MMU regulatory activities support the overall aims of the MMU programme. We focus on removing regulatory barriers preventing financial inclusion and we promote trust in mobile money services so that these services can become part of everyday lives in developing countries.
Major regulatory barriers for mobile operators offering mobile money services are registration requirements which are difficult to comply with, which result from disproportionately applied regulation (anti-money laundering and combating the financing of terrorism) and regulatory frameworks which allow only deposit-taking institutions to offer mobile money services, lacking proportionate regulation for activities such as the provision of payments and e-money.
The best way to remove these barriers and to create trust in innovative mobile money services is to engage in a dialogue between the mobile industry and financial regulators. We engage with mobile operators to develop common positions and to learn from each other. We then channel these emerging messages from industry to financial regulators.
In this section we highlight articles, blog posts and other resources that operators might find useful when researching this topic.
1. General Resources
Regulating New Banking Models that Can Bring Financial Services to All
Author : Claire Alexandre, Ignacio Mas and Dan Radcliffe. the Bill & Melinda Gates FoundationTechnology lets banks delegate ‘last mile’ cash management and customer servicing functions to third-party outlets. By making basic transactions available through local shops, there’s an opportunity to increase banks’ footprint and transform the basic economics of low-balance savings.
Mobile Banking and Financial Inclusion: The Regulatory Lessons
Author : Michael Klein and Colin Mayer, The World BankThis paper sets out a framework for considering the design of regulation of mobile financial services. Since it lies at the interface between financial services and telecoms, MFS also raise competition policy and interoperability issues that are discussed in the paper. Finally, by unbundling payments services into its component parts, MFS provide important lessons for the design of financial regulation more generally in developed as well as LDCs.
2. Money Laundering and Terrorist Financing
Methodology for Assessing Money Laundering and Terrorist Financing Risks
Author : Marina Solin, GSMA and Andrew ZerzanThis paper proposes a risk assessment methodology in response to FATF’s requirement that simplified CDD procedures only be introduced after having undertaking a comprehensive risk assessment. The methodology involves 5 steps, which will help operators and regulators to prevent money laundering and terrorist financing.
New guidance from FATF on AML/CFT and financial inclusion
Author : FATF/GAFIGuidance paper which provides support to countries and their financial institutions in designing AML/CFT measures that meet the national goal of financial inclusion, without compromising the measures that exist for the purpose of combating crime.
Protecting Mobile Money Against Financial Crimes
Author : The World BankThis book is a guide to preserving the integrity of mobile money. Based on fieldwork in eight national markets and research in several countries including India and South Africa, the book suggests ways to lower the risks associated with mobile money.
3. Licensing of Mobile Operators
Industry’s recommended regulatory practices: Philippine e-money circular
Author : Marin Solin, GSMAIn 2009, the Philippines Central Bank (BSP) issued an ‘e-money’ circular that opened e-money issuance to non-banks, thus enabling regulation for mobile money solutions. This document highlights industry regulatory solutions which are relevant and helpful to facilitate the development of MMU.
Nonbank E-Money Issuers: Regulatory Approaches to Protecting Customer Funds
Author : Michael Tarazi and Paul Breloff - CGAPThe success of Kenya’s M-PESA has raised questions about regulating nonbanks—most notably mobile network operators (MNOs)—who work directly with customers.
4. Case Study
Enabling mobile money transferThe Central Bank of Kenya’s treatment of M-Pesa
Author : AFI - Alliance for Financial InclusionDate : 2010
Late in 2008, the Kenyan Government publicly – and suddenly – requested the Central Bank of Kenya (CBK) conduct an immediate risk-assessment of the service. This case study looks at the CBK’s process of assessing M-Pesa’s risk and determining how it fits within existing regulations.
5. Other resources
Putting the Banking in Branchless Banking: Regulation and the Case for Interest-Bearing and Insured E‑money Savings Accounts
Author : Tilman Ehrbeck and Michael Tarazi, CGAPDate : 2011
E‑money represents a promising opportunity to provide low-income individuals with more than just payment and safe storage services. This paper explores the regulatory implications of interest-bearing and insured e-money savings accounts.