/TF Regulatory

only – actual flows will depend on Yes
Trigger? Authority
Service Provider’s business practices. Credit agent’s account and
Authorize Payment
Advise Both No No Action

Risk Legend
1 1.7 Customer cannot access cash from mobile money account due to lack of agent availability. 1.4 Customer’s account credentials are improperly released.
4 1.11/4.6/7.9/7.15/7.16 Including, customer cannot access account due to System availability cannot be maintained 6 1.13/1.14/1.15/1.16 Including, customer loses balance due to failure of a bank holding trust fund, or a similar situation
by provider/Privately managed payment network suspends operations or collapses, disrupting services.
1.9/4.4/4.7/5.2/5.3 Including, customer cannot access cash from mobile money account due to lack of where trust fund is compromised.
2 agent liquidity (in mobile money). 1.6/1.19 Including, customer is charged unauthorized fee by agent
3.3/3.4 Including, agent is robbed. 1.2 Existing customer cannot access mobile payment services due to inability to prove his/her identity. 4.5/7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
3.7 Provision of credit to agents by non-bank actors. 5 1.3 Customer’s identity is stolen and used to conduct fraudulent transactions
7 3.6/7.18 Agent pays out cash that proves to be counterfeit.
4.2/4.3/7.1/7.3
. Including, provider fails to adequately select, train, and supervise agents and super agents/Illicit
1.8 Agent unwilling to perform transaction for customer.
3 financial activities enabled by weak KYC/CDD requirements/enforcement
2.1 Merchants unable to easily convert mobile money into cash, limiting their flexibility to run their bus. 8 7.2/7.4/7.5/7.6/7.8/8.1 Including, inadequate transaction records impair investigation of fraud or criminal activity.
4.2 Provider fails to adequately train and supervise agents and super agents.

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Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Risk-based Policy Matrix – Appendix

PART III - Appendix

Part III, the appendix to the policy matrix, incorporates a policy narrative and market examples to accompany each risk. The policy narrative provides some context to
the select policy options noted. More importantly, the appendix presents market examples of how different countries are approaching these risks from a policy
perspective. These examples provide insight into the diversity of policy actions, and how policies must be shaped to the environment of a given country.

Clearly, this document is a work in progress, as policies are constantly being implemented and modified around the world. We hope this effort helps to provide insights
into the policy landscape for mobile financial services, and we welcome recommendations for additions or edits.

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Capitalizing on the Opportunity by Ensuring Sustainability

Risk-based Policy Matrix – Appendix

1.1. Risk (Consumers) Options Implications

program may be unaffordable or beyond the existing
“Potential customers cannot access mobile payment services due to inability to prove his/her identity.” infrastructure's legal, technical or political capacity to
enforce.
Description:
When initially registering for mobile financial services (MFS), the inability of the account provider or its agents 2. Financial ID system: • With no universal national ID, the financial sector must
to adequately verify the identity and personal information of applicants may block approval or access to mobile In the absence of universal ID, financial account providers rely on other forms of identity, which all customers may
payment services. (as a consortia) offer a financial ID with similar not have access to; however, they can set risk-based
characteristics as a universal ID, but only issued to tiers to ensure access.
National authorities may standardize national public identification (ID) to facilitate documentable measures to customers after meeting standard sector KYC • Coordination of various private actors in the financial
verify the customer and/or beneficial owner’s identity when conducting transactional activity or establishing requirements (e.g. a customer’s phone # and SIM could be sector could work through the bankers association
customer relationships. Financial institutions should implement risk management systems, in addition to used as basic form of identification) and/or MFI association, possibly with leadership from the
normal due diligence measures, to determine if a customer is a politically exposed person (PEP). In the Could link in with an industry ID system established for central bank.
absence of a national customer ID, national authorities may provide for alternative ID instruments to comply ensuring certainty of identity in credit bureaus, or with a
with these requirements. All ID requirements should pay special attention to money laundering (ML) and tax ID system.
terrorist financing (TF) threats that may arise from the anonymity of new or developing technologies. 3. Regulated KYC Requirements which leave • Each institution can interpret the requirements, which
implementation to institutions may allow various combinations of identification. Banks
According to the Financial Action Task Force (FATF), “the general rule is that customers should be subject to can set risk-based tiers to ensure access.
the full range of customer due diligence measures. However, there are circumstances in which it would be • Each individual bank must establish a policy that meets
reasonable for a country to allow its financial institutions to apply the extent of the customer due diligence regulatory requirement.
measures on a risk sensitive basis.”1 Since these recommendations do not elaborate the methods for • Reliance on existing forms of identification keeps cost
establishing customer identity verification, mobile financial Account Providers with low-income clients have low, but difference in policies across institutions creates
adopted a variety of regulatory approaches in different jurisdictions to insure financial inclusion. Regulatory some risk
approaches vary from those traditionally applied to branch banking clients to non-face-to-face alternatives,
4. No regulatory KYC requirements • Each institution will determine requirements for account
including biometrics. One risk to consumers could conceivably be that the very innovative ID methods
opening based on their perception of risk. Lack of
employed for financial inclusion in the absence of a national ID, or with implementation of a national ID, is that regulatory requirement should keep barriers to access
it may be used in a manner to subvert privacy of the individual by authoritarian state regimes or their low.
designees.
• Lack of requirement opens cross-organization risk for
criminal activity.
Objective:
¾ Know Your Customer (KYC)/Customer Due Diligence (CDD) guidelines to be set commensurate with
Policy Narrative:
the risk of the service.
Policy makers should consider measures to strengthen and standardize the national identification systems. This
¾ Subject to regulatory approval and verification of implementation. single policy initiative will not only improve all financial Account Providers’ ability to perform CDD/KYC as an
effective tool for financial inclusion but, concomitantly, serves as a cornerstone of AML and CFT compliance
Policy Table: measures. In lieu of national IDs, alternative instruments, such as financial IDs, should be considered and
Options Implications enumerated by appropriate State authorities. As World Bank authors aptly stately recently on this subject,
1.National ID system: • Universality removes potential for exclusion of those
“IDs cannot be linked to extensive verification procedures that increase the cost of compliance as a surrogate
desiring service. activity that belongs to the State. If the public infrastructure for IDs is not sufficiently secure, policy makers
Authorities issue universal IDs, which are used for access
to financial services
face the challenge of identifying which IDs could complement or substitute public IDs.”
• Burden on national authorities to institute universal ID

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Capitalizing on the Opportunity by Ensuring Sustainability

Risk-based Policy Matrix – Appendix

Market Examples:
• Ghana: at birth, national ID/financial ID include a 10-finger print scan, retinal scan, with data embedded in
a passport ID. Each individual is assigned a national ID card and a bank account to receive all social services
from cradle to grave. Rescanning/printing is done at age 16.
• Zambia: Universal National Registration Card (NRC) is available to all individuals at age 16 and used for
all social service programs.
• Tanzania – “Corporate”- style registration of SIM cards for Village Savings and Loan program participant
groups was verified, with group members designating an “officer” to act as the SIM disbursal authority for the
group.
• Korea: a customer must be a bank account holder and visit the bank branch in person. To establish
service, the customer must provide identification and fill in a form, including predefined details for funds
transfers. The customer receives an e-banking password and ID. The financial institution issues a letter
permitting the customer to obtain a SIM card from the TelCo; service is available only to post-paid individual
subscribers. Foreign citizens must present a valid passport. TelCos retain a copy of the letter.
• Hong Kong SAR of China: customers register their SIM card face-to-face with the mobile phone
operator in order to use mobile phone remittance services and are required to present their national ID.
This ID is equipped with security features, such as a chip with biometric information.
• Brazil: known as Procon, an active network of government entities, rather than a consumer protection
body, enforces Consumer Protection Codes in the financial sector. Additionally there is a newly created
Ombudsman of the Central Bank of Brazil, which has the power to require prompt correction for non-
compliance with the codes.2
• South Africa: non-face-to-face acquisition is permitted, but the m-FS provider must verify identity through
other means, such as via confirming customer information with a third party data base.3 A potential
complicating factor is the Regulation of Interception of Communication-Related Information Act (RICA),
which facilitates interception of information passed over electronic communications channels, such as mobile
phones for combating crime. This act would require full KYC by operators and distributors of mobile phones
to any individual to whom they provide a phone or a SIM card. Those provisions were suspended; the
proposed implementation highlights differing and conflicting regulatory approaches that may affect an individual
even within the same jurisdictions.
• India: The Reserve Bank of India allows for non face-to-face customer identification requirements, if there
is certification of all documents presented and the first payment is effected through the customer’s account
with another bank. This may create barriers for remote account opening.4

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x

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Capitalizing on the Opportunity by Ensuring Sustainability

Risk-based Policy Matrix – Appendix

1.2. Risk (Consumers): Options Implications
reduce regulatory burden for agents
“Existing customer cannot access mobile payment services due to inability to prove his/her identity.”
3. Require that funds transferred to recipients who do not • Risks unwarranted returns if agents do not want to
have established KYC credentials are returned to sender complete pay-outs for non-KYC reasons
Description:
Verifying identity and personal information to protect customers when using mobile payment services may 4. Require that account providers have acceptable • Balance protection of customers against theft of funds
block access if the customer is not able to adequately prove his/her identity. procedures in place for replacing PIN and other provider against inconvenience of denial of service for legitimate
transactions
Objective:
¾ Restrict access to mobile financial services to those who can meet the same KYC requirement as account
Policy Narrative:
opening
The primary obligation of the account provider and its agents is to ensure that a consumer's funds are
¾ Ensure that appropriate risk based service access requirements are established at account opening protected against improper diversion. KYC procedures that require that funds can only be withdrawn based
¾ Require that funds transferred to recipients who do not have established KYC credentials are returned to on proper identification of the beneficiary are intended to protect the owner of those funds, but may inhibit
sender legitimate access if the owner is subsequently unable to provide adequate identifying information. It is
¾ Require that Account Providers have acceptable procedures in place for replacing PIN and other provider important that proper KYC procedures be established when an account is opened to ensure difficulties in
ID withdrawing funds later are avoided. Laws, such as the recent Regulation of Interception of Communications
and Provision of Communication-related Information Act (RICA) in South Africa, require operators and
distributors of mobile phone or SIM card (including existing clients) to perform full KYC procedures on any
Policy Table:
person to whom they provide a mobile phone or SIM. Customers are, therefore, required to visit agents in
Options Implications person and produce personally identifying information (full name, identity number, and address), which will be
1. Restrict access to mobile financial services to those who • Requiring that agents repeat the same KYC verify by a current national identity document, identity card, temporary identity certificate, or a valid passport.
can meet the same KYC requirement as account opening requirements at the transaction level that are required at As the national ID cards and passport reliability are questionable, the risk is great that many will be excluded
account opening is not practical. It would place an not due to criminality, but lack of stipulated documentation. 5
enormous time requirement on agents, and should not
be necessary if the account opening procedure is
implemented. (This would be the equivalent of requiring Market Examples:
a photo ID check at the ATM.) • Jordan: As a member in the UN International Convention for the Suppression of the Financing of
• Regulatory authorities would not be able to effectively
Terrorism and the Arab Treaty for the Combating of Terrorism, Jordan issued an Anti Money
police such a requirement. Laundering Law (AML Law) in 2007, and in 2008, and the Central Bank of Jordan (CBJ) issued
Instruction 42 under the AML Law.
2. Ensure that appropriate risk based service access • Strict KYC requirement for agent transactions will KYC for bank-based model. Instruction 42 stipulates that banks must identify and verify customer
requirements are established at account opening create inconveniences for customers and create more identity. In order to comply, customers must present their national ID, as well as a proof of address,
bureaucracy for agents. in person to bank officials for verification in order to open an account. However, the ability to open
• Expecting agents to conduct this due diligence for an account without face-to-face verification greatly facilitates extending access to finance beyond the
transactions of existing customers, especially during busy reach of traditional bank branches. KYC can be conducted remotely by an agent faxing
times is impractical. documentation to the bank. Anecdotal evidence indicates that compliance with these KYC
• Risk-based allowances ensure customers still have some procedures does not pose an obstacle to low income population segments. The vast majority of poor
access even without full KYC; yet the limits protect people are able to provide a national ID and to give satisfactory proof of their address. Instruction 42
against fraud. (Option enables customers who have lost exempts wire transfer transactions below JD 700 (USD 980) from KYC procedures.72 However, it
their ID to maintain some access)
does not offer relaxed KYC procedures for the opening of low value accounts.
• Lower requirements for small, or low risk, transactions

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Capitalizing on the Opportunity by Ensuring Sustainability

Risk-based Policy Matrix – Appendix

KYC for nonbank-based model. It is unclear if e-money schemes would fall under the AML Law. The
AML Law stipulates that financial companies which, inter alia, provide payment and collection services,
must comply with Article 14 (compliance with KYC procedures, reporting suspicious transactions and
complying with all instructions issued by competent regulatory parties).73 Even if the operation of an
e-money scheme is interpreted to be a “payment and collection service”, the application of the law
still requires it to be provided by a financial company. Since MNOs are not considered financial
companies, the wording of the AML Law currently would not cover mobile banking. However, MNOs
are themselves required to conduct KYC procedures including verification of client identity.74 The
KYC requirement was implemented after many mobile subscriptions had already been sold, forcing
MNOs to conduct retroactive KYC procedures. In some cases, where it is impractical or otherwise
difficult to conduct a face to face verification, MNOs are permitted to obtain missing ID information
over the telephone and verify such information against the national database.
• Indonesia: The Bank of Indonesia’s Circular Letter 10/49/DASP outlines requirements for money
transfer services conducted by nonbanks, requiring that individuals and entities apply for a money
transfer license to provide not only their risk management procedures, including KYC. KYC must
include verification of both sender and recipient at the time of the funds transfer (via government
issued ID, driver’s license, or passport). Additionally, the sender and recipient must be re-verified in
the event the transfer exceeds IDR 100,000,000 (approximately USD 8,600), any suspicious
transactions are detected, and there is concern as to the veracity of sender/receiver provided
information.6
• El Salvador: Mobile banking is still in the embryonic stages and available only to those with a bank
account. Financial institutions are required to maintain both systems and policies that provide access
to both the identity and transaction profiles of their clientele. In order to open a bank account, a
customer must provide their name, date and place of birth, nationality, address, profession, and
marital status, in addition to presenting an identity card. The Banking Law, however, does not
stipulate which identity documents are acceptable.7
• Pakistan: The Branchless Banking Regulations, dated March 31, 2008, outlines a risk-based approach
to customer due diligence. Level 1 account customers must fill out and sign the account opening
application, provide a photocopy of the computerized national ID card (CNIC), and engage in a face-
to-face exchange with the designated financial institution account opening employee or undergo a
biometric fingerprint scan and a digital photo at the agent location, which is sent to the designated
financial institution. For Level 2 branchless banking accounts (top level and unrestricted) and level 3
(merchants, agents, businesses, banking agents, or third party account provider accounts), these are
subject to the full range of KYC and regulations applicable to all accounts.8

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x

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Capitalizing on the Opportunity by Ensuring Sustainability

Risk-based Policy Matrix – Appendix

1.3. Risk (Consumers): Options Implications
or FIU). • Enforcement mechanisms for reported illicit activity may
“Customer’s identity is stolen and used to open a mobile payment account fraudulently.” not exist or may be weak. Creating or enhancing such
mechanisms will require investment.
Description: 4. With adequate account opening protections, including • Consumer protections embedded in contracts will
The risk of stolen identity can have multiple ramifications, including: both policies above, providers can limit the liability of reduce barriers to adoption, and should not be terribly
fraudulent activity in account agreement costly with adequate fraud controls.
• Customer’s identity could be used to access other services
• Contract enforcement could be required to ensure
• Customer is held accountable for fraudulent transactions made in his/her name customer protection which would require an effective
court system.
• Customer is unable to access mobile services because an account using his/her name/identity has already
been established fraudulently. 5. No regulatory KYC/CDD requirements or provider- • Lack of KYC/CDD requirements open financial system
based consumer protection against fraudulent account to fraud risk, whether through ID theft or ID fraud.
Objective: opening. • Lack of protection represents a potential cost for
¾ Protect service users against results of identity theft consumers and thus a barrier to entry.
¾ Subject to regulatory approval and verification of implementation.
Policy Narrative:
Development of an identification infrastructure, either at the federal level or through private databases for
Policy Table:
financial verification purposes, should be of paramount concern to government authorities. As outlined in a
Options Implications
recent report, there are a variety of options that might be taken to ensure either linkages to existing
1. Biometric national ID, or financial ID, system with • Though biometric ID and validation reduces the databases, incentives for creation of new electronic databases for identity and AML/CFT purposes, and
biometric validation required for account opening possibility that a stolen ID could be used to fraudulently introduction of smartcard-based national ID systems which facilitate identity verification using biometric
open an account in a customer’s name, the cost of information. In the interim, duplicative efforts should not be imposed on financial institutions and system
implementing such a program can be high.
designers should be cognizant of the tradeoff between the barriers to adoption for financial institutions versus
• Different biometric options have varying cost associated the need for developing an adequate customer profile using alternative or tiered ID requirements for
with them (e.g. voice tends to be less expensive as it can AML/CFT in the absence of a national ID.9
occur over the phone, whereas fingerprinting and retinal
scans are more costly)
Market Examples:
• Biometric ID program may be beyond the technical • El Salvador: Regardless of the type of delivery channel used, bank customer data is protected by the
capacity of a regulator to implement and maintain, as the
infrastructure for capture and validation will require
bank secrecy rule. However, interviews by CGAP for a recent Branchless Banking assessment
maintenance. indicated work remained in the areas concerning the use of agents by banks and nonbanks, as well as
the protection of funds deposited into stored value instruments (prepaid cards and mobile banking).
2. Account providers provide an effective process for • Requiring a rapid block procedure to stop fraudulent Consumer protection issues regarding branchless banking regulations remained deficient.10
blocking accounts when notified of fraudulent activity. activity once recognized is a simple and pragmatic way to • General: In consideration of the three parties to a transaction: the customer, the agent’s employee
deal with stolen identity.
who operates the POS device, and the bank, each should authenticate itself before initiating any
• The procedure can be easily validated by regulators. transaction, preferably with two factors of security. Namely, these would be the personal attributes
3. Develop of best practices for enhancement of fraud • KYC mechanisms, which could include point-based of “something you own, something you know, and something you are.” The customer and the agent
detection systems. multiple ID requirement, limits potential for fraudulent might each have a personal card (embedded in their phones) in addition to a secret PIN (agent
Provider reports suspicious or fraudulent activity to account opening. employee may have only a name and password to the POS terminal – something you own). To avoid
central authorities (Central Bank/Financial Intelligence Unit • Reporting helps target systemic fraud, thus reducing risk. fraudulent POS terminals, the bank could also announce a unique secret key to its customers before
each transaction.11

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Capitalizing on the Opportunity by Ensuring Sustainability

Risk-based Policy Matrix – Appendix

• General: A new cloud-based service allows retailers to instantly set up and run their online
business, processing transactions using voice biometrics to authenticate/authorize their online and
mobile-based electronic payments. According to the voice biometrics-driven e-commerce platform is
a step-by-step process that allows retailers to quickly set up and build a fully functioning store that
will process Level 1 PCI compliant payments through its voice transact payment network. As well as
accepting payments from major credit card companies, the firm claims that retailers can also
automatically deploy its biometric payment system to process secure mobile payments. The
company’s voice biometrics service is billed as allowing consumers to set up their own voice
biometric as an authenticator for use over the phone or mobile phone.12
• General: “Unique information about the customer’s handset (IMEI) and SIM card (IMSI) may be
used as a second factor authentication mechanism. This will create confidence that the customer is
using his/her device/SIM (something they have), and their PIN (something they know). 13
• India: In 2009, the Government of India launched a new initiative in conjunction with Nandan
Nilekani, an Indian Minister of State and one of the founders of the technology firm Infosys, to deploy
a unique identification (UID) number. The UIDs will voluntarily offer Indian residents a biometric
finger print scan which could be associated with a unique ID number and further utilized for such
services as branchless banking efforts and transactions.14

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x

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1.4. Risk (Consumers): Options Implications
4. No formal regulatory requirement or provider policies • Lack of policy raises the systemic fraud risk.
Customer’s account security credentials and / or account information and transaction history are improperly for customer protection or disaster recovery plan • Ineffective response to a breach of privacy could
released (e.g., PIN biometrics, and stolen phone/subscriber identity module [SIM]).
undermine public confidence in the financial system and
Description: its regulators.
If a customer’s account credentials, account information and transaction history are not adequately protected,
the customer’s account can be illegally accessed to steal funds or to process illicit activities. Customers may
also be subject to identity theft or blackmail. Policy Narrative:
With respect to consumer data integrity and security, the challenges in the mobile ecosystem involve the
integration of both the technological and operational components under the purview of the various actors in
Objective: the financial services and telecommunications industries. “Who is responsible for data security and
¾ Account providers maintain a rapid account block process for customers if customer/MNO believes the authentication, and how does that credential or certainty get passed along the mobile payment supply chain?
account has been compromised. Who resolves the customer’s problem if a mistake is made? What consumer protection rights exist in case of
¾ Development of best practices for enhancement of fraud detection systems. error or fraud, and do those rights change depending on whether a traditional payment system is used to
¾ MNOs mitigate risk of unauthorized/ inappropriate access to customer transaction data. settle the transaction?”15 In lieu of formal regulation, voluntary provider-led controls may satisfy market
demands, particularly if associations or alliances of providers mitigate systemic fraud risks targeting sector-
¾ Subject to regulatory review and verification of implementation. specific operational weaknesses.

Policy Table: Market Examples:

Options Implications • General: According to a study by Mobey Forum, potential security measures for the mobile
1. Strong privacy legislation / regulation require institutions • Regulatory requirement reduces likelihood for improper ecosystem depend not only on the targeted market scope (niche, national, or international), but also
to institute controls to reduce the likelihood for release. Standard requirements for all institutions limit the inter-sector relations of the market actors, in particular those in the financial services and the
unauthorized release, or theft, of personal information. criminal targeting of weak institution policies. telecom sectors. According to Mobey, the two key functional roles are the hardware based security
• Burden on national authorities to institute and enforce; element (SE) issuer and the Platform manager. The Platform Manager owns the cryptographic keys
may be unaffordable or beyond the existing used to control the SE platform. The master key is generated during the chip personalization process
infrastructure's legal, technical or political capacity, or by the personalization bureau. And the mobile business ecosystem is defined by which industry
authority, to implement and enforce. players act in which roles and by the relationship between them.
• Requirement will impose a cost on providers. -“The highest international potential lies within the ecosystem scenario, where global
personalization bureaus take the role of Platform Manager”: the SE may be an embedded
2. Provider led controls instituted to mitigate the • Institutional policies reduce likelihood for improper chip or Secure Memory Card (SMC) sold through independent retailers, requiring a strong drive from
likelihood of unauthorized release or theft of customer release. Lack of standard requirements for all
information. personalization bureaus.
institutions allows for criminal targeting of institutions
with weaker policies. -“National solutions can be based on the ecosystem scenario where mobile operators
act both as SIM issuers and Platform Managers: this scenario may occur in markets where the
• Institutional programs will impose a cost on providers;
key players maintain trusted business relations, but incurs difficulties when market relationships
however, lack of a regulatory requirement allows
institutions to determine the level of mitigation. become more intertwined. MNOs are the key business drivers.
-“Niche solutions can be based on banks or other Account Providers acting as Platform
3. Providers institute a “disaster plan” to notify customers • Can result in denial of access to services, resulting in Managers: banks or other providers desiring to launch mobile independently may prefer this
impacted by breach, Plan could include procedures to hardship for funds recipients until problem resolved. scenario, but it is unlikely that they will achieve mass market penetration.16
block transactions on all impacted accounts and to issue
new credentials to customers.
• Quick action can limit operational, systemic, and • General: In writing on one of the concerns of Information and Communication Technology (ICT)
reputation risk. policy makers, David Porteous noted that “m-payments require the accepted use of electronic
signatures,” up to and potentially including biometric identifiers, to validate and authorize

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transactions. If this is not an accepted and legally recognized practice, then there is a payment
repudiation risk to both payment agents and payees. In many countries, there is no legislation
enabling e-commerce; while PINs are used as a mobile phone security feature, e-signatures are not,
creating a need to provide the same status to electronic transactions/signatures as physical
signatures.17 Such a provision was established in Part II, Section 6 of the Zambian Draft Electronic
Communications and Transactions Bill (2009): “(1) Where the signature of a person is required by
law and such law does not specify the type of signature, that requirement in relation to a data
message shall be met only if an advanced electronic signature is used. Subject to subsection (1), an
electronic signature shall not be without legal force and effect merely on the grounds that it is in
electronic form.”18
• General: Consumer protection and privacy laws should be concerned with, and customers should
be similarly apprised and consent to, the use of location based services on mobile phones (LBS).
Customers should consent to these services during the registration process for financial services
when they authorize a bank, MNO, or card issuer to identify their location as a security feature (for
instance, to red flag a transaction that is initiated outside of the scope where the customer would not
typically conduct transactions.)19
• Zambia: Voucher scratch cards used in conjunction with mobile payment programs may be
fraudulently manipulated at the agent level. There have been instances of consumers being tricked or
coerced into revealing the scratch card PIN to the agent or agency staff when the consumer is reliant
on a single mobile phone used at an agent location to obtain the payment due to lack of access. The
result is that the consumer is defrauded of all or part of the payment. Screening the agent is
important, as is consumer education regarding PIN security.20

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x x

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Risk-based Policy Matrix – Appendix

1.5. Risk (Consumers): Options Implications
“Customer is unable to efficiently dispute a transaction or account charge.” 5. No dispute resolution process • Lack of consumer protection raises cost for consumers,
thus creating a barrier to adoption.
Description: • The only incentive for resolving customer disputes will
Customers are not able to resolve disputes with a account provider and recourse to a government body or be customer retention and reputation, which will be
regulatory authority to arbitrate disputes is weak or non-existent. stronger in competitive environments, and environments
with an active business press corps.
Note: The dispute requiring resolution could be a transaction that is initiated by a customer on the
customer’s phone, as well as a transaction that an agent makes on behalf of a customer who does not have Policy Narrative:
his/her own phone. As with any banking/transaction service disputes between consumers and the account provider, between
Objective: consumers, and between consumers and merchants is inevitable. The ability to quickly resolve such disputes
in what is perceived to be an equitable manner is critical for consumer confidence and the eventual success of
¾ MNOs provide an efficient dispute resolution process. the service.
¾ Clear, published service standards to minimize the cause of disputes.
¾ Subject to regulatory review and verification of implementation. Lessons are available from existing banking, payment, and telecommunications models. As illustrated in Exhibit
x-x, the typical dispute resolution flow involves a company specific customer service mechanism, a
Policy Table: government or industry sanctioned arbitration body, and eventually, civil court mechanisms.
Options Implications
1. Regulatory oversight authority refers disputes back to • Licensing authority needs to set an "acceptable level of Government or
the account provider but verifies account provider dispute disputes" above which continuation of the account Company provided Issue not resolved
Industry sanctioned
Issue not resolved
Civil Court System
resolution process. provider's license may be put in question. contact center Arbitration

• Regulatory authority may not have capacity to handle

complaints of disputes
Consumer initiated dispute
2. Association of providers, or NGO, provides dispute • Association ownership could be perceived as biased Issue resolved Issue resolved
Issue resolved
resolution process. toward providers, but less biased than a provider run
system. An NGO focused on consumer protection
could be preferable.
In the United States, debit card issuers and everyone else that electronically transfers money to or from a
• Allowing other providers in the association (or NGOs
with other motivations) to interact with customers “bank account” is bound by a Federal law known as Regulation E (Reg E). Reg E clearly defines rules for banks
could create provider animosity that issue debit cards and, in particular, the strict processes which must be applied when a cardholder disputes
a transaction. These rules include, as examples, the length of time within which the bank must provide
• Association may not have capacity to support, or the
budget to develop, this function. “provisional credit” to the cardholder, the total length of time within which the dispute must be resolved, and
how long a transaction can be disputed after it has posted against the bank account.
3. Individual providers provide dispute resolution process • Provider management could be biased toward provider;
however, competition should enhance customer Since Reg E restricts the term “bank account” to mean demand deposit instruments such as checking
position. accounts, however, Reg E does NOT apply to credit card transactions. While credit card issuers generally use
4. Independent alternative dispute resolution (ADR) • Existence of an independent ADR function provides Reg E as a guideline for handling disputes, it is the issuer’s cardholder agreement and the issuer’s policies that
function developed to handle appeals to other processes. consumer protection against industry bias in other actually dictate how disputes are handled. The “zero liability” policy of Visa, as an example, is a business rule
processes. which all Visa card issuers must follow. That rule ensures cardholders that they will not be held liable for any

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Risk-based Policy Matrix – Appendix

fraudulent transactions, provided that such fraud is properly reported within the timeframes dictated by the Risk Type:
issuer. International Systemic Operational Reputation Liquidity Legal
MNO Bank Hybrid
Model Model Model
Stored value (aka “prepaid debit”) is a relatively new concept within the financial services industry but has x x x x x
quickly grown to be one of the single largest sources of payment transaction volume (and card issuance) in the
US and throughout much of the world. In fact, Visa estimates that the total prepaid debit opportunity (a view
of the future, not the current reality) is as much as $1 Trillion annually. Despite this, transactions performed
on prepaid debit/stored value are largely unregulated at the federal level in the US and abroad.

An added complexity is that disputes can also arise through use cases other than traditional merchant
transactions (e.g., peer to peer transfers). In all cases, platform record keeping capabilities and data retention
requirements will underpin any dispute resolution process and influence any regulatory requirements.

Market Examples:
• El Salvador: Ley de Proteccion al Consumidor is the general consumer protection law, which has
provisions for areas such as requiring banks to develop and publicize policies for products and pricing,
bankruptcy protection for deposits over the bank creditors, etc. There is a Consumers Defender,
which ensures compliance to the law, but no specialized agency or comprehensive regulatory
framework dealing with financial consumer protection and payments via electronic channels.21
• Indonesia: The Bank of Indonesia’s E-Money Circular addresses consumer protection-related
complaints regarding e-money. It specifies that issuers must provide the following information to
customers in clear and easily comprehensible Bahasa Indonesia:
a) information that e-money is not considered a deposit in the sense of the Banking Law and hence not
guaranteed by Indonesian deposit insurance,
b) E-money usage procedure, such as cash in, transfer of funds, cash withdrawal, and redemption, as well
as risks that may arise using e-money,
c) rights and obligations of a customer, which include:
¾ -validity period of e-money (expiry),
¾ -loss due to issue affecting customer, systemic failure, or other reasons,
¾ -type and size of costs charged
¾ procedure of submitting a claim in connection with e-money and estimated length of time
for processing a complaint;
¾ procedure of product use including for redeeming the entire e-money balance.”22
• U.S. and European Union: The Electronic Funds Transfer Act and Regulation E in the United
States and the Payments Directive in the EU set legal limits for consumer liability and procedures for
dispute resolution. Depending on the time frame of consumer notification to the financial institution
of an unauthorized transaction, the legal limit for the consumer’s liability may be capped at $50-$500.
In the EU, this limit is 150 Euros. In an effort to resolve disputes outside the court system, timelines
for dispute resolution are likewise established, typically based on a number of working days from
when the provider receives the consumer’s complaint.23

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1.6. Risk (Consumers): handset or the Internet, but should also be made publically available at the Agent locations at the time the
“Customer is charged unauthorized fees by agent.” service is performed. The provider should inform the consumer of the potential for any third party fees and
how to obtain further information regarding itemization of such additional fees (by type and amount).
Description:
Market Examples:
Agent may overcharge or have a side transaction that is not authorized that they impose on the consumer.
• General: Zain adopted the tiered model for its Zap service, with differences that are quite different
Customers may not understand the complexity of the contract signed, making it possible for him/her to face from Safaricom and M-PESA with its agents. Zain charges customers for both cash in and cash out.
additional fees/services without being Zain also permits agents to retain 100% of the tariff they charge the customer for each transaction.
While Zain recommends a fixed tariff for cash ins/outs and communicates the same to its customers,
Objective: they do recognize that agents will modify these and have limited recourse to restrain this practice.
¾ Account Providers use clear contracts that fully disclose all fees to be charged, tailored for various As a result, Zain agents will adjust rates depending on their availability of e-money and customer
customer situations, including different languages and illiteracy (i.e. pictogram-based contracts). demand. They will negotiate rates with different customers and customers will pay cash fees to the
¾ Service charges clearly posted at each agent's location. Disclosures reasonably comprehendible to all agent. By allowing its agents to set their own commissions, customers may view this as predatory
customer groups (i.e. major language disclosures and potentially pictograms) pricing versus transparent. 24
¾ Subject to regulatory review and verification of implementation. • Philippines: An important feature of the mobile payments implementation in the Philippine market
was the low user charges for purchase of and transfers of airtime and cash, which typically ranged
from US 2-4 cents, though cash deposits and withdrawals were higher at 19 cents or 1%. In a 2006
Policy Table: study, which included markets in Southern Africa, South Africa, and Kenya, some networks charged
Options Implications upwards of 5-10 times these values for similar transactions. The Philippine charges, as a result,
1. Regulatory authority requires full disclosure of all fees in • Full disclosure of all fees limits potential for consumer initially generated a much higher level of usage. The report did not even mention additional fees that
account agreement. exploitation by providers. might have been levied above and beyond base transaction charges. 25
• Regulators may lack the capacity/budget to monitor and • Tanzania: Vodacom gives agents a commission each time a customer whom they registered buys
enforce the requirement, especially considering the airtime using M-PESA. The commission was established to reduce resistance to M-PESA by agents
abuse is more likely to happen at the agent level than the and aggregators, who were concerned that their customers would stop buying airtime from them
corporate level. directly. If the provider reduces agent commissions or otherwise does not adequately compensate
2. Account providers required to ensure fee structure is • Account provider disclosure mitigates potential for them, they risk alienating the agents whom they rely on to deliver and promote their mobile money
posted in all service locations in a format understandable consumer exploitation, service. By allowing agents to set their own commissions for airtime and/or mobile money services,
to the broad population. (i.e. major language disclosures • Account providers may have difficulty ensuring
the operators risk the loss of transparency in pricing.26
and potentially pictograms) reasonable compliance throughout their agent network. • Kenya: Guideline on Agent Banking –CBK/PG/15: 4.5.1 Mandatory provisions to be included in the
Account providers required to discipline or expel contract between an institution and an agent x) Prohibition from charging the customer any fees. 27
consistently non-compliant agents.
3. No fee disclosure policy Risk Type:
• Account providers may not fully disclose fees, and/or
agents may violate terms of service, undermining public MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
satisfaction with the service, potentially resulting in Model Model Model
complaints to the regulator. x x x x x x

Policy Narrative:
Fees for services should be disclosed to the customer in a clear and conspicuous manner at Agent locations,
as well as posted in the major languages of the consumer groups being served and depicted pictorially. Given
the channel of the service provided, the form of disclosure could be deployed electronically via the mobile

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1.7. Risk (Consumers): Options Implications
“Customer cannot access cash from mobile money account due to lack of agent availability.” disclosure. SLAs. Customer complaints may rise.
• The reputation of the service may suffer.
Description: • Agent network will expand with market demand.
Insufficient numbers/availability of mobile money and/or bank correspondent agents in a given geography
results in consumers not being able to access cash or imposes excessive travel costs and inconvenience on Policy Narrative:
consumers. The primary service a mobile money agent provides for its customer is to perform the cash in/cash out
function. These transactions cannot be executed without adequate reserves of both cash and electronic value.
Objective: If the agent is either physically unavailable to the customer or lacks liquidity in either stock of inventory, the
¾ Providers responsible for market coverage reputation of the service necessarily suffers.
¾ No unreasonable regulatory constraints on expansion of agent networks
Market Examples:
• Africa: “Is there provision for agencies for cash withdrawal and deposits? For the foreseeable
Policy Table:
future, cash will remain the most widely used transaction medium in developing countries. It is
Options Implications
therefore necessary there be sufficient points at which bank money (i.e. in a bank account) or e-
1. Regulatory authority mandates minimal geographic • Requirement raises the cost for account providers so money (e.g. at a TelCo) can be deposited or cashed out. Traditionally, these transactions happed via
coverage as part of financial access/inclusion interests. that the service may not be profitable. Also, the a bank teller, but branches are expensive to set up and run; extending branch networks into lower
requirement raises barriers to entry for smaller players. income or less dense areas is unlikely to be a viable means of increasing access to cash…for
• Account providers may agree to collaborate in areas developing countries, ATMs are still relatively expensive, and typically require secure premises and
where population density does not justify multiple ongoing servicing. Therefore, there is a need to use existing businesses which carry cash anyway, as
service access points. bank agents or correspondents.”28
2. Regulatory authority mandates community reinvestment • Coverage would improve in rural areas • Brazil: It is not uncommon that retail agents can be employed in areas where transaction volumes
by account providers to extend agent coverage • Requirement is a cost for providers; however, it has and/or numbers may be too sparse to support a brick-and –mortar branch. If these agents are in
positive reputation benefits and could be scaled based on locations where there is little or no banking presence, then cash management may pose operational
network size. issues. Not surprisingly, agents find it both costly and time consuming to deposit excess cash at bank
branches where they frequently must travel into urban areas and risk theft of cash en route. In Brazil,
3. Regulatory authority requires disclosure of agent • Customer expectations are set at account opening. Banco Brandesco partnered with the national post office to create national coverage using post office
network coverage in service-level agreements (SLAs) • Cost of compliance is low for providers and the cost of locations as agents, creating Banco Postal.29
oversight is minimal. • Thailand: The banking infrastructure permits instantaneous intrabank transfers, so that an agent can
• Agent network will expand with market demand. buy electronic value by transferring money from its bank account to its e-money account (a
4. Regulatory authority allows account providers to transaction that is completed via the mobile handset). After this is done, the agent’s account is
• Allowing account providers to determine the type and
appoint agents at their discretion, but with registration at distribution of its agent network maximizes market immediately credited with e-money value. True Money Express enables this functionality by holding
the regulatory authority and subject to inspection as efficiency. bank accounts a more than a dozen banks throughout the country. The agent incurs a transfer fee of
deemed necessary. 1%. The agents also do not facilitate the cash out, which would require accumulating e-money from
• The registration of agents and potential to inspect them
provides the regulatory authority with a degree of customers and reselling it back to True Money Express.30
oversight. • Kenya and Tanzania: In most markets, it is unrealistic for agents to travel to an operator-owned
• Agent network will expand with market demand.
outlet or the branch of the operator’s bank partner to facilitate instantaneous transfers or purchase
electronic value. In these cases, operators appoint intermediaries that act like wholesalers in other
5. Treat as internal account provider issue - no regulatory • Customer expectations may not be reasonable due to distribution systems and earn lower commissions than regular agents since they deal in bulk. For a
oversight of extent of agent network or required lack of transparency regarding network coverage and fee, these “superagents” agree to buy and sell electronic value in exchange for cash. Safricom signed

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agreements with several banks in Kenya to perform this role. While banks commonly play this role,
figures called “masteragents” who act as aggregators and manage liquidity may also buy value from the
super agent and then resell it to agents under his umbrella. Vodacom in Tanzania issued its master
agents toll-free mobile numbers to communicate their liquidity needs without concern as to airtime
costs incurred.31

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x

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1.8. Risk (Consumers): agents may be disincentivized to perform small value transactions depending on their incentive and their
“Agent unwilling to perform transaction for customer.” liquidity at any given time.32 It may be difficult in some instances, for example, to discern whether denial of
service to minority groups who may have difficulties in obtaining a national ID card due to the registration
Description: process is a result of discrimination, lack of proper ID, or both. Registration for citizenship may be dependent
on birth, decent, registration, or naturalization; registration and birth typically determined by the birth
The agent may be unwilling to perform a large transaction because it is more profitable to the agent to
certificate. Decent may prove more difficult in some countries; women may not be allowed to pass nationality
perform multiple small transactions. Agent is unwilling to serve customer due to discrimination (race, tribe,
to their children or the homeless child may be “stateless.”33
religion, sex, etc).
Agent may wish to conserve cash by restricting large transactions to more profitably service a larger number Market Examples:
of smaller transactionsAgent is instructed by super agent not to perform transactions during specific hours of • Uganda and Cambodia: Paying full-time customer registration agents on commission is possible,
the day due to cash pickup and deposit burdens. though it is important to pay a sustainable wage, given both their skills sets and economic conditions.
If this does not occur, customer churn wipes out the investment the operator makes in the agent
Objective: training.34
¾ Adoption of payment services best practices including optimization of agent and super-agent compensation • Zambia: According to a GSMA report, the most common alternative to paying commissions based
models for cash distribution, cash pick up, and deposits. on tiers is to pay agents the same percentage of value transacted regardless of the size of the
¾ Standards for agents barring discriminatory practices, with regulatory review and verification of transaction. This eliminates the incentive to split transaction into multiple, small value transactions
compliance. for a higher commission, and can be supplemented by minimum cash in and cash out, ensuring that
agents are incentivized even for low value transactions.35 In fact, two agent locations visited were
Policy Table: observed to structure the lowest transaction tier for mobile money transfers with the highest fees
and, when approached regarding transfers, indicated that no e-money was available.36
Options Implications
1. Regulatory authority establishes anti-discriminatory • Motivates account providers to encourage agents to Risk Type:
policies with verification of compliance. serve the “customer in front of them” MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
• Regulatory authority may lack capacity and/or authority Model Model Model
for consumer protection oversight; Discrimination x x x x x x
complaints are the task of other agencies
2. Account providers set institutional anti-discrimination • Institutional policies mitigate discrimination likelihood by
policies and monitor agent behavior/compliance setting up a disincentive for agents.
• Providers may be more reactive in preventing
discrimination if there is no regulatory cost.
• Providers may lack the capacity, to monitor and enforce
policy.
3. No regulatory requirement or provider policies • Relies on existing general anti-discrimination statutes
requiring agents to complete transactions and practices.

Policy Narrative:
In adopting best practices for agent compensation, it is critical to structure commissions to avoid instances
where either the consumer or agent may abuse systemic loopholes. For instance, if commission structures
are set to reward agents by maximizing their incentives for transaction volumes, they may structure a single
customer deposit or withdrawal into multiple transactions to maximize commissions. On the other hand,

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1.9 Risk (Consumer): conduct cash-in/cash-out transactions. Consequently, maintaining a viable agent infrastructure is an important
“Customer cannot access cash from mobile money account due to lack of agent liquidity.” element of a strong MFS system.

To date, MFS providers have used commercial practices (e.g., commission structures, agent vetting processes,
Description: prepaid e-money reserves) to drive the proliferation of cash in/cash out agents. Market forces have
Customer cannot perform cash-out transaction because the agent does not have sufficient cash on hand to determined which agents remain viable. MFS providers generally have not developed service level agreements
perform the transaction. (SLAs) with agents requiring them to maintain cash balances.
Agent may be experiencing unusually high cash-out requests due to special events, including public events,
public disturbances, or loss of public confidence. Recent MFS conferences (e.g., M-Banking 2009, Kenya School of Monetary Studies, May 2009) have raised the
issue of an unregulated, ad hoc, cash in/cash out infrastructure and the impact this has had on consumer
Super agents providing physical cash distribution to individual agents are not able to manage cash stocks confidence. While the issue is viewed as significant, most experts agree that a regulatory solution would be
effectively. difficult to craft and implement. The current view is that consumer demand and market forces will dictate the
Objective: number of agents and the operating principles that govern agent conduct (e.g., availability of cash, hours of
operation, etc.) Further, similar to branch and ATM channels, the market will provide cash forecasting
¾ Account providers are responsible to customers for providing cash-out services in a timely manner,
solutions to minimize liquidity issues.
including contingency plans to deal with liquidity crises,
¾ Subject to regulatory review and verification of implementation. Market Examples:
• El Salvador: Under Article 1 of the Banking Law, deposit-taking, financial intermediation, and
Policy Table: “other activities carried out by banks”, permit the Central Reserve Bank (BCR) to authorize other
Options Implications operations and services. Banks are subject to regulation ranging from prudential to management and
1. Monitor complaints of unavailability of cash - factor the • Forecasting and management capabilities are similar for ownership rules, with licensing by the Superintendence of the Financial System (SupFin). However, a
level of instances into license extension ATM and Branch cash forecasting/ management. different framework governs member-based financial institutions, most of which were not subject to
discussions/decisions. • Only a regulatory issue if account provider performance supervision by SupFin. This financial sector, comprised of savings and loan societies and cooperative
egregious - impact on license extension. associations, recently pushed for a new law allowing deposit-taking from the general public. While
there is no specific regulation on the issuance of e-money by non-banks, the activity by this sector is
• Account providers face a reputation risk if they cannot
manage liquidity well. defined as taking deposits and intermediating those deposits. According to a recent CGAP
Branchless Banking Assessment, it is widely assumed that Salvadoran regulators would strictly apply
2. Account providers forecast and manage liquidity of agent • Requirement ensures customers access to cash within a this definition to e-money schemes and deem such activity to be banking activity, particularly if funds
network to optimize service for consumers. reasonable amount of time. are to be intermediated. 37
• Forecasting and management capabilities are similar for • India: Acknowledging the development of the mobile channel, The Reserve Bank of India (RBI)
ATM and Branch cash forecasting/ management. issued the Operative Guidelines for Mobile Banking Transactions (2008) pursuant to the Payment and
• Market forces will improve liquidity management Settlement Systems Act (2007). Only banks licensed, supervised and with a physical presence in India
overtime, as providers keep reliable agents; providers may offer mobile banking to their existing customers. These institutions must obtain prior approval
take on some agent responsibilities, or providers’ of RBI before launching their service offering. MNOs and nonbank financial institutions may not offer
partner with other institutions, as agents of last resort. mobile banking services. Cross-border and foreign remittances are not permitted. Daily transaction
limits are set at Rs 5,000 for transfers and Rs 10,000 for goods and services purchases. Two factor
Policy Narrative: authentication, including a PIN is required on all transactions, with a limit of Rs 50,000.38
This risk refers to the amount of capital (both cash and e-money) held by agents, available for cash in/cash out • Kenya: A recent study on the community level effects of M-PESA on local economic activity
transactions. In many mobile financial services systems, agents are the primary human interface with the indicated that money circulation was the most highly ranked of all effects. It was consistently
consumer. Initial consumer confidence in a MFS system is, to a large degree, contingent on their ability to identified by respondents (being ranked most important by men and no. 3 by women) as infusing cash
into the community via remittances where they appeared to be needed most. The higher and faster

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circulation, in turn, contributed to expansion of businesses, food security, human capital
accumulation, and rescue money (emergency funds), as well as increased employment
opportunities.39

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x

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1.10 Risk (Consumers): Market Examples:
“Customer cannot access cash from mobile money account due to lack of personal access.” • Philippines: “Circular No. 649, Series of 2009, Section 4. Provisions for All EMIs (Electronic Money
Issuers). G. EMIs shall disclose in writing and its customers shall signify agreement to the information
Description: embodied in item C above upon their participation in the e-money system [note: Section C, in part,
states that “E-money may only be redeemed at face value” and “…is not considered a deposit hence
Customer cannot receive cash from agent or perform cash-out transaction during regular “business hours”
it is not insured with the Philippine Deposit Insurance Corporation.”]. In addition, it shall provide
due to one of the following situations:
clear guidance in English and Filipino on consumer’s right of redemption, including conditions and fees
• Customer has exhausted his/her pre-paid minutes. for redemption, if any. Information on available redress procedures for complaints together with the
• Customer’s cell phone battery is dead. address and contact information of the issuer shall also be provided.” 40
• Customer has lost his/her cell phone.
Risk Type:
MNO Bank Hybrid
Objective: International Systemic Operational Reputation Liquidity Legal
Model Model Model
¾ Customer’s responsibilities and process for regaining access to cash spelled out in contracts and in account x x x x x x
provider’s operating procedures.
¾ Simple remedies to each situation spelled out and available to users.

Policy Table:
Options Implications
1. Provider ensures alternative access procedures in the • Customers responsible for maintaining their access. But
event of customer notification of access failure; terms and failure to resolve access problems could undermine
conditions of each party’s responsibilities outlined in public acceptance by increasing the user's risk.
account agreement.
2. No alternative access measures exist • Customer must pursue through dispute resolution if
they can not reestablish connectivity.

Policy Narrative:
The two core components of customer education on mobile financial services should center on the
customer’s level of understanding of the service (e.g. methods and procedures for access) and the level of
customer confidence in the service, including his/her perception of device security. Banks offering mobile
banking generally do so as an alternative delivery channel for existing banking customers, with the model
covered by an existing transactional and regulatory framework. Alternative access measures for the client
have typically been established and are enumerated in customer account agreements. In the event an agent or
correspondent network is developed in conjunction with traditional banking, such as in Brazil and India,
regulations are adapted for consumer protection and access. In the case of non-banks offering mobile financial
services, customers typically do not interact with a bank nor have a bank account; they may instead interact
with an MNO or a prepaid card issuer; regulations or dispute resolution through customer agreements
governing non-banks, e-money, and stored value, as well as the recourse for the consumer may either not
exist or may be in conflict with traditional methods with which the consumer is familiar.

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1.11 Risk (Consumers): Options Implications
“Customer cannot access cash from mobile money account due to lack of system availability. ” low, relative to this issue.
3. No system availability requirement by regulators or • Adoption rates will be low if customers cannot depend
Description: commitment by providers on system availability.
Customer cannot receive cash from agent or perform cash-out transaction during regular “business hours”
because of one of the following situations: Policy Narrative:
• Agent and/or customer cannot access the system to execute the transaction. As the population begins to rely on the mobile network infrastructure for their financial service needs, any
interruption of service will have a negative impact on the economy, beyond the impact associated with the
• The communications account provider is experiencing a temporary system outage.
ability to make calls. With payment volumes between individuals increasing, businesses integrating mobile
• A record of complaints may indicate questionable business practices, or a lack of complaints could mean payments into their operations, and governments leveraging the innovation to pay civil servants and make
there is no established avenue for consumer remediation. Unscrupulous businesses or business may change transfers to citizens, regulators must consider the availability requirements that private actors must maintain.
names and locations to hide complaint histories once the business ceases operations. In the policymaking process, regulators must balance raising barriers to entry and innovation with safeguarding
the economy and consumer protection. As such, there is a continuum of policy options, of which we present
Objective: three examples. First, the regulatory authority can set regulatory requirements for operators of mobile
¾ Providers are responsible to customers for providing cash-out services in a timely manner. network infrastructure for system availability, redundancy, and continuity planning. Such requirements would
be a precursor to licensing, and inability to maintain system availability would result in fines and negatively
¾ Account Providers post realistic access standards and area coverage to ensure appropriate client service
impact renewal of license. Second, guidelines could be provided and regulatory authorities could monitor
expectations.
availability and investigate issues as they arise. Lastly, regulators could leave system availability up to the
¾ Subject to regulatory review and verification of compliance. market. Customers would likely flock to those with the best reputation for service. Variations to each of
these options still exist. For example, regulators could tier requirements relative to customer base
Policy Table: transaction volume so that the regulatory burden is proportional to the risk that failure presents to the
Options Implications economy.
1. Regulatory authority requires system availability service • Required service levels and continuity plans mitigate
levels. Business continuity plans must be clearly stipulated system availability risk. Market Examples:
in terms and conditions of customer agreements. • Philippines: The Philippines is noted as the world’s leader in the use of text messaging (SMS).
• High system availability requirement will impose a cost
Significant complaint levels will impact license extension. to some providers and raise a barrier to entry for Current estimates place usage at seven SMSs per customer per day, with the Philippine networks
potential providers. having had to equip two data channels in place of the usual one to control the traffic. Despite this,
the introduction of SMART Money and Globe’s G-CASH reported not system overloads, though
• Regulatory authority capacity/authority to regulate and
enforce system availability may not be practical. exact transaction loads are not available (estimates are two calls per customer per day for SMART).41
(Whether the regulatory authority in this situation is • Philippines: “Circular No. 649, Series of 2009, Section 4. Provisions for All EMIs (Electronic Money
financial or telecommunication is debatable.) Issuers). D. EMIs shall ensure that e-money instruments clearly identify the issuer who is ultimately
responsible to the e-money holders. This shall be communicated to the client who shall acknowledge
2. Regulatory authority monitors system availability service • Any new market entrant is likely to take time to fully roll the same in writing.”42
levels. out its service, particularly if competition is entrenched.
Significant complaint levels could impact license extension. Failure to do so within a reasonable time could lead to
failure of the service, resulting in the regulator having to Risk Type:
ensure an orderly withdrawal. MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
• Regulatory capacity to monitor system availability may be
x x x x x x x x x
limited.
• Lack of a regulatory requirement keeps barriers to entry

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1.12 Risk (Consumers): Policy Narrative:
“Lack of network interoperability prevents consumer from transacting with desired party.” This risk focuses on the concept of interoperability among competing national and international MFS systems.
Universal acceptance by all consumers, regardless of mobile network operator or MFS platform affiliation, will
Description: impact penetration growth and the overall sustainability of MFS.
Closed loop networks with no capability to transfer funds between account holders of different Account
In markets where MFS services are being led by mobile network operators (MNOs) interoperability is limited
Providers’ payment networks due to lack of interoperability. Among providers or their non-participation on a
to peer to peer transfers to rival MNO subscribers through a mechanism that requires cash out, switching to
national payment platform block payments outside of the account provider’s network. The first player to
and registering with the sender’s service.
enter the market can gain monopoly power, limiting competition, but can help justify initial market entry into
virgin markets.
In markets where a third party is the dominant MFS provider (e.g., Wizzit) specific MNO affiliation is not a
requirement. However, all transactions must be made through the third party platform and connectivity to
Objective: other MFS providers is not possible.
¾ No protectionist barriers to transfer funds between systems.
¾ Intra- account provider transfers conducted within the account provider’s system. In markets where banks are the leading players, the existing financial sector clearing processes act as a catalyst
for interoperability. However, to date this has not translated into an effective interoperable MFS system.
¾ Inter-account provider transfers conducted through a national switch, either directly or through
correspondent clearing accounts, without unreasonable usage fees or penalties.
In other fields, consumer demand typically drives the development of industry standards and interoperability
(e.g., GSM operations). With respect to MFS, financial regulators are positioned to regulate interoperability,
Policy Table: but thus far, have not done so.
Options Implications
1. National regulators require interoperability of payment • Requirement of interoperability may raise a barrier to Market Examples:
networks (through inter-account provider links or through entry as the technology requirements could be more • El Salvador: According to a CGAP interview with the Central Reserve Bank (BCR), limited
a switch) challenging than a simple closed network. Further, the interoperability for retail payments hampers customers from cash-based deposit and withdrawal
requirement may stifle innovation in a new technology services in bank branches, as well as transferring funds from bank-to-bank using the Internet channel.
through keeping new entrants out. Mobile banking is in the embryonic stages, and similar to Internet banking, is available only to those
• Consumers might benefit as there would be no network who already have bank accounts.43
limitations on sending mobile money. • Pakistan: The State Bank of Pakistan (SBP) considered several branchless banking models before
• Account providers might be forced to compete on cost, initially deciding to allow only bank-led models. In all cases, the customer has an account relationship
products, and service, rather than size of network. with the bank through establishment of a branchless banking account. The many-to-many model
• Limits first mover advantage, potentially discouraging involves a central transaction processing system or switch, providing total interoperability. Though
initial market entry. not yet implemented, this is the preferred model of SBP and allows multiple banks to offer services to
2. Competition agency empowered to investigate non-
customers of multiple agent networks or MNOs. The switch must be controlled by the bank, an
• Requires a competition agency with the capacity to
competitive behavior investigate and enforce non-competitive behavior, such agent or a subsidiary of the bank or group of banks. Banks can purchase access to the switch, similar
as predatory pricing. to access to an ATM network, which would reduce the technology investment burden placed on any
single bank.44
3. No regulatory action • Predatory pricing and expanded monopoly power are • Indonesia: Article 27 of the E-Money Regulation mandates that e-money providers must offer
possible; however, experience with networked systems that are interoperable with other e-money systems.45
technologies (cell phones/ATMs) suggest that the market
will move toward interoperability without regulatory • South Africa: WIZZIT, founded in 2004 by two entrepreneurs and operating in partnership with
action. the Bank of Athens, offers mobile banking services to approximately 300,000 customers. The
company is mobile phone agnostic, so that customers can use phones operated by any of South
Africa’s mobile operators, for services ranging from transferring money to third parties, loading

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electricity with prepaid cards, and buying airtime for prepaid mobile phone subscriptions. Since
WIZZIT has no brick and mortar branches of its own, it operates 3,500 deposit taking sites in
conjunction with the Post Office and ABSA Bank. Customers are issued a Maestro-branded debit
card, which they may use for cash withdrawals at any South African ATM.46
• Spain: Mobipay, was launched as mobile payments platform, as a result of a joint venture between
Spain’s largest TelCo, Telefonica, and a bank, BBVA. At the time this venture, the Spanish
Competition Authority (SDC) was concerned that m-payments would affect not only e-commerce
but also mobile telephony; it approved the JV with certain stipulations:
-other mobile operators must be allowed to participate;
-the interoperability of any mobile operator and any financial institution had to be technically possible;
-customers could not be limited in their choice of other MNOs or financial Account Providers by the
service contract;
-SDC had approval authority for interchange fees.
While initially slow to market in Spain, BBVA, took the product to Mexico and North Africa in 2005.47

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x

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1.13 Risk (Consumers): Options Implications
“Customer loses balance due to failure of a bank holding trust fund, or a similar situation where trust fund is from the operating funds of the account provider. reporting.
compromised.” • Periodic regulatory verification of the adequacy of trust
funds
Description:
3. No regulatory action • Deficiencies in the trust account, if leading to the
Should the trustee fails or goes into insolvency, trust accounts that are not legally segregated from the general inability of a account provider to cash out for clients,
pool of bank assets available to satisfy creditors may be pulled into the bankruptcy process. could have systemic impact through weakening of public
Trust funds deposited by the trustee in an account with the trustee bank or other banks are pooled deposits confidence in the financial system.
that may not be fully protected under bank closing/insolvency/deposit insurance rules.
• Deposit insurance is at the account level, and the trust account is viewed as a single account, rather than Policy Narrative:
many. When a customer makes a deposit to their mobile payment account, the funds do not remain with the mobile
network operator, but are held in a trust account, along with all other deposits, at a given financial institution.
• Trust accounts are not covered as deposit accounts.
If the bank holding the trust fails or becomes insolvent, the customers, who may have no relationship with the
• There may not be deposit insurance in the country. failing institution, may risk financial loss if regulatory measures are not in place to limit the risk. Two key
The value of trust funds invested in other financial instruments or institutions may be impaired. policy measures are noted that focus on modifying the legal / regulatory framework to ensure consumer
The trust account may be technically protected, but no rapid procedure for transferring funds held in trust to protection. The first focuses on insolvency. If the law / regulation relating to insolvency segregates trust
another trustee may exist, preventing access to the funds account assets from general assets, then mobile customers would have some protection of financial loss. The
second focuses on the regulation of the trust fund itself. As noted, this law or regulation would focus on
Objective: limiting risky investment, the segregation of assets, and monitoring. These two policies work together. If a
financial institution has a policy of segregating entrusted funds from operating funds and maintains a low risk
¾ Trust funds holding the value of items in transit are legally segregated from the trustee's own assets in investment strategy with these funds, then these consumers should be protected in case of insolvency.
bankruptcy.
¾ Trust accounts are divisible (to spread risk) and transferable (in case of failure of the trustee to perform). Market Examples:
¾ Management and investment of trust funds regulated similarly to insurance company loss reserves to limit • European Union (EU): DIRECTIVE 2000/46/EC OF THE EUROPEAN PARLIAMENT
risk of impairment of value. AND OF THE COUNCIL of 18 September2000 “The issuance of electronic money may affect
the stability of the financial system and the smooth operation of payments systems. Close
Policy Table: cooperation in assessing the integrity of electronic money schemes is called for. Electronic money
Options Implications institutions shall not have any holdings in other undertakings except where these undertakings
perform operational or other ancillary functions related to electronic money issued or distributed by
1. Law / Regulation relating to bank failure or insolvency • Requires trust law - normal in common law systems but the institution concerned… 2. Electronic money institutions shall have at all times own funds
segregates assets held in trust accounts from the general typically difficult in statute law systems.
pool of assets of a trustee in the bankruptcy process.
which are equal to or above 2 % of the higher of the current amount or the average of the
• Requires a court system that both understands trust preceding six months' total amount of their financial liabilities related to outstanding
law and is empowered to enforce it. electronic money. 3. Where an electronic money institution has not completed a six months' period
2. Law / Regulation on trust funds that provides for: • Diversification of trust accounts spreads risk across of business, including the day it starts up, it shall have own funds which are equal to or above 2 % of
• Transferability of the trust to another trustee in case of multiple financial institutions thus reducing the exposure the higher of the current amount or the six months' target total amount of its financial liabilities
non-performance or failure of the trustee. of providers. Holding across multiple institutions will related to outstanding electronic money. The six months' target total amount of the institution's
create a bit more complexity for payment providers in financial liabilities related to outstanding electronic money shall be evidenced by its business plan
• Investment guidelines for trust funds that limit risk managing several bank relationships.
concentrations for funds not invested in marketable or
subject to any adjustment to that plan having been required by the competent authorities.48
short maturity government securities. • Monitoring and enforcement of trust account • Jordan: The Deposit Insurance Corporation in Jordan was established pursuant to the Deposit
diversification should be possible through periodic Insurance Corporation Law of 2000. Deposit insurance applies only to banks, as well as local
• Clear segregation of trust funds covering customer funds

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branches of foreign banks, and covers up to a maximum deposit of JD10,000 (USD 14,000). The fees
charged to banks include (i) a JD100,000 (USD 140,000) fee paid upon establishment of the bank and
(ii) an annual fee equal to 0.25 percent of the bank's aggregate deposits.49
• General (Microfinance): The field of microfinance may include not only credit transactions, but
also micro-savings, micro-insurance, remittances, and other payments, which though fractionally small
in overall payment streams, greatly impact the lives of the poor. A recent CGAP research study
noted that there exist financial institutions excluded from microfinance definitions that are
nonetheless providing services to more than 750 million account holders worldwide in low income
range.50

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x x x

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1.14 Risk (Consumers): Options Implications
from the operating funds of the account provider. reporting.
“Pooled deposits within a trust account can create a funding concentration risk which would not protect • Periodic regulatory verification of the adequacy of trust • Excessive risk concentrations in a trust fund could
individual customers if trust is impaired.” funds heighten systemic vulnerability should a loss of public
confidence in the account provider result in
Description: disintermediation with consequent demand to liquidate
investments by the trust.
Trust impaired: Trust funds deposited by the trustee in an account with the trustee bank or other banks are
pooled deposits that may be significant compared to the size of the bank, representing a funding concentration 3. No regulatory action • Deficiencies in the trust account, if leading to the
risk, and may not be fully protected under bank closing/insolvency/ deposit insurance rules. inability of a account provider to cash out for clients,
could have systemic impact through weakening of public
• Even if available, deposit insurance is at the account level, and if the trust account is viewed as a single confidence in the financial system.
account, rather than many, the cap would be insignificant compared to the size of the trust account.
• The value of trust funds invested in other financial instruments or institutions may be impaired by a decline Policy Narrative:
in market value of the investments. When a customer makes a deposit to their mobile payment account, the funds do not remain with the mobile
• Significant and unusual outflows could present the trust with liquidity difficulties if investments cannot be network operator, but are held in a trust account, along with all other deposits, at a given financial institution.
unwound. If the bank holding the trust fails or becomes insolvent, the customers, who may have no relationship with the
failing institution, may risk financial loss if regulatory measures are not in place to limit the risk. Two key
policy measures are noted that focus on modifying the legal / regulatory framework to ensure consumer
Objective: protection. The first focuses on insolvency. If the law / regulation relating to insolvency segregates trust
¾ Trust funds holding the value of items in transit are legally segregated from the trustee's own assets in account assets from general assets, then mobile customers would have some protection of financial loss. The
bankruptcy. second focuses on the regulation of the trust fund itself. As noted, this law or regulation would focus on
¾ Trust accounts are divisible (to spread risk) and transferable (in case of failure of the trustee to perform). limiting risky investment, the segregation of assets, and monitoring. These two policies work together. If a
financial institution has a policy of segregating entrusted funds from operating funds and maintains a low risk
¾ Management and investment of trust funds regulated similarly to insurance company loss reserves to limit
investment strategy with these funds, then these consumers should be protected in case of insolvency.
risk of impairment of value.
Market Examples:
Policy Table: • Philippines: “Circular No. 649, Series of 2009, Section 4. Provisions for All EMIs (Electronic Money
Options Implications Issuers). B. EMIs shall put in place a system to maintain accurate and complete record of e-money
1. Law / Regulation relating to bank failure or insolvency • Requires trust law - normal in common law systems but instruments issued, the identity of e-money holders, and the individual and consolidated balances
segregates assets held in trust accounts from the general typically difficult in statute law systems. thereof. The system must have the capability to monitor the movement of e-money transactions and
pool of assets of a trustee in the bankruptcy process. • Requires a court system that both understands trust law link e-money instruments issued to common e-money holders. The susceptibility of a system to
and is empowered to enforce it. intentional or unintentional misreporting of transactions and balances shall be sufficient grounds for
imposition by the BSP (Bangko Sentral ng Pilipinas) of sanctions, as may be applicable.”51
2. Law / Regulation on trust funds that provides for: • Diversification of trust accounts spreads risk across
• Transferability of the trust to another trustee in case of multiple financial institutions thus reducing the exposure
of providers. Holding accounts across multiple Risk Type:
non-performance or failure of the trustee.
institutions will create a bit more complexity for MNO Bank Hybrid
• Investment guidelines for trust funds that limit risk International Systemic Operational Reputation Liquidity Legal
payment providers in managing several bank Model Model Model
concentrations for funds not invested in marketable or relationships. x x x x x x x x
short maturity government securities.
• Monitoring and enforcement of trust account
• Clear segregation of trust funds covering customer funds diversification should be possible through periodic

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1.15 Risk (Consumers): Such a requirement would disallow any risk to customers by misuse of their account balance. Clearly, less
“Customer loses balance due to bank/provider not maintaining a 1:1 coverage requirement in the payment restrictive capital requirement levels could be set, yet these will expose customers to risk. As mobile
account trust fund.” payments remains a fairly nascent technology / financial service, more historical data would be required to
provide policymakers the ability to safely set lower thresholds.
Description:
Market Examples:
If the financial services provider or bank holding the trust fund does not maintain a balance equal to the total
• Indonesia: The Bank of Indonesia (BI) issued both an E-Money Regulation (11/12/2009) and a
value of all pre-paid accounts (payments in transit or float determination), the customer may not be able to
related Circular Letter 11/11/DASP, specifying that both banks and non-banks could issue e-money.
access his/her funds if there were a “run on the bank.”
Both types of issuers are required to obtain licenses from BI; nonbank issuers must place 100% of the
The risk is particularly severe if the account provider is experiencing operating losses or cash flow strains due float in a commercial bank, with funds being placed either in a savings, current account or a time
to network expansion or other operating or investment costs and may see client funds in transit as a source deposit account. Float funds may only be used to fulfill the issuer’s obligations to customers and
of operating funding. agents. Bank issuers are required to report the float as an immediate liability. Further, both types of
issuers are prohibited from issuing e-money with values other than that (higher or lower) deposited
Objective: by the holder. Definitionally e-money funds are not considered to be deposits under the E-money
¾ Prevent co-mingling of account provider operating funds and customer funds in transit. Regulation or Circular Letter and, therefore, are neither protected by Indonesian deposit insurance
nor are interest bearing.52
¾ The sum of the lower of cost or market value of trust funds in account provider trust accounts must at
least fully cover the value of all transfer items in transit or funds stored in mobile phone accounts that are • Philippines: “Circular No. 649, Series of 2009, Section 5. Provisions for EMI-Others (note: these are
defined as funds paid in by customers into payment accounts and not yet withdrawn. non-bank financial institutions which are registered as money transfer agents with Bangko Sentralng
Pilipinas). D. To further protect the e-money holders and ensure that e-money redemptions are
¾ Subject to regulatory supervision (this is probably the dominant systemic risk issue). adequately met at all times, the entity should have sufficient liquid assets equal to the amount of
outstanding e-money issued. The liquid assets should remain unencumbered and may take any of the
Policy Table: following forms:
Options Implications 1. Bank deposits separately maintained for liquidity purposes;
1. 1:1 trust account balance requirement. • Requires periodic reporting by banks/providers to 2. Government securities set aside for the purpose; and
regulators. 3. Such other liquid assets as the BSP may allow.
• Reporting requirements Regulators will need the Records pertaining to the above liquid assets shall be made available for inspection by BSP at any time
capacity to effectively monitor and verify reports. and the confidentiality of bank deposits and government securities shall be waived.”53

2. No regulatory action • Failure to ensure that items in transit are fully covered Risk Type:
by corresponding funds held in trust could result in a MNO Bank Hybrid
messy winding up of a failed account provider, with International Systemic Operational Reputation Liquidity Legal
Model Model Model
systemic impact on financial markets. x x x x x x

Policy Narrative:
To mitigate risk, financial institutions are responsible for maintaining capital requirements in line with
regulatory provisions. Such requirements help to protect consumers by ensuring banks keep enough cash on
hand to ensure liquidity even in the case of high demand periods, such as a “run on the bank” during a financial
crisis. In an MNO model, the regulatory requirements of financial institutions may not apply to MNOs
offering mobile payment accounts. Without regulatory requirements and monitoring, an MNO could leverage
mobile payment account funds to cover operating expenses, or even to make investments. Given the high
demand nature of mobile payment accounts, the policy option notes a 1:1 trust account balance requirement.

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program). However the CBJ‘s consumer complaint division minimally staffed office does not engage in
1.16 Risk (Consumers): any substantial effort to educate financial consumers of their rights. The Ministry of Industry and
“Consumers may respond to social pressures by drawing on credit lines to fund payments, risking over Trade (MIT) only supervises market conduct to the extent such conduct addresses fair pricing; MIT
indebtedness.” does not address consumer protections related to ―free market services.54

Description: Risk Type:

Increasing the ease with which funds may be transferred to family members may increase social pressures for MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
such transfers, possibly leading remitters to tap credit lines to supplement payments. This may increase the Model Model Model
risk of remitters increasing their debts to unsustainable levels. x x x x x x

Objective:
¾ Public awareness of the risks of over indebtedness.
¾ Lender policies and procedures that protect against over indebtedness.
¾ This is a general (not cell phone specific) consumer protection and portfolio quality issue that should be
already under regulatory oversight, although may not be in place in many countries.

Policy Table:
Options Implications
1. Regulatory authority prohibits use of credit facilities for • Not implementable since money is fungible.
funding mobile money accounts. • Financial institutions will reject regulators limiting how
credit facilities can be used on a situational basis.
2. Regulatory authority may provide general consumer • Requires support from the on-site examination of
protection guidelines for over indebtedness, but otherwise regulated institutions’ lending policies and procedures, as
take no action a normal part of market supervision.

Policy Narrative:
As mobile money is a rapid way to send money long distances, individuals remitting money via mobile
payments may face increased pressure to support family and friends. If mobile payment accounts could be
funded via a credit facility, consumers could rapidly indebt themselves in response to such pressure. Though
consumer debt is a valid concern, regulators will face challenges if they attempt to restrict the use to which
approved credit lines can be used. The regulatory authority, instead, should focus their attention on the
credit policies of the institution that extended the credit line.

Market Examples:
• Jordan: Currently there is no consumer protection regulation for MFI clients. Consequently, the
only recourse available to MFI clients (and MFIs themselves) is an often lengthy and costly court
system. The Central Bank of Jordan (CBJ) has a consumer complaint division for customers of
licensed banks only (and consequently available to clients of Cairo Bank of Amman’s microcredit

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1.17 Risk (Consumers):
“Customer’s family is unable to access account funds if the customer dies.” Market Examples:
• Kenya: M-Kesho is a bank account accessible by M-PESA registered users who are Equity bank
Description: account holders. They need a mobile phone and must fill out an application form at selected outlets,
If account providers have not established escheatment guidelines for customer mobile payment accounts in producing an original ID, a copy of the ID and 2 passport size photos. Funds may be transferred from
case of death, customer’s families will be unable to access the balances and the account will remain dormant Equity bank accounts or through M-PESA, though inter-account transfers are not allowed (e.g.
on the provider’s system. transfers to those who do not have an M-KESHO account.). Other features include micro credit
facilities through M-PESA and micro credit insurance insurance and accident coverage.55
Objective:
¾ Escheatment guidelines to mimic the guidelines for demand deposits accounts. Risk Type:
MNO Bank Hybrid
¾ Subject to regulatory oversight and verification of compliance. International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x
Policy Table:
Options Implications
1. Regulatory authority mandates establishing beneficial • Account opening complicated, increasing operating costs
owners for stored value fund balances payable on death of and potentially deterring usage.
the owner • Regulation implies enforcement capacity and costs.
2. No regulation, but account providers establish • Account opening complicated, increasing operating costs
beneficial owners for stored value fund balances in the and potentially deterring usage.
event of death or incapacity of the owner
3. Service users protect themselves by sharing access • Could result in misallocation of funds by overly trusted
codes with trusted family member(s) family member(s)
4. Institute “abandoned property” regulations that transfer • Requires an accounting process for abandoned funds and
unclaimed funds to the state after a prescribed period. may require a process for responding to claims received
after the prescribed period.

Policy Narrative:
A “Payable On Death” or POD option for a mobile financial services account would involve filling out
additional forms for the bank-led or hybrid MFS models and allow for the transfer of all assets to the named
beneficiary or beneficiaries upon, for instance, presentation of a death certificate of the sole owner or the last
to die of all multiple owners on an account and the proper ID of the named beneficiary or beneficiaries. POD
has no effect on ownership of the funds in the account until the owner’s death; the owner may change the
beneficiary designation at any time without the beneficiary’s knowledge or consent. There may still be
challenges for the financial institution, however, in KYC of the named beneficiary and a risk-based approach
would be prudent in responding to claims. In the event the account is opened with an MNO-based model, the
account provider may follow precedent for e-money funds in the absence of existing regulation, but in all
likelihood funds may revert to the MNO in the absence of knowledge be survivors of the account or a
regulatory requirement for notification for abandoned property.

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1.18 Risk (Consumers): Options Implications
“The beneficial owner(s) of stored value and transactional accounts (e.g., mobile money) cannot be illicit transactions by shared users.
determined by authorities in the event of illicit account activity or determining credit worthiness of individual • Regulatory authority’s ability to identify members of a
members when group accounts are allowed.” group and which member of an informal group is the
source/beneficiary of an illicit transaction will depend on
Description: collaboration by the SIM card holder whose account was
used.
Village based solidarity and small group lending programs jointly open a non-bank mobile money account
making regular deposits with an intention to “share out” funds to individual group members as micro-loans. As
the account is associated with multiple individuals, authorities have difficulty identifying specific actor when Policy Narrative:
illicit activity occurs. While any policy option should be cognizant of the size and scope of transactions currently flowing through
mobile financial services, those responsible for potential operational security risks should remain cognizant of
the underlying concerns linking these services to the broader realm of financial services where illicit actors
Objective: seek to actively conceal ownership structures. As the complexity of financial options offered via the mobile
¾ Responsibility for any transaction passing through a mobile account clearly defined. channel increases, so to must the recognition that illicit actors will increasingly employ the most convenient
methods available that entail the least perceived risk. The term “beneficial ownership” refers to the control
Policy Table: over funds versus mere signature authority. This reflects the fact that the person whose name is on an
Options Implications account may not necessarily be the person entitled to such funds or controlling the movement of such funds.
For the purposes of anti-money laundering guidelines, identifying the person controlling the movement of
1. Law / Regulation prohibits group registration for • The law cannot realistically prevent informal group use
transactional accounts. of accounts – individual associated with the SIM card
funds is a critically important step in determining the source of funds .56 Use of shared accounts is not
bears responsibility for any issues. permitted under FATF due to AML/CFT concerns, since such accounts effectively permit anonymity of most
of the beneficial owners of the account.
• Enforcement will focus on provider policy and
The FATF framework generally requires the beneficial owner(s) of an account to be known to the financial
investigation when criminal activity is suspected – implies
enforcement costs institution so using one person to send/receive money on behalf of a community is not permitted.

2. Law / Regulation limits group registration for • Corporate restriction limits flexibility for micro-finance Market Examples:
transactional accounts to corporate entities; enforced by group accounts. • Tanzania: A micro finance institution indicated that a corporate resolution was successfully used
account provider and or regulatory authorities • The law cannot prevent group use of accounts – for group registration of SIM cards. A letter identifies and attests all registered owners of the SIM
individual associated with the SIM bears responsibility for and a corporate “officer” is designated for cash ins/cash outs. The PIN code is split for security
any issues. purposes.57
• Enforcement will focus on provider policy and
investigation when criminal activity is suspected – implies Risk Type:
enforcement costs. MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
3. Law / Regulations permits group registration with • Increases documentation requirements and transaction Model Model Model
designated “signatory” SIM authority acknowledged by all costs, motivating for avoidance. x x x x x x
members in written agreement. • Ability to identify which actor within the group made a
given transaction would require collaboration from the
“signatory”.
4. No regulatory action • Account providers determine group use policy.
• SIM card holder held accountable for transactions over
the account motivating the SIM card holder to block

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1.19 Risk (Consumers): ($0.001) tax, which was not to be passed on to consumers. The country’s three largest
“Government decides to tax transactions to raise funds increasing the marginal cost of each transaction.” telecommunications companies opposed the measure, claiming that it would be a burden on low
income consumers. The head of the Philippine Long Distance Telephone regulatory affairs and policy
Description: office noted that 92% of SMS traffic is in the country is generated from bucket-priced plans. The
ways and means panel of the 264-member House of Representatives approved the proposed tax to
Governments in need of revenues may see the high transaction volume mobile payment system as an
raise 36 billion pesos ($744.5 million) after Congress was reluctant to pass a proposal on alcohol and
opportunity. If governments decide to institute a transaction tax on mobile payment system transactions, they
tobacco products.58
would raise the marginal cost of each transaction to consumers (as account providers would pass this cost
• Turkey: The tax burden on mobile users is higher than in any of the other 49 countries in a GSMA
along), thus pricing out many of the consumers that the system most benefits. The high adoption rate of
study from 2006. The study stated that 43% of the total cost of owning and using a phone in Turkey
mobile payments in most communities, and the benefits for expanding access to financial services, are driven
was a result of the taxes levied, in comparison to 18% in 50 other countries studied. Among the
largely by the low cost.
taxes noted were a Special Communication Tax (25%), the Treasury Share Premium (15%) and Value
Added Tax (18%) on each mobile call made. When initially subscribing, users paid US $18, a Wireless
Objective:
License Fee of US $7.5, and Usage Fee of US &.5 per annum, in addition to the then proposed new
¾ Keep the marginal transaction cost to a minimum Environmental Contribution Fund tax of US $9. The GSMA, a global trade association for mobile
operators globally, concluded that economic growth in the mobile channel was being limited in
Policy Table: Turkey as a result of the tax burden on the mobile users.59
Options Implications
1. Government imposes a transaction tax • Any transaction tax will reduce volume of the system. Risk Type:
The consumers that leave the system will be the MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
poorest, as they are the most price-sensitive. Thus, any Model Model Model
transaction tax would be viewed by the public as anti- x x x x
poor.
• A transaction tax would complicate operations and
accounting for account providers.
• Some funds would inevitably be raised; but offset by the
negative societal impact of decreased usage.
2. Government does not impose a transaction tax • Mobile payment adoption rate, and expanded access to
financial services, not inhibited by taxation.

Policy Narrative:
Bucketed –price plans, which are designed for low-income consumers, allow either unlimited text messages or
a predetermined number of these SMSs over a defined period of time. In mobile financial services, the SMS is
frequently used as the instruction message to convey a funds transfer or other type of mobile financial service.
Regulatory authorizes levying a tax on this component of mobile financial services may be seen as stifling
market expansion if the tax is not passed on to consumers or be accused of being “anti-consumer” if such a
revenue-generating tax is passed on.

Market Examples:
• Philippines: Considered the text messaging capital of the world, the country averages 10-12 SMSs a
day per its 70 million mobile subscribers. Government authorities recently proposed a 5 centavo

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2.1. Risk (Merchants): Market Examples:
• Please Note: A market example of a policy action associated with this risk was not identified during the
“Merchants are unable to easily convert mobile money into cash limiting their flexibility to run their business / literature review or the in-country consultations included in this project’s scope. We welcome your suggestions
store.” of relevant examples for inclusion in subsequent versions.

Risk Type:
Description:
MNO Bank Hybrid
Merchants accepting mobile money may not be able to rely on regular, flexible, and consistent methods to International Systemic Operational Reputation Liquidity Legal
Model Model Model
exchange electronic money into cash or use electronic money to trade with their suppliers. If they take in
x x x
mobile money, but their suppliers do not accept mobile money, their ability to restock efficiently may be
limited.

Objective:
¾ Merchants able to cash out as needed for liquidity management.

Policy Table:
Options Implications
1. Regulatory authority requires Account Providers to • Such regulation likely unenforceable, since cannot dictate
maintain an “agent of last resort” within specific geographic the composition of account providers’ networks or
areas to ensure liquidity for consumers. related contracts.
• It is in the interest of Account Providers to provide an
efficient agent network to ensure market penetration,
regulatory intervention is likely unnecessary.
2. No regulatory action • Merchants will adopt mobile payment capabilities into
their business model when they can either use mobile
money balances with suppliers, or when they can depend
on agents to maintain liquidity.
• It is in the interest of account providers to ensure an
efficient agent network. Monitoring of complaints of
inadequate access could feed into license considerations.

Policy Narrative:
Merchants are unlikely to adopt a product as a critical part of their business infrastructure, until the
infrastructure itself has proved reliable to meet their needs. A merchant, thus, will not adopt mobile
payments as a payment option if they do not believe they can readily cash-out when needed. Regulators can
require an “agent of last resort” within specific geographies to ensure availability and liquidity, yet the market
is likely to drive this change more quickly, as the reputation of the service would be at risk.

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2.2. Risk (Merchants): Options Implications
phones/ATMs) suggests that the market will move
“Merchant could be restricted by a contract with a payment provider from accepting payments for or from toward interoperability without regulatory action.
another account provider.”
Policy Narrative:
Description: Anti-trust legislation typically focuses on avoidance of monopolies and mergers and acquisitions (M&A) in an
Merchants locked into exclusivity agreements may be precluded from offering their clients better and/or less effort to prohibit companies within any one industry sector or sectors from dominating and being able to set
costly services from other account providers. or fix market prices. Cartels, groups of independent companies associated for the purpose of fixing high prices
Exclusivity agreements may provide economic justification for market entry of the first provider, but then may by agreement, are similarly discouraged. If account providers are signing merchants up exclusively, so that it
perpetuate a monopoly. restricts customer choice or unfairly restricts entry, it should be evaluated by the national competition agency.

Objective: Market Examples:

• Please Note: A market example of a policy action associated with this risk was not identified during the
¾ Balanced exclusivity agreements that facilitate market entry economies of scale yet prevent unreasonable
literature review or the in-country consultations included in this project’s scope. We welcome your suggestions
restrictions on competition.
of relevant examples for inclusion in subsequent versions.

Policy Table: Risk Type:

Options Implications MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
1. Exclusivity agreements restricted by law or regulation to • Allowing or not disallowing exclusivity agreements may Model Model Model
balance short term market entry facilitation against longer encourage market entry, but then block longer term x x x
term market competition, possibly through time competition.
limitations. • Blocking all exclusivity agreements could discourage first
mover market entry.
• Requires regulatory monitoring of account provider
agreements with agents and associated regulatory costs.
2. Regulatory authority requires interoperability of • Requirement of interoperability would lessen the
payment networks (through inter-provider links or switch) inconvenience of any exclusivity agreements with
merchants as they would still be able to make a
purchase, though a fee may be involved.
• Requirement of interoperability would raise the cost for
new entrants.
3. Competition agency empowered to investigate non- • Requires a competition agency with the capacity to
competitive behavior investigate and enforce non-competitive behavior. This
is not a unique issue to mobile financial services.
• Actions to restrict exclusivity agreements that harm
consumers will discourage their use in mobile financial
services too.
4. No regulatory action • Exclusivity agreements are possible; however,
experience with networked technologies (cell

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Risk-based Policy Matrix – Appendix

3.1. Risk (Agents): or unable, to service their cash-out request. To avoid this situation, the agent agreement should provide a
“Agent is unable to easily liquidate e-money inventory when the agency relationship is terminated.” process for agent cash-out. If viewed as a significant issue, regulators could require such a procedure.

Market Examples:
Description:
Agents that voluntarily or involuntarily lose their agent status must be able to convert their e-money • Please Note: A market example of a policy action associated with this risk was not identified during the
inventory to cash or deposit in a bank account. literature review or the in-country consultations included in this project’s scope. We welcome your suggestions
of relevant examples for inclusion in subsequent versions.
Objective:
¾ Cash out procedures are covered in the agency agreement. Risk Type:
¾ Contractual disputes between account provider and agents subject to court resolution. MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x x x x
Policy Table:
Options Implications
1. Regulatory authority requires providers to facilitate • Requirement mitigates agent liquidity risk in case of
agent cash-out upon termination. termination.
• Requirement removes a potential barrier for entry of
new agents, if they are uncertain of the market or the
account provider.
• Enforcement may be limited to review of agent
agreement templates.
2. Provider sets contractual agent termination provisions • Provisions set expectation for agents upon contract
with guidance from the regulatory authority. initiation. (Provisions should enable liquidation within a
timely manner.)
• If provisions do not ensure a timely liquidation, this may
constitute a barrier to entry for new agents.
3. No regulatory guidance • Account provider has a commercial interest in enabling
existing agents to exit: to reduce barriers to new
agents.
• Account provider sets own contractual obligations to
liquidate agent’s e-money inventory in a timely manner.
• Agent may liquidate balances via other agents.
• Lack of clear exit strategy at termination may constitute
a barrier to entry for new agents.

Policy Narrative:
Upon termination of the agent relationship, the agent will likely want to cash-out part, or all, of their e-money
inventory. As agents will carry larger inventories than the average consumer, other agents may be unwilling,

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3.2 Risk (Agents): Options Implications
without their phone present are at risk of losing cash if
“Agent receives cash from client but fails to provide/transfer the e-money.” the agent decides to misdirect the money, or not
process the transaction.
Description:
Agent receives funds from a service user but misdirects funds to the agent's own benefit. This situation could Policy Narrative:
arise in one of two ways: Consumer protection and public awareness campaigns, whether considered a reputational cost of doing
business by first market entrants or regulated, may be the only risk inhibiting factor against this type of fraud.
The consumer could be an existing customer without their phone with them, so they would not receive the
transaction confirmation while with the agent. Market Examples:
• Afghanistan: Discussing the critical importance of high-quality, expansive agent networks, a recent
The consumer may not be a customer but requests that the agent sends money to an existing customer, so USAID study noted the sparse agent coverage of even the most popular systems as a continuing
does not receive independent phone confirmation of the transaction. concern. Identification and public awareness campaigns for companies like M-Paisa have been
extensive, but still may not mitigate the risks of those falsely posing as agents in sparsely populated or
Objective: uncontrolled areas. In Afghanistan, there are more than 3,500 Roshan agents across the country,
though only about 700 are trained on M-Paisa. Additionally, of those trained, only about 300 are
¾ Effectively constrain diversion of funds. active M-Paisa agents. Further impeding M-Paisa’s growth is the fact that agents are not available to
complete transactions nor, if available, agent liquidity is an issue.60
Policy Table:
Options Implications Risk Type:
1. Require that service users receive, and know they have • Public confidence issue - in the account provider's MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
a right to receive, clear confirmation that funds have been interest to ensure that clients are not defrauded. Model Model Model
received and where they have been directed. This may x x x x x
• Police may need training on dealing with complaints of
include a paper receipt, if the customer does not have a abuse.
phone, or if the individual is not a customer.
• Agents require protection from spurious claims of non-
receipt.
2. Require that service users receive, and know they have • Public confidence issue - in the account provider's
a right to receive, clear confirmation that funds have been interest to ensure that clients are not defrauded.
received and where they have been directed. This may • Police may need training on dealing with complaints of
include a paper receipt, if the customer does not have a abuse.
phone, but would not apply to non-customers requesting
‘informal remittance’ service from an agent, (i.e. when the • Agents require protection from spurious claims of non-
service is not formally offered by the provider). receipt.
• Non-customers receive no more protection in this
situation, than if they asked any user on the network to
provide the same service.
3.. Raise public awareness that users should have their cell • Reduces the need for potentially costly and
phone available to ensure receipt of transaction unenforceable rules to ensure agents are crediting the
confirmations. proper accounts.
4. No confirmation requirement • Customers requesting cash-in or remittance service

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3.3. Risk (Agents): Market Examples:
“Agent is robbed.” • Please Note: A market example of a policy action associated with this risk was not identified during the
literature review or the in-country consultations included in this project’s scope. We welcome your suggestions
Description: of relevant examples for inclusion in subsequent versions.
Agents that hold both cash and e-money face a risk of robbery. The risk may be heightened if the volume of
cash/e-money required follows a predictable remittance cycle, requiring a higher than normal cash on hand Risk Type:
position. Agent may be forced to transfer all or part of its e-money inventory to the robber or other party. MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
However, agents that are also merchants may find that accepting e-money as payment for goods and services Model Model Model
sold reduces the need of cash on hand, and the risk of robbery. x x x x x

Objective:
Agent responsibility for cash security should be clearly outlined in the contract with the account provider.
¾ If the payment system is e-money, cash is owned by its bearer so cash security is the responsibility of the
bearer agent.
¾ If the agent is deposit-collecting, the cash in the till may be the customers’, in which case greater security
measures may be necessary.

Policy Table:
Options Implications
1. Regulatory authority requires agents to be insured • Insurance provides protection in case of theft.
(whether by provider or self-provided) • Insurance requirement may constitute a barrier to entry
for providers and /or agents.
2. Provider informally agrees to make the agent whole • Agents will not view theft as a barrier to entry, as they
based on sufficient evidence of robbery. will bear the theft losses.
• Creates moral hazard that may encourage thefts.
3. No account provider or regulatory action - local police • Agents bear liability for theft losses.
matter • Agent liability may create a barrier to entry.

Policy Narrative:
Insurance policies typically may be designed for cash-intensive businesses that cover burglary and robbery,
including options for coverage of guards, robbery insider and/or outside of the premises, safe burglary,
property damage resulting from the acts of burglary or robbery, burglary of merchandise, theft from the
courier transporting funds to and from financial institutions. In any case, the concern, particularly for a start up
business, would be the potential barriers to entry of required insurance or, should insurance not be mandated
but be unaffordable, losses resulting from a lack of an affordable policy.

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3.4. Risk (Agents): Recent MFS conferences (e.g., M-Banking 2009, Kenya School of Monetary Studies, May 2009) have raised the
“Agent threatened with individual customer demands or potentially larger group protests due to inability to issue of an unregulated, ad hoc, cash in/cash out infrastructure and the impact this has had on consumer
perform cash-out transactions.” confidence. While the issue is viewed as significant, most experts agree that a regulatory solution would be
difficult to craft and implement. The current view is that consumer demand and market forces will dictate the
Description: number of agents and the operating principles that govern agent conduct (e.g., availability of cash, hours of
Agent unable to perform cash out transactions due to KYC/CDD policies, insufficient cash on hand to meet operation, etc.)
occasional heightened demand, and/or system/network outages.
Market Examples:
For example, the account provider’s system may be down, preventing KYC/CDD and transaction verification.
• El Salvador: Under Article 1 of the Banking Law, deposit-taking, financial intermediation, and
Customer may have lost ID, pin code or phone; an updated account provider policy may prevent agent from “other activities carried out by banks”, permits the Central Reserve Bank (BCR) to authorize other
resetting pin without sufficient credentials, thus excluding the cash-out transaction. operations and services. Banks are subject to regulation ranging from prudential to management and
ownership rules, with licensing by the Superintendence of the Financial System (SupFin). However, a
Objective: different framework governs member-based financial institutions, most of which were not subject to
¾ Market access issue between account provider and its customers, impacting the account provider's market supervision by SupFin. This financial sector, comprised of savings and loan societies and cooperative
reputation. associations, recently pushed for a new law allowing deposit-taking from the general public. While
¾ Only becomes a regulatory issue if customers cannot reasonably retrieve their funds through other agents. there is no specific regulation on the issuance of e-money by non-banks, the activity by this sector is
Otherwise, police/public orders issue. defined as taking deposits and intermediating those deposits. According to a recent CGAP
Branchless Banking Assessment, it is widely assumed that Salvadoran regulators would strictly apply
this definition to e-money schemes and deem such activity to be banking activity, particularly if funds
Policy Table:
are to be intermediated. 61
Options Implications
• India: Acknowledging the development of the mobile channel, The Reserve Bank of India (RBI)
1. Account agreement or regulatory requirement stipulates • Account agreement or regulatory requirement mitigates issued the Operative Guidelines for Mobile Banking Transactions (2008) pursuant to the Payment and
access requirements and service levels. (see 1.2, 1.7, 1.8 unreasonable expectations. Settlement Systems Act (2007). Only banks licensed, supervised and with a physical presence in India
and 1.9) • If inability to meet service levels becomes a problem, may offer mobile banking to their existing customers. These institutions must obtain prior approval
customers can take legal action. More likely, customers of RBI before launching their service offering. MNOs and nonbank financial institutions may not offer
would simply switch providers. mobile banking services. Cross-border and foreign remittances are not permitted. Daily transaction
2. No regulatory action • Local police relied upon to handle civil disorder issues. limits are set at Rs 5,000 for transfers and Rs 10,000 for goods and services purchases. Two factor
authentication, including a PIN is required on all transactions, with a limit of Rs 50,000.62
Policy Narrative: • Kenya: A recent study on the community level effects of M-PESA on local economic activity
This risk refers to the amount of capital (both cash and e-money) held by agents, available for cash in/cash out indicated that money circulation was the most highly ranked of all effects. It was consistently
transactions. In many mobile financial services systems, agents are the primary human interface with the identified by respondents (being ranked most important by men and no. 3 by women) as infusing cash
consumer. Initial consumer confidence in a MFS system is, to a large degree, contingent on their ability to into the community via remittances where they appeared to be needed most. The higher and faster
conduct cash-in/cash-out transactions. Consequently, maintaining a viable agent infrastructure is an important circulation, in turn, contributed to expansion of businesses, food security, human capital
element of a strong MFS system. accumulation, and rescue money (emergency funds), as well as increased employment
opportunities.63
To date, MFS providers have used commercial practices (e.g., commission structures, agent vetting processes,
prepaid e-money reserves) to drive the proliferation of cash in/cash out agents. Market forces have Risk Type:
MNO Bank Hybrid
determined which agents remain viable. MFS providers generally have not developed service level agreements International Systemic Operational Reputation Liquidity Legal
Model Model Model
(SLAs) with agents requiring them to maintain cash balances.
x x x x x x x

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3.5. Risk (Agents): maintains expertise through their Counterfeit and Security Documents Branch (CSDB), providing forensic
“Agent takes in cash that proves to be counterfeit.” support, operational assistance, and technical databases to assist the 188 member countries of INTERPOL
regarding counterfeit national currencies64
Description:
Counterfeiter manufactures false notes to pass through agent and to integrate into the money supply. Market Examples:
• Kenya: “Sec. 373 Any person who – (a) utters any counterfeit coin knowing it to be counterfeit, and
Objective: at the time of such uttering has in his possession any other counterfeit coin; or (b) utters any
¾ Responsibility for accepting counterfeit currency for transfers the same as for sale of goods - with the counterfeit coin knowing it to be counterfeit, and either on the same day or on any of the ten day
agent. next ensuing utters any other counterfeit coin knowing it to be counterfeit; or (c) receives, obtains
or has in his possession any counterfeit coin knowing it to be counterfeit, with intent to utter it, is
¾ Agent training on counterfeits, and other illicit financial instruments, to be modeled on bank teller training
guilty of a felony and is liable to imprisonment of three years.”65
and provided commensurate to the perceived risk.
¾ Account provider training program for agents subject to regulatory assistance/verification. Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Policy Table: Model Model Model
Options Implications x x x x x x
1. Regulatory authority provides mechanism for reporting, • May incentivize agent to report counterfeit activity.
retrieval, and criminal investigation of suspect counterfeit • Reporting facilitates identification of issues, investigation,
notes. and apprehension of counterfeiters.
Regulatory authority sets parameters for training material
• Regulatory authority requires capacity/budget to support
for use by account providers with their agents.
anti-counterfeiting training and enforcement.
2. Account providers required, as part of AML/CFT/Fraud • Training facilitates identification of issues, investigation,
training programs, to institute and monitor agent and apprehension of counterfeiters.
compliance commensurate with perceived risk. • Active program will deter use of agents to pass
counterfeit notes.
3. No regulatory response to counterfeit currency in • Increasing circulation of counterfeit currency.
circulation. • However, agents have a vested interest in identifying and
rejecting counterfeit notes since these would be rejected
if deposited in the agent's bank account.

Policy Narrative:
As international authorities dealing with this issue reiterate, the crime of counterfeiting national currency is as
old as the creation of money itself. With the advent advanced personal computer graphics programs and low-
cost, high quality photographic and printing technologies and equipment available to the lay person, the ability
to reproduce complex images on paper stock has never been easier. The resultant effect of this bogus
currency introduced into circulation poses problems not only for national economies, but also for financial
institutions, consumers, and economies worldwide. The intersection of mobile financial services and the use
of national currencies, in this regard, pose similar need for international cooperation and private/public
partnerships. These may be encouraged through such law enforcement organizations as INTERPOL, which

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3.6. Risk (Agents): Options Implications
“Agent pays out cash that proves to be counterfeit. to be evaluated.
5. No regulatory oversight or training by account provider • Increased circulation of counterfeit currency.
Description: of agent
Agent may pay out counterfeit currency received from customers without realizing it is counterfeit. Agent
may use cash-out payments to distribute counterfeit currency. Agents may "get rid of" counterfeit currency Policy Narrative:
they realize they have taken in by passing it on. As international authorities dealing with this issue reiterate, the crime of counterfeiting national currency is as
old as the creation of money itself. With the advent advanced personal computer graphics programs and low-
Objective: cost, high quality photographic and printing technologies and equipment available to the lay person, the ability
¾ Passing counterfeit currency, whether as cash outs to e-payments or as change on trade purchases, is a to reproduce complex images on paper stock has never been easier. The resultant effect of this bogus
criminal issue for the police, not a regulatory issue. currency introduced into circulation poses problems not only for national economies, but also for financial
¾ However, account providers should provide agent training on counterfeits, as for 3.4. institutions, consumers, and economies worldwide. The intersection of mobile financial services and the use
of national currencies, in this regard, pose similar need for international cooperation and private/public
partnerships. These may be encouraged through such law enforcement organizations as INTERPOL, which
Policy Table: maintains expertise through their Counterfeit and Security Documents Branch (CSDB), providing forensic
Options Implications support, operational assistance, and technical databases to assist the 188 member countries of INTERPOL
1. Regulatory authorities should provide mechanism for • Reporting facilitates identification of issues, investigation, regarding counterfeit national currencies66
reporting, retrieval, and criminal investigation of suspect and apprehension of counterfeiters.
counterfeit notes. • Regulatory authority requires capacity/budget to support Market Examples:
anti-counterfeiting training and enforcement. • Kenya: “Sec. 373 Any person who – (a) utters any counterfeit coin knowing it to be counterfeit, and
2. Regulatory authorities to provide an incentive, or at the time of such uttering has in his possession any other counterfeit coin; or (b) utters any
• Financial incentives can increase cooperation of agent
reward, system for reporting and retrieving counterfeit network in identifying and pursuing counterfeiters. counterfeit coin knowing it to be counterfeit, and either on the same day or on any of the ten day
currency, possibly including cash payments. next ensuing utters any other counterfeit coin knowing it to be counterfeit; or (c) receives, obtains
• Regulatory authority requires budget to support
or has in his possession any counterfeit coin knowing it to be counterfeit, with intent to utter it, is
incentive program.
guilty of a felony and is liable to imprisonment of three years.”67
• Financial rewards may encourage agents to collaborate
with counterfeiters; however, authorities will monitor
Risk Type:
agents more closely that consistently turn in counterfeits
MNO Bank Hybrid
for reward. International Systemic Operational Reputation Liquidity Legal
Model Model Model
3. Account providers required, as part of AML/CFT/Fraud • Training facilitates identification of counterfeit currency x x x x x x x
training programs, to institute and monitor agent and deters acceptance/distribution.
compliance commensurate with perceived risk • Agents may recirculate counterfeit currency if not
incentivized or required to report it.
4. Regulatory authority or account provider could reward • Reward could provide the incentive for identification and
agents for identifying counterfeit currency or providing the disincentive for passing the currency along.
information on counterfeiters. • Agents with frequent identification would need
monitoring to ensure they were not involved in a
counterfeit scheme.
• Cost/capacity to implement such a scheme would need

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3.7. Risk (Agents):
“Provision of credit to agents by non-bank actors

Description:
Network models allow super agents/master agents to extend liquidity in the form of e-money directly to
agents with no controls or oversight.

Objective:
¾ Liquidity needs of account providers should be balanced with consumer protection for agents so that
extension of credit does not become a vicious cycle.
Risk Type:
Policy Table: MNO Bank Hybrid
Options Implications International Systemic Operational Reputation Liquidity Legal
Model Model Model
1. No regulatory action • Agents and super-agents will manage their own credit x x x x
needs and indebtedness, as any small business.

Policy Narrative:
Most agents are responsible for maintaining a balance of cash to service their customer base’s needs. As such,
some may seek credit from moneylenders, or other credit providers, risking potential over-indebtedness.
However, the market, overtime, will sort out the competent agents from those that cannot manage their
responsibilities. Agent liquidity requirements or service levels may lead providers to play a more proactive
role in liquidity management, which could result in their providing credit to super-agents, employing super-
agents and providing them with budget for liquidity management—see 1.9 for more on agent liquidity issues.

Market Examples:
• Tanzania: Vodacom received GSMA’s MMU grant to support M-PESA aggregator agents to
overcome liquidity issues experienced by lower-tier agents. It may be several days before agents
receive e-money transfers to phones, because the electronic money moves from the local bank,
through the agent aggregators, to the M-PESA bank account before it appears in the agent’s m-wallet.
To overcome the delay in step 5 (see diagram below), Vodacom provides credit to its aggregators,
who are responsible not only for the selection, supervision and training of the local agents, but also
with supplying them with electronic money without requiring advance payment prior to providing the
electronic float. This is supposed to increase the agent’s float, while simultaneously covering the cost
of credit to the agents and client satisfaction/increasing transaction volume. 68 A USAID interview
with a local super agent confirmed the need for this practice.69

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4.1. Risk (Account Providers): (i.e. daily settlement and fraud protection, which would identify unbacked balance increases or account set-
“Provider employee manipulates agent credit allowances, agent e-money balances, or customer e-money ups), such liabilities could go unnoticed, as the trust fund would not routinely be fully drawn down. Employees
balances for financial gain. should be subject, whether by regulatory requirement or firm policy, to due diligence screening which would
identify those with a criminal history. Further, fraud insurance could be purchased to hedge against such
Description: behavior. Again, either by regulatory requirement or firm policy, internal controls should be in place that
An insider with access to financial systems manipulates balances for his/her own financial gain. would quickly identify cash-in transactions that were not backed by physical currency. Daily settlement across
the agent network should highlight any anomalies and allow for investigation. With the legal and reputation
Objective: risk that exists, service providers have no incentive to manipulate mobile money balances; however,
¾ Account providers responsible for their own internal security as a cost of doing business. Not a regulatory employees may attempt to do so at their employer’s expense. As such, regulators and providers must be
issue unless a) defalcations threaten the financial viability of the service, possibly providing a systemic diligent in establishing the proper controls that can mitigate the potential for any systemic impact.
impact, or b) service providers’ customers are impacted, in which case the regulator has a consumer
protection interest. Market Examples:
• Philippines: In writing how to protect against fraud and system abuse, a recent GSMA study
recently cited the fact that “well-trained agents are the first line of defense.” A Central Bank
Policy Table:
requirement is for agents to receive a full day of training and the bank, in conjunction with SMART
Options Implications
Money, provides such new agent training. Back-end transaction monitoring was instituted and can
1. Regulatory authority requires providers to • Insurance will mitigate the risk of providers and the assist to identify other forms of fraud. GCASH implemented a sophisticated fraud monitoring
• obtain fraud insurance to protect against insider threats financial system against significant fraud risks. technology solution which screens billions of transactions, identifying suspicious transaction patterns
and • Legal system must have the authority to arrest and and flagging them for further investigation.70
• maintain 1:1 e-money reserve requirement in trust prosecute those who committed the fraud. • Pakistan: The State Bank of Pakistan (SBP) has regulatory authority over the payment systems that
account. • Fraud insurance may not be available or may price process payment instruments and e-money under the Payment Systems and Electronic Fund Transfer
Depending on the liability loss, enlist law enforcement. providers out of entrance into the market Act (2007), Section 3. This Act defines electronic money : “e-money is transferred through an
electronic terminal, ATM, telephone instrument, computer, magnetic medium or any other electronic
2. Providers implement institution specific fraud detection • Fraud detection allows for issue identification,
systems
device…” The ACT also provides a range of institutions, not only banks, which may apply to issue
investigation and prosecution.
electronic money, thereby becoming, “electronic money institutions.” The Branchless Banking
• Variance across institutions may let criminals target Regulations dated March 31, 2008, however, provide that those regulations do not apply to e-money,
weak systems; however, competition will allow for
though there are provisions that do address risks posed by wireless networks. 71
innovation.
3. No required regulatory response to insider employee • Small-scale insider manipulation is unlikely to have much Risk Type:
provider fraud. impact MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
• Systemic fraud by insiders could damage the stability of Model Model Model
the financial system and will significantly damage the x x x x x x x x x
reputation of the mobile system.

Policy Narrative:
Fundamental to most business models is the integrity of the employees. However, without proper safeguards,
employees may be tempted to steal from their employer. If an employee of a service provider set up new
mobile money accounts with mobile money balances which were not backed by currency, they could use that
mobile money, whether through a cash-out, merchant purchase, or person-to-person transaction, and create a
liability for the service provider. In effect, they are stealing from their employer. Without proper safeguards

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4.2. Risk (Account Providers): Options Implications
“Provider fails to adequately select, train and supervise agents and super agents.” 4. No required training or licensing process for agents • Agent selection entirely up to the account provider.
• Lax screening and/or inadequate training could result in
Description:
service quality problems.
Agents acting on behalf of a account provider can damage the account provider’s business reputation, both
with the public and with the regulator if they act improperly.
Policy Narrative:
Objective: Training programs not only assist in protecting the financial account provider’s reputation and the integrity of
financial systems, they also reduce the likelihood of these institutions becoming a vehicle for or a victim of
¾ Account provider agent selection, training and supervision policies and procedures are acceptable to the
financial crime and suffering consequential reputational damage through the uninformed actions of their
regulator, subject to verification of compliance.
employees or designated third party account providers and agents. Additionally, such programs comprise an
¾ However, this is primarily a business management issue rather than a regulatory issue unless agent essential part of sound risk management (e.g. by providing the basis for identifying, limiting and controlling risk
performance problems become flagrant. Regulator may mandate KYC/CDD as a component of sound exposures in assets and liabilities, including assets under management). Providers, or their designees, should
AML/CFT programs. not only establish the identity of their customers, but should also monitor account activity to determine those
transactions that do not conform with the normal or expected transactions for the financial footprint of that
Policy Table: customer. Not only should KYC be a core feature of the provider’s risk management procedures, it should be
Options Implications facilitated by the education of staff and complemented by regular compliance reviews and internal audit. A
1. Regulatory authority trains and licenses agents to ensure • Training and licensing can help to ensure a base capacity tiered approached to KYC/CDD is prudential based on the perceived degree of risk.72
capacity. among agents.
• Regulatory ownership or training licensing is high cost
Market Examples:
and requires capacity that the regulator is unlikely to • Indonesia: The Money Transfer Regulation of 2006, requires a nonbank e-money provider to obtain
have. a remittance license to offer P2P transfers, both domestic and international. Administrator is a
person or entity that acts as a remitter agent or beneficiary agent of a money transfer, while an
2. Regulatory authority requires provider to institute an • Training helps to ensure greater competence among the Operator merely provides the facility or system used for the transfer and/or performs the act of
AML/CFT/anti-Fraud training program which incorporates agent network, and thus a stronger, more stable mobile
KYC/CDD guidelines. Training, compliance monitoring,
receiving or forwarding data and or information from one Administrator to another. This regulation
payment system.
and registration of agents is required by account provider. does not permit Administrators to undertake money transfer activities through their owned
• The agent may not have sufficient training, resources or networks or those provided by an Operator, or through a network of agents. Thus, the use of
motivation to follow prescribed guidelines without
agents by non-banks is prohibited. Neither does the Regulation permit money remitters to conduct
threat of penalty or termination of agent relationship for
non-compliance. transactions through their agents. According to CGAP, “Current regulations would require every
airtime dealer to apply individually for a remittance license, unless the airtime dealer is a ‘branch
• Regularity verification of training program is low cost
office’ of a money remittance license holder.”73
and requires low capacity.
• Kenya: The Registration of Persons Act requires all Kenyan citizens reaching the maturity of 18
3. Provider institutes training program that certifies an • Training helps to ensure greater competence among the years to be issued a national ID card after registering with the National Registration Bureau. This
agent according to policies and procedures of the company agent network, and thus a stronger, more stable mobile provides a unique identifier in Kenya.74 For KYC purposes, the M-PESA agent collects the name,
for KYC/CDD; may encourage agents to adopt sound payment system. identification number (national ID or passport number), ID type, and date of birth of each user at the
business practices and follow government guidelines for • The agent may not have sufficient training, resources or time of registration and enters this information into an electronic database. Safaricom retains this
KYC/CDD. motivation to follow prescribed guidelines without data for 10 years. Unless a fraud complaint or a high transaction occurs, the national ID is not cross
threat of penalty or termination of agent relationship for referenced against the National Registration Bureau Database. In terms of the transactions on M-
non-compliance. PESA, the data captured includes whether an agent was used and whether or not it was with a
• No regulatory oversight of training program may allow registered or unregistered M-PESA user. MNOs track every transaction detail on their network,
sub-optimal programs.

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whether call or text, forming the call detail records. This includes the date and time the call started
and ended, the number dialed, if it was caller initiated or roaming, etc.75
• Palestine: According to the Palestinian National Authority, The President, Anti-Money Laundering
Decree Law of 2007, financial institutions and nonfinancial businesses and professions should institute
and implement programs to prevent money laundering, which include, among other activities, the
“ongoing training of officials and employees to help them identify transaction and actions linked to
money laundering and to know the procedures which they must follow in such cases.”76
• South Africa: Questions regarding outsourcing arrangements were addressed in guidance provided
by a 2004 South African Reserve Bank (SARB) circular. While the circular does not specify which
bank functions may be outsourced, it does clarify that the internal audit function may be outsourced
on a case-by-case basis only and the compliance function may not be outsourced at all for a bank.
Banks are left with discretion over outsourcing arrangements provided that the agreements are
legally scrutinized and services are adequately performed in accordance with the institution’s internal
policies and procedures. This may include access to the outsourced entity by both the bank’s internal
and external auditors, as well as external agencies and SARB on outsourced functions and activities.77
• Zambia: One provider indicated a multi-tiered approach to agent selection and training, which
included reviewing initial selection of the location, reputation ID, verification of the physical address,
bank account, business license, as well as training on KYC documentation, account opening and
maintenance, and assignment of a Customer Care Representative for ongoing support. The agents
are also tiered as to service offerings: the top tier agency is a standalone location capable of
supporting itself through cash in/cash out transactions and may obtain start up loans; the second tier
is placed in strategic locations, such as service stations, where other cash-related business may
support the agency; the third tier is reserved for those areas where the cash flow may be
constrained, with low-end transactions of $100 or less.78

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x

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4.3. Risk (Account Providers): establishing customer relationships. In the absence of a national customer ID, national authorities may provide
“Account provider or provider’s agent does not meet required regulatory responsibilities for AML.” for alternative ID instruments to comply with these requirements. All ID requirements should pay special
attention to money laundering and terrorist financing threats that may arise from the anonymity of new or
Description: developing technologies.

Depending on the division of responsibilities, some AML procedures could be carried out by agents. Agents Simplified or reduced CDD measures could apply to the beneficial owners of pooled accounts held by
are generally not employees of the account provider and thus are related only through contractual designated non financial businesses or professions, in the event such individuals are subject to AML/CFT
arrangements. If roles are not clearly stipulated and enforced, compliance can be difficult. requirements and related monitoring. The Basel CDD paper may provide guidance to financial institutions
Objective: holding such accounts as well (see Section 2.2.4).79 In the absence of a national customer ID, Banks, MNOs
and agents should have policies and procedures in place to address specific risks associated with new or
¾ Account providers complying with such regulatory oversight as provided in law and regulation, including
developing technologies that permit remote and non-face-to-face business relationships and transactions, in
effective suspicious transaction reporting.
addition to any risks associated with the nested agent relationships that might obscure customer identities in
¾ Predictable and enforceable penalties for non-compliance sufficient to motivate routine compliance. the payment chain.

Policy Table: Market Examples:

Options Implications • Cambodia: WING is a payment platform wholly owned by ANZ Banking Group, which partners
1. Regulatory non-compliance results in corrective action • Penalties will create disincentive for non-compliance. with ANZ Royal to hold client deposits. It launched an m-banking, USSD solution with SMS receipting
and fine. Repeated non-compliance or significant instances in January 2009 that is capable of working with any MNO. WING currently offers airtime top-ups, bill
• Implies that the regulatory authority has sufficient staffing
of non-compliance will lead to a cease and desist order to payments, and money transfers, and has partnered with five telcos in Cambodia. WING continues to
and financial resources available to demonstrate effective
the account provider. enforcement. engage the National Bank of Cambodia (NBC) since electronic money legislation is still being
developed and keeps in close contact with the bank regarding this. In the meantime, it WING
2. Provider’s agent agreement allows for termination for • Termination threat will create a disincentive for agent operates under a letter of no objection issued by NBC.80
non-compliance. non-compliance. • India: Under the Prevention of Money Laundering Act of 2002, the law issued AML guidelines,
• Despite contractual obligations of the agents, ML/TF including KYC standards. Banks were advised to tier customer risk according to low, medium, and
risks will remain if not appropriately monitored by high, adjusting account ID requirements. Reserve Bank of India’s 2005 Circular relaxed the proof of
account provider and enforced by regulatory authorities. residence requirements of small value accounts, permitting identity and address verification via
3. No civil or criminal penalties for provider or provider’s • Enforcement of AML problematic, increasing risk of introduction by another account holder who passed full KYC in at least the preceding 6 months.81
agent for non- compliance FATF censure. • Kenya: Under Kenya’s Registration of Persons Act, citizens 18 or over must register with the
National Registration Bureau and obtain a national ID. Failure to do so is a crime. Individuals
Policy Narrative: obtaining citizenship by birth only need to demonstrate that one parent is a Kenyan citizen, usually by
One risk-based approach is known as point-based KYC. This approach may be less restrictive for both agents presenting a parent’s national ID. However, for Nubians, Kenyan Somalis, and coastal Arabs, the
and consumers, as it presumes the more KYC evidence a customer can provide (ranging from a national ID, standard is stricter. Registration officials have broad discretion under Section 8 of the Registration
passport, physical presence, utility bills, introduction by other clients, driver’s license, etc.), then the more Act, which permits officers to require an applicant to produce additional evidence. The Principle
proportional the risk is to the institution. Services are then offered on a basis proportional to the perceived Registrar may demand proof of "other particulars as may be prescribed (Section 5)." Moreover,
risk. under Kenyan citizenship law, women cannot pass nationality to their children. Children of “unknown
origin” or who might otherwise be stateless, including some orphans and street children, are not
Chatain et al identified several innovative risk mitigating factors in mobile banking and securities accounts, or automatically granted Kenyan nationality.82 Refugees cannot naturalize, increasing the risk of
those similar to other electronic channels such are utilized in electronic banking channels for Internet banking statelessness over time. In terms of flexible ID requirements for users, account provider M-Pesa
and ATMs. National authorities may standardize national public identification to facilitate documentable accepts a national ID, a passport (Kenyan or foreign), Alien certification, and military or diplomatic
measures to verify the customer and/or beneficial owner’s identity when conducting transactional activity or IDs. It is also is considering lowering the minimum age of its users from 18 to 16 with parental
consent.83

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• Korea: According to one study, TelCos in many jurisdictions where m-FS predominates did not
sufficiently perform CDD on non-residents; it is recommended that enhanced KYC and CDD be
performed for such customers similar to the manner in which banks perform such measures. In
Korea, there are comprehensive procedures in place for mitigating the risks of anonymity with
cooperation between the banks and the TelCos. To conduct m-FS, a customer must hold a bank
account, travel in person to the bank branch and provide ID (a valid passport for foreign citizens), and
complete a funds transfer form in order to receive access to e-banking. Upon completion of these
steps, an ID and password are issued to the customer, as well as a letter permitting the customer to
obtain a SIM card from the TelCo. Service for m-FS is available only to post-paid individual
subscribers, rather than corporate entities.84
• Zambia: Engaging regulators by sharing information on technologies and proposed AML, KYC/CDD
procedures at each stage of product initiation has provided nonrestrictive environment for mobile
financial services to develop. For instance, under the auspices of the AML directives of 2004, the KYC
procedures allow for the use of alternative verification methods when identifying a potential bank
customer. Opening an account, the law requires a national registration card, driver’s license, or
passport, and proof of name and address. Flexibility is permitted in that once a customer receives
his/her identity document, another bank customer, the potential customer’s employer, or a village
chief can verify his/her identity.85

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x x x

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4.4. Risk (Account Providers): Options Implications
“Trust fund is inadequately funded.” current global practices and dilute the incentive
for service users to open a formal bank account.

Description: 4. No regulatory action. • Customers may lose mobile money balances if

account provider is not managing trust accounts
The account provider fails to adequately fund the trust account, thereby making the trustee inoperative.
appropriately.
A trustee’s fund investment strategy fails to conserve the fund’s value.
Policy Narrative:
Objective: The non-bank account provider is responsible for ensuring that funding of the trust account covering the value
¾ Trust funds are regulated and supervised similar to insurance reserve accounts to ensure adequate of payments in transit is adequate to cover the sum of the value of those payments. The trustee's primary
coverage of trust liabilities. responsibility is to protect the value of those funds in the trust account to ensure that no losses are incurred
that would impair that coverage. It is incumbent on the account provider to chose a qualified trustee, and on
Policy Table: the trustee to develop and comply with a sound investment strategy that will ensure that the value of the trust
Options Implications account is preserved and that the trust account provides adequate liquidity to ensure that all payment
obligations can be honored. In its Examiner’s Guide to Problem Bank: Identification, Rehabilitation, and Resolution
1. Regulatory authority requires minimum1:1 reserve • Reporting requirements allow banks/providers to document, the U.S. Comptroller of the Currency noted prior to the recent financial crisis that the increase in
requirement which is monitored through daily/weekly demonstrate to regulators and consumers their
reporting with tiered enforcement options, including fines national bank securitization activity and the proliferation of capital markets products had shifted increasing
stability and soundness by meeting their
for non-compliance. requirement. The frequency of the reporting levels of credit risk to off-balance-sheet transactions. The credit risks inherent in capital market products, such
creates greater assurance, and thus lower risk. as asset securitizations and derivatives, is difficult to quantify due to the need to assign a credit risk equivalent
to these types of instruments. A bank that engages in securitizations needs to be fully aware of relevant risk-
• Reporting requirements will impose a cost on
banks/Account Providers. based capital rules applying to these transactions. As part of its overall internal controls and risk management
policies, senior management and its supervising board of directors should include an assessment of off-balance-
• Frequent reporting requirements could create a
sheet and any other indirect exposures when determining the overall quantity of risk assumed by the financial
capacity issue for regulators that do not have the
staff to review reports and monitor compliance. institution that is custodian of a trust account. Moreover, both parties should ensure that all valuation
methods and key assumptions used to value the residuals and servicing assets and liabilities associated with
2. Regulator requires trustee to be bonded to cover the • Bonding will diversify the exposure of trust management are reasonable, fully documented, and well supported.86
performance risk. stakeholders; however, the cost could create a
barrier to entry. If the cost is passed on to Market Examples:
customers, the adoption/usage rate might slow.
• Please Note: A market example of a policy action associated with this risk was not identified during the
• Bonding costs could be covered by the interest literature review or the in-country consultations included in this project’s scope. We welcome your suggestions
that the trust accounts generate. of relevant examples for inclusion in subsequent versions.
• Monitoring and enforcement will focus on the
acceptability of the bonding (insurance) company Risk Type:
and the coverage provided. MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
3. Regulatory agency creates a new type of deposit • Not needed for bank Account Providers Account Model Model Model
insurance at the payment account holder level. Providers, since funds already on deposit in x x x x x x x
covered bank accounts.
• For cell-phone based Account Providers Account
Providers with pooled trust funds, this would
substantially expand deposit insurance beyond

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4.5. Risk (Account Providers):
“Agent fraud untraceable due to poor records.” There is no consensus on how to implement standards internationally, though the majority of TelCos perform
some KYC and CDD measures as best business practices.88
Description:
Lax or non-existent record keeping of transactions by agents creates challenges for providers trying to Market Examples:
research fraud issues. Transactions may be commingled among merchant receipts, possibly leading to fraud • Kenya: In a recent presentation entitled “10 YEARS ON FROM THE US EMBASSY BOMB BLAST”
and agent employee theft. in Nairobi, Kenya,”89 Director Samuel Mutungi provided a case study on lessons learned for terrorist
attacks regarding disaster recovery and business continuity planning for financial services. One of the
Objective: main mitigating strategies aiding in recovery for Co-Operative Bank, despite the fact that the ICT
¾ Agents able to document their mobile financial transactions. equipment was damaged and networks/systems were destabilized, was that the Bank’s systems back-
up e.g , redundancies, had recently been moved off site.
¾ Account Providers able to support police investigation of complaints of fraud.
• South Africa: The South African Financial Intelligence Center Act (FICA) permits electronic record
¾ Regulatory involvement only in cases of systematic failure of account provider to ensure its agent network keeping and outsourcing to third party intermediaries. For MTN group, the South African
operates within reasonable bounds. telecommunications company, client identification records are collected by agents, but forwarded to
the main office for verification and retention.90 Value in mobile financial transactions, at some point in
Policy Table: the transfer, is typically stored on the computer servers of account providers or financial institutions.
Options Implications These servers, however do not have to reside in the country of originating activity. This may or may
1. Regulatory authority requires agents to maintain paper • Audit trail requirements will discourage fraud, not create concerns for national regulators in terms of evidence collection, search, seizure, asset
records for a time period (consistent with other financial but may increase operating expenses and may forfeiture/sharing, and information sharing.91
records) to support account provider’s electronic records not be complied with, particularly if fraud is • Philippines: The use of new and developing technologies, such as the intersection of information
for investigation purposes. involved. and communications technologies and financial services, raises new areas of consideration in terms of
• Account provider’s electronic records may be records retention and retrieval. In the “Effects of Cell phone on Anti-Money Laundering/Combating
sufficient and more reliable. Terrorism (AML/CFT) Wire Remittance Operations”92 which examined mobile financial services
practices in the Philippines, the author cites several emergent safety and soundness factors:
Account provider operating and record keeping • Generally in account provider’s own interests to
procedures developed, in concert with regulators, to ensure transaction audit trails.
i. Tests of electronic systems security, hardware, and software,
support investigation in case of agent fraud. ii. Tests of customer ID and point-of-sale samples,
• Providers will determine the degree of fraud iii. Anti-virus protection,
protection on an institution by institution basis.
iv. Internal security policies and procedures for electronic systems,
v. Cross industry and regulatory collaboration in records involving text and SIM cards,
Policy Narrative: and
In some cases, particularly when the service links “traditional” bank channel accounts to TelCo partners, vi. Critical infrastructure protection for the telecommunications and the financial sectors.
AML/CFT obligations likely reside with the bank, as the primary financial institution responsible for providing
m-FS. However, when the TelCo can be a channel through which other services are provided and the Customer Detail Records: Mobile financial account providers maintain customer activity records
merchant can also receive payments and conduct non-bank account transfers, the line between financial and (Customer Detail Records) similar to financial institutions and payment system providers. These
telecommunication providers blurs. detailed customer records relate to the mobile operator’s system usage and include information
Chatain et. al posit that TelCos and some other non-bank entities providing m-FS should be included within relevant to AML and CFT, such as each mobile calls originating and receiving phone and the call’s
the regulatory definition of “financial institutions” when according to FATF these TelCos function as: “any duration.
person or entity who provides its customer with transfer of money or values services, or issues and managers • Malaysia: In Malaysia, Maxis maintains ongoing transaction records for active customers and for
means of payment, inter alia, electronic money.” This broad definition would permit the TelCo’s AML/CFT terminated customer retains them for an additional seven years.
to comport with the actual role it performs within the financial or non-financial sector.87

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• Hong Kong: In Hong Kong SAR of China, AML regulations for mobile account providers require
that records be maintained on all transactions over HK $8,000, however transactions below this
figure are recorded in the mobile service provider systems, too.93
Safeguarding electronic customer and business data: avoiding data leaks, and maintaining high –
quality IT systems is a critical business enabler in records retention efforts for AML and CFT. In light
of recent data leaks, e-finance regulations are emerging.
• Macao SAR: For instance, Banks in Macao SAR of China do not permit m-FS transfers outside of
the same bank or internationally.
• Philippines: The Philippines caps m-FS transactions per day and per month in order to mitigate ML
risks.94
• Indonesia: The Bank of Indonesia’s Circular Letter 10/49/DASP outlines requirements for money
transfer services conducted by nonbanks, requiring that individuals and entities apply for a money
transfer license to provide not only their risk management procedures, including KYC. KYC must
include verification of both sender and recipient at the time of the funds transfer (via government
issued ID, driver’s license, or passport). Additionally, the sender and recipient must be re-verified in
the event the transfer exceeds IDR 100,000,000 (approximately USD 8,600), any suspicious
transactions are detected, and there is concern as to the veracity of sender/receiver provided
information. Additionally, nonbank providers must ask for information about the source of funds, as
well as the purpose of the funds transfer; and have appropriate information systems in place for
monitoring, analyzing and reporting transactions in which they engage and reporting suspicious
transactions to the Financial Intelligence Unite and Financial Transactions and Reports and Analysis
Center (PPATK)95

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x x

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4.6. Risk (Account Providers): Options Implications
“System availability cannot be maintained by account provider.” access. the duration when a failure occurs.
• Should be supported by documented alternative
Description: access procedures in the event of system failures
for providers.
Customers will seek other providers, and potentially regulators will take action, if providers are unable to
effectively maintain their system availability. • Lack of regulatory requirement will allow each
institution to define the extent of their
contingency planning, which may leave some less
Objective: protected than may be appropriate for a payment
¾ Account provider’s services reasonably consistently available during normal business hours. system. However, it will also allow individual
institutions to innovate.
¾ Continuation of operating license contingent on maintaining reasonable service.
Policy Narrative:
Policy Table:
The core components of any payment system must ensure availability, capacity, operational continuity, and
Options Implications security to the public that is being served. This may necessitate both integrating existing technologies in new
1. Regulatory authority mandates system redundancy • Redundancy and continuity will mitigate the risk ways, as well as providing interoperability among new actors with innovative technologies. The National Fire
requirements and disaster recovery to ensure continued of system availability and limit the duration when Prevention Association NFPA 1600 defines Business Continuity Program (BCP) in its general definitions as
financial system access, particularly for significant Account a failure occurs. follows: An ongoing process supported by senior management and funded to ensure that the necessary steps
Providers. • Documented alternative access procedures in the are taken to identify the impact of potential losses, maintain viable recovery strategies and recovery plans, and
event of system failures for providers. ensure continuity of services through personnel training, plan testing, and maintenance. An enhancement to
• Regulations that focus on achieving the objective NFPA includes recovery actions, which often extend long after the incident itself and the related programs,
rather than prescribing specific procedures will should be designed to include mitigation components for avoiding damage from future incidents.96 Contingency
enable account providers to innovate to provide plans for e-government can mitigate the risks of external events, specifically if the BCP encompasses resilience
the least cost solution. in communications and financial services via mobile banking and payments.
• Implies the regulator has, or can procure, the
technical expertise to validate account providers' Market Examples:
contingency plans. • Brazil: All clearing and settlement account providers are either banks or entities controlled by
2. Regulatory authorities permit off-shore data hosting • In some jurisdictions where the infrastructure is weak, banks, with the largest ATM and POS networks controlled by the largest banking conglomerates.
and/or backup. hosting data records in a more developed jurisdiction Access to these systems is self-regulated, with oversight by the Central Bank of Brazil (CBB). The
may be necessary to ensure adequate data security and interoperability among the 25 ATM and 4 POS networks, as well as the dominance of the large banks,
integrity. is driving small and medium sized institutions to create an independent automated clearing house
• Can reduce operating expenses (and service fees) (ACH) for low value payments, including mobile banking. While in the nascent stages, it is
by facilitating economies of scale. nonetheless encouraged by CBB.97
• May require availability of fiber optic connections • El Salvador: The Central Reserve Bank (BCR) has broad regulatory authority over check
to ensure adequate band width. clearinghouses and other payment systems used and operated by financial institutions; however there
• May require agreement with hosting country is no national payments law in El Salvador. El Salvador is a signatory to the Central American Treaty
regulator to verify compliance with data safety on Payments, under which BCR maintains oversight of what it considers to be systemically important
and security requirements. payment and settlement systems. BCR also defines the parameters of high and low value payments
under the Treaty terms and conditions, though the Treaty does not specifically cover retail payments.
3. Providers establish their own redundancy requirements • Redundancy and continuity planning will mitigate
and disaster recovery to ensure continued financial system
The issuance of stored value instruments, such as prepaid cards and mobile banking, have not been
the risk of failure in system availability and limit
clarified within the context of the regulatory framework for payment services.98

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• South Africa: Under the auspices of The South African Reserve Bank Act, the South African
Reserve Bank (SARB) is authorized to “perform the functions, implement the rules and procedures,
and in general, take the steps necessary to establish, conduct, monitor, regulate, and supervise
payment, clearing, and settlement systems. Access to the national payment and settlement systems is
restricted to banks only, with non-bank actors able to access the system via joint ventures with banks
that are existing members. Under the National Payment System Act of 1998, SARB can delegate its
responsibilities to a self-regulatory industry body, while retaining oversight control, and has done so
with respect to the Payments Association of South Africa (PASA); PASA has appointed Bankserv as
the payment clearinghouse for the South African banking industry and Bankserv provides interbank
electronic transaction switching services to the banking sector. The switching services are majority
owned by the countries four largest banks, ABSA Bank, First National Bank of South Africa (FNB),
Nedbank, and Standard Bank, with 90% of the market. 99

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x

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4.7. Risk (Account Providers): Options Implications
“Agents are consistently out of cash.” management.
3. No oversight for agent liquidity • Customers may be unable to withdraw cash from
Description:
mobile money accounts from time to time, when
Without effective cash forecasting mechanisms, agents may have difficulty managing their cash needs. Not only agents run out of cash.
will this reduce the benefit of the service for customers, it will also damage the reputation of the
• Market forces will improve liquidity management
service/provider.
over time, as account providers keep reliable
agents, take on some agent responsibilities, or
Objective: partner with other institutions as agents of last
¾ Agents have sufficient cash on hand to support most cash-out requests. resort.
¾ Account providers support agents with cash management and forecasting.
Policy Narrative:
Policy Table: This risk refers to the amount of capital (both cash and e-money) held by agents, available for cash in/cash out
Options Implications transactions. In many mobile financial services systems, agents are the primary human interface with the
consumer. Initial consumer confidence in a MFS system is, to a large degree, contingent on their ability to
1. Regulator mandates liquidity requirements for • Requirement may enhance access to cash within conduct cash-in/cash-out transactions. Consequently, maintaining a viable agent infrastructure is an important
providers. (by agent or by geographic region) The a reasonable amount of time.
provider could be required to appoint an “agent of last
element of a strong MFS system.
• Consistent shortages decrease confidence in a
resort” to ensure customer access. provider’s system. To date, MFS providers have used commercial practices (e.g., commission structures, agent vetting processes,
• Requirement could raise a cost barrier to entry prepaid e-money reserves) to drive the proliferation of cash in/cash out agents. Market forces have
as small players may not have cash determined which agents remain viable. MFS providers generally have not developed service level agreements
forecasting/cash management capabilities. (SLAs) with agents requiring them to maintain cash balances.
• Providers may decide to hire some agents as
employees, as independent agents in high-volume Recent MFS conferences (e.g., M-Banking 2009, Kenya School of Monetary Studies, May 2009) have raised the
areas may not be able to maintain balances or issue of an unregulated, ad hoc, cash in/cash out infrastructure and the impact this has had on consumer
deal with security issues. confidence. While the issue is viewed as significant, most experts agree that a regulatory solution would be
• Forecasting and management capabilities are difficult to craft and implement. The current view is that consumer demand and market forces will dictate the
similar for ATM and Branch cash forecasting/ number of agents and the operating principles that govern agent conduct (e.g., availability of cash, hours of
management. operation, etc.) Further, similar to branch and ATM channels, the market will provide cash forecasting
• Regulation implies monitoring and enforcement solutions to minimize liquidity issues.
capacity.
2. Providers forecast and manage liquidity of agent • Enhances customer access to cash within a Market Examples:
network to optimize service for consumers. reasonable amount of time, improving public • El Salvador: Under Article 1 of the Banking Law, deposit-taking, financial intermediation, and
perception of service. “other activities carried out by banks”, permits the Central Reserve Bank (BCR) to authorize other
• Providers may decide to hire some agents as operations and services. Banks are subject to regulation ranging from prudential to management and
employees, as independent agents in high-volume ownership rules, with licensing by the Superintendence of the Financial System (SupFin). However, a
areas may not be able to maintain balances or different framework governs member-based financial institutions, most of which were not subject to
deal with security issues. supervision by SupFin. This financial sector, comprised of savings and loan societies and cooperative
• Forecasting and management capabilities are associations, recently pushed for a new law allowing deposit-taking from the general public. While
similar for ATM and Branch cash forecasting/ there is no specific regulation on the issuance of e-money by non-banks, the activity by this sector is

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defined as taking deposits and intermediating those deposits. According to a recent CGAP
Branchless Banking Assessment, it is widely assumed that Salvadoran regulators would strictly apply
this definition to e-money schemes and deem such activity to be banking activity, particularly if funds
are to be intermediated. 100
• India: Acknowledging the development of the mobile channel, The Reserve Bank of India (RBI)
issued the Operative Guidelines for Mobile Banking Transactions (2008) pursuant to the Payment and
Settlement Systems Act (2007). Only banks licensed, supervised and with a physical presence in India
may offer mobile banking to their existing customers. These institutions must obtain prior approval
of RBI before launching their service offering. MNOs and nonbank financial institutions may not offer
mobile banking services. Cross-border and foreign remittances are not permitted. Daily transaction
limits are set at Rs 5,000 for transfers and Rs 10,000 for goods and services purchases. Two factor
authentication, including a PIN is required on all transactions, with a limit of Rs 50,000.101
• Kenya: A recent study on the community level effects of M-PESA on local economic activity
indicated that money circulation was the most highly ranked of all effects. It was consistently
identified by respondents (being ranked most important by men and no. 3 by women) as infusing cash
into the community via remittances where they appeared to be needed most. The higher and faster
circulation, in turn, contributed to expansion of businesses, food security, human capital
accumulation, and rescue money (emergency funds), as well as increased employment
opportunities.102

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x x x

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4.8. Risk (Account Providers): Market Examples:
“Agent contracted to multiple account providers (i.e. a cell phone provider and a bank) with different • Kenya: “GUIDELINE ON AGENT BANKING, PART VI AGENT OPERATIONS6.1 Non-
regulatory requirements (e.g. KYC) does not meet its responsibilities for one or more.” exclusivity
6.1.1. No contract between an institution and an agent shall be exclusive.
6.1.2. An agent may provide services for agent banking to multiple institutions provided that
Description:
the agent has separate contracts for the provision of such services with each institution and
When an agent contracts with more than one provider (i.e. a account provider and a bank), and the regulatory
provided further that the agent has the capacity to manage the transactions for the different
requirements differ between the institutions, the agent may confuse their responsibilities, meet the lower
institutions.
regulatory burden between the two, or not meet the regulatory requirements for either.
6.1.3. An institution seeking to contract an entity which has already been contracted by
another institution to carry out agent banking shall assess the capacity of the agent to
Objective:
manage transactions for different institutions. Due regard shall be taken to the space,
¾ Account providers to hold agents responsible for their individual contractual agreements, whether technological capacity and adequacy of funds or float of the agent.”
exclusive or not.
Risk Type:
Policy Table: MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Options Implications Model Model Model
1. Regulatory authority prohibits agents • Restricting multiple agent relations may limit competition,
x x x x x x x
from representing multiple account particularly if the first mover has locked in the most suitable agents.
providers. • Agents may not achieve adequate volumes to justify being a paying
agent is not able to link to multiple account providers.
• Difficult and expensive to monitor.
2. Providers do not permit agents to • Helps first mover justify market entry.
enter into contractual obligations with • Limits subsequent competition by locking in the most suitable
other account providers without prior agents.
consent.
• May limit agent profitability below breakeven point, limiting service
expansion.
3. No action is taken by regulatory • Agents may link to multiple account providers.
authorities or account providers • Ensures competition based on service quality.
restrict agents to a single account
provider. • May reduce incentive for first mover.

Policy Narrative:
Competition can be seen to raise productivity because it allows the most productive companies to gain
market share, thereby creating more jobs and obliging the less productive ventures to improve or concede
and close operations. Permitting agents to manage their relations on a contractual basis may encourage
competition based on service quality.

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4.9. Risk (Account Providers): Options Implications
“Individual poses as agent to collect deposits or payments from unsuspecting customers.” 4. No regulatory action • Public may not understand that account
providers are not accountable for actions of
Description: these bad actors.
If an individual poses as an agent for a account provider, they could accept deposits or payments from • Instances of fraud subject to normal police
customers and pocket the funds. The risk is likely higher in remote areas where oversight is limited, and investigation.
where financial literacy is lower.
Policy Narrative:
Objective: In conformity with FATF Recommendation 23 and Special Recommendation VI103, countries, at the national
¾ Consumers able to avoid fraud through spurious agents. and sub-national level may AML/CFT requirements that include agent registration and licensing requirements,
as well as the submission of updated registration lists to competent authorities. Registration of sub-agents may
be included. Agent registration and licensing fees vary from flat rates to a percentage of business services
Policy Table:
offered. Non-prohibitive agent registration and licensing fees should be employed to encourage compliance.
Options Implications
1. Regulatory authority requires all account provider • Increased public information of registered agents Licensing for financial account providers may be an effective way to ensure that account providers adhere to
agents to be registered. allows consumers to protect themselves by only AML and CFT procedures, prevent potentially hazardous business models from reaching the market, and
This list of registered agents published, and all registered frequenting registered agents. obtain revenue minimal operating revenues for licensing fees. In addition, such practices may assist in
agents post evidence of registration. • Implies regulatory capacity for agent registration mitigating risks in a rapidly changing market environment by helping regulators keep abreast of new entrants in
and the public information campaign. the service arena.
• Requires that account providers require each
agent to post registration at its place of business. FATF 23 mentions that “other financial institutions should be licensed or registered and appropriately
• Most susceptible consumers, those who are regulated, and subject to supervision or oversight for anti-money laundering purposes, having regard to the
financially illiterate, will be the most difficult to risk of money laundering or terrorist financing in that sector.” Though it does not specify m-FS, businesses
reach with an information campaign. which provide a service of “money or value transfer, or currency changing” are noted.104
2. Regulatory authority requires providers to publish a list • Account provider assumes responsibility for
of official agents on a periodic basis to limit the potential distributing and advertising list of its agents. Special Recommendation VI on Alternative Remittances includes licensing and registration provisions for
for fraud. persons or legal entities providing services for the transmission of money or value through informal transfer
• Increased public information of official agents
systems or networks.105 This provision has likewise been interpreted by some as applying to m-FS.
allows consumers to protect themselves by only
frequenting official agents.
Chatain et. al posit that TelCos and some other non-bank entities providing m-FS should be included within
• Most susceptible consumers, those who are
the regulatory definition of “financial institutions” when according to FATF these TelCos function as: “any
financially illiterate, will be the most difficult to
reach with an information campaign. person or entity who provides its customer with transfer of money or values services, or issues and managers
means of payment, inter alia, electronic money.” This broad definition would permit the TelCo’s AML/CFT
3. Rely on the significant consumer protection built into • During cash in, the agent will have to have enough e- to comport with the actual role it performs within the financial or non-financial sector.106
the system through electronic receipts and account limits money available to initiate the transaction and resulting
to mitigate fraud. confirmation to the service user. Market Examples:
• Transaction limits inhibit service users from acting as • Kenya: The Banking Act in Kenya defines banking business as having two key components. The first
informal agents. defines how funds are accepted and utilized by the institution and the second defines where the
• Monitoring systems flag suspicious behaviour, enabling physical location of the institution may be organized to transact business. A bank may transact
the account provider to shut down informal agents. business only at its head office, branch, or place of business, all of which can only be operated with

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the approval of the Central Bank of Kenya. CGAP notes in its examination of Kenyan banking that it
would be difficult to determine if agents would be included in the definition of a bank under the
Banking Act. Outsourcing of banking activities is not addressed in the regulations, but is approved on
a case-by-case basis by CBK. Non-bank institutions are not under the same regulatory scrutiny.107
• Brazil: In Brazil, authorities enable compliance and mitigate risk by making banks fully liable for the
acts of their agents. For instance, bank authorities have supervisory oversight as to the transaction
details and records of their agents.108 As the authors in “Integrity in Mobile Financial Services”
conclude, “Licensing/registration and ongoing monitoring of m-FS providers should be implemented.
As observed during fieldwork and recommended by FATF, licensing for financial Account Providers is
an effective way to make certain m-FS providers adhere to AML and CFT procedures and prevent
potentially hazardous business models from reaching the market.” Of particular note, the authors cite
this practice may prevent the creation of shell corporations, or front companies, which might be used
to conceal and divert funds for criminal purposes via an m-FS platform.109

In Brazil, for instance, agent networks are either managed directly by a bank or outsourced to a third
party, which is considered an agent by the Central Bank of Brazil (CBB). Network managers provide
services that range from AML/CFT training to agent selection, as well as point of sale maintenance
and cash handling. The expansive reach of agent networks enables financial services to those
individual who might not otherwise have access in Brazil and CBB oversight actually identified agent
breaches in consumer protection rules; agents were noted as not disclosing fees and charging extra
fees; selling client information to third parties; and committing loan fraud (not making bill payments
for which they had received funds), among other transgressions. Such weeding out of dishonest
actors in the system may be a facilitator of faith and trust in the public perceptions of the agent
community.110

• India: In November 2006, India took limited steps toward the outsourcing of small value remittances
and other payment instruments through business correspondents; restrictions included limiting
eligible institutions to operate as correspondents to non-profit institutions, post-offices and
cooperatives, as well as denying the ability of the correspondent to charge the customer for services
rendered on behalf of the bank. Guidelines require that the Reserve Bank of India remain responsible
for the actions of the agent as a risk mitigator, allowing RBI the authority to inspect the agent, as well
as review agent records relevant to outsourced activities.111

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x

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5.1. Risk (Trust Account Holding Financial Institutions): addressing issues of liability concentration caused by an expanding trust account.
“Liability concentration risk caused by an expanding trust account that may have a material impact on the
trustee institution’s balance sheet, particularly for those trust funds on deposit with the trustee bank.” Market Examples:
• Please Note: A market example of a policy action associated with this risk was not identified during the
Description: literature review or the in-country consultations included in this project’s scope. We welcome your suggestions
Trust funds of a successful account provider could become significant to the point of representing a funding of relevant examples for inclusion in subsequent versions.
concentration risk for the trustee bank - liquidity risk - should there be a sudden reduction in the volume of
items in transit through the account provider's system. This could be due to new competition, changes in Risk Type:
regulation, account provider decision to diversify its own risks, or civil disturbances that cause a flight to cash. MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
Objective: x x
¾ Trustee banks limit the size of trust accounts they manage to what is reasonably manageable for that
institution.

Policy Table:
Options Implications
1. Bank regulators limit risk concentrations as a normal • Concerns with managing risk concentrations may
part of their supervisory activities - this process should restrict bank interest in providing trust services.
include funds held in trust, so off-balance sheet unless held • Trust funds need investment opportunities that
in deposit accounts. provide adequate liquidity in case of rapid
disintermediation.

Policy Narrative:
The issue of liability concentration risk caused by an expanding trust account should be addressed within the
overall framework of the trust account holding financial institution’s asset-liability management, and its policies
on funding concentration and liquidity management. However, since these are moneys held in trust, the overall
management of the funds might warrant a separate, and perhaps more conservative, set of policies relative to
those pertaining to on-balance sheet liabilities. Ultimately, it is the responsibility of both bank senior
management and the institution’s Board of Directors to ensure that a sound internal control system is in place,
and in effect, to safeguard a trust account from any material risks that could adversely affect the achievement of
the bank’s goals through recognition of risks and continuous assessment.

At the level of the national regulator, banking supervisors should uphold Basel Core Principle #14 which
asserts that “banking supervisors must determine that banks have in place internal controls that are adequate
for the nature and scale of their business,” including trust account management, if applicable. In line with Basel
Core Principle 13, supervisors should require that all banks—regardless of size—have an effective system of
internal controls that (a) is consistent with the nature, complexity and risk inherent in their on- and off-
balance-sheet activities (including trust account management); (b) responds to changes in the bank’s
environment and conditions; and c) in cases where Supervisor’s determine an action or activity is not adequate
or effective for that bank’s specific risk profile, take appropriate and necessary action. This would include

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5.2. Risk (Trust Account Holding Financial Institutions):
“The reputation of the financial institution which holds the trust account for the mobile financial account Market Examples:
provider is damaged due to its mismanagement of the trust account.” • Please Note: A market example of a policy action associated with this risk was not identified during the
literature review or the in-country consultations included in this project’s scope. We welcome your suggestions
Description: of relevant examples for inclusion in subsequent versions.
The financial institution which holds the trust fund for the account provider takes on reputational risk. If the
trust funds are invested in instruments that do not conserve their value, the liability coverage provided by the Risk Type:
trust assets may become inadequate, potentially leading to a crisis in confidence in the service. MNO Bank Hybri
Internationa Systemi Operationa Reputatio Liquidit Lega Mode Mode d
Objective: l c l n y l l l Model
¾ Preserve the value of the trust funds through prudent investment management, subject to regulatory x x x x
oversight (as for insurance company reserves)
¾ The affiliation risk will be managed by the market. Banks should not enter into agreements with
mobile financial account providers with which they have concerns.

Policy Table:
Options Implications
1. Regulatory requirements govern the investment • Conservative investment strategies for the trust
instruments in which trust account holding financial funds will preserve asset values but limit
institutions may invest funds. investment income which might otherwise be
applied to offset account provider costs and keep
transaction fees low.
2. Regulators evaluate reputational risk of major trust • Adverse selection may come into play - those
relationships. banks most qualified to act as trustees may be
the most reluctant to take on the risks of doing
so.

Policy Narrative:
In its Examiner’s Guide to Problem Bank: Identification, Rehabilitation, and Resolution document, the U.S. Comptroller
of the Currency noted prior to the recent financial crisis that the increase in national bank securitization
activity and the proliferation of capital markets products had shifted increasing levels of credit risk to off-
balance-sheet transactions. The credit risks inherent in capital market products, such as asset securitizations
and derivatives, is difficult to quantify due to the need to assign a credit risk equivalent to these types of
instruments. A bank that engages in securitizations needs to be fully aware of relevant risk-based capital rules
applying to these transactions. As part of its overall internal controls and risk management policies, senior
management and its supervising board of directors should include an assessment of off-balance-sheet and any
other indirect exposures when determining the overall quantity of risk assumed by the financial institution that
is custodian of a trust account. Moreover, both parties should ensure that all valuation methods and key
assumptions used to value the residuals and servicing assets and liabilities associated with trust management
are reasonable, fully documented, and well supported.112

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5.3. Risk (Trust Account Holding Financial Institutions): Market Examples:
“The reputation of the financial institution which holds the trust account for the mobile financial account • Kenya: Several articles have been written of late that aim to distill the salient features of M-PESA’s
provider is damaged due to its association with an account provider whose payment system is poorly run.” sudden and sustained success in Kenya. 114 Others maintain that much of M-PESA’s rapid success is
directly correlated with the high level of trust which the Kenyan public places on its account provider,
Description: Safaricom, and its management. If this is true and there should be a sudden deterioration in
The financial institution which holds the trust fund for the account provider takes on reputational risk. If the Safaricom’s good fortune due even to exogenous shocks beyond its management or control, this level
account provider is poorly managed, the trustee’s affiliation with an institution that loses the public trust could of trust could correspondingly diminish and pose a strong contagion risk on the fortunes and
damage its own reputation. reputation of the financial institution holding the trust account/s that form a key link in Kenya’s mobile
phone banking ecosystem.
Objective:
¾ Preserve the value of the trust funds through prudent investment management, subject to regulatory Risk Type:
oversight (as for insurance company reserves) MNO Bank Hybri
¾ The affiliation risk will be managed by the market. Banks should not enter into agreements with mobile Internationa Systemi Operationa Reputatio Liquidit Lega Mode Mode d
financial account providers with which they have concerns. l c l n y l l l Model
x x
Policy Table:
Options Implications
1. Regulatory requirements govern the investment • Conservative investment strategies for the trust
instruments in which trust account holding financial funds will preserve asset values but limit
institutions may invest funds. investment income which might otherwise be
applied to offset account provider costs and keep
transaction fees low.
2. Regulators evaluate reputational risk of major trust • Adverse selection may come into play - those
relationships. banks most qualified to act as trustees may be
the most reluctant to take on the risks of doing
so.

Policy Narrative:
The risk identified above relates to the reputation risk brought on to the financial institution holding the trust
account on behalf of a mobile network operator (account provider) by the account provider’s poorly run
payment system. The contagion risk of the account provider is born by the bank holding the trust account. As
part of its overall risk management policy, a bank should not enter into agreements with mobile financial
account providers with which they have concerns, and they should undertake appropriate due diligence on any
prospective mobile network operator partner prior to engaging in any legally binding partnership. As is the
case with any trust and foundation establishment, when opening an account for a trust, the bank should take
reasonable steps to verify the trustee(s), the settler(s) of the trust (including any persons settling assets into
the trust), any protector(s), beneficiary (ies), and signatories. Beneficiaries should be identified when they are
defined.113

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6.1. Risk (Payment Systems): operator A can only send and receive payments from others on mobile operator A’s network, but not those
“Government mandated usage of government owned payment utility to process and clear all payment on B or C’s network. Therefore, in a “closed loop” system, customers would be weary of using the services
transactions regardless of type.” of a new player, as they would not be able to transfer/receive payments to or from individuals who are not on
their network. This phenomenon, known as “network effect,” occurs when the value of the service to each
Description: individual user increases with the overall number of the users of the service. Network effects foster the “first
Government may have invested in a national payment system designed not just for inter-bank settlements but player advantage” where a mobile operator who enters the market early is able to “lock in” customers who
to reach down to the retail level, and may seek to protect its investment by blocking development or use of seek to maximize the number of people they can connect to (assuming quality of service is high).2 This system
other payment systems. This risks blocking innovation to improve efficiency and lower payment costs. poses challenges to regulators not only because it limits the public’s freedom to choose between providers,
but it can also stifle innovation and potentially lead to anti-competitive pricing. On the other hand, in an
Objective: “open loop” system, payments are able to be made across different networks through a central “switch.”
Limit government involvement in payment systems to a) interbank settlements, and b) establishing an enabling Therefore, customers of mobile operator A (see diagram below) are not limited to only sending/receiving
environment for retail payments that encourages competition and innovation within accepted security payments to others on their network, but can also connect to customers of mobile operator B. This system
standards. of interoperability expands customers’ choice in selecting providers and fosters competition.

Policy Table: Closed Loop System

Options Implications
1. Government ownership of the payment switch • Interoperability creates benefits to consumers, as
effectively requiring any existing and new account provider they can transfer to any other consumer
to connect to and use the system for its payment services. regardless of network. Mobile Mobile Mobile
• If government perceives a profit opportunity, Operator A Operator B Operator C
rather than a public good, monopolistic pricing of
the transaction could ensue.
• There is no incentive for a new technology
innovations since the government requires all
transactions to be processed through the system
2. Mobile financial account providers allowed to use • Market pricing Open Loop System
whatever payment system best serves the needs of their • Incentive to innovate processing systems and
clients. reduce transaction costs
• Interoperability will be market driven. Mobile Mobile
Operator A Operator B
Policy Narrative:
When there is a lack of interoperability requirements or a strong competition agency present, it is not
uncommon for a single mobile operator to dominate the market. According to CGAP, “The mobile industry is
an oligopoly, especially in developing countries, where the smaller market size may justify only two or three Central “switch”
competitors. Having these players dominate the branchless banking market may not be a palatable option for connecting two
banking regulators and competition authorities alike.”1 Market domination by a single entity is commonly seen networks
in countries which have a “closed loop” system of mobile banking (see diagram below). Customers of mobile

1
Ivatury, Gautam and Ignacio Mas (2008) “The Early Experience with Branchless Banking.” CGAP, Washington DC.
2
[Online] http://www.cgap.org/gm/document-1.9.2640/FocusNote_46.pdf Porteous, David. (2006)

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Market Examples:
• Nigeria: “As switches connect consumers to their bank accounts to authorize transactions, only Risk Type:
banks or a consortium of banks or agents for banks or banking consortium or any other company as MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
approved by the CBN, can act as a switching company. This provision is to minimize fraud and Model Model Model
mitigate risk to the banking system. Third party providers are to submit themselves to the scrutiny x x x x
of the Central Bank only after having signed a switching agreement with a bank or consortium of
banks. The switching companies must meet the standards defined in the 3rd party service provider
agreement. Third parties or account providers must meet the guidelines as described under
‘Guidelines for Vendors and Outsourcing.’” Additionally, the report advises that settlement of e-
payment transactions that are delivered through the mobile channel should be done through the
banking system only.115
• Ghana: The e-Zwich was designed as an electronic clearing and payment settlement system with a
common platform to link all Ghanaian financial institutions. It anchors on biometric (fingerprint) ID
technology, permitting smartcard holders to perform financial transactions and services for goods and
services, at any e-Zwich point-of-sale (POS) or ATM. In addition to performing all transactions
associated with a traditional bank account, such as money transfers, cash withdrawals, bill pays, the
card holder can also receive pensions, salaries, and use mobile banking services.116 Some press
reports indicate that there have been user complaints regarding false negatives during biometric
authentication, requiring them to establish their identity prior to using their cards. Merchants’
complaints include inability to synchronize transactions with the e-Zwich mainframe at the end of the
day; e-Zwich utilizes GPRS modems when Internet connections are unavailable, resulting in failed
connectivity. Other concerns include the fact that the electronic switch is not managed by the Bank
of Ghana and the biometric portion is not the province of the National Health Insurance Scheme
(NHIS), Electoral Commission, DVLA (Drivers & Vehicles Licensing Authority), and Ghana Passport
Office.117
• Mexico: The mobile phone industry is highly concentrated in a single MNO, Telcel, which has 85% of
the market share. The Communications and Transport Secretariat (SCT), the country’s
telecommunications policy maker, has the authority to impose special price, quality, and disclosure
requirements on dominant MNOs to promote competition. Despite complaints against Telcel’s
pricing practices and its dominant position, the SCT has taken no measures so far.118
• South Africa: [Example of open loop system] WIZZIT works across all networks in the country. To
transfer money Wizzit uses the well developed South African inter-bank clearing house system. It
accesses the clearing system as an autonomous division of the South African Bank of Athens Ltd. This
‘any-to-any’ feature is seen as a significant advantage in giving the Wizzit account the ability to
transact with any mobile user regardless of the identity of their network operator or their bank.119
• Kenya: Safaricom, the dominant mobile network operator, holds 79% of the market share. This is
despite extensive efforts by its competitor, Zain, which only holds 20% of the market. Safaricom’s m-
banking product, M-PESA, is only compatible with M-PESA account holders and certified agents.
Therefore, M-PESA operates under a closed system, limiting interoperability.120

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7.1. Risk (National Regulators): Options Implications
“Illicit financial activities enabled by weak KYC/CDD requirements/enforcement.” network.
• Cost of building a network to support would be
Description: costly.
If the AML?CFT requirements do not apply to mobile financial services, illicit actors could leverage the mobile
3. account providers institute institution specific • Point-based AML/CFT system allows flexibility for
network for illicit means. If the party providing the financial service is held to these standards, but its ability to
KYC/CDD policy for agents, which should comport with consumers with various forms of identification;
comply/enforce them is limited, the risk still remains. (The ability to enforce AML/CFT among a disparate sound AML/CFT standards. while limiting risk by embedding a standard due
agent population is a critical element.). diligence requirement network-wide.
• Lack of regulatory guidelines will lead to variance
According to FATF, “the general rule is that customers should be subject to the full range of customer due
in system strength which can allow for
diligence measures. However, there are circumstances in which it would be reasonable for a country to allow exploitation.
its financial institutions to apply the extent of the customer due diligence measures on a risk sensitive basis.”121
• Implies regulatory capacity to monitor individual
Additionally, the Basel Committee on Banking Supervision notes that KYC is directly associated with the fight
account provider policies and procedures, but
against money laundering and, as such, should form a core feature of a bank’s risk management and control allows for innovation in achieving the objective.
procedures. Further, KYC should be complemented by regular compliance reviews and internal audit. “The
intensity of KYC programmes beyond these essential elements should be tailored to the degree of risk.”122 4. No regulatory action for mobile on AML/CFT. • Illicit actors leverage mobile networks for
illegitimate financial purposes; illicit activity
The financial institution should adopt procedures for limiting transactions prior to customer verification. This flourishes in economically disadvantaged
regions/zones where provider enforcement
may include restrictions as to the type, number, and/or amount of transaction performed, in addition to
mechanisms are weak
monitoring transactions outside of the customer’s projected financial footprint. This is particularly critical in
non-face-to-face business relationships123 (such as m-FS).
Policy Narrative:
Objective: One risk-based approach is known as point-based AML/CFT. This approach may be less restrictive for both
agents and consumers, as it presumes the more KYC evidence a customer can provide (ranging from a
¾ Risk-based supervision and enforcement of AML/CFT safeguards to enable authorities to focus on the
national ID, passport, physical presence, utility bills, introduction by other clients, driver’s license, etc.), then
highest priority risks.
the more proportional the risk is to the institution. Services are then offered on a basis proportional to the
perceived risk.
Policy Table:
Options Implications Chatain et al identified several innovative risk mitigating factors in mobile banking and securities accounts, or
1. Regulatory authority implements and enforces a point – • Point-based AML/CFT system allows flexibility for those similar to other electronic channels such are utilized in electronic banking channels for Internet banking
based (stepped based on risk) AML/CFT system. consumers with various forms of identification; and ATMs. National authorities may standardize national public identification to facilitate documentable
however, limits risk by embedding a standard due measures to verify the customer and/or beneficial owner’s identity when conducting transactional activity or
diligence requirement industry-wide. establishing customer relationships. In the absence of a national customer ID, national authorities may provide
• Regulatory authority to for alternative ID instruments to comply with these requirements. All ID requirements should pay special
implement/monitor/enforce can be costly, attention to money laundering and terrorist financing threats that may arise from the anonymity of new or
considering that agents are the implementers. developing technologies.
2. Account providers elect to have account opening • Account providers can hedge risk by controlling
conducted by employees rather than agents, so as to account opening process. Simplified or reduced CDD measures could apply to the beneficial owners of pooled accounts held by
maintain stricter AML/CFT controls. • Potential customers inconvenienced as account
designated non financial businesses or professions, in the event such individuals are subject to AML/CFT
provider has limited footprint relative to agent requirements and related monitoring. The Basel CDD paper may provide guidance to financial institutions
holding such accounts as well (see Section 2.2.4).124 In the absence of a national customer ID, Banks, MNOs

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and agents should have policies and procedures in place to address specific risks associated with new or requirements of small value accounts, permitting identity and address verification via introduction by
developing technologies that permit remote and non-face-to-face business relationships and transactions, in another account holder who passed full KYC in at least the preceding 6 months.130
addition to any risks associated with the nested agent relationships that might obscure customer identities in • Brazil: HSBC uses cross channel verification, such as confirming credit card transactions via mobile phone
the payment chain. text messages.131
• Mexico: AML/CFT regulation is based on several laws that require a broad range of entities to have
Market Examples: AML/CFT policy, specialized personnel, training, systems, and procedures. All financial institutions, money
• Kenya: Under Kenya’s Registration of Persons Act, citizens 18 or over must register with the National transferors, and the third parties providing services on their behalf are covered by the law. MNOs are not.
Registration Bureau and obtain a national ID. Failure to do so is a crime. Individuals obtaining citizenship by To open an account, banks must produce a file on the client that includes name, address, birth date,
birth only need to demonstrate that one parent is a Kenyan citizen, usually by presenting a parent’s national nationality, profession, professional activity, and telephone, copies of the identification document, tax card,
ID. However, for Nubians, Kenyan Somalis, and coastal Arabs, the standard is stricter. Registration officials and proof of address (if different from the ID document). Foreigners must provide proof of legal residence,
have broad discretion under Section 8 of the Registration Act, which permits officers to require an in addition to an address in their country of origin.132
applicant to produce additional evidence. The Principle Registrar may demand proof of "other particulars • Jordan: In Jordan, banks must identify and verify customer identity according to the Central Bank of
as may be prescribed (Section 5)." Moreover, under Kenyan citizenship law, women cannot pass Jordan Instruction 42 under its Anti-Money Laundering Law issued in 2007 and 2008. Verification consists
nationality to their children. Children of “unknown origin” or who might otherwise be stateless, including of customers presenting their Jordanian national ID and proof of address, which must be verified in a face-
some orphans and street children, are not automatically granted Kenyan nationality.125 Refugees cannot to-face setting by a “bank employee.” Agents may fax ID to branches to comply with Instruction 42
naturalize, increasing the risk of statelessness over time. In terms of flexible ID requirements for users, requirements. Mobile network operators are not considered financial companies under the AML law and
account provider M-Pesa accepts a national ID, a passport (Kenyan or foreign), Alien certification, and would not be covered by mobile banking, however, do require presentment of national ID for Jordanians
military or diplomatic IDs. It is also is considering lowering the minimum age of its users from 18 to 16 or passports for non-Jordanians for KYC requirements.133
with parental consent.126
• South Africa: Admitted to FATF in June 2003, South Africa conformed to the CDD/KYC standards. Risk Type:
However, in practice this left nearly one third of its citizens unable to qualify for opening bank accounts. MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
The “mass banking clients” compliance exemption (Number 17) in the Financial Intelligence Centre Act Model Model Model
(FICA) of 2001, is an example of how South Africa addressed this issue for low income clients who had x x x x x x x x
now tax number and were unable to produce address verification. The exemption limits the maximum
account balance to US $4,000 and limits deposit and withdrawals, as well as the ability to conduct cross
border funds transfers.127 To mitigate the risk of anonymity, TelCo representatives for Wizzit travel to
remote locations for customer verification procedures. MTN-Standard Bank allows remote registration via
Internet, call center or mobile, however, customer information is then cross-verified by 3rd party database
checks.128
• Korea: According to one study, TelCos in many jurisdictions where m-FS predominates did not sufficiently
perform CDD on non-residents; it is recommended that enhanced KYC and CDD be performed for such
customers similar to the manner in which banks perform such measures. In Korea, there are
comprehensive procedures in place for mitigating the risks of anonymity with cooperation between the
banks and the TelCos. To conduct m-FS, a customer must hold a bank account, travel in person to the
bank branch and provide ID (a valid passport for foreign citizens), and complete a funds transfer form in
order to receive access to e-banking. Upon completion of these steps, an ID and password are issued to
the customer, as well as a letter permitting the customer to obtain a SIM card from the TelCo. Service for
m-FS is available only to post-paid individual subscribers, rather than corporate entities.129
• India: Under the Prevention of Money Laundering Act of 2002, the law issued AML guidelines, including
KYC standards. Banks were advised to tier customer risk according to low, medium, and high, adjusting
account ID requirements. Reserve Bank of India’s 2005 Circular relaxed the proof of residence

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7.2. Risk (National Regulators): enforcement authorities should develop clear rules and guidelines for m-FS transaction providers. Once
“Identification of illicit financial activities hampered by insufficient reporting requirements.” received, FIUs or investigative authorities should ensure they have the capacity to analyze STR information
that is reported and effectively use the information in prosecutorial and/or enforcement actions.
Description:
Reporting of large or suspicious transactions to appropriate authorities and/or the Financial Intelligence Units According to FATF Recommendation 13, if a financial institution suspects that funds are the proceeds of
(FIUs) provides information on mobile financial transactions that exceed or are structured to avoid reporting criminal activity or TF, it should be reported promptly to the FIU. Consequently, AML/CFT reporting
requirements, as well as on trends and patterns of unusual mobile financial activity. obligations are particularly germane to mobile financial services as most activities are identified ex-post.
Further, FATF Special Recommendation IV stipulates that should financial institutions, other businesses or
FATF recommendations specify creation of specialized government units, called Financial Intelligence Units entities subject to anti-money laundering obligations, suspect or reasonably suspect funds may be linked or
(FIUs), to be a central node for monitoring and analyzing financial transactions, as well as collecting and related to terrorism135 , then such suspicions should be reported with due haste to competent authorities.136
disseminating related information to appropriate authorities. FIUs operate under different guidelines, but
under special provisions may exchange information with foreign counterpart FIUs to detect, deter, and disrupt Likewise, FATF Recommendation 25 provides that competent authorities should establish guidelines that will
ML/TF and other illicit financial crimes.134 assist financial institutions and non-financial intermediaries in the detection and deterrence of ML/TF and other
illicit financial crimes. As the national center for receiving and analyzing suspicious financial transaction
Objective: reports, the FIU may provide guidelines on the limitations on size and velocity of mobile financial transactions
¾ Risk-based supervision and enforcement of AML/CFT safeguards to enable authorities to focus on the and related reporting that exceeds or is structured to avoid limits, as well as trends and patterns of unusual
highest priority risks mobile financial activity.137

According to the authors of “Integrity in Mobile Financial Services: Measures for Mitigating Risks from Money
Policy Table:
Laundering and Terrorist Financing,” there is general trepidation in law enforcement circles over the fact that
Options Implications
m-FS providers are outside of the regulatory regime imposed upon other financial institutions. Based on the
1. Financial regulatory authority includes mobile providers • Standardized reporting, in line with financial authors’ fieldwork, not all m-FS providers fully followed the same AML and CFT practices as traditional banks,
in AML/CFT reporting requirements to appropriate institutions, mitigates potential for illicit activities insurance, and securities firms. If TelCos did comply with such controls, partner entities, such as agents,
authorities and/or the FIUs. Account providers file and facilitates investigation. merchants, and third party processors may not be in compliance. Additionally, all parties had varying degrees,
Suspicious Transaction Reports (STR) for transactions • Reporting requirements impose a cost on the
meeting specified criteria. if any training or awareness of the necessity for AML and CFT standards, which enabled them to differing
account provider, which would be reflected in degrees to protect not only their own businesses but all those in the financial transaction chain.138
usage fees.
2. STRs for all reporting entities indicate the channel used, • Account provider may not have the technology Market Examples:
including mobile. to identify suspicious transactions, resulting in a • Africa: several Account Providers in (Zambia, Kenya) noted that despite efforts at identifying
dump of all transactions on the FIU. suspicious activity and/or working with appropriate authorities, there was no centralized FIU to
• FIU may not have the capacity or budget to which to report these activities formally. Central authorities noted a need for AML and CFT capacity
analyze reports for mobile sector. building and training.139
• Philippines: One of the most collaborative agent - FIU models to date in terms of working directly
3. Account Providers are not included in STR reporting • Mobile financial services could be used to channel
requirement. large quantities of small payments in support of
with the mobile financial services industry has been that of the Philippines. Over 10% of the 89 million
illicit activities. Filipinos working abroad in 2007 sent an estimated $14.45 billion USD home through formal
remittance channels. This equated to 10% of the Philippines GDP. 140 Both Globe and G-Cash are
regulated by Bangko Sentral ng Pilipinas (BSP), the Central Bank, and the Anti-Money Laundering
Policy Narrative:
Council (AMLC), the Philippines FIU. Both are regulated as money service businesses, non-bank
While the internal financial intelligence/fraud units of Account Providers require due diligence information
financial institutions.141
from their customers for business purposes, there is no standardization by authorities as to the requirements
• Korea: Having conducted fieldwork in Brazil, Hong Kong, SAR of China, Malaysia, the Philippines,
for mobile financial Account Providers and related transactions in terms of STRs. Financial intelligence and law
South Africa, and South Korea, the authors of “Integrity in Mobile Financial Services” noted that while

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Telcos in these areas required information for business purposes, uniform guidance from the FIU had
not been provided. A related challenge in some jurisdictions appeared to be the technical ability of
the FIU to analyze financial data at the same sophistication level as the Telco or bank involved in the
m-FS transactions. “To detect criminal or TF activity, it is imperative that such information be made
available to and fully processed by intelligence and law enforcement authorities.”142
KoFIU (The Korean Financial Intelligence Unit) receives and analyzes suspicious transaction reports
(STRs) from financial transactions conducted through a variety of channels, including m-FS.
Typologies143 released by KoFIU to educate their FIU counterparts in illicit mobile usage, include:
i. Cyber Gaming Case: Proceeds from illegal online gaming and identity theft were
placed in the Korean banking system via m-FS and other electronic methods.
ii. Cross-border Remittance Case: A person used false identities and several bank
accounts, sending the funds cross border by m-FS and other electronic means to
various unspecified sources.
iii. Swindling and investment fund Case: A person founded a fraudulent financial
consulting firm and clients sent funds to him via m-FS and other electronic means.144
• El Salvador: Mobile banking is still in the embryonic stages and available only to those with a bank
account. Financial institutions are required to maintain both systems and policies that provide access
to both the identity and transaction profiles of their clientele. In order to open a bank account, a
customer must provide their name, date and place of birth, nationality, address, profession, and
marital status, in addition to presenting an identity card. The Banking Law, however, does not
stipulate which identity documents are acceptable. Further, banks and insurance companies are
required to inform the country’s Financial Intelligence Unit (FIU) customers conducting single or
aggregate transactions in a one month period exceeding USD 500,000 and are to confirm that the
activity is in line with the client’s financial footprint. Supporting documentation on the transactions is
to be maintained for a minimum of 5 years.145

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x

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7.3. Risk (National Regulators): Options Implications
“Illicit financial activities facilitated by unlicensed/ unmonitored agent network.” 4. No required training or licensing process • Least direct costs for account providers and
regulators.
Description:
• May result in indirect costs through use of
As agents are a critical component of the mobile payment network, they have the ability to facilitate fraud or mobile financial services to support illicit
criminal activity (e.g. if they do not comply with KYC / CDD requirements, customers could conceivably set activities.
up accounts under false identities). In conformity with FATF Recommendation 23 and Special
Recommendation VI146, countries, at the national and sub-national level may AML/CFT requirements that
Policy Narrative:
include agent registration and licensing requirements, as well as the submission of updated registration lists to
Licensing for financial account providers may be an effective way to ensure that account providers adhere to
competent authorities. Registration of sub-agents may be included. Agent registration and licensing fees vary
AML and CFT procedures, prevent potentially hazardous business models from reaching the market, and
from flat rates to a percentage of business services offered. Non-prohibitive agent registration and licensing
obtain revenue minimal operating revenues for licensing fees. In addition, such practices may assist in
fees should be employed to encourage compliance.
mitigating risks in a rapidly changing market environment by helping regulators keep abreast of new entrants in
the service arena.
Objective:
¾ Risk-based supervision and enforcement of AML/CFT safeguards to enable authorities to focus on the FATF 23 mentions that “other financial institutions should be licensed or registered and appropriately
highest priority risks. regulated, and subject to supervision or oversight for anti-money laundering purposes, having regard to the
risk of money laundering or terrorist financing in that sector.” Though it does not specify m-FS, businesses
Policy Table: which provide a service of “money or value transfer, or currency changing” are noted.147
Options Implications
1. Regulatory authority trains and licenses agents to ensure • Training and licensing can help to ensure a base Special Recommendation VI on Alternative Remittances includes licensing and registration provisions for
capacity. capacity among agents. persons or legal entities providing services for the transmission of money or value through informal transfer
systems or networks.148 This provision has likewise been interpreted by some as applying to m-FS.
• Regulatory ownership or training licensing is high
cost and requires capacity that the regulator is
unlikely to have. Chatain et. al posit that TelCos and some other non-bank entities providing m-FS should be included within
the regulatory definition of “financial institutions” when according to FATF these TelCos function as: “any
2. Regulatory authority requires account provider to • Training helps to ensure greater competence person or entity who provides its customer with transfer of money or values services, or issues and managers
institute an AML/CFT/anti-fraud training program which among the agent network, and thus a stronger, means of payment, inter alia, electronic money.” This broad definition would permit the TelCo’s AML/CFT
incorporates AML/CFT guidelines. Training, compliance more stable mobile payment system.
monitoring of, and registration of agents is required by
to comport with the actual role it performs within the financial or non-financial sector.149
• Motivating agents o follow prescribed guidelines
account provider. may be challenging. Market Examples:
• Implies regulatory support for and verification of • Kenya: The Banking Act in Kenya defines banking business as having two key components. The first
training program. defines how funds are accepted and utilized by the institution and the second defines where the
3. Provider institutes training program that certifies an • Training helps to ensure greater competence physical location of the institution may be organized to transact business. A bank may transact
agent according to policies and procedures of the company among the agent network, and thus a stronger, business only at its head office, branch, or place of business, all of which can only be operated with
for AML/CFT; may encourage agents to adopt sound more stable mobile payment system the approval of the Central Bank of Kenya. CGAP notes in its examination of Kenyan banking that it
business practices and follow government guidelines for • Motivating agents to follow prescribed guidelines would be difficult to determine if agents would be included in the definition of a bank under the
AML/CFT. may be challenging. Banking Act. Outsourcing of banking activities is not addressed in the regulations, but is approved on
• No regulatory enforcement of training program
a case-by-case basis by CBK. Non-bank institutions are not under the same regulatory scrutiny.150
may allow sub-optimal programs. • Brazil: In Brazil, authorities enable compliance and mitigate risk by making banks fully liable for the
acts of their agents. For instance, bank authorities have supervisory oversight as to the transaction

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details and records of their agents.151 As the authors in “Integrity in Mobile Financial Services”
conclude, “Licensing/registration and ongoing monitoring of m-FS providers should be implemented.
As observed during fieldwork and recommended by FATF, licensing for financial account providers is
an effective way to make certain m-FS providers adhere to AML and CFT procedures and prevent
potentially hazardous business models from reaching the market.” Of particular note, the authors cite
this practice may prevent the creation of shell corporations, or front companies, which might be used
to conceal and divert funds for criminal purposes via an m-FS platform.152

In Brazil, for instance, agent networks are either managed directly by a bank or outsourced to a third
party, which is considered an agent by the Central Bank of Brazil (CBB). Network managers provide
services that range from AML/CFT training to agent selection, as well as point of sale maintenance
and cash handling. The expansive reach of agent networks enables financial services to those
individual who might not otherwise have access in Brazil and CBB oversight actually identified agent
breaches in consumer protection rules; agents were noted as not disclosing fees and charging extra
fees; selling client information to third parties; and committing loan fraud (not making bill payments
for which they had received funds), among other transgressions. Such weeding out of dishonest
actors in the system may be a facilitator of faith and trust in the public perceptions of the agent
community.153

• India: In November 2006, India took limited steps toward the outsourcing of small value remittances
and other payment instruments through business correspondents; restrictions included limiting
eligible institutions to operate as correspondents to non-profit institutions, post-offices and
cooperatives, as well as denying the ability of the correspondent to charge the customer for services
rendered on behalf of the bank. Guidelines require that the Reserve Bank of India remain responsible
for the actions of the agent as a risk mitigator, allowing RBI the authority to inspect the agent, as well
as review agent records relevant to outsourced activities.154

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x

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7.4. Risk (National Regulators): Options Implications
“Inadequate transaction records impair investigation of fraud or criminal activity.” 3. Regulatory authority requires the account provider to • Record retention requirements will facilitate
maintain all payment transaction records for 5 years investigation.
Description: following the completion of the transaction. (Should • Records retention responsibilities may be tiered
Full transaction audit trails are essential to investigations to follow the money trail. Records retention should mimic financial requirements) to transaction amounts and type of services
permit reconstruction of transaction details, including personally identifying data of the transaction parties. provided (e-money issuer, remittance services,
Telco)
FATF Special Recommendation VII notes that “countries should take measures to require financial institutions, • Retention requirements will impose a cost on
including money remitters, to include accurate and meaningful originator information (name, address and providers, which would be passed on to service
account number) on funds transfers and related messages that are sent, and the information should remain users.
with the transfer or related message through the payment chain.” • Differs from normal cell phone call records,
which may be subject to shorter record
FATF Recommendation 10155 notes that records retention to reconstruct transaction details, including retention.
personally identifying data of the transactor, aids evidence collection in administrative, civil, and criminal
sanctions. Further, necessary records should be available to competent authorities for at least five years.156
4. Provider sets internal policies and procedures for • Record retention requirements will facilitate
Objective: maintaining all records obtained through the CDD process investigation.
and transaction records (Customer Detail Records-CDRs) • If the standards for retention are low, authorities
¾ Regulatory framework follows international standards for financial records retention to mitigate risks, for a specified period following the completion of the
which sets 5 years to enable information requests from competent authorities. may not be able to trace transactions within a
transaction, failure of the account provider, and/or payment chain from one provider to another or
termination of customer relationship. reconstruct sender/receiver identities in the
Policy Table: prosecution of financial crimes.
Options Implications
5. No mandatory or implied records retention policies for • Ability to reconstruct audit trail is dependent on
1. All service users required to maintain an individual bank • Cell phone company role limited to messaging - mobile financial services business practices for records retention and
account through which all transactions flow. actual transactions occur in the bank. retrieval capability of account providers and
• Ensures that full transaction records exist within others in the account provider's network.
the formal banking system.
• Acceptable to users who already have bank Policy Narrative:
accounts, but represent a high cost barrier to In some cases, particularly when the service links “traditional” bank channel accounts to TelCo partners,
users who have no need for a full banking
AML/CFT obligations likely reside with the bank, as the primary financial institution responsible for providing
relationship.
m-FS. However, when the TelCo can be a channel through which other services are provided and the
• Would substantially restrict expanding access to merchant can also receive payments and conduct non-bank account transfers, the line between financial and
financial services to the unbanked.
telecommunication providers blurs.
2. Regulator requires transaction level reporting and • Internal systems facilitate investigation
implements internal suspicious transaction identification • Lowers account provider costs by enabling a raw Chatain et. al posit that TelCos and some other non-bank entities providing m-FS should be included within
process. data dump on the FIU, without the need for the regulatory definition of “financial institutions” when according to FATF these TelCos function as: “any
analysis. person or entity who provides its customer with transfer of money or values services, or issues and managers
• Implies FIU capacity to absorb and analyze large means of payment, inter alia, electronic money.” This broad definition would permit the TelCo’s AML/CFT
volumes of transaction data, essentially all of to comport with the actual role it performs within the financial or non-financial sector.157
which will be routine.

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There is no consensus on how to implement standards internationally, though the majority of TelCos perform • Hong Kong: In Hong Kong SAR of China, AML regulations for mobile account providers require
some KYC and CDD measures as best business practices.158 that records be maintained on all transactions over HK $8,000, however transactions below this
figure are recorded in the mobile account provider systems, too.163
Market Examples: Safeguarding electronic customer and business data: avoiding data leaks, and maintaining high –
• Kenya: In a recent presentation entitled “10 YEARS ON FROM THE US EMBASSY BOMB BLAST” quality IT systems is a critical business enabler in records retention efforts for AML and CFT. In light
in Nairobi, Kenya,”159 Director Samuel Mutungi provided a case study on lessons learned for terrorist of recent data leaks, e-finance regulations are emerging.
attacks regarding disaster recovery and business continuity planning for financial services. One of the • Macao SAR: For instance, Banks in Macao SAR of China do not permit m-FS transfers outside of
main mitigating strategies aiding in recovery for Co-Operative Bank, despite the fact that the ICT the same bank or internationally.
equipment was damaged and networks/systems were destabilized, was that the Bank’s systems back- • Philippines: The Philippines caps m-FS transactions per day and per month in order to mitigate ML
up e.g , redundancies, had recently been moved off site. risks.164
• South Africa: The South African Financial Intelligence Center Act (FICA) permits electronic record
keeping and outsourcing to third party intermediaries. For MTN group, the South African Risk Type:
telecommunications company, client identification records are collected by agents, but forwarded to MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
the main office for verification and retention.160 Value in mobile financial transactions, at some point in Model Model Model
the transfer, is typically stored on the computer servers of account providers or financial institutions. x x x x
These servers, however do not have to reside in the country of originating activity. This may or may
not create concerns for national regulators in terms of evidence collection, search, seizure, asset
forfeiture/sharing, and information sharing.161
• Philippines: The use of new and developing technologies, such as the intersection of information
and communications technologies and financial services, raises new areas of consideration in terms of
records retention and retrieval. In the “Effects of Cell phone on Anti-Money Laundering/Combating
Terrorism (AML/CFT) Wire Remittance Operations”162 which examined mobile financial services
practices in the Philippines, the author cites several emergent safety and soundness factors:
vii. Tests of electronic systems security, hardware, and software,
viii. Tests of customer ID and point-of-sale samples,
ix. Anti-virus protection,
x. Internal security policies and procedures for electronic systems,
xi. Cross industry and regulatory collaboration in records involving text and SIM cards,
and
xii. Critical infrastructure protection for the telecommunications and the financial sectors.

Customer Detail Records: Mobile financial account providers maintain customer activity records
(Customer Detail Records) similar to financial institutions and payment system providers. These
detailed customer records relate to the mobile operator’s system usage and include information
relevant to AML and CFT, such as each mobile calls originating and receiving phone and the call’s
duration.
• Malaysia: In Malaysia, Maxis maintains ongoing transaction records for active customers and for
terminated customer retains them for an additional seven years.

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7.5. Risk (National Regulators): compliance, and to impose adequate administrative sanctions for failure to comply with such requirements.”
“National regulators and/or law enforcement authorities unable to effectively investigate fraud or criminal Countries, as well, should both provide their competent authorities involved in AML and CFT with sufficient
activity due to lack of operational support systems and human capacity.” “financial, human, and technical resources” (Rec. 30) and well as ensuring that “policy makers, the FIU, law
enforcement and supervisors” can effectively and efficiently develop and implement AML and CFT policies
Description: (Rec 31).
Investigative officials are unlikely to have the human capacity to effectively regulate the network of providers,
agents, trust accounts and customers necessary to mitigate the known risks. If the regulatory framework Market Examples:
entailed licensing/supervising agents, as well as providers and banks, the number of regulators required for this Of the countries reviewed for this study, only Nigeria currently has an FIU that is a member of the Egmont
activity would likely be well beyond that on staff for the regulatory authorities. Group. Several countries are members of the FATF Regional-Style Bodies. Eastern and Southern Africa Anti-
Money Laundering Group (ESAAMLG), the purpose of which is to combat money laundering by implementing
Objective: the FATF Forty Recommendations. ESAAMLG’s efforts include co-coordinating with other international
¾ Risk based regulatory framework that minimizes the role of the regulator while providing an enabling organizations concerned with combating money laundering, studying emerging regional typologies, developing
environment that mitigates against risks to the customer, account provider network and the financial institutional and human resource capacities to deal with these issues, and co-coordinating technical assistance
system. where necessary. ESAAMLG enables regional factors to be taken into account in the implementation of anti-
money laundering measures. The Intergovernmental Anti-Money Laundering Group in Africa, GIABA , was
¾ Regulatory capacity sufficient to provide a deterrent to illicit use of mobile financial services through
established on 10 December 1999 by a decision of the Authority of Heads of State and government of the
heightened risk of discovery and prosecution.
ECOWAS. GIABA's mandate was revised in January 2006 to fully incorporate and properly reflect the
imperative to fight the financing of terrorism. GIABA members acknowledge that money laundering and
Policy Table: financing of terrorism are issues of critical importance to the world community which require global action.
Options Implications Further, that the economies and financial systems of the countries need to be protected from laundered
1. Establish an FIU with sufficient resources to credibly • Would enable the country to comply with FATF money and proceeds from terrorist activities. GIABA members recognize that West Africa needs to address
investigate suspicious transactions and initiate prosecution guidelines and participation in the Egmont group. these issues and find global solutions to them
of illicit activity. • Would extend activities already in principle • Ghana- GIABA
Establish specialized investigative, prosecutorial and judicial required for banking and insurance to mobile • Zambia - ESAAMLG
expertise within the legal system. financial services. • Tanzania - ESAAMLG
• Has cost implications - may require a fee regime • Nigeria – Egmont, GIABA
on account providers, which would be passed on • Kenya - ESAAMLG
to users, reducing the financial incentives to use • Rwanda – N/A
mobile financial services.
• Uganda- ESAAMLG
2. FIU established but not adequately resourced, or no FIU • No direct cost incurred, but
established. • Not in compliance with FATF guidelines, Risk Type:
potentially risking inclusion in the list of non- MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
compliant countries, leading to restrictions of Model Model Model
access to international financial markets. x x x x

Policy Narrative:
FATF Recommendations 29-31 address adequate powers, adequate resources and effective mechanisms
regarding human capacity of both appropriate authorities to monitor and mitigate illicit financial activity.
Compliance by financial institutions is addressed by Recommendation 29; Supervisors should be “authorised to
compel production of any information from financial institutions that is relevant to monitoring such

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7.6. Risk (National Regulators): Options Implications
“National regulators and/or law enforcement authorities unable to effectively investigate fraud or criminal 3. No Formal System (Ad hoc – on a case-by-case basis as • Lack of defined responsibility regarding specific
activity due to lack of authority.” determined). risks will create confusion and uncovered areas,
creating risk for the financial sector.
Description:
In many country contexts, the regulatory framework for mobile payment service provision has not been Policy Narrative:
established. Thus, it is unclear whether the financial regulators have the authority to oversee the payment FATF Recommendations 29-31 address adequate powers, adequate resources and effective mechanisms
network, or if it is the responsibility of the telecommunications regulators, or if anyone has the requisite regarding human capacity of both appropriate authorities to monitor and mitigate illicit financial activity.
authority. Compliance by financial institutions is addressed by Recommendation 29; Supervisors should be “authorised to
compel production of any information from financial institutions that is relevant to monitoring such
Jurisdictional concerns may be exaggerated, since the service functions are distinct. For instance, in the compliance, and to impose adequate administrative sanctions for failure to comply with such requirements.”
United States, many grocery stores provide access to financial services (credit unions, etc) but their core Countries, as well, should both provide their competent authorities involved in AML and CFT with sufficient
business is selling groceries. Their financial activities are easily overseen by financial authorities and their core “financial, human, and technical resources” (Rec. 30) and well as ensuring that “policy makers, the FIU, law
business is overseen by state food safety regulators. enforcement and supervisors” can effectively and efficiently develop and implement AML and CFT policies
(Rec 31).
Objective: Market Examples:
¾ Clearly defined centralized regulatory authority for mobile payment networks. • Malawi: The Malawi FIU was established under the Money Laundering, Proceeds of Serious Crime
¾ Clearly defined authority to refer breaches of public trust or illicit activities to law enforcement authorities and Terrorist Financing Act, Number 11 of 2006 and became operational in July 2007. The FIU is an
for prosecution. autonomous national body which reports directly to the Malawi Minister of Finance. Under the
auspices of the Act, the FIU is responsible for identifying the proceeds of serious crime and
Policy Table: combating money laundering and terrorist financing activities. To meet these obligations, it works in
Options Implications coordination with investigative authorities, such as the Anti-Corruption Bureau (ACB), the Director
of Public Prosecution (DPP), Fiscal and Fraud Police Unit (FFU), the National Intelligence Unit (NIS)
1. Empower through law/regulation either the financial • Sole authority limits confusion regarding and the Malawi Revenue Authority (MRA).165 The Act itself imposes reporting obligations, such as
regulator or telecommunications regulator as the sole investigative authority.
regulatory authority over mobile payment system. KYC of the customer and beneficial owner when, for instance, carrying out an electronic funds
• However, different issues may require different transfer.166
subject matter expertise which may not be
• India: The law governing AML/CFT issues was promulgated in 2002 under the Prevention of Money
resident in the sole regulator.
Launder Act and applies to banks and financial institutions. The Reserve Bank of India (RBI), the
• Capacity/Budget of sole regulator may need to be Central Bank, has experimented with the use of third party business correspondent (BCs) regulations
adjusted to accommodate increased
to deliver financial services outside bank branches, though this met with limited success and the
responsibility.
original circular issued in 2006 was subsequently revised in 2009 to lessen the restrictions on BCs.
2. Harmonize enforcement and penalty authority • Harmonization process defines which regulator is While the AML/CFT regulations regarding KYC and residency requirements for small value accounts
framework across Communications and Financial Services responsible for which tasks, mitigating risks of were relaxed in 2005 for banks, the potential for MNOs and mobile financial services was less
regulatory authorities. issues “falling between the cracks” or of optimistic until 2008. The Payment and Settlement System Act went into effect then and RBI issued
overlapping or contradictory activities. guidance regarding the issuance of prepaid payment instruments, which would permit MNOs in
• However, emerging risks may create confusion partnership with banks, to issue mobile wallets.167 The Financial Intelligence Unit of India (FIU-IND)
regarding responsibility. was established by the government in 2004 as the central agency responsible for receiving,
• Authorities may lack capacity to implement processing, analyzing, and disseminating information relating to suspicious financial transactions. FIU-
across institutional silos.

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IND is an independent body reporting directly to the Economic Intelligence Council (EIC), which is
headed by the Finance Minister. FIU-IND is currently staffed at 43 individuals.168
• Pakistan: The State Bank of Pakistan (SBP) supports legal and regulatory adaptations facilitating
branchless banking, which uses information and communication technologies and non-bank retail
agents, while also remaining cognizant of potential risks that may arise from these models. The
Ministry of Information Technology (MoIT) expressed interest during a CGAP assessment in lessons
learned from international experience of such models. The Pakistan Telecommunications Authority
(PTA), as the telecommunications regulator, requires notification prior to the introduction of m-
banking services as with any value-added service launch. Should an MNO provide financial services,
this would fall under the auspices of the SBP or the Securities and Exchange Commission of Pakistan
(SECP).169 In November 2009, the “Ordinance to Provide for the Prevention of Money Laundering
(AML Ordinance) established a Financial Monitoring Unit (FMU) to receive and analyze reports of
suspicious transactions, assist in investigations, and exercise general AML responsibility. Strategic
oversight and administration of the FMU was established by the AML Ordinance with creation of the
National Executive Committee, which publishes an annual AML strategy.170
• Philippines: The Anti-Money Laundering Council (AMLC), The Philippines’ Financial Intelligence
Unit, is composed of the Governor of the Bangko Sentral ng Pilipinas (BSP) as Chairman and the
Commissioner of the Insurance Commission (IC) and the Chairman of the Securities and Exchange
Commission (SEC) as members. AMLC was established in 2001 with Republic Act No. 9160,
otherwise known as The Anti-Money Laundering Act of 2001. In addition to creating the FIU, the
Act, a) criminalizes money laundering; b) imposes customer ID, record and reporting of covered and
suspicious transaction requirements; c) provides for freezing/seizure/forfeiture/recovery of dirty
money/property; d)provides for international cooperation; e) relates bank deposit secrecy laws.171
Several Resolutions were passed in 2004 by AMLC to combat text messaging scams (No. 361), where
deceiving messages were sent to prospective victims through cell phones using the names of the
Bangko Sentral ng Pilipinas, the Philippine Charity Sweepstakes Office, the Philippine Amusement and
Gaming Corp., and other institutions, advising recipients about an alleged raffle drawing with
purported winnings of millions of pesos.172

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x

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7.7. Risk (National Regulators): According to FATF Recommendation 8, financial institutions should pay special attention to any money
“Service provider may fail to institute appropriate safeguards against newly emerging risks.” laundering threats that may arise from new or developing technologies that might favor anonymity, and take
measures, if needed, to prevent their use in money laundering schemes. In particular, financial institutions
Description: should have policies and procedures in place to address any specific risks associated with non-face-to-face
Mobile financial services are a dynamically growing market with new account providers, new services and new business relationships or transactions. Further to Chaitlan et al’s work, is the prudent aim that, prior to
vulnerabilities developing rapidly. Ensuring that information on the risk factors is disseminated and instituting regulatory controls, competent authorities should conduct risk-based assessments as risk mitigation
understood, and appropriate safeguards instituted, is a significant challenge. factors will vary by jurisdiction and services provided. Consequently, this necessitates analysis for national
regulators to “ (i) better understand the issues, (ii) gauge the magnitude of risks, and (iii) take the appropriate
Objective: policy measures.”
¾ Regulators to ensure account providers monitor evolving new risks, and institute appropriate risk
mitigation. Market Examples:
• Zambia: THE ELECTRONIC COMMUNICATIONS AND TRANSACTIONS BILL, 2009, “An Act
¾ Regulators routinely disseminating warnings of new risks as these are identified.
to develop a safe, secure and effective environment for the consumer, business sector and the
Government to conduct and use electronic communications; promote legal certainty and confidence,
Policy Table: and encourage investment and innovation, in the electronic communications industry; facilitate the
Options Implications creation of secure communication systems and networks; establish the Central Monitoring and
1. Regulatory authority, or financial intelligence unit (FIU), • Emerging risk monitoring will help the providers Coordination Centre and define its functions; repeal the Computer Misuse and Crimes Act, 2004;
monitors emerging risk for financial sector, including be vigilant with regards to emerging risk, so they and provide for matters connected with or incidental to the foregoing.”
mobile payment systems. can develop mitigation strategies early. • El Salvador: Providing service offerings via electronic channels, banks are required to submit their
• Would benefit from integration into the global respective service level contracts for review to the Superintendence of the Financial System (SupFin).
FIU network. SupFin may request contract changes. Under Article 56 of the Banking Law, banks must clarify the
• FIU may not have the skills / capacity necessary rights and obligations for electronic transactions, as well as provide customers with instructions for
to analyze risks associated with this new channel. the use of the technology and institute systems for the substitution of the client’s signature
• FIU may not have the budget to cover this area. substitution in electronic records.173
• Pakistan: Under the Commercial Bank Regulations, commercial and Islamic banks must collect
2. Association of account providers monitors emerging • Emerging risk monitoring will help the account additional information on their Level 2 and 3 customers, which may include:
risk for financial sector, including mobile payment systems. providers be vigilant with regards to emerging
a) an attested photocopy of the computerized national identity card (CNIC), verified by NADRA,
risk, so they can develop mitigation strategies
early. b) if the CNIC does not contain a photograph, then an additional ID, such as a driver’s license,
c) if no other photo ID is available, then a photograph attested by a bank officer and the CNIC attested by
• Individual account providers generally linked to
the same individual, with a written confirmation attesting there is no other photo ID extant,
international institutions operating in multiple
countries, allowing for cross fertilization.
d) an attested copy of a service card or certification from an employer,
e) for an illiterate person, a passport size photo with both the right and left thumb print on the signature
• There may be no association at the country level card. CNIC verification may be completed online. In terms of the transactions, the banks must obtain
- but account providers linked to the GSM
Association.
“accurate and meaningful” information on the originator, including the name, address, and account
number. This information should follow the funds transfer throughout the course of the payment chain.
3. No oversight of emerging risks • Emerging risks may not be spotted until the risk Further, these financial institutions should both track and report all suspicious transactions and retain all
is has become a significant problem. identifying records and transaction data for at least five years.174

Policy Narrative: Risk Type:

MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model

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x x x x x x

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7.8. Risk (Account Providers):
“The ability to track/investigate illicit transactions is made difficult by the number of financial intermediaries Such financial intermediaries should be identified in the case of alternative remittances as well. FATF Special
(e.g. agents, super agents, providers, banks managing the trust accounts); and as these various actors are not Recommendation VI states that “each country should take measures to ensure that persons or legal entities,
vertically integrated, the lack of transparency between them exacerbates the challenge for regulators.” including agents, that provide a service for the transmission of money or value, including transmission through
an informal money or value transfer system or network, should be licensed or registered and subject to all the
Description: FATF Recommendations that apply to banks and non-bank financial institutions. Each country should ensure
Criminal elements can utilize the lack of standard processes in conducting transactions, particularly in that persons or legal entities that carry out this service illegally are subject to administrative, civil or criminal
commingled accounts and instances where it is difficult to identify the beneficial owner. This risk may be sanctions.”
heightened with remote and non-face-to-face transactions, particularly in the cross-border context of some
MFS business segments. Account providers should be sure that accurate and meaningful information travels with the transfer or
related message through the payment chain to mitigate risks.
Objective:
Seven countries were the subject of a multi-year, regulatory diagnostic study by CGAP on the emergence of
¾ Minimum standard audit trail for SMS/USSD (Unstructured Support Service Data) transactions to enable branchless banking.176 The two models identified in the CGAP study – bank-based and non-bank based –
investigation through account providers’ payment transaction processing system consistent with employ the use of professional intermediaries to deliver mobile financial services.
international standards, with accurate and meaningful information that travels with each transaction.
¾ Contracts clearly identify the responsibilities of each party in the transaction and provide clear channels for The key distinction between the two models examined in the CGAP study is that in the non-bank based
sharing information. model, the customer has no direct contractual relationship with a prudentially licensed and regulated financial
institution. Rather, the customer exchanges cash or value with a retail agent, such as a merchant or retail
Policy Table: market, in exchange for an electronic record of value. This virtual transaction record is stored on the server
Options Implications of the non-bank intermediary, such as a mobile operator or stored value card issuer. A more limited version
of the non-bank based model exists in the form of the payment networks, which utilize either ATMs or
1. Regulatory authority mandates inclusion of accurate and • Implies regulatory involvement in data standards merchant point-of-sale terminals to conduct transactions.177
meaningful information with transfer or related message and oversight over account provider data
through the payment chain. transmission and retention policies and
Market Examples:
procedures. • Kenya: Draft CBK bill impact on remittance sector, according to authors of Genesis, would be
dramatic. Complying with FATF Special Recommendations VI and IX will be pose a burden for
2. Regulatory authorities prohibit mobile financial services • Would limit the complexity of transactions. informal money remitters, given that these recommendations specify that governments “should
outside of the same account providers or bank. • Prohibits the expansion of low cost mobile license or register all informal transfer operators and ensure that they are AML/CFT compliant to the
financial services and would inhibit service level of banks (SRVI), and should put measures in place to detect the physical cross border
innovation and outreach. transportation of currency (SRIX). The informal sector exists in part because the right to transfer
3. No regulatory action • Regulatory authorities would rely on account money formally is reserved for license-holders (banks, partners of banks, Postbank or POSTA). For
provider records. an informal provider to become “formalized”, it would be necessary to register as a bank or partner
with a bank – both difficult options for current informal players.”178
Policy Narrative: • India: Prior to 2009, only banks and financial institutions were allowed to issue e-money and collect
The Basel Committee on Banking Supervision recommendations on CDD/KYC for such financial funds for payment to third parties. The Reserve Bank of India (RBI) issued further payment guidance
intermediaries corresponds in this regard to similar due diligence to mitigate risks for mobile financial services relative to the Payment and Settlement Systems Act of 2007 in the form of the April 2009
accounts opened or operated by professional intermediaries. Where funds/value are held by an intermediary Prepayment Instrument Guidelines. Only banks may issue the three types of payment instruments
and are not co-mingled in pooled accounts, but can be attributed to a beneficial owner, then beneficial owners identified by the Guidelines and only those authorized by RBI may provide mobile banking
should be identified. If funds/value are co-mingled in pooled accounts, the mobile financial services providers transactions or launch mobile wallets. The three categories of prepaid instruments include the
should look through to the beneficial owner.175 terms paper vouchers, smart cards, magnetic stripe cards, Internet wallets, and mobile accounts and
wallets. The categories include: (1) closed system payment instruments, utilized only for purchase of

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goods and services; (2) semi-closed payment instruments, which may be either used at identified
merchant locations, but not for cash withdrawal/redemption; (3) open payment instruments, which
may be used at any point-of-sale (POS) enabled merchant and for ATM cash withdrawals. In August
2009, RBI expanded the Guidelines so that “other persons” where permitted to issue mobile phone-
based semi-closed prepaid instruments restricted to Rs 5,000 ($110) value, with no P2P transfers or
airtime recharges. RBI relaxed the KYC procedures in the interest of financial inclusion, with semi-
closed instruments of Rs 1,000 or less issued against any identity document, provided the issuer
confirms the customer holds only one instrument at a time; any prepaid instrument of Rs 5,000 or
less issued against any officially valid ID document defined in the Prevention of Money Laundering Act
and semi-closed instruments of up to Rs 5,000 issued to companies, which may, in turn, issue them to
employees or other beneficiaries provided they maintain full details of the reissuance. Issuers must
comply with existing AML/CFT rules, as well as maintain a transaction log of prepaid instruments
available for review by RBI. 179
• Indonesia: The E-Money Circular details licensing specifications for both bank and non-bank issuers
of e-money. Among the risk mitigation factors which may assist in identifying financial intermediaries
are requirements for among the required documentation of obtaining licensing, such as first year
business projections, written agreements with key partners, proof of liquidity risk management,
independent IT risk auditing, disaster recovery planning, accounting systems used for e-money
issuance, and “identification of product risk and other risks like operational, legal and reputational
risks.”180

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x

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7.9. Risk (National Regulators): Policy Narrative:
“Account provider suspends operations or collapses, disrupting service.” The core components of any payment system must ensure availability, capacity, operational continuity, and
security to the public that is being served. This may necessitate both integrating existing technologies in new
Description: ways, as well as providing interoperability among new actors with innovative technologies. The National Fire
Temporary or permanent failure of a systemically important account provider could trigger loss of public Prevention Association NFPA 1600 defines Business Continuity Program (BCP) in its general definitions as
confidence that could spread beyond the account provider, causing a general crisis of confidence among the follows: An ongoing process supported by senior management and funded to ensure that the necessary steps
public. are taken to identify the impact of potential losses, maintain viable recovery strategies and recovery plans, and
ensure continuity of services through personnel training, plan testing, and maintenance. An enhancement to
As communication networks are relied upon for financial services, disaster recovery is critical and it may
NFPA includes recovery actions, which often extend long after the incident itself and the related programs
become increasingly dependent upon regulatory authorities to set redundancy requirements.
should be designed to include mitigation components for avoiding damage from future incidents.181
Contingency plans for e-government can mitigate the risks of external events, specifically if the BCP
Objective:
encompasses resilience in communications and financial services via mobile banking and payments.
¾ Contingency response policies and procedures to ensure continuity of operations and rapid
recovery in case of failure. Market Examples:
• Brazil: All clearing and settlement account providers are either banks or entities controlled by
Policy Table: banks, with the largest ATM and POS networks controlled by the largest banking conglomerates.
Options Implications Access to these systems is self-regulated, with oversight by the Central Bank of Brazil (CBB). The
1. Regulatory authority mandates system redundancy • Redundancy and continuity will mitigate the risk interoperability among the 25 ATM and 4 POS networks, as well as the dominance of the large banks,
requirements and disaster recovery policies and of system availability and limit the duration when is driving small and medium sized institutions to create an independent automated clearing house
procedures to ensure continued public access. a failure occurs. (ACH) for low value payments, including mobile banking. While in the nascent stages, it is
• Documented alternative access procedures in the nonetheless encouraged by CBB.182
event of system failures for providers • El Salvador: The Central Reserve Bank (BCR) has broad regulatory authority over check
clearinghouses and other payment systems used and operated by financial institutions; however there
2. For cell phone based systems, regulator requires off-site • Implies an orderly liquidation process or transfer is no national payments law in El Salvador. El Salvador is a signatory to the Central American Treaty
storage of backup data in a format that would enable an to an alternate account provider similar to that
orderly liquidation of the trust account(s) through
on Payments, under which BCR maintains oversight of what it considers to be systemically important
used for a failed financial institution.
repayment to system users. payment and settlement systems. BCR also defines the parameters of high and low value payments
under the Treaty terms and conditions, though the Treaty does not specifically cover retail payments.
For bank based systems based on individual bank accounts,
normal bank processes required. The issuance of stored value instruments, such as prepaid cards and mobile banking, have not been
clarified within the context of the regulatory framework for payment services.183
3. Providers establish their own redundancy requirements • Redundancy and continuity will mitigate the risk • South Africa: Under the auspices of The South African Reserve Bank Act, the South African
and disaster recovery to ensure continued financial system of loss of system availability and limit the duration Reserve Bank (SARB) is authorized to “perform the functions, implement the rules and procedures,
access. when a failure occurs. and in general, take the steps necessary to establish, conduct, monitor, regulate, and supervise
• Documented alternative access procedures in the payment, clearing, and settlement systems. Access to the national payment and settlement systems is
event of system failures for providers. restricted to banks only, with non-bank actors able to access the system via joint ventures with banks
• Lack of regulatory requirement will allow each that are existing members. Under the National Payment System Act of 1998, SARB can delegate its
institution to define the extent of their responsibilities to a self-regulatory industry body, while retaining oversight control, and has done so
contingency plans, which will leave some less with respect to the Payments Association of South Africa (PASA); PASA has appointed Bankserv as
protected than may be appropriate for the the payment clearinghouse for the South African banking industry and Bankserv provides interbank
payment system. However, it will also allow
electronic transaction switching services to the banking sector. The switching services are majority
individual institutions to innovate.
owned by the countries four largest banks, ABSA Bank, First National Bank of South Africa (FNB),
Nedbank, and Standard Bank, with 90% of the market. 184

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Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x x x x x x x x

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7.10. Risk (National Regulators): Options Implications
“Account provider employee sets up accounts on the system with balances not backed by currency. Such an stability of the financial system and will
act would create a liability for the MNO. Also, national regulators would be concerned of the impact on the significantly damage the reputation of the mobile
economy if such a scheme were executed on a large scale.” system.

Description: Policy Narrative:

Generally, when a customer sets up a prepaid mobile payment account, they make a deposit of real currency Fundamental to most business models is the integrity of the employees. However, without proper safeguards,
for an equivalent balance of mobile money. However, an employee of the MNO with access to the backend employees may be tempted to steal from their employer. If an employee of a service provider set up new
systems could set up fraudulent new accounts that were not backed by currency. The employee could then mobile money accounts with mobile money balances which were not backed by currency, they could use that
either cash-out or spend their mobile money creating a liability for the MNO that could go unnoticed without mobile money, whether through a cash-out, merchant purchase, or person-to-person transaction, and create a
proper internal safeguards. Since e-money is backed by real money deposited in the trust account (or the liability for the service provider. In effect, they are stealing from their employer. Without proper safeguards
capital of the account provider, if deficient), creation of e-money may increase the velocity of money, but not (i.e. daily settlement and fraud protection, which would identify unbacked balance increases or account set-
the volume. ups), such liabilities could go unnoticed, as the trust fund would not routinely be fully drawn down. Employees
should be subject, whether by regulatory requirement or firm policy, to due diligence screening which would
Objective: identify those with a criminal history. Further, fraud insurance could be purchased to hedge against such
¾ Account providers ensure sufficient internal controls and monitoring of the trust balances against the behavior. Again, either by regulatory requirement or firm policy, internal controls should be in place that
amount in transit to discourage such defalcations and rapidly identify them should they occur. would quickly identify cash-in transactions that were not backed by physical currency. Daily settlement across
¾ Subject to regulatory oversight. the agent network should highlight any anomalies and allow for investigation. With the legal and reputation
risk that exists, account providers have no incentive to manipulate mobile money balances; however,
employees may attempt to do so at their employer’s expense. As such, regulators and providers must be
Policy Table: diligent in establishing the proper controls that can mitigate the potential for any systemic impact.
Options Implications
1. Regulatory authority requires account providers to • Insurance will mitigate the risk to account Market Examples:
conduct due diligence screening on key employees and providers and the financial system of fraud.
• Please Note: A market example of a policy action associated with this risk was not identified during the
obtain fraud insurance (bonding) to protect against insider • Fraud insurance may not be available or be
fraud. literature review or the in-country consultations included in this project’s scope. We welcome your suggestions
expensive. of relevant examples for inclusion in subsequent versions.
• Bonding costs lower if the legal system has the
capacity to arrest, prosecute and convict those
Risk Type:
who commit fraud.
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
2. Providers implement institution specific fraud detection • Account providers have a vested interest in protecting Model Model Model
systems. themselves from internal fraud and in implementing x x x x x x x
appropriate internal controls.
• Fraud detection allows for issue identification,
investigation and prosecution.
• Variance across institutions may let criminals
target weak systems; however, competition will
allow for innovation.
3. No required regulatory response to insider employee • Small-scale insider manipulation is unlikely to
fraud. have much impact.
• Systemic fraud by insiders could damage the

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7.11. Risk (National Regulators): CGAP survey. In an effort to address this issue, the E-Money Regulation does distinguish between
“In economies where minutes are exchanged like currency, and could be cashed-out for currency, distributor registered and unregistered issuance of e-money, with registered e-money requiring substantial data
of airtime vouchers or distributor employee could increase the amount of airtime on the market.” capture on the customer. For instance, issuers must record the name, address, date of birth and
other data as listed in the customer’s identity card. Unregistered e-money is limited to IDR
Description: 1,000,000 or USD 100 with the top value of 5,000,000 (approximately USD 500). While e-money
In some economies, mobile minutes have been used as a means of exchange. Generally, an MNO will provide loads may be performed by agents, cash-outs require a money remitters license.185
mobile minutes as a service for a specific price. However, an MNO could increase the number of minutes on • Kenya, South Africa, Tanzania: Me2U, offered by MTN in South Africa, or Sambaza, offered by
the market without compensation for various reasons, such as extra minutes to reward customer loyalty. Safaricom in Kenya, offer popular airtime transfer services whereby for a small fee one prepaid
MNO employees could also set up accounts with minutes for which they did not pay. An increase in the customer may transfer a portion of airtime to another customer on the same network. This
number of minutes on the market will depreciate their worth overtime. If a cash-out opportunity is available, phenomenon has led some pundits to comment that airtime has become an alternative form of e-
an individual that set up fraudulent accounts could make quick money. currency. The Economist reported in 2005 that a woman in the Democratic Republic of the Congo
settled a bribe to officials across the country by sending them airtime. While airtime is not
Objective: redeemable at par into cash and a telco commission for redemption is typically 15% on the face value
¾ The account provider's business model will determine the extent of service discounts they wish to provide of airtime at first sale. An airtime vendor, according to anecdotal interview with a Super Agent in
to their customers. Not a regulatory issue. Tanzania, indicated that “second hand” airtime transfers at a 15-20% discount that he could re-sell to
other users effectively match or exceed his commission. This compensates for the loss of his
network commission. He noted that this method of airtime re-sell is frequently used by parents to,
Policy Table:
with him as intermediary, to earn funds for their college age students.186
Options Implications
• Saudi Arabia: The company, TransferTo, advertises international airtime transfers as “an effective
1. No regulatory action • Hopefully cell phone company "sales" that reduce compliment to money remittance.” The company has initially identified 25 mobile operator airtime
the cost of airtime will result in increased transfer corridors in 7 countries (Jordan, Egypt, India, Pakistan, Sri Lanka, Indonesia, and the
business rather than losses.
Philippines) between Saudi Arabia. There are potentially over 100 migration corridors where the
service could be deployed.187
Policy Narrative:
FATF’s 9 Special Recommendations, specifically on Alternative Remittances (SRVI) stress that each country Risk Type:
should “take measures to ensure that persons or legal entities, including agents, that provide a service for the MNO Bank Hybrid
transmission of money or value, including the transmission through an informal money or value transfer International Systemic Operational Reputation Liquidity Legal
Model Model Model
system or network” should be subject to licensing or registration, as well as subject to all FATF x x x x x x
recommendations that apply to banks and non-bank financial institutions. Further to the interpretive notes
provided, a money or value transfer service may be defined as including “persons providing either through the
formally regulated financial system or informally through non-bank financial institutions or other business
entities or any other mechanism either through the regulated financial system (for example, use of bank
accounts) or through a network or mechanism that operates outside the regulated system.” Considering SRVI
in its entirety, including the interpretive notes, which elaborate that these alternative remittances may be
defined as including underground banking systems such as hawala, then airtime value transfers may be
considered an informal value transfer mechanism.

Market Examples:
• Indonesia: It is estimated by the World Bank that approximately 205 of total Indonesian
remittances occur through formal channels. The predominant forms of remittance are returning
migrants (hand delivery), courier, employment agencies, and money changers, according to a recent

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7.12. Risk (National Regulators): With the increasing demand for mobile financial services, customers will have a broader range of financial
“Increasing reliance on mobile financial services may result in a concentration of deposits in one or a few products and services from which to choose and will likely have the opportunity to “bundle” this new mobile
trustee financial institutions, leading to disintermediation from smaller institutions and reductions in access to financial service with other financial services and products offered through the same financial institution. As a
finance from those institutions.” result, there could be a significant move of customers away from smaller deposit taking institutions (such as
the savings and loan model) or a cooperative, toward a larger commercial bank that is safer, and which offers
the convenience and reduced costs associated with cell phone banking. New funds will flow into a bank
Description:
account if they are in a savings account linked to the mobile phone banking service, or a trust account if they
Rather than having funds dispersed across the financial system, or outside of the financial system entirely, the
are just payments in process. Either way, both the savings account and the trust account are considered bank
uptake of mobile payment services will concentrate payment account funds in the trust funds held in only a
accounts, and so form part of the deposit base of the bank. The bank may choose to invest some of these
few institutions. The financial institutions where some of these funds would have been deposited will have
funds in government paper which would, in the short run, reduce the funds available in the bank account.
fewer resources with which to make loans. The institutions holding these funds could be restricted by
However, the remaining balance would still be available as part of the bank’s overall deposit and lending base.
regulations, or their own credit policy decisions, from using these funds for lending. The institutions holding
The net result would be an increase in the commercial bank’s lending capital base, and a corresponding
these funds could be restricted by regulations, or their own credit policy decisions, from using these funds for
decrease in the lending capital base of the smaller, less competitive financial institutions, particularly those that
lending, thus reducing the level of loan funding available to the economy. This could lead to consolidation
are unlicensed and that lack core back office technological and human capacity necessary to adopt front-end
within the financial system resulting from those institutions that are not able to keep up with the technology
mobile phone banking technologies. Should the larger commercial banks choose to extend their market into
having increasing difficulty competing. However, the conversion of cash in circulation to deposits in the trust
rural regions through mobile phone banking that does not require the setting up of costly rural bricks-and-
accounts would increase the resources of the banking system as a whole.
mortar branches, they will likely crowd out the smaller institutions, including those smaller unregulated
microfinance institutions that lack the core technology capacity to become integrated into the cell phone
Objective:
banking ecosystem. MFIs can consider partnering as an agent network with a mobile network operator, taking
¾ Application of prudential guidelines on risk concentrations/dependencies to account provider trust advantage of the MNO’s comparative advantage in having in place many of the technological and payment
accounts. systems necessary to engage in mobile phone banking. Moreover, the commercial banks can capitalize on the
¾ Expansion of larger financial institutions down-market as the technology lowers transaction costs and MFI’s ability to reach down-market into rural communities, and maintain a strong client base through their
service break even points. comparative advantage in utilizing relationship banking as part of their core operating strategy.

Policy Table: Market Examples:

Options Implications • Kenya: In May 2010 a new product was launched in Kenya that links M-PESA cell phone users with
one of Kenya’s leading commercial banks, Equity Bank, through an interest-bearing savings account.
1. Law/Regulation that limits the size of a trust account or • Diversification of trust accounts holdings across
group of trust accounts from any account provider in any
“M-Kesho” will now allow M-PESA users to have direct access to mobile microsavings,
multiple financial institutions reduces risk
one trustee institution to a percentage of the trustee's risk concentrations. microinsurance, and other banking services with and through a regulated commercial bank.188
weighted capital. • Spreading trust funds across multiple financial
Risk Type:
institutions will add complexity for account
MNO Bank Hybrid
providers, increasing operating costs. International Systemic Operational Reputation Liquidity Legal
Model Model Model
• Implies regulatory oversight to ensure x
compliance.
2. No regulatory action • account providers hedge their risk relating to
concentration of deposits based on profit motive,
which may not align with what is best for the
market as a whole.

Policy Narrative:

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7.13. Risk (National Regulators): Options Implications
“Single dominant player in a closed-loop environment abuses market power (predatory pricing).” network transaction capability.
3. No regulatory action • Predatory pricing and expanded monopoly power
Description: are possible. However, experience with
A single telecom company can dominate the market in the absence of adequate competition. The first player networked technologies (cell phones/ATMs)
to enter the market can create a monopoly, which can potentially lead to anti-competitive pricing and suggests that the market will move toward
restricted services/innovation. interoperability without regulatory action.
• Provided that account providers are given
Objective: consistent market entry requirements, abuse of
the first mover advantage will encourage
¾ Fair competition among providers on products/services. competition to enter the market.
¾ No unreasonable barriers to the flow of funds between account providers.
¾ Predictable market entry for qualified applicants to ensure that the prospect of competition discourages Policy Narrative:
predatory pricing. This risk focuses on the concept of interoperability among competing national and international MFS systems.
¾ National and regional payment systems able to transmit payments between account providers and between Universal acceptance by all consumers, regardless of mobile network operator or MFS platform affiliation, will
countries. impact penetration growth and the overall sustainability of MFS.

In markets where MFS services are being led by mobile network operators (MNOs) interoperability is limited
Policy Table:
to peer to peer transfers to rival MNO subscribers through a mechanism that requires cash out, switching to
Options Implications
and registering with the sender’s service.
1. Regulators require interoperability of payment networks • Requirement of interoperability could raise a
(through inter-provider links or through a switch) barrier to entry as the technology requirements In markets where a third party is the dominant MFS provider (e.g., Wizzit) specific MNO affiliation is not a
could be more challenging than a simple closed requirement. However, all transactions must be made through the third party platform and connectivity to
network. Further, the requirement could stifle
innovation in a new technology through keeping
other MFS providers is not possible.
new entrants out.
In markets where banks are the leading players, the existing financial sector clearing processes act as a catalyst
• Customers would benefit as there would be no
for interoperability. However, to date this has not translated into an effective interoperable MFS system.
network limitations on sending mobile money.
• Providers would be forced to compete on cost, In other fields, consumer demand typically drives the development of industry standards and interoperability
products, and service, rather than size of
(e.g., GSM operations). With respect to MFS, financial regulators are positioned to regulate interoperability,
network which could represent a first mover
advantage. but thus far, have not done so.
• By reducing the first mover advantage, could
Market Examples:
discourage potential first movers from entering
the market. • El Salvador: According to a CGAP interview with the Central Reserve Bank (BCR), limited
interoperability for retail payments hampers customers from cash-based deposit and withdrawal
2. Competition agency empowered to investigate non- • Implies a competition agency with the capacity to services in bank branches, as well as transferring funds from bank-to-bank using the Internet channel.
competitive behavior investigate and enforce non-competitive Mobile banking is in the embryonic stages, and similar to Internet banking, is available only to those
behavior, such as predatory pricing, to who already have bank accounts.189
counteract the incentive for monopoly pricing,
thus protecting the consumer. • Pakistan: The State Bank of Pakistan (SBP) considered several branchless banking models before
initially deciding to allow only bank-led models. In all cases, the customer has an account relationship
• However, may impede development of cross

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with the bank through establishment of a branchless banking account. The many-to-many model
involves a central transaction processing system or switch, providing total interoperability. Though
not yet implemented, this is the preferred model of SBP and allows multiple banks to offer services to
customers of multiple agent networks or MNOs. The switch must be controlled by the bank, an
agent or a subsidiary of the bank or group of banks. Banks can purchase access to the switch, similar
to access to an ATM network, which would reduce the technology investment burden placed on any
single bank.190
• Indonesia: Article 27 of the E-Money Regulation mandates that e-money providers must offer
systems that are interoperable with other e-money systems.191
• Iraq: The U.S. Department of Defense funded a $2 million initiative in cooperation with private
banks to develop a shared, multi-channel electronic funds transfer switch to enable m-banking,
Mastercard/VISA POS, and ATM services. M-banking features include a USSD user interface with P2P
transfers, airtime top-up, and balance inquiry services. As of 2010, five banks and one MNO were
participating in the system.192
• South Africa: WIZZIT, founded in 2004 by two entrepreneurs and operating in partnership with
the Bank of Athens, offers mobile banking services to approximately 300,000 customers. The
company is mobile phone agnostic, so that customers can use phones operated by any of South
Africa’s mobile operators, for services ranging from transferring money to third parties, loading
electricity with prepaid cards, and buying airtime for prepaid mobile phone subscriptions. Since
WIZZIT has no brick and mortar branches of its own, it operates 3,500 deposit taking sites in
conjunction with the Post Office and ABSA Bank. Customers are issued a Maestro-branded debit
card, which they may use for cash withdrawals at any South African ATM.193
• Spain: Mobipay, was launched as mobile payments platform, as a result of a joint venture between
Spain’s largest telco, Telefonica, and a bank, BBVA. At the time this venture, the Spanish
Competition Authority (SDC) was concerned that m-payments would affect not only e-commerce
but also mobile telephony; it approved the JV with certain stipulations:
-other mobile operators must be allowed to participate;
-the interoperability of any mobile operator and any financial institution had to be technically possible;
-customers could not be limited in their choice of other MNOs or financial account providers by the
service contract;
-SDC had approval authority for interchange fees.
While initially slow to market in Spain, BBVA, took the product to Mexico and North Africa in
2005.194

Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
x x

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7.14. Risk (National Regulators): Market Examples:
“Illicit actors conduct high volume transactions using multiple accounts, bypassing monitoring systems before • Tanzania: During investigations of operations, the DECI (T) Limited company did not operate
regulators can step in.” a microfinance bank account in its name, but apparently collected funds from its members and
deposited them in personal bank accounts.196 “The public is also notified that the capital markets
Description: and securities authority (CMSA) has not granted a license to DECI (T) Limited to operated
Because of the speed of the payment process using a mobile system, it is possible to make multiple collective investment schemes in Tanzania. It should be noted that promotion and participation
transactions quickly, in a near real-time transaction environment. in any pyramid schemes is an offence in terms of the provision of the penal code (as amended in
2006) While authorities are still carrying out investigation to establish the scope and nature of
Objective:
operations of DECI (T) Limited in the country, the general public is warned to desist from
¾ Account providers flag and limit opening multiple accounts based on similar KYC/ CDD data. participating in the scheme operated by DECI (T) Limited.”197
¾ Subject to regulatory oversight. • Pakistan: The Financial Monitoring Unit (FMU) provides the following functions related to
suspicious transactions: (b) to analyze the Suspicious Transaction Reports and CTRs and in that
Policy Table: respect may call for record and information from any agency or person in Pakistan (with exception of
Options Implications income tax information) related to the transaction in question. All such agencies or persons shall be
1. Account providers required to flag and block multiple required to promptly provide the requested information. (j) to engage a financial institution or an
• Monitoring systems can deter most illicit activity
accounts with similar KYC/ CDD data. intermediary or such other. non-financial businesses and professions or any of its officers as may
• Implies regulatory verification of account
be necessary for facilitating implementation of the provisions of this-Act, the rules or regulations
provider policies, procedures and its capacity to
comply. made hereunder…”198
2. Rely on account monitoring as another alternative to • . Multiple accounts of the same owner can be identified Risk Type:
KYC. via pattern identification systems that recognize activity MNO Bank Hybrid
similarities (e.g. several account all sending money to the International Systemic Operational Reputation Liquidity Legal
Model Model Model
same place/agent/customer or e.g. an unusual level of x x x x
transactions from one place to another in a given
timeframe.)
• Enables expanded access where national ID systems may
be weak.
3 No regulatory action. • Providers will institute risk mitigation systems in
line with their perceived risk to abuse of their
system.

Policy Narrative:
The alleged Madoff $50 billion dollar Ponzi scheme is perhaps a classic example of massive fraud, both in terms
of scope and duration, where monitoring systems and human capacity failed on a systemic level.195 Madoff
founded his investment advisory business (Bernard Madoff Investment Securities) in 1960 and maintained a
prominent standing in the securities industry throughout his career until the fraud was exposed in 2008. Not
only was he a member of the NASDAQ Stock Market’s board of governors and its executive committee, he
also served as chairman of its trading committee and vice chairman of the NASD. When educated of such
schemes, public awareness campaigns may provide the best, first line of defense.

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7.15. Risk (National Regulators): Market Examples:
“Financial terrorists target payment network to disrupt financial system.” • United States: The Al Qaida attacks of September 11, 2001, specifically targeted the hub of
acknowledged seat of U.S. financial operations, both for sites such as the NY Stock Exchange, The
Description: Clearing House, and SWIFT NY HQ, and major commercial financial institutions. Disaster recovery
Financial terrorists hack into mobile payment network to disrupt the economy. The mobile payment network was aided, in large part, due to long standing attention to cyberprotection issues by financial
may be targeted, as the security is perceived as less than that of the financial system. Alternatively, terrorists institutions. In 1999, industry participants established and funded one of the first information sharing
may target the data center of the account provider to damage or destroy service capacity. and analysis centers (ISACs). More than forty of the U.S. largest banks, securities and insurance firms,
investment companies, and financial utilities, representing a significant portion of assets in the financial
Objective: system, participate in the ISAC. The ISAC maintains an industry wide database of electronic security
¾ Mobile payment networks’ security requirements, including possible redundancy, to be commensurate with threats, vulnerabilities, incidents, and solutions. Security specialists analyze reports and distribute to
the proportionate systemic importance of the account provider. members warnings and information about threats and solutions or mitigation procedures. Financial
institutions also actively participate in a number of other information-sharing organizations, such as
the Federal Computer Incident Response Center (FedCIRC) and the System Administration,
Policy Table:
Networking, and Security Institute (SANS).199
Options Implications
• Kenya: In a recent presentation entitled “10 YEARS ON FROM THE US EMBASSY BOMB BLAST”
1. Regulatory authority mandates system redundancy • Redundancy and continuity will mitigate the risk in Nairobi, Kenya,”200 Director Samuel Mutungi provided a case study on lessons learned for terrorist
requirements and disaster recovery to ensure continued of impaired system availability and limit the attacks regarding disaster recovery and business continuity planning for financial services. One of the
financial system access, particularly for significant Account duration when a failure occurs.
Providers. main mitigating strategies aiding in recovery for Co-Operative Bank, despite the fact that the ICT
• Documented alternative data access and equipment was damaged and networks/systems were destabilized, was that the Bank’s systems back-
recovery procedures in the event of system up e.g , redundancies, had recently been moved off site. The 1998 attack disrupted Co-Operative
failures for account providers
Bank operations alone for 4 years; terrorist acts are not covered by insurance and rent alone cost an
2. Providers establish their own redundancy requirements • Redundancy and continuity will mitigate the risk additional 400 million Kenyan shillings per annum for this period.
and disaster recovery to ensure continued financial system of impaired system availability and limit the
access. duration when a failure occurs. Risk Type:
• Documented alternative data access and MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
recovery procedures in the event of system Model Model Model
failures for providers x x x x x x x x x
• Lack of regulatory requirement will allow each
institution to define the extent of its contingency
plans, which will leave some less protected than
may be appropriate for the payment system.
However, it will also allow individual institutions
to innovate.

Policy Narrative:
Recognizing the imperative nature of combating the financing of terrorism, the FATF outlined and agreed to
nine Special Recommendations, which, when combined with the FATF Forty Recommendations on money
laundering, set out the basic framework to detect, prevent and suppress the financing of terrorism and
terrorist acts which seek to disrupt financial systems.

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7.16. Risk (National Regulators): ecosystem, they are in many countries arguably one of the larger and more significant of actors in terms of
“Account provider fails / enters insolvency limiting customer access to funds and potentially destabilizing their ability to move forward—or bring down—the entire system. As such, service providers of this size and
financial system.” level of market importance will need to be monitored as if they are an actual component of the financial
system. Moreover, acknowledging the bailout that resulted from the fear of the systemic risk that could have
Description: been brought on by the collapse of Lehman Brothers, any one actor in the mobile banking ecosystem should
Mobile payment Account providers, like other companies, may fail / enter insolvency for a variety of reasons. not be permitted to grow “too big to fail” so as to pose a systemic risk to the entire system. At a minimum,
However, unlike normal companies, their service provision is a component of the financial system and their guidelines should be established for a service provider that are similar in function to those used to identify and
insolvency can destabilize the economy if not properly managed. rehabilitate problem banks, to enact resolution management and address accounting issues in problem banks,
and to address problems in large and multi-charter banking companies.201
Objective:
¾ Mobile payment Account providers’ insolvency procedures should mimic those of financial institutions. Market Examples:
• United States: The downfall of a large Orange County investment fund in December 1994 was the
¾ Established process for obtaining records of items in transit and enabling rapid cash out liquidation or
harbinger of the more recent financial crisis brought on by the interaction of large market players
transfer to another account provider using the trust funds.
taking excessive risks with derivatives and other highly leveraged instruments. In the Orange County
¾ Clear regulatory policies and procedures to manage such events. case, the losses to the fund were high mainly because 60 percent of its assets were bought on credit
with fund managers borrowing short-term to buy bonds maturing as far of as 1998. Soon after the
Policy Table: collapse of the investment fund, U.S. government officials began looking closely at other large market
Options Implications players—such as pension funds—with the rightful concern that a sudden sell-off of derivatives from
1. Incorporate winding up provisions in the Law / • Protection of payment system assets and records such large market players could lead to systemic risk viz. the financial markets. These market
Regulation covering mobile financial account providers, in case of insolvency would minimize the examples can provide valuable lessons to the mobile phone banking system, particularly related to the
particularly on assuring regulatory access to transaction systemic impact of a mobile payment system development of appropriate and prudent investment and fund management guidelines for key players
records and trust funds that back items in transit. failure. in the system, including service providers and the corresponding bank partners holding the trust
• Assets of clients, as in customer funds in transit accounts.
or temporary storage, should be kept out of the
general pool of assets available to satisfy Risk Type:
creditors. This is particularly important in MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
countries under statute law that does not Model Model Model
accommodate separation of assets into trusts. x x x x x x x x x
2. Insolvency handled like any other business. • Financial system stability would be at risk
depending on the size of the network.
• Consumer protection for payment account
holders would be a significant issue if the
insolvency process did not protect these
accounts differently from the general assets of
the account provider.

Policy Narrative:
While mobile network operators are not subject to national banking regulation and supervision, they do, in a
practical sense, undertake activities that at least mimic banking functions that would warrant such oversight.
And while mobile network operators are one of several agents interacting within a mobile phone banking

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7.17. Risk (National Regulators): support, operational assistance, and technical databases to assist the 188 member countries of INTERPOL
“Counterfeit funds accepted by an agent. regarding counterfeit national currencies202

Description: Market Examples:

Agents will be targeted as an entry point for counterfeiters to unload money into the system. Counterfeiters • Kenya: “Sec. 373 Any person who – (a) utters any counterfeit coin knowing it to be counterfeit, and
will perceive agents as less knowledgeable than bank employees, the security/monitoring of agents to be less at the time of such uttering has in his possession any other counterfeit coin; or (b) utters any
than banks, and yet still have a high enough transaction volume that they would be difficult to identify. counterfeit coin knowing it to be counterfeit, and either on the same day or on any of the ten day
next ensuing utters any other counterfeit coin knowing it to be counterfeit; or (c) receives, obtains
Objective: or has in his possession any counterfeit coin knowing it to be counterfeit, with intent to utter it, is
¾ Agent training on counterfeits to be modeled on bank teller training and provided by account providers guilty of a felony and is liable to imprisonment of three years.”203
commensurate to the perceived risk.
Risk Type:
MNO Bank Hybrid
Policy Table: International Systemic Operational Reputation Liquidity Legal
Model Model Model
Options Implications x x x x x x x
1. Regulatory authority provides mechanism for reporting, • May incentivize agent to report counterfeit
retrieval, and criminal investigation of suspect counterfeit activity.
notes. • Reporting facilitates identification of issues,
Regulatory authority sets parameters for training material investigation, and apprehension of counterfeiters.
for use by account providers with their agents.
• Regulatory authority requires capacity/budget to
support anti-counterfeiting training and
enforcement.
2. Account providers required, as part of AML/CFT/Fraud • Training facilitates identification of issues,
training programs, to institute and monitor agent investigation, and apprehension of counterfeiters.
compliance commensurate with perceived risk. • Active program will deter use of agents to pass
counterfeit notes.
3. No regulatory response to counterfeit currency in • Increasing circulation of counterfeit currency.
circulation.

Policy Narrative:
As international authorities dealing with this issue reiterate, the crime of counterfeiting national currency is as
old as the creation of money itself. With the advent advanced personal computer graphics programs and low-
cost, high quality photographic and printing technologies and equipment available to the lay person, the ability
to reproduce complex images on paper stock has never been easier. The resultant effect of this bogus
currency introduced into circulation poses problems not only for national economies, but also for financial
institutions, consumers, and economies worldwide. The intersection of mobile financial services and the use
of national currencies, in this regard, pose similar need for international cooperation and private/public
partnerships. These may be encouraged through such law enforcement organizations as INTERPOL, which
maintains expertise through their Counterfeit and Security Documents Branch (CSDB), providing forensic

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7.18. Risk (National Regulators): Options Implications
“Counterfeit funds distributed by an agent.” need to be evaluated.
5. No regulatory oversight or training by account provider • Increased circulation of counterfeit currency.
Description: of agent
Counterfeiters may try to recruit agents into their networks to distribute counterfeit currency into the
economy.
Policy Narrative:
Objective: As international authorities dealing with this issue reiterate, the crime of counterfeiting national currency is as
old as the creation of money itself. With the advent advanced personal computer graphics programs and low-
¾ MNOs responsible for supervision of agents and collaborate with law enforcement authorities on cost, high quality photographic and printing technologies and equipment available to the lay person, the ability
investigation of counterfeit currency to enable criminal prosecution of agents. to reproduce complex images on paper stock has never been easier. The resultant effect of this bogus
currency introduced into circulation poses problems not only for national economies, but also for financial
Policy Table: institutions, consumers, and economies worldwide. The intersection of mobile financial services and the use
Options Implications of national currencies, in this regard, pose similar need for international cooperation and private/public
1. Regulatory authorities should provide mechanism for • Reporting facilitates identification of issues, partnerships. These may be encouraged through such law enforcement organizations as INTERPOL, which
reporting, retrieval, and criminal investigation of suspect investigation, and apprehension of maintains expertise through their Counterfeit and Security Documents Branch (CSDB), providing forensic
counterfeit notes. counterfeiters. support, operational assistance, and technical databases to assist the 188 member countries of INTERPOL
• Regulatory authority requires capacity/budget to regarding counterfeit national currencies204
support anti-counterfeiting training and
enforcement. Market Examples:
2. Regulatory authorities to provide an incentive, or
• Kenya: “Sec. 373 Any person who – (a) utters any counterfeit coin knowing it to be counterfeit, and
• Financial incentives can increase cooperation of
reward, system for reporting and retrieving counterfeit agent network in identifying and pursuing at the time of such uttering has in his possession any other counterfeit coin; or (b) utters any
currency, possibly including cash payments. counterfeiters. counterfeit coin knowing it to be counterfeit, and either on the same day or on any of the ten day
next ensuing utters any other counterfeit coin knowing it to be counterfeit; or (c) receives, obtains
• Regulatory authority requires budget to support
incentive program. or has in his possession any counterfeit coin knowing it to be counterfeit, with intent to utter it, is
guilty of a felony and is liable to imprisonment of three years.”205
• Financial rewards may encourage agents to
collaborate with counterfeiters; however,
authorities will monitor agents more closely that
Risk Type:
consistently turn in counterfeits for reward. MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
3. Account providers required, as part of AML/CFT/Fraud • Training facilitates identification of counterfeit x x x x x x x x
training programs, to institute and monitor agent currency and deters acceptance/distribution.
compliance commensurate with perceived risk • Agents may recirculate counterfeit currency if
not incentivized or required to report it.
4. Regulatory authority or account provider could reward • Reward could provide the incentive for
agents for identifying counterfeit currency or providing identification and the disincentive for passing the
information on counterfeiters. currency along.
• Agents with frequent identification would need
monitoring to ensure they were not involved in a
counterfeit scheme.
• Cost/capacity to implement such a scheme would

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Risk-based Policy Matrix – Appendix

7.19. Risk (National Regulators): exposure that the bank can reasonably take on. Any foreign exchange risk associated with currency
“Currency redenominated while in transit.” redenomination of mobile banking funds while in transit relates to the bank’s ability to acquire and maintain the
necessary expertise, such as the ability to conduct ongoing revaluations of currency through a strong internal
Description: controls system backed by adequate capital reserves.206
When a country redenominates its currency, often after a period of high inflation, service users may lose
much of the value of payments in transit unless these transit amounts are also redenominated. A bank’s ability to manage any risk—including foreign exchange risks—rests on the fact that sound
management of internal operations and risks requires appropriately qualified and well-trained staff which
Objective: upholds sound business practices. Failure of staff to observe appropriate internal controls, as well as failure of
¾ Treat items in transit in the same was as deposits in the banking system are treated in case of the control environment, will likely lead to significant financial losses for the institution (and its partner
redenomination of the currency. institutions, if applicable) and will likely tarnish the reputation of the reserve management entity.

In a MNO-led model, the remittance transfer provider should be required to disclose to the customer the
Policy Table:
amount that will be received at the other end of the transaction prior to the initiation of any transfer of funds.
Options Implications
1. Financial regulators include mobile payment system in • Implies account provider capacity to adjust the Market Examples:
any implementation plans for currency redenomination nominal value of items in transit during a • United States: The recently passed U.S. “Wall Street Reform and Consumer Protection Act of
and handle them as they do deposits in the banking system. redenomination.
2010” is expected, among other things, to provide federal oversight for remittance transfers through
• Regulatory requirements mandating that capacity the creation of a new “Consumer Financial Protection Bureau.” This proposed legislation addresses
may send a message to the market that the issue of currency redenomination of a remittance transfer while in transit through a transfer
redenomination is likely, possibly undermining
provider using mobile phones. In this case, the remittance transfer provider must tell the consumer
confidence in the national currency.
what the value on the receiving end will be in the recipient’s country. (The exception to this rule
• May complicate the public education process pertains to countries with fixed currency exchange rates.) Remittance transfer providers are
during redenomination by bunching the impact required to disclose, prior to initiating a transaction for a consumer, the amount that will be received
for people who may be less financially
sophisticated.
at the other end, making it possible for consumers to comparison shop. This will address the finding
of much research that consumers frequently have difficulty understanding the total cost of sending a
2. No regulatory action • An incentive is created for moving money into or remittance—including the exchange rate and fees charged by the provider—before they engage in a
out of the mobile payment system around transaction. (Appleseed, “The Fair Exchange,” April 2009). Currently, U.S. federal regulations that
redenomination to benefit from arbitrage apply to many consumer payments transactions, chiefly under the Electronic Funds Transfer Act
opportunity - could bankrupt the account (EFTA), generally do not apply to remittance transfers. The Consumer Protection Act of 2010
provider and deplete the trust funds so that only
proposes to provide consumer protection to remittance transfers that is similar to protection found
the first to cash out could be paid.
in the EFTA that covers many other consumer payments transactions.207
Policy Narrative: Risk Type:
In a bank-led model, the issue of currency redenomination of electronic funds while in transit should be MNO Bank Hybrid
handled in a way similar to the manner in which deposits in the banking system are treated in the case of a International Systemic Operational Reputation Liquidity Legal
Model Model Model
sudden revaluation (up or down) of the underlying currency. The issuer of electronic cash is exposed to a x x x
number of risks related to its development and operation of a stored value system, (namely strategic,
transaction, compliance, and reputation risk) as well as risks associated with its ownership of electronic cash
and investing proceeds from the “sale” of electronic cash (or the holding of an account backing up the value of
electronic cash). These latter risks include credit, liquidity, interest rate, and foreign exchange risk. The
investment policy of the initiating entity should dictate the extent of credit, liquidity, and interest rate risk

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Risk-based Policy Matrix – Appendix

7.20. Risk (National Regulators): account balance(s) with those of the service provider’s accounts. These monthly reconciliations should be
“Regulator unreasonably blocks a particular service model.” retained for a specified period of time, and be subject to banking regulatory review.

Description: Market Examples:

The extraordinary success of some cell phone based systems have raised concerns in other countries based • General: The dynamics of the relationship between the account provider and bank acting as fund
on “loss of control” over uncertain risks or resistance to competition with exiting formal financial institutions. trustee is somewhat comparable to that found in trust accounts for property management or
association management. In this context, brokers who manage real property or community
Objective: associations may maintain designated rental or assessment trust or escrow accounts separate from
¾ Enable all proven business models within a predictable legal and regulatory environment. their other trust or escrow accounts. The account would be utilized for paying bills on behalf of an
owner or an association from any designated rental or assessment escrow or trust account, and there
would need to be sufficient funds credited and deposited to the owner’s or the association’s account
Policy Table:
to cover such bills. Security deposits would be clearly identified and credited to tenants, and there
Options Implications
would always need to be a balance in the account equal to the total of the accumulated security
1. Limit mobile financial services to bank based models • Restricts usage to those who have reason to deposits. In such an arrangement, monthly reconciliation of trust accounts is maintained and the trust
requiring users to pass all transactions over individual bank have a full bank account, effectively excluding the account is subject to periodic external examination and audit.Mexico: In early 2009, Mexico’s
accounts poor. supervisory Comisión Nacional Bancaria y de Valores (National Banking and Securities Commission
• Little or no developmental impact. or CNBV) began preparing a new e-money regulations which facilitate mobile payments and internet
2. Allow both cell phone company and bank based • Opens access to financial services to the poor banking by credit institutions. The new regulations will not broaden the non-bank role in regards to
services. through low cost payment services that do not e-money issuance. The resolution loosened consent requirements for credit institutions in offering
require a full bank account – significant mobile payment, ATM and POS terminal services (such as prepaid cards) and internet banking. Rather
developmental impact. than requiring explicit consent by signature, users may consent to additional services with a second
• Acts as a catalyst for building confidence in the form of electronic authentication once they have started the relevant electronic session or, for
financial system and in using formal financial mobile payment, through call centers. In order for credit institutions to avail themselves of these
services rather than dependence on cash. loosened requirements in regards to mobile payments, they must institute controls to prevent the
association of more than one mobile phone line to the account of a user, and of one number of a
Policy Narrative: mobile phone line to several users. The e-money regulation issuance was delayed in part due to
If a bank is holding a trust account on behalf of a mobile network operator, then interest is earned from concerns as to potential unfair competition concerning the future provision of e-money by mobile
investments made on a joint account held in multiple names and would, in a normal trust situation, be divided network operators, given Telcel’s dominant position of the Mexican mobile telephony market, with
equally among all account holders on a periodic basis. Practically speaking, imposing such a mechanism on a 85% market share [Notes on Branchless Banking Policy and Regulation in Mexico, CGAP, March
mobile phone trust account system would impose a high accounting burden on the service provider and 2009]. These concerns may ultimately be the reason why the current regulation did not, in fact,
supervisory burden on national regulators monitoring the bank-led portion of the transaction. Nonetheless, extend mobile payments to non-banks such as MTOs.208
the issue of who “owns” the interest earned from investments of trust account holdings is a significant one,
and should be addressed from a consumer protection and overall transparency context. Risk Type:
MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
Model Model Model
At a minimum, both the service provider and bank should undertake monthly reconciliation of flows into and
x x x x x x
out of trust accounts. The minimum information to be included in the monthly reconciliation statement shall
be the date the reconciliation was undertaken, the date used to reconcile the balances, the name of the
bank(s) holding the trust account(s), the name(s) of the account(s), the account number(s), the account
balance(s) and date(s), any deposit(s) in transit, and an itemization of the outstanding trust liability showing the
amount and source of funds received and not yet disbursed, and other items necessary to reconcile the bank

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Risk-based Policy Matrix – Appendix

7.21. Risk (National Regulators):
“Interest income on service users’ trust funds is improperly allocated to the detriment of service users.” Policy Narrative:
If a bank is holding a trust account on behalf of a mobile network operator, then interest is earned from
Description: investments made on a joint account held in multiple names and would, in a normal trust situation, be divided
The trustee will invest the trust funds in interest bearing instruments, such as government securities or equally among all account holders on a periodic basis. Practically speaking, imposing such a mechanism on a
interest bearing deposit or savings accounts with financial intermediaries. So the trustee, the account provider mobile phone trust account system would impose a high accounting burden on the account provider and
or the service users will benefit from this interest. supervisory burden on national regulators monitoring the bank-led portion of the transaction. Nonetheless,
the issue of who “owns” the interest earned from investments of trust account holdings is a significant one, and
Objective: should be addressed from a consumer protection and overall transparency context.
Ensure that the benefit of income generated by the trust funds is most efficiently allocated back to the
benefit of service users, based on the account provider's business model. At a minimum, both the account provider and bank should undertake monthly reconciliation of flows into and
Policy Table: out of trust accounts. The minimum information to be included in the monthly reconciliation statement shall
Options Implications be the date the reconciliation was undertaken, the date used to reconcile the balances, the name of the bank(s)
1. Require that interest income be credited back to • Adds an additional level of complexity to the holding the trust account(s), the name(s) of the account(s), the account number(s), the account balance(s) and
individual service user’s accounts, based on the average account provider’s service by requiring date(s), any deposit(s) in transit, and an itemization of the outstanding trust liability showing the amount and
amounts in transit during the period. calculation of the interest and crediting back to source of funds received and not yet disbursed, and other items necessary to reconcile the bank account
the service users’ individual accounts, adding to balance(s) with those of the account provider’s accounts. These monthly reconciliations should be retained for
the cost of providing the service. a specified period of time, and be subject to banking regulatory review.
• Complicates account reconciliation for service
users by adding transactions not originated by Market Examples:
service users. • Please Note: A market example of a policy action associated with this risk was not identified during the
• Could encourage service users to leave funds “on literature review or the in-country consultations included in this project’s scope. We welcome your suggestions
deposit” in lieu of opening a formal savings of relevant examples for inclusion in subsequent versions.
account, reducing the incentive to move savings
into the formal financial sector.
Risk Type:
2. Allocate some or all of the interest income to the • Motivates trustees to provide the trustee MNO Bank Hybrid
trustee to cover trustee fees for managing the trust services. International Systemic Operational Reputation Liquidity Legal
Model Model Model
account. • Eliminates pass back of trustee fees to the x x x x
account provider.
• Implies monitoring by the account provider to
avoid over-charging by the trustee.
• May motivate trustee to reach for higher yield,
higher risk investments, implying a need for
regulatory oversight of investments.
3. Allocate some or all of the interest income to the • Augments the revenue stream for the account
account provider as additional revenue. provider, in principle enabling lower direct
service fees to service users.
• Benefit will vary with market interest rates.

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Risk-based Policy Matrix – Appendix

8.1. Risk (International Regulatory Issues): Market Examples:
“Heightened difficulty tracking and prosecuting illicit cross-border transactions given the new cross border • Please Note: A market example of a policy action associated with this risk was not identified during the
payment capability with a national regulatory framework and enforcement mechanism.” literature review or the in-country consultations included in this project’s scope. We welcome your suggestions
of relevant examples for inclusion in subsequent versions.
Description:
Illicit financial activities, such as money laundering and the financing of terrorist activities, can be facilitated (and
more difficult to prevent) when cross-border transactions are allowed where different regulatory systems are Risk Type:
MNO Bank Hybrid
in place. The incompatible regulation can prevent, or make more complicated, identifying suspicious International Systemic Operational Reputation Liquidity Legal
Model Model Model
transactions, investigating the transactions, as well as prosecuting and convicting those involved in illicit
x x x x x x x
transactions. This risk applies to any cross border payment system, not just those using mobile financial
services.

Objective:
¾ Regional harmonization of the legal and regulatory framework for mobile financial services.

Policy Table:
Options Implications
1. Regulatory authority harmonizes mobile financial service • Harmonization with FATF standards facilitates
definitions in the context of FATF Special tracking and prosecution.
Recommendation VII (SRVII) within their own AML/CFT • New requirement imposes a new cost on
regimes. stakeholders
2. No regulatory action • Continued, or possibly, increased ability of
terrorist and/or criminal elements to leverage
mobile payment network and avoid prosecution
for illicit cross-border financial crimes.
• However, transaction size and volume limits
mitigate this risk, particularly versus other
payment systems that can handle larger amounts.

Policy Narrative:
In crafting the revised interpretive notes for SR VII, FATF specifically stipulated that it is not the intent of the
organization to impose “rigid standards or to mandate a single operating process that would negatively affect
the payment system.” This is particularly important to note, as the revisions were undertaken, in part, to
consider the effects posed by small wire transfers and the continued ability to trace them through the financial
system. Given the low thresholds of payments associated with most mobile financial services, harmonization
of this FATF standard in AML/CFT regimes may facilitate the future tracking, detection, and prosecution of
illicit financial crimes that may be associated with this payment channel.

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8.2. Risk (International Regulatory Issues): they cannot conduct even small scale transactions from one national network to the other. (Clearly, some
“Small-scale traders face a theft risk due to their ‘cash & carry’ business.” workarounds can be used where a national network has coverage in a bordering country, or an individual has
accounts on both national networks and acts as the ‘go-between’, but this does not resolve the eventual need
Description: to change currencies.) To facilitate mobile-commerce, rather than simply small-scale person-to-person
Currently, in-country and regional traders conduct a cash and carry business that relies on cash settlement of transactions, regulatory authorities could allow for separate user categories that allow for larger transaction
trade transactions outside of any financial institution, with no audit trails and with theft risk to the traders. sizes. These users may be subject to more extensive KYC/CDD requirements, and their accounts may be
monitored more closely, but this flexibility would enable traders to leverage the technology to facilitate trade.
Objective: Eventual regional harmonization efforts should be considered that allows for interoperability between national
¾ Regional harmonization of the legal and regulatory framework for mobile financial services. providers and a legal and regulatory framework that can facilitate mobile payment use in trade while mitigating
risks associated with cross-border financial transactions.
Policy Table:
Options Implications Market Examples:
1. Regulatory authorities prevent the larger transactions • Regulatory authorities limit mobile payment • Ghana, Nigeria, Senegal: The USAID-funded West Africa Trade Hub Project’s Mobile Money
needed for traders or businesses via mobile payments. system to small-scale personal transactions, Transfer Initiative attempted to leverage the interconnected region, which has approximately $10
limiting its usefulness for commerce. billion in cash crossing borders annually. Targeting intraregional traders and remittance senders, the
• Risk of mobile system use for ML/TF is limited by project initially focused on the countries of Ghana, Nigeria, and Senegal and attempted to facilitating
the small scale of transactions. cross-border, multi-currency transactions via the mobile phone channel. Among the enabling
• Traders continue to use cash for commerce and
challenges encountered were regional bank settlements and foreign exchange convertibility and
the risk of theft and lack of audit trails persists. controls. Technology issues included regional payment switch integration, interconnectivity and
roaming.209
2. Regulatory authorities to allow for a separate user • Regulatory authorities enable traders and
category for traders that allow for larger scale businesses to use mobile payments through Risk Type:
transactions. stepped user categories. MNO Bank Hybrid
International Systemic Operational Reputation Liquidity Legal
• Implies higher level of monitoring to contain the Model Model Model
risk of mobile system use for ML/TF. x
• Risk of theft reduced by access to non-cash,
mobile channel.
3. Regulatory authorities do not restrict transaction size. • Regulatory authorities enable traders and
businesses to use mobile payments as transaction
limits do not restrict their capacity.
• Risk of mobile system use for KYC/CDD
increases, as large transactions enabled without
segregated from general consumer transactions.
• Risk of theft reduced by access to non-cash,
mobile channel.

Policy Narrative:
One of the key benefits of mobile payments is the reduced risk of theft, as individuals no longer have to carry
cash. However, transaction thresholds may limit the ability of traders to use mobile for their transactions,
which tend to be larger. For small scale traders who trade across the borders, the issue is exacerbated, as

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8.3. Risk (International Regulatory Issues): simply force the informal cash transactions to continue, and could potentially lead to other workarounds such
“Cross-border payments through a mobile financial service could be seen as bypassing a country’s foreign as relying on a dominant national network with coverage in both countries, or adoption of the strongest
exchange restrictions.” currency for all trade transactions.

Description: Market Examples:

Convenience and safety may encourage cross-border traders to tap into a neighboring country’s mobile • Ghana, Nigeria, Senegal: The USAID-funded West Africa Trade Hub Project’s Mobile Money
payment system to settle trade payments. If both buyer and seller use the same system, then the funds will Transfer Initiative attempted to leverage the interconnected region, which has approximately $10
remain in the country hosting the buyer’s system. The seller will either have to buy goods or services using billion in cash crossing borders annually. Targeting intraregional traders and remittance senders, the
the e-money from the system host country, or cash out through an exchange office that can use the buyer’s project initially focused on the countries of Ghana, Nigeria, and Senegal and attempted to facilitating
currency of origin. cross-border, multi-currency transactions via the mobile phone channel. Among the enabling
If a foreign exchange conversion facility is built into the service, then transactions that otherwise would be challenges encountered were regional bank settlements and foreign exchange convertibility and
settled in cash move into electronic form. controls. Technology issues included regional payment switch integration, interconnectivity and
roaming.210
Objective:
¾ Enable use of mobile financial services in cross border trade transactions without unreasonable Risk Type:
foreign exchange restrictions. International Systemic Operational Reputation Liquidity Legal
MNO Bank Hybrid
Model Model Model
Policy Table: x x x x x x x x
Options Implications
1. Regulatory authorities prohibit foreign exchange • Cross border traders limited to using cash or a
conversion using mobile financial services. currency both buyer and seller can use.
• May encourage use of a larger neighboring
country’s currency, as for cash transactions,
lowering acceptance of the domestic currency.
2. Regulatory authorities specifically allow foreign • Facilitates monitoring of foreign exchange flows.
exchange conversion using mobile financial services. • Implies development of linkages between
neighboring services that enable currency
conversion.
3. No Regulatory Action • Market for mobile financial services across
borders may be impeded by lack of clarity on the
potential regulatory response.

Policy Narrative:
As noted in 8.2, utilization of mobile financial services for cross border trade transactions can reduce the risk
of theft to the trader. Further, encouraging the usage of a mobile network, formalizes what used to be
untraceable ‘hand-to-hand’ cash transactions, allowing regulatory authorities to more easily monitor foreign
exchange flows. If regulatory authorities establish a low-risk mechanism for interoperability between national
networks, including a foreign exchange conversion, regulators could simultaneously lower the cost of cross-
border trade and increase transparency. Prohibition of foreign exchange conversion through mobile will

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Risk-based Policy Matrix – Appendix

End Notes

1
http://www.fatf-gafi.org/document/28/0,3343,en_32250379_32236930_33658140_1_1_1_1,00.html. Hereafter: FATF 40. Recommendations 5, 6 and 8 and interpretive notes, where applicable.
2
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in Brazil,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.2319/Brazil-Notes-On-Regulation-Branchless-Banking-2008.pdf. pg. 16.
3
Chatain, Pierre-Laurent. (June 24-26, 2008) “Applying the FATF International standards to Mobile Financial Services.” Workshop on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) for Mobile Financial Services (m-FS). Bangkok, Thailand. Hereafter:
Chatain.
4
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in India,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.2322/India-Notes-On-Regulation-Branchless-Banking-2008.pdf. pg. 8.
5
“Update on Regulation of Branchless Banking in South Africa,” CGAP, January 2010, pgs. 10-11.
6
Flaming, Mark, Prochaska, Klaus, and Staschen, Stefan. (June 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in Indonesia,” CGAP in cooperation with IFC and GTZ, p. 16.
7
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pgs. 8 and 11.
8
“Update on Regulation of Branchless Banking in Pakistan,” CGAP, February 2010, pg. 9.
9
Bester, Hennie, Chamberlian, Doubell, Koker de, Louis, Hougaard, Christine, Short, Ryan, Smith, Anja, Walker, Richard, G:ENESIS: Implementing FATF Standards in Developing Countries and Financial Inclusion: Findings and Guidelines,” Final Report, www.firstinitative.org, February
2008, pg. 39.
10
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pg 14.
11
Mas, Ignacio, Siedek, Hannah, “Banking Through Networks of Retail Agents”, CGAP, Focus Notes NO 47, May 2008, pg.4.
12
“Cloud Based Voice Biometrics E-commerce Platform”, 15 June 2010, http://www.infosecurity-magazine.com/view/10223/couldbased-voice-biometrics-ecommerce-platform-introduced/
13
“Best Practices for Mobile Device Banking Security: International minimum security guidelines for mobile device banking applications,” ATMIA, ATM Industry Association, pg. 3.
14
“Update on Regulation of Branchless Banking in India,” CGAP, January 2010, pg.8.
15
Oliver, Rich, “Synthesizing the mobile ecosystem: Resolving customer problems in mobile payments clearing and settlement models,” March 29, 2010. [online} http://portalsandrails.frbatlanta.org/2-1-/03/consumer-confidence-vital-to-mobile-payments-success.html
16
Rishikko, Juha, Choudhary, Bishwajit, “Mobile Financial Services Business Ecosystem Scenarios & Consequences: Summary Document,” Mobey Forum, Mobile Financial Services Ltd., 2006, pgs. 1-8.
17
Porteous, David, “The Enabling Environment for Mobile Banking in Africa,” Report commissioned by Department for International Development (DFID), Bankable Frontier Associates, Boston, MA, May 2006, pg 29.
18
The Electronic Transactions and Communications Bill, 2009, Section 6 (1) and (2).
19 19
“Best Practices for Mobile Device Banking Security: International minimum security guidelines for mobile device banking applications,” ATMIA, ATM Industry Association, pg. 3.
20
USAID interviews, Zambia, February 16-17, 2010.
21
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pg 13.
22
Flaming, Mark, Prochaska, Klaus, and Staschen, Stefan. (June 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in Indonesia,” CGAP in cooperation with IFC and GTZ, p. 18.
23
Porteous, David, “The Enabling Environment for Mobile Banking in Africa,” Report commissioned by Department for International Development (DFID), Bankable Frontier Associates, Boston, MA, May 2006, pg 45.
24
Davidson, Neil, Leishman, Paul, “Building, Incentivizing and Managing a Network of Mobile Money Agents: A Handbook for Mobile Network Operators,”GSMA, Vol. 2, [email protected], accessed July 7, 2010, pg. 6-7.
25
Wishart, Neville. (2006) “Micro-Payment Systems and Their Application to Mobile Networks: Examples of Mobile Enabled Financial Services in the Philippines,” The World Bank/InfoDev, Washington DC.
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26
Davidson, Neil, Leishman, Paul, “Building, Incentivizing and Managing a Network of Mobile Money Agents: A Handbook for Mobile Network Operators,”GSMA, Vol. 2, [email protected], accessed July 7, 2010, pg. 6-7.
27
http://www.centralbank.go.ke/downloads.bsd/GUIDELINES520ON%20AGENT20BANKING-CBK%20PG%2015.pdf
28
Porteous, David, “The Enabling Environment for Mobile Banking in Africa,” Report commissioned by Department for International Development (DFID), Bankable Frontier Associates, Boston, MA, May 2006, pgs. 30-31.
29
Mas, Ignacio, Siedek, Hannah, “Banking Through Networks of Retail Agents”, CGAP, Focus Notes NO 47, May 2008, pg. 9.
30
Davidson, Neil, Leishman, Paul, “Building, Incentivizing and Managing a Network of Mobile Money Agents: A Handbook for Mobile Network Operators,”GSMA, Vol. 3, [email protected], accessed July 7, 2010, pg. 2
31
Davidson, Neil, Leishman, Paul, “Building, Incentivizing and Managing a Network of Mobile Money Agents: A Handbook for Mobile Network Operators,”GSMA, [email protected], accessed July 7, 2010, pg. 2-3.
32
Davidson, Neil, Leishman, Paul, “Managing a Network of Mobile Money Agents,”GSMA, [email protected], accessed July 7, 2010, pg. 3-5.
33
Lynch, Maureen, “Kenya: National Registration Processes Leave Minorities on the Edge of Statelessness,” Refugees International, 5/23/2008 [online] http://www.refugeesinternational.org/policy/field-report/kenya-national-registration-processes-leave-minorities-edge-statelessness
34
Davidson, Neil, Leishman, Paul, “Building, Incentivizing and Managing a Network of Mobile Money Agents: A Handbook for Mobile Network Operators,”GSMA, [email protected], accessed July 7, 2010, pg. 5-6.
35
Davidson, Neil, Leishman, Paul, “Building, Incentivizing and Managing a Network of Mobile Money Agents: A Handbook for Mobile Network Operators,”GSMA, [email protected], accessed July 7, 2010, pg. 6.
36
USAID Street Interviews, February 16-17, 2010, Zambia.
37
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pgs. 8 and 11.
38
“Update on Regulation of Branchless Banking in India,” CGAP, January 2010, pg. 10.
39
Pyler, Megan G., Haas, Sherri, and Nagarajan, Geetha, “Community-Level Economic Effects of M-PESA in Kenya: Initial Findings,” IRIS Center, University of Maryland, June 2010 [online]http://www.fassessment.umd.edu/publications/Community%20Effects%Paper%Final.pdf, pgs. 20-21.
40
http://www.bsp.gov.ph.downloads/Regulations/attachments/2009/c649.pdf, pg. 2-3.
41
Wishart, Neville, “Micro-Payment Systems and Their Applicatin to Mobile Networks: Examples of Mobile-Enabled Financial Services in the Philippines,” IBRD/The World Bank, 2006, pgs, 13-20.
42
http://www.bsp.gov.ph.downloads/Regulations/attachments/2009/c649.pdf, pg. 2.

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Capitalizing on the Opportunity by Ensuring Sustainability

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43
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pg 8.
44
“Update on Regulation of Branchless Banking in Pakistan,” CGAP, February 2010, pg. 4-5.
45
Flaming, Mark, Prochaska, Klaus, and Staschen, Stefan. (June 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in Indonesia,” CGAP in cooperation with IFC and GTZ, p. 19.
46
“Update on Regulation of Branchless Banking in South Africa,” CGAP, January 2010, pg. 5.
47
Porteous, David, “The Enabling Environment for Mobile Banking in Africa,” Report commissioned by Department for International Development (DFID), Bankable Frontier Associates, Boston, MA, May 2006, pg 46.
48
DIRECTIVE 2000/46/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 18 September2000, Articles 1, Section 5b and 4, Sections 2 and 3.
49
Abbassi, Ala‘a, Mohammed Khaled, Klaus Prochaska, and Michael Tarazi. (2009) “Access to Finance: Microcredit and Branchless Banking in The Hashemite Kingdom of Jordan,” CGAP, Washington, DC.
[Online] http://www.cgap.org/gm/document-1.1.1304/Jordan_Diagnostic_Report_2009.pdf, p. 17.
50
Hernandez-Coss, Raul, Egwauagu, Chinyere, Isern, Jennifer, Porteuous, David, “AML/CFT Regulation: Implications for Financial Service ProviderAccount Providers that Serve Low-Income People,” IBRD/The World Bank, 2005, pgs. 9-18.
5151
http://www.bsp.gov.ph.downloads/Regulations/attachments/2009/c649.pdf, pg. 2.
52
Flaming, Mark, Prochaska, Klaus, and Staschen, Stefan. (June 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in Indonesia,” CGAP in cooperation with IFC and GTZ, p. 12.
53
http://www.bsp.gov.ph.downloads/Regulations/attachments/2009/c649.pdf, pg. 4.
54
Abbassi, Ala‘a, Mohammed Khaled, Klaus Prochaska, and Michael Tarazi. (2009) “Access to Finance: Microcredit and Branchless Banking in The Hashemite Kingdom of Jordan,” CGAP, Washington, DC.
[Online] http://www.cgap.org/gm/document-1.1.1304/Jordan_Diagnostic_Report_2009.pdf, p. 17.
55
http://www.safaricom.co.ke/fileadmin/template/main/downloads/m-pesa_resource_centre/mkesho_FAQs/M-KESHO%20FAQS.pdf
56
http://www.wolfsberg-principles.com/faq-ownership.html
57
USAID interview, Tanzania, February 19, 2010.
58
http://www.reuters.com/article/idUSMAN37950920090910
59
http://www.gsmworld.com/newsroom/press-releases/2041.htm
60
FS SERIES #9: ENABLING MOBILE MONEY INTERVENTIONS PRIMER, DIAGNOSTIC CHECKLIST, AND MODEL SCOPES OF WORK, USAID and Financial Sector Knowledge Sharing, April 2010, pg. 20.
61
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pgs. 8 and 11.
62
“Update on Regulation of Branchless Banking in India,” CGAP, January 2010, pg. 10.
63
Pyler, Megan G., Haas, Sherri, and Nagarajan, Geetha, “Community-Level Economic Effects of M-PESA in Kenya: Initial Findings,” IRIS Center, University of Maryland, June 2010 [online]http://www.fassessment.umd.edu/publications/Community%20Effects%Paper%Final.pdf, pgs. 20-21.
64
http://www.interpol.int/pv_obj_cache/pv_obj_id_7DA31F4675F7441C17F0BB94D705DB7DDEF40200/filename/FHT04.pdf
65
Http://www.centralbank.go.ke/currency/currencylaws.aspx
66
http://www.interpol.int/pv_obj_cache/pv_obj_id_7DA31F4675F7441C17F0BB94D705DB7DDEF40200/filename/FHT04.pdf
67
Http://www.centralbank.go.ke/currency/currencylaws.aspx
6868
FS SERIES #9: ENABLING MOBILE MONEY INTERVENTIONS PRIMER, DIAGNOSTIC CHECKLIST, AND MODEL SCOPES OF WORK, USAID and Financial Sector Knowledge Sharing, April 2010, pg. 33.
69
USAID interview, Tanzania, February 17, 2010.
70
Davidson, Neil, Leishman, Paul, “Managing a Network of Mobile Money Agents,”GSMA, [email protected], accessed July 7, 2010, pg. 7.
71
“Update on Regulation of Branchless Banking in Pakistan,” CGAP, February 2010, pg. 9.
72
Bank for International Settlements. (2001) “Customer Due Diligence for Banks,” Basel Committee on International Settlements, Basel, Switzerland. [Online] http://www.bis.org/publ/bcbs85.htm, pgs. 3-5.
73
Flaming, Mark, Prochaska, Klaus, and Staschen, Stefan. (June 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in Indonesia,” CGAP in cooperation with IFC and GTZ, p. 13.
74
http://www.identity.go.ke.
75
Liu, Alice and Mithika, Michael, “Mobile Banking –The Key to Building Credit History for the Poor? Kenya Case Study: Linking Mobile Banking and Mobile Payment Platforms to Credit Bureaus,” USAID, April 2009, pg. 7.
76
http://www.pma.ps/pdf/anti-money%20laundry%20law%20eng.pdf
77
“Updated on Regulation of Branchless Banking in South Africa,” CGAP, January 2010, pg. 9.
78
USAID interview, Zambia, February 17, 2010.
79
FATF 40, Interpretive Notes.
80
FS SERIES #9: ENABLING MOBILE MONEY INTERVENTIONS PRIMER, DIAGNOSTIC CHECKLIST, AND MODEL SCOPES OF WORK, USAID and Financial Sector Knowledge Sharing, April 2010, pg. 25-27.
81
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in India,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.2322/India-Notes-On-Regulation-Branchless-Banking-2008.pdf. pg. 8.

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82 Kenya: National Registration Processes Leave Minorities on the Edge of Statelessness, Maureen Lynch and Katherine Southwick, 05/23/2008, http://refugeesinternational.org/policy/field-report/kenya-national-registration-processes-leave-minorities-edge-
statelessness.
83
M-Pesa interview, Nairobi, Kenya, February 20, 2010.
84
WP416. 35-36.
85
FS SERIES #9: ENABLING MOBILE MONEY INTERVENTIONS PRIMER, DIAGNOSTIC CHECKLIST, AND MODEL SCOPES OF WORK, USAID and Financial Sector Knowledge Sharing, April 2010, pg. 24.
86
See the “Asset Securitization” booklet of the Comptroller’s Handbook and OCC Bulletin 99-46, “Interagency Guidance on Asset Securitization Activities” (December 16, 2999) and An Examiner’s Guide to Problem Bank Identification, Rehabilitation, and Resolution: A Guide for Examiners. (OCC,
January 2001).
87
WP416. pgs 43-47.
88
Chaitain, Pierre-Laurent. (June 24-26, 2008). “Applying the FATF International standards to Mobile Financial Services.” Workshop on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) for Mobile Financial Services (m-FS).
89
AITEC PRESENTATION SESSION, 17TH–25TH, FEBRUARY, 2010, Samuel Mutungi, The Co-Operative Bank of Kenya, Ltd.
90
“Notes on AML-CFT Compliance: Challenges with Branchless Banking and Examples of Industry and Regulatory Responses.” http://www.cgap.org/technology. (2007). pg. 3.
91
Forbes, John (19 April 2007). “The Convergence of Telecom and Financial Services and its Effects on AML/Wire Remittance Operations.” United States Treasury, Office of Technical Assistance. Presentation.
92
Forbes, John (March 2007) “Effects of Cell phones on Anti-Money Laundering/Combating Financial Terrorism (AML/CFT)Wire Remittance Operations.” ADB Working Paper, pg. 43.
93
Chatain.
94
WP416. pgs 38.
95
Flaming, Mark, Prochaska, Klaus, and Staschen, Stefan. (June 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in Indonesia,” CGAP in cooperation with IFC and GTZ, p. 16.
96
Khan, Zain, “Developing ICT Capacities,” AITEC Banking & Mobile Money COMESA, February 25, 2010, Nairobi, Kenya.
97
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in Brazil,” CGAP, Washington DC. [Online] http://www.cgap.org/gm/document-1.9.2319/Brazil-Notes-On-Regulation-Branchless-Banking-2008.pdf. pg. 9
98
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pg 12.
99
“Update on the Regulation of Branchless Banking in South Africa,” CGAP, January 2010, pgs 3-4.
100
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pgs. 8 and 11.
101
“Update on Regulation of Branchless Banking in India,” CGAP, January 2010, pg. 10.
102
Pyler, Megan G., Haas, Sherri, and Nagarajan, Geetha, “Community-Level Economic Effects of M-PESA in Kenya: Initial Findings,” IRIS Center, University of Maryland, June 2010 [online]http://www.fassessment.umd.edu/publications/Community%20Effects%Paper%Final.pdf, pgs. 20-21.
103
http://www.fatf-gafi.org/document/9/0,3343,en_32250379_32236920_34032073_1_1_1_1,00.html. Hereafter: Special Recommendations. Special Recommendation VI.
104
FATF 40. Recommendation 23.
105
Special Recommendations VI.
106
WP416. pgs 43-47.
107
CGAP. (2007) “Notes on Branchless Banking Policy and Regulation in Kenya,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.2321/Kenya-Notes-On-Regulation-Branchless-Banking-2007.pdf. pg 7.
108
Lyman, Timothy R., Gautman Ivatury, and Stefan Staschen. (2006) “Use of Agents in Branchless Banking for the Poor: Rewards, Risks and Regulation.” CGAP Focus Note 38. pg. 10-11.
109
Chatain, Pierre-Laurent, et al. “Integrity in Mobile Phone Services: Measures for Mitigating Risks from Money Laundering and Terrorist Financing.” World Bank, Washington, DC
[Online] http://siteresources.worldbank.org/INTAML/Resources/WP146_Web.pdf. pg. 51.
110
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in Brazil,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.2319/Brazil-Notes-On-Regulation-Branchless-Banking-2008.pdf. Pgs. 7-8.
111
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in India,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.2322/India-Notes-On-Regulation-Branchless-Banking-2008.pdf. pgs. 7-8.
112
See the “Asset Securitization” booklet of the Comptroller’s Handbook and OCC Bulletin 99-46, “Interagency Guidance on Asset Securitization Activities” (December 16, 2999) and An Examiner’s Guide to Problem Bank Identification, Rehabilitation, and Resolution: A Guide for Examiners. (OCC,
January 2001).
113
See General Guide to Account Opening and Customer Identification, Attachment to Basel Committee publication No. 85 “Customer due diligence for banks”, February 2003. (http://www.bis.org/publ/bcbs85annex.htm).
114
See Ignacio Mas and Daniel Radcliffe Mobile Payments Go Viral: The Story of M-PESA and Ignacio Mas and Amolo Ng’weno Three Keys to M-PESA’s Success: Branding, Channel Management, and Pricing.
115
Report on the Technical Committee on Electronic Banking, Central Bank of Nigeria, February 2003, pg. 22.
116
http://www.ifir1000.com/legislationguide/192/the-e-zwich-electronic-clearing-and-payment-system.html
117
E-Zwich Becoming a Colossal Waste of Resources? http://allafrica.com/stories/201002091058.html
118
CGAP. (2009) “Notes on Branchless Banking Policy and Regulation in Mexico,” Consultative Group to Assist the Poor, Washington DC.

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[Online] http://www.cgap.org/gm/document-1.1.1306/Mexico%20Branchless%20Banking%20Notes.pdf.
119 Vodafone (2007) “The Transformational Potential of m-Transactions,” Policy Paper Series, No. 6, Vodaphone, London

[Online] http://www.gsmworld.com/documents/VOD833_Policy_Paper_Series_FINAL.pdf.
120
Economist Intelligence Unit. (2009) “Kenya Telecoms: Banking on M-Banking.” Industry Briefing.
121
http://www.fatf-gafi.org/document/28/0,3343,en_32250379_32236930_33658140_1_1_1_1,00.html. Hereafter: FATF 40. Recommendations 5, 6 and 8 and interpretive notes, where applicable.
122
Basel Committee on Banking Supervision. (October 2001) “Customer Due Diligence for Banks.” Bank for International Settlements. Pgs. 2. Hereafter: Basel.
123
FATF 40, Interpretive Notes.
124
FATF 40, Interpretive Notes.

125 Kenya: National Registration Processes Leave Minorities on the Edge of Statelessness, Maureen Lynch and Katherine Southwick, 05/23/2008, http://refugeesinternational.org/policy/field-report/kenya-national-registration-processes-leave-minorities-edge-
statelessness.
126
M-Pesa interview, Nairobi, Kenya, February 20, 2010.
127
Hernandez-Coss, Raul, and Chinyere Egwuagu, Jennifer Isern, and David Porteous (2005) “AML/CFT Regulation: Implications for Financial Account Providers that Serve Low-income People.” World Bank and CGAP. Pg. 17.
128
Chatain, Pierre-Laurent, et al. “Integrity in Mobile Phone Services: Measures for Mitigating Risks from Money Laundering and Terrorist Financing.” World Bank, Washington, DC
[Online] http://siteresources.worldbank.org/INTAML/Resources/WP146_Web.pdf. pg. 22-27. Hereafer WP416.
129
WP416. 35-36.
130
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in India,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.2322/India-Notes-On-Regulation-Branchless-Banking-2008.pdf. pg. 8.
131
WP416 pg. 27.
132
CGAP. (2009) “Notes on Branchless Banking Policy and Regulation in Mexico,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.1.1306/Mexico%20Branchless%20Banking%20Notes.pdf.
133
Abbassi, Ala’a, et. al. (March 16, 2009) “Access to Finance: Microcredit and Branchless Banking in the Hashemite Kingdom of Jordan.” Pgs. 32-33.
134
http://www.egmontgroup.org/about/what-is-an-fiu
135
Including terrorist acts or organizations.
136
Special Recommendations IV.
137
Hereafter: FATF 40. Recommendations 25 and 26.
138
WP416 pg. 13.
139
USAID Field Visits, Zambia, Kenya, February 9-28, 2010.
140
Estioko, Raymond. (June 24-26, 2008). “Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) for Mobile Financial Services (m-FS): The Philippine Experience.” Bangkok, Thailand.
141
Forbes, John (March 2007) “Effects of Cell phones on Anti-Money Laundering/Combating Financial Terrorism (AML/CFT)Wire Remittance Operations.” ADB Working Paper, pg. 26. Hereafter: Effects.
142
WP416. pgs. 50-51.
143
Korean Financial Intelligence Unit, Financial Services Commission (June 24-26, 2008) , “Countering the Use of Mobile-FS in the Money Laundering.” Workshop on AML/CFT, Bangkok, Thailand.
144
WP416. pgs. 13-14.
145
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pgs. 8 and 11.
146
http://www.fatf-gafi.org/document/9/0,3343,en_32250379_32236920_34032073_1_1_1_1,00.html. Hereafter: Special Recommendations. Special Recommendation VI.
147
FATF 40. Recommendation 23.
148
Special Recommendations VI.
149
WP416. pgs 43-47.
150
CGAP. (2007) “Notes on Branchless Banking Policy and Regulation in Kenya,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.2321/Kenya-Notes-On-Regulation-Branchless-Banking-2007.pdf. pg 7.
151
Lyman, Timothy R., Gautman Ivatury, and Stefan Staschen. (2006) “Use of Agents in Branchless Banking for the Poor: Rewards, Risks and Regulation.” CGAP Focus Note 38. pg. 10-11.
152
Chatain, Pierre-Laurent, et al. “Integrity in Mobile Phone Services: Measures for Mitigating Risks from Money Laundering and Terrorist Financing.” World Bank, Washington, DC
[Online] http://siteresources.worldbank.org/INTAML/Resources/WP146_Web.pdf. pg. 51.
153
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in Brazil,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.2319/Brazil-Notes-On-Regulation-Branchless-Banking-2008.pdf. Pgs. 7-8.

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154
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in India,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.2322/India-Notes-On-Regulation-Branchless-Banking-2008.pdf. pgs. 7-8.
155
Also, see Special Recommendations VI and VII.
156
FATF 40. Recommendation 10.
157
WP416. pgs 43-47.
158
Chaitain, Pierre-Laurent. (June 24-26, 2008). “Applying the FATF International standards to Mobile Financial Services.” Workshop on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) for Mobile Financial Services (m-FS).
159
AITEC PRESENTATION SESSION, 17TH–25TH, FEBRUARY, 2010, Samuel Mutungi, The Co-Operative Bank of Kenya, Ltd.
160
“Notes on AML-CFT Compliance: Challenges with Branchless Banking and Examples of Industry and Regulatory Responses.” http://www.cgap.org/technology. (2007). pg. 3.
161
Forbes, John (19 April 2007). “The Convergence of Telecom and Financial Services and its Effects on AML/Wire Remittance Operations.” United States Treasury, Office of Technical Assistance. Presentation.
162
Forbes, John (March 2007) “Effects of Cell phones on Anti-Money Laundering/Combating Financial Terrorism (AML/CFT)Wire Remittance Operations.” ADB Working Paper, pg. 43.
163
Chatain.
164
WP416. pgs 38.
165
http://www.fiumalawi.gov.mw/fiu2/index.php?option=com_content&view=article&id=19&itemid=27
166
http://www.fiumalawi.gov.mw/fiu2/documents/money_laundering_act.pdf
167
“Update of Regulation of Branchless Banking in India,” CGAP, January 2010, pgs. 6-7.
168
http://fiuindia.gov.in/about-overview.htm
169
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in Pakistan,” CGAP, Washington DC. [Online] http://www.cgap.org/gm/document-1.9.2304/PKNotes_RegulationBranchless_2007.pdf, pgs 1-3.
170
“Update on Regulation of Branchless Banking in Pakistan,” CGAP, February 2010, pg. 10.
171
http://www.amlc.gov.ph/amla.html
172
http://www.amlc.gov.ph/archive/reso361.pdf
173
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pg 13.
174
“Update on Regulation of Branchless Banking in Pakistan,” CGAP, February 2010, pg. 9.
175
Basel Pgs. 7-11.
176
Isern, Jennifer, and Louis de Koker. (August 2009) “AML/CFT: Strengthening Financial Inclusion and Integrity.” Focus Note 56. CGAP, Washington, D.C. [Online], pg. 1-2.
177
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in South Africa,” Consultative Group to Assist the Poor, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.2320/SouthAfrica-Notes-On-Regulation-Branchless-Banking-2008.pdf. pg. 1-3.
178
Genesis, Implementing FATF standards in developing countries and financial inclusion: Findings and guidelines Final report May 2008, 74-90.
179
“Updated on Regulation of Branchless Banking in India,” CGAP, January 2010, pgs 8-9.
180
Flaming, Mark, Prochaska, Klaus, and Staschen, Stefan. (June 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in Indonesia,” CGAP in cooperation with IFC and GTZ, p. 8.
181
Khan, Zain, “Developing ICT Capacities,” AITEC Banking & Mobile Money COMESA, February 25, 2010, Nairobi, Kenya.
182
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in Brazil,” CGAP, Washington DC. [Online] http://www.cgap.org/gm/document-1.9.2319/Brazil-Notes-On-Regulation-Branchless-Banking-2008.pdf. pg. 9
183
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pg 12.
184
“Update on the Regulation of Branchless Banking in South Africa,” CGAP, January 2010, pgs 3-4.
185
Flaming, Mark, Prochaska, Klaus, and Staschen, Stefan. (June 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in Indonesia,” CGAP in cooperation with IFC and GTZ, p. 9.
186
Porteous, David, “The Enabling Environment for Mobile Banking in Africa,” Report commissioned by Department for International Development (DFID), Bankable Frontier Associates, Boston, MA, May 2006, pgs. 22-23 and USAID Interview for the Mobile Financial Services Risk
Matrix, February 2010, Tanzania.
187 Barbier, Eric, “TransferTo,” MMT09 Conference and Expo, JW Marriot, Dubai, 26-27 October 09.
188
http://technology.cgap.org/2010/05/18/m-pesa-meets-microsavings-with-equity-bank-deal-in-kenya/.
189
Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. (August 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in El Salvador,” CGAP, pg 8.
190
“Update on Regulation of Branchless Banking in Pakistan,” CGAP, February 2010, pg. 4-5.
191
Flaming, Mark, Prochaska, Klaus, and Staschen, Stefan. (June 2009). “Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in Indonesia,” CGAP in cooperation with IFC and GTZ, p. 19.
192
FS SERIES #9: ENABLING MOBILE MONEY INTERVENTIONS PRIMER, DIAGNOSTIC CHECKLIST, AND MODEL SCOPES OF WORK, USAID and Financial Sector Knowledge Sharing, April 2010, pg. 16.
193
“Update on Regulation of Branchless Banking in South Africa,” CGAP, January 2010, pg. 5.
194
Porteous, David, “The Enabling Environment for Mobile Banking in Africa,” Report commissioned by Department for International Development (DFID), Bankable Frontier Associates, Boston, MA, May 2006, pg 46.
195
http://www.sec.gov/litigation/complaints/2008/comp-madoff121108.pdf

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Risk-based Policy Matrix – Appendix

196
http://ringofquality.choseit.com/revealeddeci-has-no-account/
197
http://www.bot-tx.org/Adverts/PressRelease/2009-Apr%2003-Press%20Release.pdf.
198
Anti-Money Laundering Act, 2010, State Bank of Pakistan, http://www.sbp.org.pk/about/act/Anti-Act-2010.pdf, [online] pg. 107.
199
“Implications of 9/11 for the Financial Services Sector,” Remarks by Vice Chairman Roger W. Ferguson, Jr. At the Conference on Bank Structure and Competition, Chicago, Illinois May 9, 2002, http://www.federalreserve.gov/boarddocs/speeches/2002/20020509/default.htm
200
AITEC PRESENTATION SESSION, 17TH–25TH, FEBRUARY, 2010, Samuel Mutungi, The Co-Operative Bank of Kenya, Ltd.
201
For a useful template, see the U.S, Comptroller of the Currency, Administrator of National Banks “An Examiner’s Guide to Problem Bank Identification, Rehabilitation, and Resolution: A Guide for Examiners.” (OCC, January 2001).
202
http://www.interpol.int/pv_obj_cache/pv_obj_id_7DA31F4675F7441C17F0BB94D705DB7DDEF40200/filename/FHT04.pdf
203
Http://www.centralbank.go.ke/currency/currencylaws.aspx
204
http://www.interpol.int/pv_obj_cache/pv_obj_id_7DA31F4675F7441C17F0BB94D705DB7DDEF40200/filename/FHT04.pdf
205
Http://www.centralbank.go.ke/currency/currencylaws.aspx
206
U.S. Office of the Comptroller of the Currency provides sound guidance that could relate to mobile banking agent networks in relation to currency redenomination of funds while in transit (see http://www.occ.treas.gov/ftp/bulletin/96-48.txt).
207
See http://www.financialstability.gov/roadtostability/regulatoryreformhtml.
208
E-Money Regulation in Mexico, April 8, 2010 [online] http://www.mobilemoneyexchange.org/Feeds/Research/Read/e-money-regulation-in-mexico.aspx
209
FS SERIES #9: ENABLING MOBILE MONEY INTERVENTIONS PRIMER, DIAGNOSTIC CHECKLIST, AND MODEL SCOPES OF WORK, USAID and Financial Sector Knowledge Sharing, April 2010, pg. 5.
210
FS SERIES #9: ENABLING MOBILE MONEY INTERVENTIONS PRIMER, DIAGNOSTIC CHECKLIST, AND MODEL SCOPES OF WORK, USAID and Financial Sector Knowledge Sharing, April 2010, pg. 5.

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Annotated Bibliography
Country Specific Reports

Abbassi, Ala‘a, Mohammed Khaled, Klaus Prochaska, and Michael Tarazi. (2009) “Access to Finance: branchless banking would particularly benefit Palestine because of the restrictions on the movement
Microcredit and Branchless Banking in The Hashemite Kingdom of Jordan,” CGAP, Washington, DC. of people, goods, services, and cash.
[Online] http://www.cgap.org/gm/document-1.1.1304/Jordan_Diagnostic_Report_2009.pdf
CGAP. (2009) “Notes on Branchless Banking Policy and Regulation in Mexico,” CGAP, Washington DC.
This CGAP country diagnostic focuses on the policy and regulatory environment for microcredit and [Online] http://www.cgap.org/gm/document-1.1.1306/Mexico%20Branchless%20Banking%20Notes.pdf.
branchless banking in Jordan. Jordanian MFIs offer only small loans and some minor business
development services to entrepreneurs and are not involved in payment transfers. While Jordan has This CGAP country note is the latest in a series of country diagnostics that review mobile banking
one of the highest market coverage rates in the region, there is a significant gap between the supply models in various countries. Of importance to highlight from this study is that non-banks in Mexico
of microfinance and potential demand in the market. The same can be said of branchless banking, are currently not allowed to issue e-money, but preparations to create e-money regulation are
which is still a relatively new concept in Jordan and the Central Bank remains hesitant to authorize underway. Further issues affecting branchless banking and financial access are: lack of a national
the use of non-bank led branchless banking models. identification document, a new tax on cash deposits, low competition in banking and payments
services, and weak enforcement of rules against digital crimes.
Berger, Estelle. (2009) “Expanding Outreach in Malawi: OIBM’s Efforts to Launch a Mobile Banking Program,”
The SEEP Network and Opportunity International, Washington, DC. CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in Brazil,” CGAP, Washington DC.
[Online] http://www.seepnetwork.org/Resources/M-banking_Case.pdf [Online] http://www.cgap.org/gm/document-1.9.2319/Brazil-Notes-On-Regulation-Branchless-Banking-
2008.pdf.
This case study presents the efforts, still in progress, of Opportunity International Bank of Malawi
(OIBM) to develop its own m-banking program. The country had no telco-led programs when this This CGAP country note focuses on the potential for non-bank-based branchless banking in Brazil
project began in 2008. As a result, OIBM had to construct a bank-led model in order to offer given the country’s long history of banks using agents. However, like in Mexico, some obstacles are
Malawi’s poor people the benefits of access to financial services through m-banking. At the time of that non-banks are not permitted to issue e-money and mobile network operators and other non-
writing, OIBM’s program was near launch, but not yet in operation. This study documents some of bank e-money and prepaid card issuers are not covered by the AML/CFT law.
the challenges faced and solutions developed prior to implementation.*
CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in India,” CGAP, Washington DC. [Online]
Bruynse, Dirk and Jeremiah Grossman. (2008) “Mobile Money Study: Palestine,” IRIS Center, University of http://www.cgap.org/gm/document-1.9.2322/India-Notes-On-Regulation-Branchless-Banking-2008.pdf.
Maryland.[Online]http://www.microlinks.org/file_download.php/FIELD_Report_No_6_Mobile_Money_Study_i
n_WBG.pdf?URL_ID=29737&filename=12283246521FIELD_Report_No_6_Mobile_Money_Study_in_WBG.p This CGAP country note asserts that the potential for payment and m-banking services to be
df&filetype=application%2Fpdf&filesize=1217392&name=FIELD_Report_No_6_Mobile_Money_Study_in_WB provided by mobile network operators and other non-banks has not yet been realized in India due to
G.pdf&location=user-S/ restrictions on non-banks from accepting funds from the public and the prohibition on any e-money
issuance by non-banks. There have been indications, however, that change is on the horizon. In 2007,
Branchless banking in Palestine is still in the early stages of development. Services in Palestine are the Reserve Bank of India issued two reports showing its willingness to consider the possible use of
limited to customers performing debit/credit transactions on POS devices and accessing certain mobile phones and prepaid cards for banking purposes. (see “country specific regulations” section)
account information via SMS, but it does not allow the customer to transfer funds to another
individual or pay bills on the phone. Currently, there are no regulations defining e-money or CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in Pakistan,” CGAP, Washington DC.
providing guidelines on the types of providers who can issue e-money. However, the Palestinian [Online] http://www.cgap.org/gm/document-1.9.2304/PKNotes_RegulationBranchless_2007.pdf.
Monetary Authority does not intend to permit non-banks to issue e-money. The authors argue that
Pakistan was selected as the pilot for the CGAP country diagnostic series because regulators and
policymakers are keenly interested in branchless banking and several private operators (banks and
* Summary taken from abstract

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Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography
mobile network operators) are exploring various business models. However, to date, only banks are Flaming, Mark, Klaus Prochaska, and Stefan Staschen. (2009) “Diagnostic Report on the Legal and Regulatory
allowed to accept deposits withdrawable by check from the public and current AML/CFT laws do not Environment for Branchless Banking in Indonesia,” CGAP, in cooperation with IFC and GTZ. [Online]
cover non-banks. http://www.cgap.org/gm/document-1.9.34817/Branchless%20Banking%20Diagnostic%20in%20Indonesia.pdf

CGAP. (2008) “Notes on Branchless Banking Policy and Regulation in South Africa,” CGAP, Washington DC. Indonesia does not have any outstanding examples of bank or non-bank providers successfully
[Online] http://www.cgap.org/gm/document-1.9.2320/SouthAfrica-Notes-On-Regulation-Branchless-Banking- providing financial services to low-income customers through branchless banking. The Bank of
2008.pdf. Indonesia has recently issued regulations on e-money, including limits on the use of e-money to
making retail payments. Neither banks nor non-banks are allowed to use agents to provide financial
South Africa has a variety of successful branchless banking models – from mobile banking to services, posing a significant barrier to branchless banking.
Non-bank payment services, despite regulations which limit electronic money issuance to banks only.
By easing the documentation requirements for opening an account while capping transaction limits on Hughes, Nick and Susie Lonie. (2007)“M-PESA: Mobile Money for the “Unbanked” Turning Cellphones into
such accounts, South Africa has became a model for addressing financial security concerns while 24-Hour Tellers in Kenya.” Innovations: Technology, Governance, Globalization.
allowing the poor to have greater access to financial services. The authors believe that pending [Online] http://www.policyinnovations.org/ideas/policy_library/data/m_pesa/_res/id=sa_File1/INNOV0201_pp-
telecommunications regulations threaten to limit South Africa’s branchless banking potential. 63-81_hughes-lonie_1.pdf

CGAP. (2007) “Notes on Branchless Banking Policy and Regulation in Kenya,” CGAP, Washington DC. Written by a Vodafone executive who started M-PESA, Nick Hughes, this paper explores the
[Online] http://www.cgap.org/gm/document-1.9.2321/Kenya-Notes-On-Regulation-Branchless-Banking- company’s commitment to the Millennium Development goals and the steps Hughes took to convince
2007.pdf. senior executives about his idea for M-PESA. The second section of the paper is written by Susie
Lonie, an m-commerce expert who was brought into Kenya to manage the overall delivery of M-
Branchless banking in Kenya is dominated by mobile operator, Safaricom’s M-PESA service. The non- PESA from pilot into commercial operation. She describes the day-to-day obstacles she faced while
bank-based model appears to be free of any financial regulation as long as services provided are not managing this process.
deemed to fall within the definition of banking business under the Banking Act. The general lack of
regulatory guidance and oversight is problematic because it may lead to increased risk to customers Isern, Jennifer, et al. (2009) “Access to Finance in Nigeria: Microfinance, Branchless Banking and SME Finance,”
and the financial sector. The authors believe that these concerns could be addressed by requiring CGAP, Washington DC. [Online] http://www.cgap.org/gm/document-
reporting regulations, minimum capital and liquidity requirements, and restrictions on how e-money 1.1.1706/Access_to_finance_in_Nigeria_25_feb_09.pdf
proceeds may be held.
This paper provides a high level description of the supply of microfinance services, branchless banking
Economist Intelligence Unit. (2007) “South Africa: From Mattress to Mobile Banking.” Industry Briefing. , and SME finance in Nigeria. Five over-arching issues are covered in all of the areas: the need for
[Online] transparency of financial performance and market information; the need for capacity within the
http://globaltechforum.eiu.com/index.asp?layout=rich_story&doc_id=11066&title=South+Africa%3A+From+m Central Bank of Nigeria to supervise financial service provision; the need to ensure that the payment
attress+to+mobile+banking&categoryid=31&channelid=4 system, private credit registries and collateral registries are upgraded; the need to promote
consumer protection; and the need to continue coordinating efforts between funders, the federal
government and state governments.
This article explores some of the reasons behind the success of Wizzit in South Africa, particularly
among the poor. Wizzit charges lower fees than many retail banks in South Africa, making it easy for
Ivatury, Gautam and Mark Pickens. (2006) “Mobile-Phone Banking and Low-Income Customers - Evidence
the poor to access credit. Opening an account with Wizzit is also very simple, as agents are sent to
from South Africa,” supported by CGAP, UN Foundation and Vodafone Group Foundation.
the applicant's home or workplace. To transfer money, Wizzit uses the South African inter-bank
[Online] http://www.globalproblems-globalsolutions-
clearing house system. This feature gives Wizzit account-holders the ability to transact with any files.org/unf_website/PDF/mobile_phone_bank_low_income_customers.pdf
mobile user regardless of the identity of their network operator or their bank.

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Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography
This paper presents findings on how low-income people in South Africa view Wizzit. Wizzit’s low between users load. The authors also discuss the pros and cons of G-Cash and Smart Money, and
income customers give m-banking high marks for its convenience, accessibility, and affordability. The conclude the article with a discussion of how market conditions in Africa are similar to those in the
study found that while the poor do use Wizzit, they are not among South Africa’s poorest people, Philippines prior to the growth of mobile banking.
who still remain unbanked. Part one of this paper introduces Wizzit; part two details findings from
the survey in South Africa; and part three puts this research into a broader context to assist banks, Mjojo, Angela. (2008) “Financial Inclusion Through Micro-finance Services Provision and Information
mobile network operators, and other parties interested in extending financial services to low-income Communications Technology (ICT) Pertinent Issues for Malawi,” MIT Working Paper (website not available)
people.
This working paper explores the possibility of employing ICT, specifically in the form of cell phone
Kumar, Anjali, et al. (2006) “Expanding Bank Outreach through Retail Partnerships: Correspondent Banking in services, in micro-financial services provision to aid in the financial inclusion process. Using Malawi as
Brazil.” World Bank Working Paper, No. 85. an example, the paper highlights the high demand that exists for microfinance services, defines the
[Online] challenges that are encountered in micro financial services provision such as high transactions costs;
http://siteresources.worldbank.org/INTTOPCONF3/Resources/363980Retail0p101OFFICIAL0USE0ONLY1.pd and proposes that mobile phone financial services (m-FS) in Malawi may be one possible low cost
f solution that can be pursued in order to attain financial inclusion. The paper does however point out
the risks that are likely to be encountered in m-FS, and the possible mitigation measures that exist to
This paper explores the extent to which formal, regulated financial institutions such as counter these risks. The paper concludes with recommendations for the stakeholders that would
banks have been able to partner with “correspondents,” using the case of Brazil, where banks have need to be involved in this process.*
recently developed extensive networks of such correspondents. It shows that such arrangements
result in lower costs and shared risks for participating financial institutions. The example from Brazil Morawczynski, Olga and Mark Pickens. (2009) “Poor People Using Mobile Financial Services: Observations on
may be replicable elsewhere if appropriate regulatory adjustments are undertaken.* Customer Usage and Impact from M-PESA,” CGAP Brief, Washington DC.
[Online] http://www.cgap.org/gm/document-1.9.36723/MPESA_Brief.pdf
Liu, Alice and Michael Mithika. (2009) “Mobile Banking – The Key to Building Credit History for the Poor?
Kenya Case Study: Linking Mobile Banking and Mobile Payment Platforms to Credit Bureaus,” Prepared by This CGAP brief draws on some of the first ethnographic research on M-PESA and offers insights into
DAI for USAID. [Online] http://fletchermbanking.com/Kenya_PACT-Final%20Report-5-19-09.pdf. how poor people use M-PESA and its impact on their lives. One noteworthy finding of the research is
that poor customers are increasingly using M-PESA as a savings account, which reveals a latent
The hypothesis of this study is that mobile transaction data may potentially help Kenyans establish a demand for appropriate savings products. This is an important opportunity for Safaricom as it looks
formal credit history, help lenders more accurately evaluate credit risk, and lead to increased access to broaden its services.
to financial services for the poor. However, current telecom regulations prohibit the disclosure of
statement and account data, including m-payment data that credit bureaus would be interested in Morawczynski, Olga. (2008) “Surviving the Dual System: How M-PESA is Fostering Urban-to-Rural
using. The author’s main conclusion is that there is potential for MNO data to be used to support a Remittances in a Kenyan Slum,” University of Edinburgh, UK.
credit information system, but current telecom regulations are preventing this. [Online] http://www.gsmworld.com/documents/Olga_Morawczynski-M-PESA-2008.pdf.

Mendes, Shawn, Erwin Alampay, Edwin Soriano and Cheryll Soriano. (2007) “The Innovative Use of Mobile The ‘dual system’ thesis has been used to describe the continuing commitment of urban migrants to
Applications in the Philippines—Lessons for Africa,” Swedish International Development Agency. the village in various African countries. According to literature, urban workers maintain strong ties
[Online] http://siteresources.worldbank.org/EXTEDEVELOPMENT/Resources/20071129- with the rural area, even after spending a substantial amount of time in the city. This study uses
Mobiles_PH_Lessons_for_Africa.pdf?resourceurlname=20071129-Mobiles_PH_Lessons_for_Africa.pdf. ethnographic data collected in a Kenyan slum to show that MPESA is becoming a tool for the
maintenance of urban‐rural relations. It further asserts that because it is helping migrants to maintain
The article discusses the factors that led to the rapid growth of mobile banking in the Philippines, such relations, it is facilitating survival in the ‘dual system’.*
including favorable telecommunications policies and the widespread use of mobile phones and SMS. A
precursor to m-Commerce in the Philippines was Pasaload, or the capability of individuals to transfer

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Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography
State Bank of Pakistan. (2007) “Draft Policy Paper on Regulatory Framework for Mobile Banking in Pakistan,” Wishart, Neville. (2006) “Micro-Payment Systems and Their Application to Mobile Networks: Examples of
Banking Policy & Regulations Department. Mobile Enabled Financial Services in the Philippines,” The World Bank/InfoDev, Washington DC.
[Online] http://www.sbp.org.pk/bprd/2007/Policy_Paper_RF_Mobile_Banking_07-Jun-07.pdf. [Online] http://www.infodev.org/en/Publication.43.html.

This State Bank of Pakistan policy paper outlines three mobile banking models: bank-focused, bank-led This article explores some of the reasons behind the success of mobile financial services in the
and non-bank-led, and discusses the risks involved with each model. Agent related risks are common Philippines, including the ability to load prepaid airtime credits, the ability to transfer both cash and
to all transformational models; however, e-money risks are more typical in the non-bank-led model airtime credits between customers, and low values set by the operator for prepaid top-ups or credit
because non-bank entities are not subjected to prudential regulation and supervision. The State Bank transfers. The author also discuss some of the similarities between successful mobile banking models
of Pakistan’s conclusion is that Pakistan should start with the basic bank led model and gradually move used in the Philippines, South Africa and Kenya, including provisions for cash deposits and
to the other models as its regulations are expanded. withdrawals, the ability for third parties to make deposits into a user account and the ability to make
retail purchases at selected outlets.

AML/CFT

ATM Industry Association. (2008) “Best Practices for Mobile Device Banking Security: International Minimum high net-worth customers. In a number of specific sections in this paper, there are recommendations
Security Guidelines for Mobile Device Banking Applications.” for higher standards of due diligence for higher risk areas within a bank, where applicable.*
[Online]
http://www.atmia.com/ClassLibrary/Page/Information/DataInstances/1556/Files/525/Best_Practices_for_Mobile Bankable Frontiers Associates. (2008) “Managing the Risk of Mobile Banking Technologies,” commissioned by
_Phone_Banking_Security_-_Published_version.pdf. FinMark Trust. [Online] www.bankablefrontier.com/assets/MBTechnologies_risks.pdf.

This article identifies the key steps that consumers of mobile banking, including users of mobile This report provides a process for identifying, assessing and mitigating risks in mobile banking. It also
phones and the internet, should take to prevent fraud. The article provides practical advice on using a reviews the particular technologies relevant to the mobile environment and benchmarks these against
PIN number to protect information on SIM cards, dealing with lost or stolen mobile phones/devices, other electronic systems such as e-banking and ATMs. Four main Use Cases are outlined and are
and the use of voice biometrics to provide an added layer of security. Of most importance to this differentiated by the key factors related to the technological choices which have a fundamental impact
audience is the discussion on know your customer (KYC) requirements and AML/CFT requirements on risk. The report concludes with the choice of business model and the question of environmental
to protect the customer and financial institution. risk factors which need to be taken into account in reaching a final adjusted and scaled risk rating.*

Bank for International Settlements. (2001) “Customer Due Diligence for Banks,” Basel Committee on Bester, Hennie, et al. (2008) “Implementing FATF Standards in Developing Countries and Financial Inclusion:
International Settlements, Basel, Switzerland. Findings and Guidelines,” FIRST Initiative, Washington, D.C.
[Online] http://www.bis.org/publ/bcbs85.htm. [Online]
http://www.firstinitiative.org/Projects/_actProjectDocumentDownload.cfm?iDocumentID=5370&iProjectID=37
This paper reinforces the principles established in earlier Basel Committee papers by providing more 3.
precise guidance on the essential elements of KYC standards and their implementation. In developing
this guidance, the Working Group has drawn on practices in member countries and taken into This report considers the impact of the implementation of AML/CFT controls on financial inclusion in
account evolving supervisory developments. The essential elements presented in this paper are five countries (Indonesia, Kenya, Mexico, Pakistan and South Africa). Based on these findings, it
guidance on minimum standards for worldwide implementation for all banks. For example, enhanced develops a set of guidelines to assist the authorities in developing countries to design effective
diligence is required in the case of higher-risk accounts or for banks that specifically aim to attract AML/CFT regimes that are compliant with Financial Action Task Force (FATF) standards and support
financial inclusion.

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Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography

Chatain, Pierre-Laurent, et al. (2008) “Integrity in Mobile Phone Services: Measures for Mitigating Risks from The Guidance was developed by the FATF in close consultation with representatives of the
Money Laundering and Terrorist Financing,” World Bank, Washington, DC. international banking and securities sectors. The Guidance supports the development of a common
[Online] http://siteresources.worldbank.org/INTAML/Resources/WP146_Web.pdf. understanding of what the risk-based approach involves, outlines the high-level principles involved in
applying the risk-based approach, and indicates good public and private sector practice in the design
This working paper explores strategies to identify and manage potential money laundering and implementation of an effective risk-based approach.*
and terrorist financing risks in mobile financial services. Using fieldwork in seven economies (Brazil,
Hong Kong, Macao, Malaysia, Philippines, South Africa, South Korea) as a basis, the paper provides Isern, Jennifer, et al. (2005) “AML/CFT Regulation: Implications for Financial Service Providers That Serve
guidance on the best means of assessing perceived versus actual ML and TF risks, then identifies Low-Income People,” CGAP/World Bank, Washington, D.C.
specific measures to mitigate the actual risks. The paper concludes with recommendations that aim to [Online] http://siteresources.worldbank.org/EXTAML/Resources/396511-
promote a regulatory balance to foster an enabling environment for business while minimizing ML and 1146581427871/AML_implications_complete.pdf.
TF.*
This article explores how the introduction of new or tightened AML/CFT regulations may have the
Chatain, Pierre-Laurent, et al. (2009) “Preventing Money Laundering and Terrorist Financing,” World Bank, unintended and undesirable consequence of reducing the access of low income people to formal
Washington, D.C. [Online] financial services. In order to avoid this outcome, this paper argues in favor of (1) gradual
http://siteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/Preventing_Money_Laundering_Terr implementation of new measures; (2) the adoption of a risk-based approach to regulation; and (3) the
orist_Financing.pdf. use of exemptions for low-risk categories of transactions. The authors cite the South African model
as an example of how a country’s AML/CFT regulations can be modified to take into account the
This World Bank publication is specifically designed for bank supervisors who may be needs of low-income clients.*
looking for ways to devise a program of AML/CFT supervision or who are looking for alternatives to
their current system of supervision. The objective of this book is to provide a “how to” reference for Mobey Forum, Mobile Financial Services. (2003) “Mobile Device Security Element: Key Findings from Technical
practitioners of financial regulation and supervision. The authors have attempted to conceive a Analysis, V 1.0.”
practical guide, with the purpose of resolving strategic and operational supervisory issues. The authors [Online]
cover topics including supervision objectives, the design and carrying out of onsite and offsite http://www.mobeyforum.org/files/Mobey%20Forum%20White%20Paper%20on%20Mobile%20Financial%20Serv
inspection programs, cooperation with other domestic and international AML/CFT authorities, ices%20v1_14.pdf.
sanctions and enforcement.
This paper discusses the security requirements and technical aspects of mobile financial services.
Financial Action Task Force. (2007) “Guidance on the Risk Based Approach to Combating Money Laundering Furthermore, current and emerging mobile technologies are evaluated together with Mobey Forum
and Terrorist Financing.” [Online] http://www.fatf- requirements. The main goal of the document is to give advice and information for the financial
gafi.org/LongAbstract/0,3425,en_32250379_32235720_38960577_1_1_1_1,00.html industry on how they can start offering mobile services to customers.*

Country Specific Regulations

Central Bank of the Philippines. (2009) “Circular No. 649.” Among other things, the Circular states that (1) EMIs should maintain accurate and complete records
[Online] http://www.bsp.gov.ph/downloads/Regulations/attachments/2009/c649.pdf of e-money transactions; (2.) E-money instruments are subject to an aggregate monthly load limit of
PhP100k; (3) EMIs must comply with KYC and AML standards.
This recently released Circular provides guidelines on minimum requirements for Electronic Money
Issuer (EMI), which includes non-banks registered by the Central Bank as a money transfer agent.

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Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography
Reserve Bank of India (2009) “Policy Guidelines for Issuance and Operation of Prepaid Payment Instruments being developed by Mobile Payments Forum of India (MPFI) concerning switching of ATM
in India.” [Online] http://www.rbi.org.in/scripts/NotificationUser.aspx?Mode=0&Id=5216 transactions, which may be suitably adapted for communication between switches where the source
and destination are credit card/ debit cards/pre-paid cards.
This Reserve Bank of India guideline states that mobile phone based semi-closed system pre-paid
payment instruments are permitted in India, given that operators fully comply with KYC provisions, South African Reserve Bank. (2006) “Banks Act Circular 6/2006: Cell-Phone Banking.” [Online]
there is no person-to-person transfer of value, and the maximum value of such instruments does not http://www.icbs.co.za/internet/Publication.nsf/LADV/E690E58853D2A429422571AA00458CCE/$File/Banks+Ac
exceed Rs 5000. t+Circ+6+of+2006.pdf.

Reserve Bank of India. (2009) “Mobile Payment in India - Operative Guidelines for Banks.” This circular deals with bank accounts that are operated by cell phone operators. It sets out minimum
[Online] http://www.rbi.org.in/Scripts/bs_viewcontent.aspx?Id=1365 criteria that must be met in order for such products to be offered to clients including: (1) the bank
account must meet all the parameters and conditions of exemption under the Financial Intelligence
This guideline states that it is responsibility of the banks offering mobile payment service to ensure Centre Act; (2) debits must be limited to R1,000 per day; (3) control measures must be included to
compliance to these guidelines, including KYC and AML. To promote interoperability between banks prevent a person from opening more than one account.
and mobile payments service providers, the RBI recommends that banks adopt the message formats

Mobile Operator Reports

CTIA, The Wireless Association. (2009) “Best Practices and Guidelines for Mobile Financial Services.”
[Online] files.ctia.org/pdf/CTIA_MFS_Guidelines_BP_Final_1_14_09.pdf. Vodafone. (2007) “The Transformational Potential of m-Transactions,” Policy Paper Series, No. 6, Vodafone,
London. [Online] http://www.gsmworld.com/documents/VOD833_Policy_Paper_Series_FINAL.pdf.
This report provides guidelines to MFS providers regarding industry best practices to authenticate
user identity and obtain user authorization. Some of the best practices specific to mobile banking This Vodafone policy paper is made up of six articles, including those that discuss early lessons from
include multifactor authentication, PINs, challenge questions, one-time use passwords and codes, and the M-PESA model, the regulatory implications of MFS convergence, competition issues in the
express authorization of transactions. General guidelines for theft protection, dispute resolution and development of m-transaction schemes, and using a two-sided-platforms approach toward mobile
security of data transmissions are also provided. transactions.

Vodafone. (2009) “India: The Impact of Mobile Phones,” Policy Paper Series, No. 9, Vodafone, London Vodafone. (2005) “Africa: The Impact of Mobile Phones,” Policy Paper Series, No. 2, Vodafone, London
[Online] [Online]
http://www.vodafone.com/etc/medialib/public_policy_series.Par.56572.File.dat/public_policy_series_9.pdf. http://www.vodafone.com/etc/medialib/public_policy_series.Par.77697.File.dat/public_policy_series_2.pdf.

This report explores the economic impact of telecommunications in India, particularly in the area of This report is similar in structure to the Vodafone report written on mobile phones in India, in that it
agricultural productivity. The report provides compelling findings on the correlation between mobile evaluates the connection between an increase in mobile phone usage and economic growth and FDI
phone penetration and a rise in per capita income. While the report does not focus on mobile in Africa. This report also includes a discussion on the impact of mobile phone use on social capital in
banking, it does clearly show that mobile phone usage is widespread both in urban and rural settings, rural South Africa and Tanzania and presents the findings from community and business surveys on
which is an important precondition for the success of mobile financial services. mobile communications in South Africa, Tanzania and Egypt.

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Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography
Consumer Related Documents

Meso, Peter, Phillip Musa and Victor Mbarika. (2005) “Towards a Model of Consumer Use of Mobile propose a scheme for their representation and comparison and, based on these results, examine the
Information and Communication Technology in LDCs: the Case of Sub-Saharan Africa.” Information Systems relevance of the different criteria with empirical results. Additionally, they propose an approach for
Journal (15). [Online] http://www.icitd.org/attachments/058_ISJ_Paper_in_PDF.pdf the usage of mobile payment procedures based on the theory of informational added values. Finally,
applications and constrictions of the results are shown and an outlook on the future of mobile
Using theories of technology acceptance and technology transfer, this article identifies factors payment is given.*
affecting the use of mobile information and communication technology (mobile ICT) in sub- Saharan
Africa. The researchers surveyed mobile ICT users in Kenya and Nigeria and found that access to Wright, Graham, et al. (2006) “Mobile Phone Based Banking: The Customer Value Proposition,” MicroSave
mobile ICT and cultural influences on mobile ICT diffusion strongly influence individuals’ perceptions Briefing Note 47.
of the usefulness and ease of use of mobile ICT. The results suggest that, although extensive ICT [Online]
diffusion (high mobile ICT levels per capita) may be necessary for m-commerce, it may not be http://www.ruralfinance.org/servlet/BinaryDownloaderServlet?filename=1145534725265_BN_47___Mobile_P
sufficient. Firms conducting business in sub-Saharan Africa need to pay attention to the factors that hone_Banking_The_Custome1146149706.pdf.
explain individual mobile ICT use because these factors will most likely determine the optimal market
segmentation, business development and customer service strategies for leveraging m-commerce The main argument of this MicroSave briefing is that MFS providers will only be successful if they are
operations. For government units, the understanding of such factors would also be beneficial in aiding able to respond to the needs of the low-income customer. These customers are mainly concerned
economic planning and commerce.* about convenience, cost, security and being able to move money around quickly. Wizzit is cited as
being a successful model because as part of its preparatory phase, Wizzit used focus groups to
Pousttchi, Key. (2003) “Conditions for the Acceptance and Usage of Mobile Payment Procedures,” The establish the spending patterns and financial transactions of its low-income target group. Based on
Second International Conference on Mobile Business, Vienna. [Online] http://mpra.ub.uni-muenchen.de/2912/. this research, Wizzit learned that their clients wanted inter-operability with the mainstream
ATM/POS-device based payments system, which is available in South Africa.
This paper examines the conditions for acceptance and actual usage of mobile payment procedures by
the customer. It identifies essential conditions such as cost, security and convenience. The authors

General Documents

Bank of International Settlements. (2006) “General Guidance for National Payment System Development,” mechanisms, this report takes a broad perspective on the composition of a payment system.*
Committee on Payment and Settlement Systems, Basel, Switzerland.
[Online] http://www.bis.org/publ/cpss69.pdf?noframes=1. Bank for International Settlements. (2004) “Survey of Developments in Electronic Money and Internet and
Mobile Payments,” Committee on Payment and Settlement Systems, Basel, Switzerland.
The purpose of this report is to assist countries that are building their national payment systems, and [Online] http://www.bis.org/publ/cpss62.pdf?noframes=1.
those that wish to develop their system further, with practical guidance for development. The report
contains 14 guidelines, which are based on the experiences of a broad group of central banks from This report provides the findings from a survey conducted by the Committee on National Payment
developed and developing countries around the world, and those of the World Bank and the IMF, and Settlement Systems regarding developments in internet and mobile payments around the world.
with 95 central banks and monetary authorities from around the world participated in this survey. For
regard to the development of payment systems. It draws as well on earlier and current work of the each country, card-based products, software based products and mobile payments are discussed, as
CPSS, the World Bank, the IMF and other central banks on payment systems. However, unlike much well as the policy responses to these new developments.
of this work, which often refers to specific instruments, procedures and inter-bank transfer

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Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography
Bank of International Settlements. (2001) “Core Principles of Systemically Important Payment Systems,” banking and considering the value proposition for this group is one of the most important issues that
Committee on Payment and Settlement Systems, Basel, Switzerland. branchless banking operators face.
[Online] http://www.bis.org/publ/cpss43.pdf?noframes=1.
Davis, Ben and John Owens. “POS vs. Mobile Phone as a Channel for M-Banking,” MicroSave Briefing Note 66.
This report outlines the core principles that govern the design and operation of payment systems in [Online] http://www.microfinancegateway.org/gm/document-
all countries, as established by the Committee on Payment and Settlement Systems. Guidance is also 1.9.34160/1_POS%20vs.%20Mobile%20Phone%20as%20a%20Channel%20for%20M-Banking.pdf
provided on how to interpret and implement the core principles. Some of the issues that the
principles tackle concern settlement, security, operational reliability and efficiency. The core This note focuses on the relative merits of using the point of sale (POS) system and the mobile phone
principles are not intended to be a blueprint for the design of a payment system; rather, they suggest for branchless banking. The two types of systems are assessed based on their transactional
the key characteristics that payment systems should have. capabilities, convenience and product appropriateness. The authors conclude that a model that
combines and offers the ease of a mobile phone-based system while offering a POS card, that builds
Choi, Sean and David Collins. (2007) “Mobile Payments in Asia Pacific,” KPMG. on the existing network of POS and ATM terminals, will most likely offer a significant advantage to a
[Online[ http://www.kpmginsiders.com/pdf/Mobile_payments.pdf. mobile phone-based or POS-based only solution.

This report explores the various types of m-payments systems in Asia, including MNO-centric, bank- Duncombe, Richard and Richard Boeteng. (2009) “Mobile Phones and Financial Services in Developing
centric, vendor-centric, and payments platform-centric. Different business models such as business- Countries: A Review of Concepts, Methods, Issues, Evidence and Future Research Directions,” Institute for
to-consumer, business-to-business, consumer-to-consumer, and remittances are discussed as well. Development Policy and Management, Manchester, UK.
These models are discussed in the context of the markets of Japan, Korea, China, India, Indonesia, [Online] http://www.sed.manchester.ac.uk/idpm/research/publications/wp/di/documents/di_wp37.pdf
Philippines, Hong Kong, Singapore, Malaysia, Thailand and Vietnam.
This paper seeks to improve understanding of mobile financial services in developing countries by
Cracknell, David. (2004) “Electronic Banking for the Poor- Panacea, Potential and Pitfalls,” MicroSave, Nairobi reviewing the content of 43 research articles related to this topic. A framework is developed that
[Online] http://www.microfinancegateway.org/gm/document-1.9.29225/25231_file_MicroSave_ebanking.pdf categorizes and analyses the research according to a socio-technical spectrum. Research weaknesses
and gaps are identified suggesting that issues relating to financial needs and the measurement of
This article discusses the various forms of electronic banking including automatic teller machines and impacts have been comparatively neglected, while application design and adoption have received
point of sale devices, personal digital assistants, magnetic stripe cards, smart cards and cell phones. greater attention. In order to correct this imbalance in research, the paper identifies key research
The author argues that for any of these methods to be successful, the customer value proposition of gaps relating to concepts, methodologies, issues addressed and evidence presented and provides
accessibility, affordability and ease of use must be considered. There is also a business case for pointers to future research directions.*
electronic banking which seeks to increase profitability through appropriate fees and charges and
focusing on efficiency gains. Hoffmann, Jenny. “Issues in Mobile Banking 2: Regulatory and Technical Issues,” MicroSave Briefing Note 52.
[Online] http://www.microsave.org/briefing_notes/bn52-regulatory-and-technical-issues-in-mobile-banking-
Davis, Ben and John Owens. “Incentivising 3rd Party Agents to Service Bank Customers,” MicroSave Briefing
Note 69. Meeting regulation requirements remains one of the key barriers for financial institutions to
[Online] http://www.microsave.org/briefing_notes/briefing-note-69-incentivising-3rd-party-agents-to-service- implementing mobile banking. In addition, many financial institutions struggle with technology issues
bank-customers around selecting appropriate systems and delivery channels. Whether it is picking the correct system,
properly selecting and managing agents, or instituting appropriate face-to-face interactions with the
This article compares the two models for using agents: branchless banking service agents and mobile customer, This Briefing Note provides examples from various countries to show how these
commerce providers. For both models, the agent’s willingness to provide services is impacted by the challenges have been met.
complexity of services, expected volume of transactions, the impact on the agent’s primary business,
and fees generated. The authors argue that third party agents are crucial to the success of the mobile

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Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography
Ivatury, Gautam and Ignacio Mas. (2008) “The Early Experience with Branchless Banking,” CGAP, Washington far. It concludes by leaving policy makers and regulators with considerations for future branchless
DC. [Online] http://www.cgap.org/gm/document-1.9.2640/FocusNote_46.pdf banking efforts.

Using examples from Colombia, the Philippines, Kenya, Pakistan, South Africa and the Maldives, this Lyman, Timothy, Mark Pickens, and David Porteous. (2008) “Regulating Transformational Branchless Banking:
CGAP paper discusses seven common trends observed in branchless banking in these countries. Mobile Phones and Other Technology to Increase Access to Finance,” CGAP Focus Note #43. CGAP,
Some of the trends include: the first mover advantage for mobile operators, MFIs are largely being left Washington, DC. [Online] http://cgap.org/gm/document-1.9.2583/FocusNote_43.pdf.
out of this process, and branchless banking channels are used mainly for payments, not for savings or
credit. The authors conclude the paper with four key uncertainties that remain with branchless This CGAP article offers guidance and recommendations to policy makers and regulators regarding
banking, such as issues with interoperability and AML/CFT requirements. how to formulate regulatory policy that gives space for innovation and permits branchless banking to
scale up safely. The authors outline “necessary but not sufficient” policies for transformational
Jefferis, Keith. (2009) “Product Innovation and Access to Finance in Africa,” Econsult (Botswana) Pty Ltd, branchless banking, followed by policies that will ensure the sustainability of branchless banking. The
Gabarone. [website] http://www.econsult.co.bw/. authors’ core recommendation for policy makers and regulators is to use proportionality as a guiding
principle when regulating branchless banking.
This paper provides an overview of the various types of financial products that have been made
available in recent years (such as person to person money transfers, remote payments, e-commerce, Mas, Ignacio and Kabir Kumar. (2008) ”Banking on Mobiles: Why, How, for Whom?” CGAP Focus Note # 48.
agency banking, internet and mobile banking). Jefferis then questions the extent to which technology CGAP, Washington DC. [Online] http://www.cgap.org/gm/document-1.9.4400/FN_48%20ENG_9-10-08.pdf
based products and services have extended access to finance for the poor. Using examples from
Kenya and Botswana, Jefferis concludes by providing a list of conditions that support the development This CGAP article focuses on the advantages to using mobile banking for smaller banks and MFIs.
of innovative business models for accessing finance. The authors argue that using phones as an access tool is advantageous to banks because they can
increase penetration, sell more services, retain the most valuable customers, and reduce the cost of
Krueger, Malte. (2001) “The Future of M-Payments—Business Options and Policy Issues,” Institute for providing services. Mobile banking stands apart from other types of m-banking options because the
Prospective Technological Studies, Seville, Spain. [Online] ftp://ftp.jrc.es/pub/EURdoc/eur19934en.pdf. phone can be used as a virtual identity (PIN and account number) storage system and the phone can
be used to check on account information, move money, and make payments.
The task of this background paper is to show that m-payments are likely to become an Mas, Ignacio and Jim Rosenberg. (2009) “The Role of Mobile Operators in Expanding Access to Finance,” CGAP
important section of the retail payment sector and to identify future policy issues related Brief. CGAP, Washington DC. [Online] http://www.cgap.org/gm/document-
to their development. While there are many actors that might provide m-payment services, banks 1.9.34485/Mobileoperators_Brief.pdf.
and telcos are the most obvious candidates. An effective functioning of m-payments will require co-
operation and interoperability between these two players. This raises a number of competition policy This CGAP brief discusses why phone companies that operate mobile networks would want to
issues in particular with respect to pricing that are discussed in this paper.* provide financial services as well. While additional revenues and increased brand recognition may be
motivating factors for mobile operators to offer payment services, the authors caution operators
Lyman, Timothy, Gautam Ivatury, and Stefan Staschen. (2006) “Use of Agents in Branchless Banking for the against risks such as fraudulent transactions. Mas and Rosenberg provide various value chain options
Poor: Rewards, Risks and Regulation,” CGAP Focus Note # 38. CGAP, Washington, D.C. for mobile operators in the delivery of mobile transactions that can mitigate these risks.
[Online] http://www.cgap.org/gm/document-1.9.2585/FocusNote_38.pdf
Mas, Ignacio and Sarah Rotman. (2008) “Going Cashless at the Point of Sale: Hits and Misses in Developing
The authors discuss the main issues involved with branchless banking through retail agents, focusing Countries,” CGAP Focus Note # 51. CGAP, Washington DC. [Online] http://www.cgap.org/gm/document-
on two main models: the bank-led model and nonblank-led model. They examine the various risks 1.9.7885/FN_51.pdf..
involved with the use of retail agents, including credit risk, operational risk, legal risk, liquidity risk,
and reputational risk. Drawing from examples from Brazil, India, South Africa, the Philippines and This CGAP focus note explores why some countries have been more successful than others in
Kenya, the article illustrates how banking regulators have responded to these agent-related risks thus launching electronic payments. The objective of this report is to extract some lessons behind the

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Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography
failures and the successes. The report discusses three broad approaches (smartcard-based electronic Porteous, David. (2007) “Just How Transformational is M-Banking?” Bankable Frontiers Association.
cash providers, mobile operators facilitating existing payment instruments, mobile operator-centric [Online] http://www.finscope.co.za/documents/2007/transformational_mbanking.pdf.
payment schemes), and in each case looks at two providers who met different degrees of acceptance
in the marketplace. This paper asks how mobile banking has changed access to basic banking accounts. It analyses recent
data from South Africa on financial service use and attitudes, using the access frontier approach.
Owens, John. “The Role of Partnerships and Strategic Alliance to Promote Mobile Phone Banking at the Porteous finds that barriers around trust and ignorance must be overcome to encourage even
Bottom of the Pyramid,” MicroSave Briefing Note 68. existing banked people to use mobile phones. Rapid dispute resolution and a guarantee that
[Online] consumer loss resulting from fraud will be limited is recommended. Porteous also finds that
http://www.globaldevelopmentcommons.net/files/BN%2068%20Strategic%20Partnerships%20for%20M- persuading existing banked customers to use mobile banking may in fact be harder than targeting
banking.pdf. unbanked customers, but does not provide a solution for addressing this challenge.

This report discusses how smaller banks and MFIs can best provide mobile financial services. The Porteous, David with Neville Wishart. (2006) “M-Banking: A Knowledge Map.”
author concludes that smaller banks and MFIs would benefit from working together to share a mobile [Online] http://www.mifos.org/knowledge/resources/development/mifos-mobile/prelim-info/infoDev%20m-
phone banking platform, which creates economies of scale and a more promising business case for BANKING%20A%20KNOWLEDGE%20MAP%28web%29.pdf.
larger banks or MNOs that could host a mobile phone banking platform for the smaller banks.
Smaller banks and MFIs can also outsource technical development and management of agent This report considers why donors should support mobile banking, using the theory that links m-
networks to a third-party mobile banking service provider. banking with poverty reduction. The authors also discuss the needs and gaps arising from the
development of the sector to date, in the light of what donor funded programs are already doing. The
Owens, John. “Pilot and Rollout Issues for Mobile Phone Banking Services,” MicroSave Briefing Note 70. report concludes with strategies and particular initiatives which donors may take to respond to the
[Online] http://www.microsave.org/briefing_notes/bn70-pilot-and-rollout-issues-for-mobile-phone-banking. needs and gaps that are identified in the report.

This note echoes many of the issues raised in the MicroSave note above regarding the need for small Porteous, David. (2006) “The Enabling Environment for Mobile Banking in Africa,” DFID, London.
MFIs to partner with other groups in order to be successful. Owens also adds that institutional issues, [Online] http://www.bankablefrontier.com/assets/ee.mobil.banking.report.v3.1.pdf
such as proper training for frontline and back office staff, is necessary when piloting mobile banking
programs. Owens cautions against the potential for exponential uptake during pilot testing, which This report investigates the extent to which the expansion of mobile telephony is likely to lead to the
may make controlled pilot tests more difficult. expansion of access to appropriate financial services in developing countries. In particular, it seeks to
answer two main questions: (1) Which models of mobile banking are emerging globally, and especially
Pickens, Mark, David Porteous, Sarah Rotman. (2009) “Scenarios for Branchless Banking in 2020,” CGAP Focus in Africa, and are they likely to be accelerate access? (2) Will it happen spontaneously or is
Note #57. CGAP, Washington DC. [Online] http://www.cgap.org/gm/document-1.9.40599/FN57.pdf. enablement required for this to happen? To answer these questions, the report investigates emerging
models of development in m-payments and m-banking through interviews with emerging African
For this CGAP note, the authors undertook a scenario-building project in which they attempt to providers and the use of secondary material. It assesses the policy and regulatory elements of an
answer the question “How can government and private sector most affect the uptake and usage of enabling environment for this sector based in part on the analysis of circumstances in two pilot
branchless banking among the poor by 2020?” To answer this question, the authors created four African countries (Kenya and South Africa).*
scenarios in different settings to produce very different trajectories over the next 10 years. The
scenarios pertain to: (1) which types of entities will be allowed to provide branchless financial Saji, K.B and Aditya Agarwal. (2006) “Mobile Payments- Six Issues.” International Journal of Mobile Marketing
services; (2) will providers craft viable business models for services beyond payments?; (3) how will (awaiting publication). [Online] http://www.scribd.com/doc/2241323/Mobile-Payment-l-Six-Issues
competition play out?; and (4) how will consumer, business, and regulator confidence be affected by
the inevitable failures that will happen? The authors discuss six factors which they believe govern the success of mobile payment systems.
These factors are: current payment relationships, relationship scenarios, sustainability, ubiquity,

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Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography
regulatory and security concerns, and market segmentation. Drawing from the success of mobile have to be met before expecting mass adoption of mobile banking.
banking in the Philippines, the researchers conclude that the numerous issues addressed in the paper

Mobile Banking Presentations

Windsor II Global Leadership Seminar on Regulating Transformational Branchless Banking, 2009:

Rolling out of New Mobile Banking Business in Zambia and DRC:
Protecting Branchless Banking Consumers: Policy Responses to New Ways of Doing Business: http://siteresources.worldbank.org/INTAML/Resources/Mobile_Banking_Zambia_DRC.pdf
http://www.cgap.org/gm/document-1.1.1174/ConsumerProtection-BranchlessBanking-1.pdf
Countering the Use of Mobile-FS in the Money Laundering:
Defining Regulatory Space for Non-Bank Service Providers: http://siteresources.worldbank.org/INTAML/Resources/Countering_ML_Mobile_Banking_Korea.pdf
http://www.cgap.org/gm/document-
1.9.9811/Defining%20Regulatory%20Space%20for%20Nonbank%20service%20providers.pdf Regulating and Overseeing Mobile Payments: A Payment Systems Perspective
http://siteresources.worldbank.org/INTAML/Resources/Regulating_and_Overseeing_Mobile_Payments.pdf
World Bank Conference on Mobile Financial Services, Bangkok 2008:
(For a full list of presentations, see:
http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTFINANCIALSECTOR/EXTAML/0,,contentMDK:21847685~i
sCURL:Y~pagePK:210058~piPK:210062~theSitePK:396512,00.html)
Updates as of July 2010

AITEC PRESENTATION SESSION, 17TH–25TH, FEBRUARY, 2010, Samuel Mutungi, The Co-Operative Bank CGAP, January 2010 “Update on the Regulation of Branchless Banking in South Africa”
of Kenya, Ltd.
CGAP, January 2010 “Updated on Regulation of Branchless Banking in India”.
Bank for International Settlements, Basel Committee on Banking Supervision (October 2001) - “Customer
Due Diligence for Banks.” CGAP 2009, Washington, DC Abbassi, Ala‘a, Mohammed Khaled, Klaus Prochaska, and Michael Tarazi.
“Access to Finance: Microcredit and Branchless Banking in The Hashemite Kingdom of Jordan”.
Barbier, Eric, “TransferTo,” MMT09 Conference and Expo, JW Marriot, Dubai, 26-27 October 09.
CGAP 2009, Washington, DC Abbassi, Ala’a, et. al. “Access to Finance: Microcredit and Branchless Banking in
CGAP Washington DC (2007) “Notes on Branchless Banking Policy and Regulation in Kenya,” Consultative the Hashemite Kingdom of Jordan.”
Group to Assist the Poor.
CGAP 2009, Aguirre, Ernesto, Dias, Denise, Seltzer, Yanina. “Diagnostic Report on the Legal and Regulatory
CGAP 2007 “Notes on AML-CFT Compliance: Challenges with Branchless Banking and Examples of Industry Environment for Branchless Banking in El Salvador”.
and Regulatory Responses.” http://www.cgap.org/technology
CGAP Washington DC 2008 “Notes on Branchless Banking Policy and Regulation in Brazil,” CGAP.
CGAP, January 2010 “Update on Regulation of Branchless Banking in India”. http://www.cgap.org/gm/document-1.9.2319/Brazil-Notes-On-Regulation-Branchless-Banking-2008.pdf

CGAP, February 2010 “Update on Regulation of Branchless Banking in Pakistan”. CGAP Washington DC 2008 “Notes on Branchless Banking Policy and Regulation in Brazil,” Consultative
Group to Assist the Poor.

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Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography

E-Money Regulation in Mexico, April 8, 2010 - http://www.mobilemoneyexchange.org/Feeds/Research/Read/e-

CGAP Washington DC 2008 “Notes on Branchless Banking Policy and Regulation in South Africa,” money-regulation-in-mexico.aspx
Consultative Group to Assist the Poor.
Estioko, Raymond. (June 24-26, 2008). “Anti-Money Laundering and Combating the Financing of Terrorism
CGAP Washington DC 2009 “Notes on Branchless Banking Policy and Regulation in Mexico,” Consultative (AML/CFT) for Mobile Financial Services (m-FS): The Philippine Experience.” Bangkok, Thailand.
Group to Assist the Poor.
E-Zwich Becoming a Colossal Waste of Resources? - http://allafrica.com/stories/201002091058.html
CGAP, Washington, D.C 2009 “AML/CFT: Strengthening Financial Inclusion and Integrity” by Isern, Jennifer,
and Louis de Koker Focus Note 56. Ferguson, Roger. “Implications of 9/11 for the Financial Services Sector,” Remarks from the Conference on
Bank Structure and Competition, Chicago, Illinois May 9, 2002.
Chaitain, Pierre-Laurent. (June 24-26, 2008). “Applying the FATF International standards to Mobile Financial http://www.federalreserve.gov/boarddocs/speeches/2002/20020509/default.htm
Services.” Workshop on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) for
Mobile Financial Services (m-FS). Flaming, Mark, Prochaska, Klaus, and Staschen, Stefan. (June 2009). “Diagnostic Report on the Legal and
Regulatory Environment for Branchless Banking in Indonesia,” CGAP in cooperation with IFC and GTZ.
Chaitain, Pierre-Laurent. (June 24-26, 2008). “Applying the FATF International standards to Mobile Financial
Services.” Workshop on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) for Forbes, John (19 April 2007). “The Convergence of Telecom and Financial Services and its Effects on
Mobile Financial Services (m-FS). AML/Wire Remittance Operations.” United States Treasury, Office of Technical Assistance.

Chatain, Pierre-Laurent. (June 24-26, 2008) “Applying the FATF International standards to Mobile Financial Forbes, John (March 2007) “Effects of Cell phones on Anti-Money Laundering/Combating Financial Terrorism
Services.” Workshop on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) for (AML/CFT) Wire Remittance Operations.”
Mobile Financial Services (m-FS). Bangkok, Thailand.
FS SERIES #9: ENABLING MOBILE MONEY INTERVENTIONS PRIMER, DIAGNOSTIC CHECKLIST, AND
“Cloud Based Voice Biometrics E-commerce Platform”, 15 June 2010, http://www.infosecurity- MODEL SCOPES OF WORK, USAID and Financial Sector Knowledge Sharing, April 2010.
magazine.com/view/10223/couldbased-voice-biometrics-ecommerce-platform-introduced/
Genesis May 2008 “Implementing FATF standards in developing countries and financial inclusion” Findings and
Davidson, Neil, Leishman, Paul, “Building, Incentivizing and Managing a Network of Mobile Money Agents: A guidelines Final report.
Handbook for Mobile Network Operators,”GSMA, [email protected], accessed July 7, 2010.
Hernandez-Coss, Raul, Egwauagu, Chinyere, Isern, Jennifer, Porteuous, David, “AML/CFT Regulation:
Davidson, Neil, Leishman, Paul, “Building, Incentivizing and Managing a Network of Mobile Money Agents: A Implications for Financial Service Providers that Serve Low-Income People,” IBRD/The World Bank, 2005.
Handbook for Mobile Network Operators,”GSMA, Vol. 2, [email protected], accessed July 7, 2010.
Refugees International Kenya “National Registration Processes Leave Minorities on the Edge of Statelessness”
Davidson, Neil, Leishman, Paul, “Building, Incentivizing and Managing a Network of Mobile Money Agents: A Maureen Lynch and Katherine Southwick, May 2008 - http://refugeesinternational.org/policy/field-
Handbook for Mobile Network Operators,”GSMA, Vol. 3, [email protected], accessed July 7, 2010. report/kenya-national-registration-processes-leave-minorities-edge-statelessness

Davidson, Neil, Leishman, Paul, “Managing a Network of Mobile Money Agents,”GSMA, [email protected], Khan, Zain, “Developing ICT Capacities,” AITEC Banking & Mobile Money COMESA, February 25, 2010,
accessed July 7, 2010. Nairobi, Kenya.

Economist Intelligence Unit. (2009) “Kenya Telecoms: Banking on M-Banking.” Industry Briefing. Korean Financial Intelligence Unit, Financial Services Commission (June 24-26, 2008) , “Countering the Use of
Mobile-FS in the Money Laundering.” Workshop on AML/CFT, Bangkok, Thailand.

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Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography

Rishikko, Juha, Choudhary, Bishwajit, “Mobile Financial Services Business Ecosystem Scenarios &
Lynch, Maureen, “Kenya: National Registration Processes Leave Minorities on the Edge of Statelessness,” Consequences: Summary Document,” Mobey Forum, Mobile Financial Services Ltd., 2006.
Refugees International, 5/23/2008 http://www.refugeesinternational.org/policy/field-report/kenya-national-
registration-processes-leave-minorities-edge-statelessness State Bank of Pakistan 2010 Anti-Money Laundering Act, http://www.sbp.org.pk/about/act/Anti-Act-2010.pdf

Mas, Ignacio, Siedek, Hannah, “Banking Through Networks of Retail Agents”, CGAP, Focus Notes NO 47, The Electronic Transactions and Communications Bill, 2009, Section 6 (1) and (2).
May 2008.
USAID Field Visits, Zambia, Kenya, February 9-28, 2010.
M-Pesa interview, Nairobi, Kenya, February 20, 2010.
USAID interview, Tanzania, February 17, 2010.
Oliver, Rich, “Synthesizing the mobile ecosystem: Resolving customer problems in mobile payments clearing
and settlement models,” March 29, 2010. http://portalsandrails.frbatlanta.org/2-1-/03/consumer-confidence- USAID interviews, Zambia, February 16-17, 2010.
vital-to-mobile-payments-success.html
USAID Street Interviews, February 16-17, 2010, Zambia.
Pyler, Megan G., Haas, Sherri, and Nagarajan, Geetha, “Community-Level Economic Effects of M-PESA in
Kenya: Initial Findings,” IRIS Center, University of Maryland, June 2010. Wishart, Neville, “Micro-Payment Systems and Their Applicatin to Mobile Networks: Examples of Mobile-
Enabled Financial Services in the Philippines,” IBRD/The World Bank, 2006, pgs, 13-20.
Report on the Technical Committee on Electronic Banking, Central Bank of Nigeria, February 2003.
FS SERIES #9: ENABLING MOBILE MONEY INTERVENTIONS PRIMER, DIAGNOSTIC CHECKLIST, AND
MODEL SCOPES OF WORK, USAID and Financial Sector Knowledge Sharing, April 2010.

Websites Consulted:

CGAP CGAP
http://www.cgap.org/gm/document-1.1.1304/Jordan_Diagnostic_Report_2009.pdf http://www.cgap.org/gm/document-1.9.2322/India-Notes-On-Regulation-Branchless-Banking-2008

CGAP Financial services Assessment

http://www.cgap.org/gm/document-1.1.1306/Mexico%20Branchless%20Banking%20Notes.pdf http://www.fsassessment.umd.edu/

CGAP World Bank Working Paper 146

http://www.cgap.org/gm/document-1.9.2319/Brazil-Notes-On-Regulation-Branchless-Banking-2008.pdf http://siteresources.worldbank.org/INTAML/Resources/WP146_Web.pdf

CGAP GSM World

http://www.cgap.org/gm/document-1.9.2320/SouthAfrica-Notes-On-Regulation-Branchless-Banking-2008.pdf http://www.gsmworld.com/documents/VOD833_Policy_Paper_Series_FINAL.pdf

CGAP Info/DEV – Innovate, Connect, Transform

http://www.cgap.org/gm/document-1.9.2321/Kenya-Notes-On-Regulation-Branchless-Banking-2007.pdf http://www.infodev.org

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Capitalizing on the Opportunity by Ensuring Sustainability

Annotated Bibliography
MALAWI GOVERNMENT - Money Laundering, Proceeds of Serious Crime Terrorist Financing 1 http://fiuindia.gov.in/about-overview.htm
http://www.fiumalawi.gov.mw/fiu2/documents/money_laundering_act.pdf
Anti-Money Laundering Council
Financial Intelligence Unit http://www.amlc.gov.ph/amla.html
http://www.fiumalawi.gov.mw/fiu2/index.php?option=com_content&view=article&id=19&itemid=27
Anti-Money Laundering Council
Kenyan Department of National Registration Bureau http://www.amlc.gov.ph/archive/reso361.pdf
http://www.identity.go.ke.
Central Bank of Kenya
IFLR 1000 – The Guide to the World’s Leading Financial Law Firms http://www.centralbank.go.ke/currency/currencylaws.aspx
http://www.iflr1000.com/legislationguide/192/the-e-zwich-electronic-clearing-and-payment-system.html
Central Bank of Kenya
Interpol International http://www.centralbank.go.ke/downloads.bsd/GUIDELINES520ON%20AGENT20BANKING-
http://www.interpol.int/pv_obj_cache/pv_obj_id_7DA31F4675F7441C17F0BB94D705DB7DDEF40200/filenam CBK%20PG%2015.pdf
e/FHT04.pdf
The Egmont Group of Financial Services Unit
Palestinian National Authority - Anti-Money Laundering Decree Law http://www.egmontgroup.org/about/what-is-an-fiu
http://www.pma.ps/pdf/Anti-Money%20Laundry%20Law%20Eng.pdf
Financial Action Task Force (FATF) / Le Groupe d'Action financière (GAFI)
India Financial Intelligence Unit http://www.fatf-gafi.org/document/9/0,3343,en_32250379_32236920_34032073_1_1_1_1,00.html

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Contributors

Name Organization E-Mail Phone

Ghana

Michael Fields ACDI/VOCA [email protected] 2.33544E+11

Ernest Addison Bank of Ghana [email protected] 663082 (work), 0202012723 (mobile)

John Mullenax USAID/Ghana [email protected] Mobile: 233 244 313 543 , Tel: 233 21 741 403
Dela Selormey Formerly with Bank of Ghana [email protected], [email protected] 020-8112519 / 233244311552 (mobile)
Direct Line: +233-30-7010250, Main: +233-21-235400/238382
Sam Mensah SEM International Associates Limited [email protected]
Cell: +233-24-4314428
Kenya

Prof. Kinandu Muragu KSMS [email protected] 254-20-8646117

Moses Kiptui KSMS

Dr. Dulacha Galgallo Barako KSMS [email protected]

Stephen Mwaura Nduati Head, National Payments System [email protected]
Pauline Vaughan Head, M-PESA [email protected]
Brian Muthiora Principal In House Counsel, M-PESA
Mark Rostal USAID/ Chief of Party [email protected] 375-5541/42 (Mark)

Pharesh Ratego USAID/Kenya [email protected]

David Ferrand Financial Sector Deepening [email protected] +254 (20) 2718809/8814/2627, +254 (735) 319706, +254 (724) 319706

Nigeria

Adedeji Adesemoye Central Bank of Nigeria [email protected] 234-8023220898 (mobile)

Charles Ifedi Interswitch, Chief Strategy and Expansion Officer [email protected] 2.34802E+12

David Kaye MoneyBox CEO [email protected] 2.34803E+12

Adeniyi Elumaro (Niyi) Integrated Captil Services Ltd [email protected] 2348034020993
Rwanda

Angelique Kantengwa National Bank of Rwanda [email protected] 00 250 573197 (office)

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Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Contributors

Name Organization E-Mail Phone

Steve Caley Managing Director of FINA Bank; Chairman of Banker's Association '[email protected]' 250 598600
Fina Kayisanabo USAID/Rwanda [email protected] (250)78 830 4369 (mobile)

Tanzania

Ben Christiaanse National Microfinance Bank (NMB), CEO [email protected]

Ian Robinson Financial Sector Deepening [email protected] 255 (0)756 092564 (cell)

Patricia Mwangi Financial Sector Deepening [email protected]

James Onyutta FINCA

Mark Staehle CARE Access Africa

Nadeem Juma E-Fulusi Africa

Steve Akwera PUM-Netherlands Senior Experts
Uganda

Brian Conklin USAID/Uganda [email protected]

Angela Kenyonza Kaula Zain [email protected] 25675 2670777

Astollo Obbdo Bank of Uganda, Director of Commercial Banking 2.56414E+11
Zambia

Mark Wood USAID/PROFIT [email protected] 260.976.919.938 (cell) 260.211.251.371 (office)

Rob Munro USAID/PROFIT

Mike Quinn MTZL [email protected] +260976664643 (cell)

Binoy George MTZL

Dr. Denny Kalyalya Bank of Zambia [email protected] 2601229928 (office)

Mrs. Edna Mudenda Bank of Zambia

Norbert Mumba Bank of Zambia

Chisha Mwanakatwe Bank of Zambia

Abraham Nyirongo KPMG Africa

Mobile Financial Services Risk Matrix 190 July 23, 2010

Mobile Financial Services
Capitalizing on the Opportunity by Ensuring Sustainability

Contributors

Name Organization E-Mail Phone

Malala Simungala KPMG Africa

Roy Muyelu Access Bank

Mwaka Chilangi Access Bank

USAID Washington

Chris Barltrop USAID/EGAT/EG/EDFM [email protected], +1 202 368-1086 (cell)

Maria Stephens USAID/EGAT/PR/MD [email protected]

Booz Allen Hamilton

Lisa Dawson Booz Allen Hamilton [email protected]

Michael Ingram Booz Allen Hamilton [email protected]

Sameera Pochiraju Booz Allen Hamilton [email protected]

Michael Catalano Open Revolution [email protected]

Patrick Brennan Independent

US Treasury

David Murray U.S. Treasury [email protected]

Federal Reserve Bank of Atlanta

Cynthia Merritt Federal Reserve, Atlanta [email protected]

GSMA

Andrew Zerzan GSM Association [email protected]

Mobile Financial Services Risk Matrix 191 July 23, 2010