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Northern Africa<br />

TUNISIA<br />

Tunisia already has a significant proportion of its<br />

citizens accessing financial services through its La<br />

Poste service. Though not a bank nor a microcredit<br />

firm, over 6 million of the country’s 11 million have<br />

postal financial accounts. Of those in the country that<br />

are part of a formal financial service, 90 percent of<br />

them are with the La Poste system. La Poste offers a<br />

large array of FinTech products from MFS, domestic<br />

and international remittances (through MoneyGram<br />

and Western Union), bill payments and smartcard<br />

purchases. Nevertheless the Tunisian Central Bank<br />

(Banque Centrale de Tunise – BCT) is still trying<br />

to improve MFS for its citizens through regulatory<br />

reforms.<br />

There are three institutions representing the<br />

government legalization process for the mobile<br />

money service. These are: Banque Centrale de Tunisie<br />

(BCT), the Ministry of Communication Technologies<br />

(MCT), and Société Monétique Tunisie (SMT), which is<br />

a technology arm of the BCT.<br />

a) The Banque Centrale de Tunisie (BCT):<br />

defines the prudential regulation, control and<br />

supervises banks and other financial institutions.<br />

It is the primary regulator for MFS too. It has<br />

partnered with Societe Monetique Tunisie (SMT) for<br />

the provision of switching and clearing services.<br />

In 2011, the BCT issued a circular on MFS, stating<br />

that they may only be used for payments – all<br />

loading needed to be dealt with at a bank branch<br />

or through the use of a prepaid card issued by a<br />

bank. This effectively left the development of MFS<br />

to banks.<br />

b) The Ministry of Communications Technologies<br />

(MCT): is responsible for the organisation<br />

of the telecommunications sector and oversees all<br />

planning, control and supervision of its activities.<br />

In 2013, following a series of talks between the Ministry<br />

of Telecommunications and other stakeholders –<br />

they agreed a change was needed in MFS. The talks<br />

reached a standstill and in 2014, both World Bank<br />

and Consultative Group to Assist the Poor (CGAP)<br />

launched an assessment of the country’s MFS usage<br />

and market potential.<br />

At present the business model practiced is a bank-led<br />

one, with MNO involvement limited to the development<br />

process. AML/CFT and KYC requirements must be<br />

performed at a bank with a photograph ID. However,<br />

there remains a lack of clarity about these elements<br />

(AML/CFT and KYC) and also interoperability.<br />

MOROCCO<br />

Efforts are being made by Moroccan authorities to<br />

modernise its banking systems and increase financial<br />

services access to its population. The country is a<br />

significant financial centre in Africa, particularly for<br />

in¬surance where it is the second largest market<br />

after South Africa. In 2010, the CGAP conducted a<br />

favourable evaluation of the country’s financial<br />

inclusion strategy. Since then, the Bank of Morocco<br />

(BAM) has implemented the Strategic Plan (2013 – <strong>2015</strong>)<br />

to address some of the concerns raised. The country<br />

has a lot to gain from using MFS as it has a high mobile<br />

phone subscription rate per 100 people. This figure<br />

has grown from 30 (2004), to 100 (2011) 1 to over 135 in<br />

the most recent studies (<strong>2015</strong>) 2 .<br />

There are two public entities responsible for the<br />

regulation of MFSs in the country. These are Bank Al-<br />

Maghrib (BAM), which is the Central Bank of Morocco,<br />

along with L’Agence Nationale de Réglementation des<br />

Télécommunications (ANRT) – the Telecommunications<br />

Authority.<br />

a) The Bank Al-Maghrib (BAM): is the prudential<br />

regulator and supervisor of financial institutions.<br />

Its responsibilities include monitoring and ensuring<br />

security payments systems and related standards<br />

are maintained. It also acts as the government<br />

advisor on aspects relating to the banking and<br />

financial sector. In 2014, BAM was given assistance 3<br />

by the European Investment Bank to promote<br />

financial inclusion in the country.<br />

Some of the difficulties which had already been<br />

aired included the requirement for all MNOs<br />

and their respective agents be registered as<br />

public limited or limited companies 4 . However,<br />

amendments made to Loi N° 30-03 Relative aux<br />

Etablissements de Credit et Organisme Assimiles<br />

(2013) have not only put forward clearer definitions<br />

24

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