FiA_2015

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) Tanzania Communication and Regulatory Authority (TCRA): was established under both the Tanzania Communication and Regulatory Authority Act (2003), and the Electronic and Postal Communications (Licensing) Regulations (2011). It ensures MNOs perform to the required standard whenever any financial transactions are carried out through their services. The BOT and TCRA have a good working relationship which has been formalised through a Memorandum of Understanding (MOU). AML/CFT and KYC are conducted on a tiered basis with the minimum requirement of identity documentation including such items as voter registration cards, passports, or employee cards. The tier level determines the size and daily transfer limits as well as the maximum account balance permissible for customers. A key aspect of the updated regulations is interoperability. The regulations are in line with the BOT’s National Financial Inclusion Framework released in 2013, which aims to “build on the country’s recent successful experience with mobile money services... to increase Financial Inclusion” in the country 14 . Southern Africa ZIMBABWE There are two primary bodies responsible for regulating the MFS sector in Zimbabwe. These are the Reserve Bank of Zimbabwe (RBZ) and Postal and Telecommunication Regulatory Authority of Zimbabwe (POTRAZ). Initially, POTRAZ had complete oversight of the MNOs, but with the emergence of MFS, this responsibility is now shared with the RBZ. With no unique legislation or guidance around MFS and its activities this has reportedly caused regular clashes between the regulatory bodies. The main legislative piece used by the RBZ is the National Payment Systems Act (2001) which does not mention MFS or its components. Only financial institutions are governed by the act, so MNOs must partner with financial institutions covered in the Act to offer MFS. a) The Reserve Bank of Zimbabwe (RBZ): has primary responsibility and oversight and is guiding the retail payment services in Zimbabwe. These are performed over two separate departments: the National Payment Service Department (NPSD) and the Banking Licensing Supervision and Surveillance Division (BLSSD). I. National Payment Service Department (NPSD) – proactively seeks to encourage innovative solutions for the payments service modernisation ecosystem in such areas as MFS and in increasing the use of low value payment systems. II. Banking Licensing Supervision and Surveillance Division (BLSSD) – has more of a supportive role, assisting the NPSD in the application and approval of financial institutions intending to introduce new MFS products. The RBZ has a set of internally developed operational guidelines and frameworks to regulate MFS. These guidelines are supposedly based on the Bank of International Settlements and the Bankable Frontiers Association. With little transparency concerning these guidelines, their enforcement is subject to interpretation. Nevertheless, all financial institutions must apply for ‘permission’ to offer MFSs. Both financial institutions and MNOs offering MFS must send weekly reports to the RBZ about the volume and values of their transactions. b) Postal and Telecommunication Regulatory Authority of Zimbabwe (POTRAZ): allows MNOs to offer MFS, which it regards as ‘valueadded services’. Its primary concern relates to how their services are administered and the services’ robustness. The absence of any specific act, guideline or regulation concerning MFS means the RBZ (through the NPSD) communicates to the sector using monetary policy statements. This absence also means the RBZ cannot enforce MNOs or financial institutions to comply on these matters; instead it relies on moral suasion. All MNOs and financial institutions have been persuaded to use the ZIMSWITCH gateway to offer MFS – part of the Zimswitch Instant Payment Interchange Technology (ZIPIT) system – thus ensuring interoperability in the industry. This lack of legislation has meant there are no clear guidelines on aspects relating to AML/CFT and KYC within Zimbabwe’s MFS sector. Neither is there a mandate on MFS systems being interoperable. 28
SOUTH AFRICA As the first country in Africa to be introduced to MFSs, the South African Reserve Bank (SARB) made its stance known on the product in 2006 with its Position Paper on Electronic Money. This was more recently followed up in the Position Paper on Electronic Money (2009) and Position Paper on Interoperability (2011). In the former position paper, SARB outlines that the transference if “not normally due to the beneficiary in terms of an obligation” is classified as “deposittaking” under the Bank Act, No. 94 of 1990. As ‘deposittaking’ is defined in the Banks Act No. 94 of 1990 as the “business of a bank”, only banks may undertake MFS. A recent legislation, the Financial Sector Regulation Bill (currently in its second draft – October <strong>2015</strong>), is said to represent a huge restructure to the country’s financial regulations, has reaffirmed SARB’s position on MFS. Though the Bill does not make any explicit reference to MFS, it does state that acceptance of deposits are defined as financial products regulated by the prudential and conduct authorities. There are two governing bodies within the country tasked with regulating the provision of MFS. These are SARB and the Independent Communications Authority of South Africa (ICASA). a) The South African Reserve Bank (SARB): oversees and supervises the National Payment System. SARB is also responsible for regulating the payment, clearing and settlement systems, powers given to it via the National Payment System and South African Reserve Bank Acts. It is possible for a non-bank to enter into an agreement with a bank to offer these MFSs. Before a bank partners with an MNO, to offer any MFSs, it must inform the SARB. b) The Independent Communications Authority of South Africa (ICASA): provides regulation of the telecommunications services, such as mobile phones. It is given its authority under the Electronic Communications Act 36 of 2005. Under Guidance Note 6 (released in 2008), banks are allowed to open low level MFS accounts without having to undertake face-to-face KYC procedures i.e. without any documentary evidence. However, most banking institutions have still chosen to take a more prudent approach. This has been in an attempt to avoid AML/CFT violations and the personal penalties which could be levied against bank compliance officers. This, together with the relatively low daily transaction limits on these forms of accounts has made MFS less attractive for South Africans. Neither the Position paper on Interoperability or Electric Money mandates interoperability within MFS. This omission was intentional with the hope that it will encourage innovation within the sector. However, the papers are clear about emphasising this position of interoperability as the most preferred option. Western Africa NIGERIA The Central Bank of Nigeria Act (2007) included provisions for the Central Bank of Nigeria promoting best practice and financial inclusion. At the same time the Financial System Strategy 2020 was erected to ensure competitiveness in the country’s economy. Since then the CBN has been very forthcoming in the development of guidelines to manage the growing use of MFS. These have included: The Regulatory Framework for Mobile Payment Services in Nigeria (2009), and the Regulatory Framework for Licensing Super Agents. a) The Central Bank of Nigeria (CBN): holds the primary oversight for MFS providers through the Central Bank of Nigeria Payments Division. This is legislated through the National Payment Systems Management Bill and the guidance given in the Mobile Money Regulatory Framework. The NPS Management Bill provides management, administration and supervision of payments, and the clearing and settlement systems. While the Regulatory Framework for Mobile Payment deals with creating an enabling environment for mobile payment services, and in specifying the minimum technical and business requirements needed for MFSs. It also defines the three major models for the implementation of MFS: I) Bank-Focused Model: where banks provide MFS using the mobile phone as the delivery channel. This model may only be used by licensed financial institutions. II) Bank-Led Model: where a bank or consortium of banks in partnership with other organisations jointly provide MFSs by leveraging on a mobile banking system. III) Non-bank Led Model: allows non-banks, who have registered with the CBN as Payment Service Providers, to deliver MFSs. The model is applicable for any organisation except, licensed deposit 29
Page 1 and 2: EXPLORING AFRICAN FINTECH OKA-HR ww
Page 3 and 4: Contents EXECUTIVE SUMMARY.........
Page 5 and 6: level of success in coordination (w
Page 7 and 8: for cash or a stored value that is
Page 9 and 10: PART 1: COUNTRY HIGHLIGHTS Establis
Page 11 and 12: Barn Khayelitsha — a co-working s
Page 13 and 14: majority of activity occurs in Lago
Page 15 and 16: un cashless payment systems in Ghan
Page 17 and 18: public sector teachers, and EABL, t
Page 19 and 20: Egypt (Cairo) Population: Between
Page 21 and 22: MFS Potential - Formal banked and m
Page 23 and 24: PART 2: ACROSS THE CONTINENT Legisl
Page 25 and 26: of MFS and other concepts, but also
Page 27: RWANDA By 2006, The National Bank o
Page 31 and 32: Enabling Environment - Mapping the
Page 33 and 34: Orange Moves East As well as facing
Page 35 and 36: Percentage and geographical spread
Page 37 and 38: Saving In itself MFS does not encou
Page 39 and 40: Overall the numbers are hugely posi
Page 41 and 42: Financial Deepening Through M-Pesa
Page 43 and 44: Incubators HIGHLIGHTED START-UP ENA
Page 45 and 46: number of events and by providing b
Page 47 and 48: payments for agricultural products
Page 49 and 50: 19. Instituto Nacional de Estatisti
Page 51 and 52: 14. Aker, J. C., and Mbiti, I.M., (

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