Mobile Money: Cautious Optimism

  • 7,403 views
Uploaded on

Payment Innovation Team's newest member, Marcella Willis, put this great presentation together for our colleagues at USAID Mobile Solutions. It hones in on the delicate equation of striking the right …

Payment Innovation Team's newest member, Marcella Willis, put this great presentation together for our colleagues at USAID Mobile Solutions. It hones in on the delicate equation of striking the right balance between financial inclusion and AML/CTF regulation among other topics. Check it out!

  • Full Name Full Name Comment goes here.
    Are you sure you want to
    Your message goes here
    Be the first to comment
    Be the first to like this
No Downloads

Views

Total Views
7,403
On Slideshare
0
From Embeds
0
Number of Embeds
1

Actions

Shares
Downloads
28
Comments
0
Likes
0

Embeds 0

No embeds

Report content

Flagged as inappropriate Flag as inappropriate
Flag as inappropriate

Select your reason for flagging this presentation as inappropriate.

Cancel
    No notes for slide
  • What is “mobile money?”  No universal definition exists, but the contours are pretty well-defined:Simplified:mMoney is money in digital form accessed through a mobile phone.A bit more detailed:mMoney is an electronic store of monetary value that is used and accessed through a mobile phone that is:accepted as a means of payment;mirrored by an equivalent store of money held by a regulated bank in trust; and redeemable for cash.
  • What does mMoney enable?  Technically speaking, it allows:Transfers - person-to-person, domestic and internationalPayment transactions - bill payments, merchant payments, micro-insurance premium payments, airtime top-ups, online payments, ticketing, loan repaymentsDisbursement transactions - bulk payments, including salary payments, government-to-person payments, and loan disbursementsConversion transactions - transactions converting money between digital and hard forms, such as cash-in and cash-out transactions and transfers between bank and mobile money accounts.Administrative transactions - PIN resets and balance inquiries
  • In terms of utility and value-added services, it allows you to:Send money to friends and family quickly and over long distancesPay merchants for goodsReceive payments from customers for goodsMake utility payments for water and electricityPay taxesReceive salary, pension, welfare, emergency, and other forms of paymentsReceive a loan disbursement and make loan paymentsReceive insurance policy disbursements and make premium paymentsAccess fee-for-service products, such as solar power (mKopa), clean water, and health or agriculture informationReceive payments from and make payments to business suppliers
  • Why is mMoney relevant to economic development?At a macro-level: mMoney ecosystems enable a means to dramatically deepen financial inclusion (remember, mMoney functions on mobile phones, the most commonly used ICT platform in developing countries), achieve inclusive economic growth, and reinforce efforts to increase the financial system’s stability, integrity, and level of protection offered to users of financial services.   Moreover, higher use of electronic payments (cards, etc.) has had contributed on average to an 0.8 percent increase in GDP (Moody’s Analytics), and evidence in Latin America suggests that for each ICT-sector job created, 2.42 additional jobs are created in other sectors, and since mobile phones are the primary ICT platform used in developing countries, governments would seem to have an interest in the sector’s growth (WEF). Mobile financial services in Pakistan have contributed to rise in financial inclusion from 20% to 41% (BCG for Telenor)
  • At a micro-level:Protects Against Income Shocks: In Kenya, negative income shocks cause a 7 percent drop in consumption by households that don’t use M-PESA and virtually no change in consumption by households that do.   This consumption-smoothing capability translates to a value equal to 3 to 4 percent of household income.Yields Income Growth and Time Savings: In Nigeria, mobile-based social transfers helped beneficiaries save time equal in value to the grain necessary to feed five people for a day.  Moreover, mobile-based transfers corresponded with more diet diversity, slower asset depletion, and more diverse baskets of agricultural goods produced.  Income growth attributed to the use of mobile applications has been measured at 19 percent for potato farmers in India, 29 percent for grain traders in Niger, and 36 percent for banana farmers in Uganda.Allows Safe Money Transfers In Challenging Environments: In Sudan, 92 percent of adults using mobile money do not have a bank account.  Similarly, in Somalia, the average number of transactions is significantly higher than the global average, with person-to-person transactions alone accounting for 23 transactions per month.
  • How much has mMoney grown since it first began in the early 2000s?A lot: Mobile Money is most ubiquitous in East Africa.  Led by Kenya, four countries have more mobile money accounts than bank accounts, and three use mobile money to transfer funds equal to a significant proportion of GDP (from 20 percent in Uganda to 60 percent in Kenya).Worldwide, roughly 190 mobile money services now exist, with 41 launched in 2012.  In 28 countries, more mobile money agent outlets exist than bank branches.  In a single month, June 2012, over 30 million users (out of 80 million total) conducted 224 million transactions to transfer $4.6 billion through mobile money services.  At least two mobile money services are available in 40 markets, at least three in 18, and at least 10 in four, which points to the sector’s increasing degree of competitiveness.But growth has been uneven:The GSMA has spoken of a 2-tier mMoney landscape forming, with 14 fast-growing services existing in 10 countries and only 6 services boasting over 1 million active users and 20 percent of services boasting over 1 million registered users.The 14 fast-growing mMoney services have tended to: focus on just one or two of the services that mobile money can perform (the tagline for Kenya’s M-PESA began as “send money home”); make a sustained, adequate investment in building the technical platform and equipping the network of agents; and partner with MNOs, banks, and regulators by clearly defining objectives, roles, and responsibilities.  Notably, the 14 fast-growing services do not all boast competitive advantages: three are run by MNOs with less than 25 percent market share, and others are run by MNOs with penetration as low as 28 percent.
  • But growth has been uneven:The GSMA has spoken of a 2-tier mMoney landscape forming, with 14 fast-growing services existing in 10 countries and only 6 services boasting over 1 million active users and 20 percent of services boasting over 1 million registered users.The 14 fast-growing mMoney services have tended to: focus on just one or two of the services that mobile money can perform (the tagline for Kenya’s M-PESA began as “send money home”); make a sustained, adequate investment in building the technical platform and equipping the network of agents; and partner with MNOs, banks, and regulators by clearly defining objectives, roles, and responsibilities.  Notably, the 14 fast-growing services do not all boast competitive advantages: three are run by MNOs with less than 25 percent market share, and others are run by MNOs with penetration as low as 28 percent.
  • So with so much uneven growth, what’s unique about M-PESA’s success in Kenya?
  • So with so much uneven growth, what’s unique about M-PESA’s success in Kenya?M-PESA in a nutshellHistory: launched in 2007 enabling remote payments initially between other M-PESA customers. DFID’s Role: DFID grant matched by the Vodafone Foundation provided initial investments (each contributed 1M Pounds) to deepen financial inclusion in Kenya.MNO led model. Safaricom (Vodafone affiliate). One of four MNOs in market with highest market share (64.5% subscribers) (M-PESA ppt p27)Key factors affecting why M-PESA originally took off? Market context: 78% Rural/22%Urban spread. Only 8% paved roads. Only 19% Access to formal banks. High mobile penetration rate at 74% in 2012. Cultural/social norms to support and send money to extended family members. Channels: M-PESA was a significant improvement compared with traditional Kenyan distribution channels of banking and payment services - money was often sent by bus or P.O. and methods were costly, lengthy, risky, inconvenient, etc.
  • Key success factors: Three key elements for success in launching and developing a mobile money service were identified by Mas and Ng’weno (Gates Foundation, 2010) as being: (i) a strong and trustworthy brand, customers already used and trusted Safaricom making them more open to try a new service transacting their cash(ii) active management of the agent channel to build service points and maintain customer service, ensuring convenience and cash availability(iii) proper pricing, which in the case of M-Pesa implies charging where clients see most value, when money is sent to another person, or withdrawn after receipt, at affordable costs
  • Key M-PESA Statistics as of 2013: Most successful Mobile Money deployment to date.(http://www.safaricom.co.ke/images/Downloads/Resources_Downloads/FY_2013_Results_Presentation.pdf)Customers: 17.11 mn customers (p13) and 10.5 million 30 day active users (p26)Revenues: M-PESA Contributes 18% of Safaricom’s total revenue. (P12) M-PESA revenue grew by 29.5% to 21.84 billion. Agent network: There are 65,547 M-PESA agents, with 26,000 agents added in the last financial year. (p13)Transactions: (www.xe.com: 1 KES = 0.0114 USD / 1 USD = 87.6 KES)Kshs 522bn (app. $5,958,930,694) was transacted between customers within M-PESA (p13)Kshs 444bn was deposited into M-PESA via agents.Kshs 390bn was withdrawn from M-PESA via agent.32% of airtime top-ups were done directly through M-PESA.
  • Additional products: (p28)M-KESHO: before M-SWHARI and in conjunction with Equity Bank offers a banking service of micro-savings, micro-credit, micro-insurance (personal accident)Launched M-SHWARI to provide interest bearing deposits and micro-loans and now has 1.2m active customers. (p26)Launched m-health, e-learning and m-agriculture services Changamka M-Kadiya Maternity and M-Kadiya Family HealthLaunched m-KOPA solar lighting: pay as you go Lipana M-PESA allows merchants to accept payments for goods and services from their customers
  • C. M-PESA within the Kenya landscape:i. Key points from the GSMA Infographic on Kenya, M-PESA, and the journey to financial inclusion: The following data includes all mobile money deployments in Kenya:Total mobile money users: 23,018,500 or 74% adult populationAverage value per transaction: US$ 29.3Kenyan GDP transacted though MM services: 31%Value 142bn Kshs/month of MM transactions in April Volume: 56m transactions in April 2013
  • ii. Key moments in Kenya’s Regulatory transition: 2006 Safaricom approaches CBK re: M-PESA2007 CBK determines M-PESA not a banking business and issues “letter of No Objection”2008 International transfers proposed to CBK 2009 CBK adopts Guidelines on Agent Banking following amendments to the Banking Act permitting 3rd parties to provide services on behalf of banks(2009 First competitor launches Yu Cash)2010 M-KESHO, Equity bank account managed via M-PESA (introducing explicit banking services)2011 Landmark National Payment System Bill grants CBK power of oversight over the payment systems2013: ONLY NOW, the CBK holds public consultation on a. Electronic Money Regulations; b. Regulation for the provision of Electronic Retail Transfers; c. Anti-Money Laundering Guidelines for the provision of Mobile Payment Services
  • d. difference between M-KESHO and M-SHWARI IFC Case Study on M-SHWARI in Kenya: http://www.ifc.org/wps/wcm/connect/91a41e8040475ba0b90dbb82455ae521/Tool+10.3.+Case+Study_M-Shwari.pdf?MOD=AJPERES.Ignacio Mas and Tonny Omwansa, NexThought Monday - A Close Look at Safaricom’s M-Shwari: Mobile, yes, but how ‘cool’ is it for customers?, December 10, 2012, http://www.nextbillion.net/blogpost.aspx?blogid=3050M-KESHO, launched May 2010This is a banking service by both Equity and Safaricom where your money can earn interest from as little as Ksh1.  You can transfer cash from your Equity Account to your M-PESA account and also make deposits through your M-PESA account to your M-KESHO account.Other features of the account include Micro-credit facilities (emergency credit availed through M-PESA), Micro-insurance facilities as well as a personal accident cover that translates into a full cover after 1 year.  To open this account, you must be an M-PESA subscriber. Main features of the account include:1) Micro-savings2) Micro-Credit3) Micro-insurance Product – Personal Accident related Equity BankStrong brand promotion and ambition in retail banking (led rivalry with Safaricom)No account opening or monthly fees, no min account balancesInterest earning micro-savingsMicro-credit Key DifferencesTransfers between M-pesa and M-kesho accounts are not free, fees applyConsidered a full bank account with out limits thus enabling higher balances and transactionalityconnected to a full fledged bank accountparticularly useful for small businesses to have higher balance/transactions M-SHWARI, launched Nov 2012A revolution in banking is in the offing through M-Shwari. M-Shwari is the revolutionary new banking product for M-PESA customers that allows you to save and borrow money through your phone while earning you interest on money saved. With M-Shwari, you are also entitled to affordable emergency loans. M-Shwari is a paperless banking service offered through M-PESA. It will;Enable you open and operate an M-Shwari bank account through your mobile phone, via M-PESA, without having to visit banks or fill out any forms.Provide you the ability to move money in and out of your M-Shwari savings account to your M-PESA account at no charge.Give you an opportunity to save as little as Ksh.1 and earn interest on your saving balance. This cash is moved into the savings account via M-PESA.Enable you to access micro credit product (loan) of a minimum of Ksh.100 any time and receive your loan instantly on your M-PESA account.This is a product for everyone who feels that banking should be hassle-free. No forms to fill in, no branches to visit. Just one click on your phone and you have a savings account! Commercial Bank of Africa (CBA)Corporate bank with no branding ambitions in low end retail market. Interest is access to mobilized savings without operational hassles and reputational risks No account opening or monthly fees, no min account balancesInterest earning micro-savingsMicro-credit Key DifferencesTransfers between M-pesa and M-shwari accounts are free thus cheaperCBA has no retail presence, so rely on Mpesa client identity data – thus not full fledged bank account implying same transactional and balance limitations as mpesa, and no ability to withdraw larger sums at CBA branches. So limitation on store-of value capacity is only double of an mpesa account. customers can store twice the amt than simple mpesa actcan use as a discipline building separate pocket to save against objectivesearn interest instant authorization up to particular loan amount based on history of all product usageSafaricom establishing preferential treatment for only one bank rather than equal partner for all banks may limit financial inclusion for customers. Appears to be business model of competing brands as they chose a bank with little interest in brand promotion
  • 2. How do we balance the imperative for increasing financial inclusion with the institutional need for increasing bank capacity and implementing an effective regulatory framework for mMoney? (i.e. low barriers to entry for entrepreneurs and customers), building central bank capacity, and implementing effective regulation and supervision. Transition: Following from the previous discussion of M-PESA, its success brought global attention to the provision of mobile money services. The CBK openly allowed this service to progress and evolve, while observing closely, and engaging with the MNOs and Banks. The success inspired other deployments around the world to replicate and/or tweak the M-PESA model spurring policy makers to react. Based on much research, dialogue and policymaking with regards to mobile money and financial inclusion, the following section explains some of the perspective of the main policy leaders, and the key issues. Consensus is that a balance can be established to ensure appropriate regulations and at the same time promote financial inclusion through mobile money. No reason for alarm. Given regulatory context: In most developing countries, mobile money is regulated by the Central Banks. ICT ministries and telecommunication regulators may also be involved.Central banks are usually focused on risk but increasingly also care about financial inclusion given the high percentage of populations unbanked in the developing world. Some governments also have adopted national financial inclusion strategies.
  • Who are the key players and what do they propose?TheFinancial Action Task Force (FATF), established 1989Independent inter-governmental body, established by the Ministers of its Member jurisdictions, that develops and promotes policies to protect the global financial system against money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction.FATF Recommendations are recognized as the global anti-money laundering (AML) and counter-terrorist financing (CFT) standard. They form the basis for a co-ordinated response to these threats to the integrity of the financial system and help ensure a level playing field.  First issued in 1990, FATF Recommendations revised most recently in 2012. In 2013, FATF updated 2010 Guidance on Anti-Money Laundering and Terrorist Financing Measures and Financial Inclusion which states: FATF is convinced that the promotion of well regulated financial systems and services is central to any effective and comprehensive Anti-Money Laundering and Terrorist Financing (AML/CFT) regime. However, applying an overly cautious approach to AML/CFT safeguards can have the unintended consequence of excluding legitimate businesses and consumers from the financial system.2013 published Guidance for a Risk-Based Approach to Prepaid Cards, Mobile Payments and Internet-Based Payment ServicesThe main aims of the document are to develop a common understanding of the FATF Standards1that are relevant when promoting financial inclusion and explicit the flexibility that the Standards offer, in particular the risk-based approach (RBA), enabling jurisdictions to craft effective and appropriate controls. The Guidance paper was initially published in 2011 and was revised following the adoption of the new set of FATF Recommendations in 2012. It is non-binding and does not override the purview of national authorities. It highlights the need to better inform the assessors and the assessed countries of the financial inclusion dimension of the AML/CFT national frameworks.
  • ii. G20, established 1999G20 brings together finance ministers and central bank governors from 19 countries for international cooperation on the most important issues of the global economic and financial agenda.G20 Toronto Summit June 2010, Principles for Innovative Financial Inclusion issued, including: 8 Proportionality: Build a policy and regulatory framework that is proportionate with the risks and benefits involved in such innovative products and services and is based on an understanding of the gaps and barriers in existing regulation.9 Framework: Consider the following in the regulatory framework, reflecting international standards, national circumstances and support for a competitive landscape: an appropriate, flexible, risk-based Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) regime; conditions for the use of agents as a customer interface; a clear regulatory regime for electronically stored value; and market-based incentives to achieve the long-term goal of broad interoperability and interconnection.
  • iii. Alliance For Financial Inclusion (AFI), founded in 2008AFI is a global network of central banks and financial policymakers from developing and emerging countries working together to increase access to appropriate financial services for the poor, AFI’s unique peer-to-peer learning model encourages and enables financial policymakers to interact and exchange knowledge which results in the building of a more comprehensive knowledge base on financial inclusion and the subsequent formulation and implementation of effective policy by members in their home countriesMaya Declaration signed in 2011 signed by 80+ institutions representing over 75% of world’s unbanked, and agreed to make measurable commitments in four broad areas that have been proven to increase financial inclusion including “implement a proportional framework.” Recommends Balancing Integrity and Inclusion: A proportional approach to regulation that balances financial stability, integrity and inclusion is increasingly important. Proportional regulation relies on each country assessing the risks of financial inclusion policy (such as money laundering and terrorist financing) and developing risk-appropriate regulations. Lower risk areas (like services for the poor) may not require the same level of regulation and oversight as higher risk areas. Policymakers are increasingly recognizing that there is a mutually beneficial connection between a more inclusive financial sector and an effective AML/CFT regime. The practical challenge facing many countries is how to assess risks and implement proportional regulations. Some countries have already made progress in this area and are sharing their lessons and successes. AFI brings together working groups of policymakers from around the world to build networks, share experiences, and develop capacities for regulators and supervisors to mitigate risks of mobile money and promote financial inclusion.
  • b. Bank based VS Non-bank based (Should this be included? It’s relevant, but would add several more slides / time)Bank based: Clients have claim to value indicated in mobile money systemValue is linked to individual retail accounts in core banking system (may or may not be “real time”)Bank utilizes funds in accordance with regulations , i.e. they intermediateFunds are “as safe” as the bank is sound provided the two systems are adequately integrated.Non-bank based:Clients have claim to electronic valueElectronic value is issued by non-bank, and is usually backed 100% by one or more bank accounts;Funds must be clearly delineated as property of customers and not of issuerFunds may not be used by non-bank, but Funds may be used by banks in accordance with regulations and termsFunds are “as safe” as the bank is sound provided the 100% backing is controlled and maintained.
  •  c. What are the Key Issues? (sources: FATF, AFI, PFIP/UNCDF, GSMA,CGAP)i. Broad Prudential/Systemic IssuesSafety of Funds: 100% of value in mobile money system must be in a regulated institution at all timesTransaction Speed and Security: Transactions must happen in real time, be confirmed instantly and be secure (eg. Pin)Settlement procedures: confirmation of transactions or reversalsKYC/CDD: proportionate to riskAML/CFT
  • ii. AML/CFT Traditional AML/CFT rules that are appropriate for new technologies and agent relationships FATF advocates a risk-based approach that allows regulation to be tailored and proportionate to perceived riskContrary to cash, mobile transactions can provide additional investigative leads for law enforcement agencies because such transactions generate electronic records, whereas cash does not. (FATF. Money Laundering and New Payment Methods. October 2010) (“Better than Cash”)AML monitoring continues to be based on transaction monitoringIdentify and define unusual or suspicious transactionsIdentify cases where the same user has multiple accountsRegular, reasonable reporting to regulatorRegulators’ mechanism puts limits on transactions volume, frequency, and accounts  (Source: GSMA) “Little evidence thus far of money laundering or terrorist financing using mobile money: There have been no cases of money laundering through mobile money services in countries where these services have thrived, and there have been no reports of terrorist financing. World Bank research indicates that, so far, mobile money has been of little interest to criminals or terrorists compared to other payment channels such as cash or the Internet. Although no payment system can be 100% free of abuse, it is important to gather data that measures the attractiveness of a particular system to criminal activity.”
  • ii. AML/CFT  (Source: GSMA) “Little evidence thus far of money laundering or terrorist financing using mobile money: There have been no cases of money laundering through mobile money services in countries where these services have thrived, and there have been no reports of terrorist financing. World Bank research indicates that, so far, mobile money has been of little interest to criminals or terrorists compared to other payment channels such as cash or the Internet. Although no payment system can be 100% free of abuse, it is important to gather data that measures the attractiveness of a particular system to criminal activity.”
  • iii. Customer Due DiligenceStandard KYC procedures don’t always work for the unbanked KYC and CDD requirements should be proportionate to riskImposing low value limits in order to qualify as a “low risk” product and be allowed to apply simplified CDD measuresWhere customer data cannot be reliably verified, it may be appropriate to apply alternative risk mitigation measures Example, in Fiji, people lack national id cards, the Central Bank and the Financial Intelligence Unit (FIU) have permitted mobile money providers (and their agents) to use a “referee letter” to verify a customer’s identity (GSMA)Specifically, if mobile money is to contribute to financial inclusion, regulators have to consider that the average mobile money customer, particularly the unbanked, maintains a low account balance, conducts relatively small transactions, and, in many countries, lacks a permanent address and/or government-issued identification. The average value of peer-to-peer (P2P) transfers is US$35 per transaction (GSMA).
  • iii. Customer Due DiligenceSpecifically, if mobile money is to contribute to financial inclusion, regulators have to consider that the average mobile money customer, particularly the unbanked, maintains a low account balance, conducts relatively small transactions, and, in many countries, lacks a permanent address and/or government-issued identification. The average value of peer-to-peer (P2P) transfers is US$35 per transaction (GSMA).
  • iv. Consumer ProtectionNew Challenges presented by Mobile phone financial services: Large distance between providers and customers Third parties may lack clear incentives or liability for transparency Cash in/out function by agents may open the door to fraud Requires technology-tailored solutions to data security and privacy, redress mechanisms and pricing transparencyDETAILS: Mechanisms required:Funds should be the legal property of the subscribersThe provider-agent relationship must be clearly defined and legal liability prescribedAgents must be carefully monitored and supported Client information must be safeguarded Complaints tracking/Dispute resolution & reportingProcedures for complaints stated, followedCall centre support (ideally 24/7)Policies for loss of pin, sim, etc.Policies for death of clientComplaint handling and redress procedures must be clearly stated and followedRobust treatment of claims for loss or fraudTransparent pricingPricing posted with agentsNotice given prior to price changesCost of transaction noted in confirmation
  • iv. Consumer ProtectionMechanisms required:Funds should be the legal property of the subscribersThe provider-agent relationship must be clearly defined and legal liability prescribedAgents must be carefully monitored and supported Client information must be safeguarded Complaints tracking/Dispute resolution & reportingProcedures for complaints stated, followedCall centre support (ideally 24/7)Policies for loss of pin, sim, etc.Policies for death of clientComplaint handling and redress procedures must be clearly stated and followedRobust treatment of claims for loss or fraudTransparent pricingPricing posted with agentsNotice given prior to price changesCost of transaction noted in confirmation
  • v. Third Parties / Agent NetworksBanks and non-banks must outsource customer registration, cash collection, and disbursement activities to lower the cost of financial services, expand their reach, and thereby increase financial inclusion. Building an efficient mobile money distribution network depends on proportional and cost-effective regulation (GSMA)Most regulators opt for a light touch in regulating distribution networks because they recognize that the risks posed by mobile money distribution can be effectively monitored and mitigated by the providers (GSMA)Regulators often recognize that business decisions about the distribution network should be freely negotiated between the provider and the third party, and limit their intervention to set baseline standards for vetting third parties and rely on provider liability. (GSMA)The roles and responsibilities of agents should be clearly and contractually definedRetail agents should be permitted to transact on behalf of providers and enroll new customers and verify customer identity. KYC role.A list of authorized third parties, including location and contact information, should be available to the regulators upon requestThe legal liability between provider and agent should be clearly and contractually definedAgent selection, training, and monitoring procedures must be proportionate to risk and are primarily the responsibility of the provider
  • On creating a level playing field to leave the choice to users: (source: GSMA) “From the regulator’s perspective, the concerns involved in allowing mobile operators to offer payment services can be easily addressed. In fact, there is not a trade-off between the participation of financial intermediaries and mobile operators. [...] In the end, by allowing all types of participants, the financial regulator leaves the market to figure out what works best, and the customers will benefit from the result.”NardaSotomayorHead of the Microfinance Analysis DepartmentSuperintendencia de Banca, Seguros y AFP, Peru
  • On mobile money and monetary policy (source: GSMA) “Although electronic money has become more important in some countries, the impact of these developments on the composition of the monetary base is considered negligible thus far. Moreover, even if the usage of electronic money were to expand massively, there would still be various ways in which central banks could preserve a tight link between electronic money and central bank money and to keep control over short-term rates. Most central banks therefore judge that the influence of innovations in retail payments on monetary policy is neutral or of low importance.”Working Group on Innovations in Retail PaymentsCommittee on Payment and Settlement SystemsBank for International Settlements (BIS
  • Sources Referenced:Safaricom Ltd, FY 2013 Presentation, http://www.safaricom.co.ke/images/Downloads/Resources_Downloads/FY_2013_Results_Presentation.pdf.Ignacio Mas and AmoloNg’weno, Bill & Melinda Gates Foundation, 2009, “Three keys to M-PESA’s success: Branding, channel management and pricing”, http://www.gsma.com/mobilefordevelopment/wp-content/uploads/2012/03/keystompesassuccess4jan69.pdf.The Kenyan Journey to Digital Financial Inclusion and infographic, GSMA, 2013, http://www.gsma.com/mobilefordevelopment/mmu-releases-infographic-on-the-kenyan-experience-with-mobile-moneyFATF, “Anti-Money Laundering and Terrorist Financing Measures and Financial Inclusion, 2013, http://www.fatf-gafi.org/topics/financialinclusion/documents/revisedguidanceonamlcftandfinancialinclusion.html.Alliance for Financial Inclusion, “Bringing Smart Policies to Life, The basics: Mobile phone financial services”, 2010 http://www.afi-global.org/policy-areas/balancing-integrity-and-inclusion Simone di Castri, “Mobile Money: Enabling Regulatory Solutions,” GSMA: Mobile Money for the Unbanked, February 2013, available at http://www.gsma.com/mobilefordevelopment/wp-content/uploads/2013/02/MMU-Enabling-Regulatory-Solutions-di-Castri-2013.pdf.PFIP/UNCDF, “Some thoughts on mobile money regulation” internal presentation prepared for Bank of Papua New Guinea, 2011. G20, Toronto Summit, 2010, “Principle of Financial Inclusion” http://www.g20.utoronto.ca/2010/to-principles.html.Maya Declaration signed in 2011: http://www.afi-global.org/maya-declaration.Ignacio Mas and TonnyOmwansa, NexThought Monday - A Close Look at Safaricom’s M-Shwari: Mobile, yes, but how ‘cool’ is it for customers?, December 10, 2012, http://www.nextbillion.net/blogpost.aspx?blogid=3050.Additional Sources Available:USAID, “Mobile Financial Services Risk Matrix,” 2010, http://www.gsma.com/mobilefordevelopment/wp-content/uploads/2012/06/mobilefinancialservicesriskmatrix100723.pdf.CGAP, “AML/CFT: Strengthening Financial Inclusion and Integrity,” August 2009, available at http://www.cgap.org/publications/amlcft-strengthening-financial-inclusion-and-integrity. CGAP, “Protecting Branchless Banking Consumers: Policy Objectives and Regulatory Options,” http://www.cgap.org/publications/protecting-branchless-banking-consumers.United Nations Conference on Trade and Development (UNCTAD), “Mobile Money for Business Development in the East Africa Community: A Comparative Study of Existing Platforms and Regulations,” UNCTAD, 2012, available at http://unctad.org/en/PublicationsLibrary/dtlstict2012d2_en.pdf.Marina Solin and Andrew Zernan, “Mobile Money: Methodology for Assessing Money Laundering and Terrorist Financing Risks,” GSMA: Discussion Paper, January 2010, available at http://www.mymms.nfcmobilemoneysummit.com/mobilefordevelopment/wp-content/uploads/2012/06/amlfinal58.pdf.Beth Jenkins, “Developing Mobile Money Ecosystems,” IFC, 2008, available at http://www.hks.harvard.edu/m-rcbg/papers/jenkins_mobile_money_summer_008.pdf. (Great chart on page 8 on stakeholders and their assets/capabilities, incentives, roles, and constraints.)BFA (for Better Than Cash Alliance), “The Journey Toward ‘Cash Lite’: Addressing Poverty, Saving Money and Increasing Transparency by Accelerating the Shift to Electronic Payments,” Better Than Cash Alliance, 2012, available at http://betterthancash.org/wp-content/uploads/2012/09/BetterThanCashAlliance-JourneyTowardCashLite.pdf.Tim Hatt, Martin Harris, and Adam Wills, “Scaling Mobile for Development: A Developing World Opportunity,” GSMA: Mobile for Development Intelligence, Interim Report, April 2013, https://mobiledevelopmentintelligence.com/insight/Scaling_Mobile_for_Development:_A_developing_world_opportunity.Claire Pénicaud, “State of the Industry: Results from the 2012 Global Mobile Money Adoption Survey,” GSMA: Mobile Money for the Unbanked, available at http://www.gsma.com/mobilefordevelopment/wp-content/uploads/2013/02/MMU_State_of_industry.pdf.AsliDemirguc-Kunt, LeoraKlapper, “Measuring Financial Inclusion: The Global Findex Database,” World Bank: Working Paper 6025, April 2012, available at http://www-wds.worldbank.org/external/default/WDSContentServer/IW3P/IB/2012/04/19/000158349_20120419083611/Rendered/PDF/WPS6025.pdf. Beth Cobert, Brigit Helms, and Doug Parker, “Mobile money: Getting to scale in emerging markets,” McKinsey on Society, February 2012, available at http://mckinseyonsociety.com/downloads/reports/Economic-Development/Mobile-money-Getting%20to-scale-in-emerging-markets.pdf.Global Partnership for Financial Inclusion (GPFI), “Executive Brief: G20 Principles for Innovative Financial Inclusion,” available at http://www.gpfi.org/sites/default/files/documents/G20%20Principles%20for%20Innovative%20Financial%20Inclusion%20-%20AFI%20brochure.pdf.GSMA Intelligence database, available at http://www.gsmaintelligence.com. World Bank Global Findex database, available at http://data.worldbank.org/data-catalog/financial_inclusion. Jenny Aker, RachidBoumnijel, and Niall Tierney, “Zap It To Me: The Short-Term Impacts of a Mobile Cash Transfer Program,” Center for Global Development, Working Paper 268, September 2011, available at http://www.cgdev.org/sites/default/files/1425470_file_Aker_et_al_Zap_It_to_Me_FINAL.pdf.Mark Zandi, Virendra Singh, and Justin Irving, “The Impact of Electronic Payments on Economic Growth,” Moody’s Analytics, February 2013, available at http://corporate.visa.com/_media/moodys-economy-white-paper.pdf.United Nations Conference on Trade and Development (UNCTAD), “Mobile Money for Business Development in the East Africa Community: A Comparative Study of Existing Platforms and Regulations,” UNCTAD, 2012, available at http://unctad.org/en/PublicationsLibrary/dtlstict2012d2_en.pdf.William Jack, TavneetSuri, “The Risk Sharing Benefits of Mobile Money,” American Economic Review, Forthcoming, July 2011, available at http://www.mit.edu/~tavneet/Jack_Suri.pdf.World Bank, “Information and Communications for Development 2012: Maximizing Mobile,” World Bank,  available at http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTINFORMATIONANDCOMMUNICATIONANDTECHNOLOGIES/0,,contentMDK:23190786~pagePK:210058~piPK:210062~theSitePK:282823,00.html.World Economic Forum (WEF), “The Global Information and Technology Report: 2013,” WEF, available at http://www3.weforum.org/docs/WEF_GITR_Report_2013.pdf.  
  • Sources Referenced:Safaricom Ltd, FY 2013 Presentation, http://www.safaricom.co.ke/images/Downloads/Resources_Downloads/FY_2013_Results_Presentation.pdfIgnacio Mas and AmoloNg’weno, Bill & Melinda Gates Foundation, 2009, “Three keys to M-PESA’s success: Branding, channel management and pricing”, http://www.gsma.com/mobilefordevelopment/wp-content/uploads/2012/03/keystompesassuccess4jan69.pdfThe Kenyan Journey to Digital Financial Inclusion and infographic, GSMA, 2013, http://www.gsma.com/mobilefordevelopment/mmu-releases-infographic-on-the-kenyan-experience-with-mobile-moneyFATF, “Anti-Money Laundering and Terrorist Financing Measures and Financial Inclusion, 2013, http://www.fatf-gafi.org/topics/financialinclusion/documents/revisedguidanceonamlcftandfinancialinclusion.htmlAlliance for Financial Inclusion, “Bringing Smart Policies to Life, The basics: Mobile phone financial services”, 2010 http://www.afi-global.org/policy-areas/balancing-integrity-and-inclusion Simone di Castri, “Mobile Money: Enabling Regulatory Solutions,” GSMA: Mobile Money for the Unbanked, February 2013, available at http://www.gsma.com/mobilefordevelopment/wp-content/uploads/2013/02/MMU-Enabling-Regulatory-Solutions-di-Castri-2013.pdfPFIP/UNCDF, “Some thoughts on mobile money regulation” internal presentation prepared for Bank of Papua New Guinea, 2011. G20, Toronto Summit, 2010, “Principle of Financial Inclusion” http://www.g20.utoronto.ca/2010/to-principles.htmlMaya Declaration signed in 2011: http://www.afi-global.org/maya-declarationIgnacio Mas and Tonny Omwansa, NexThought Monday - A Close Look at Safaricom’s M-Shwari: Mobile, yes, but how ‘cool’ is it for customers?, December 10, 2012, http://www.nextbillion.net/blogpost.aspx?blogid=3050Additional Sources Available:USAID, “Mobile Financial Services Risk Matrix,” 2010, http://www.gsma.com/mobilefordevelopment/wp-content/uploads/2012/06/mobilefinancialservicesriskmatrix100723.pdf.CGAP, “AML/CFT: Strengthening Financial Inclusion and Integrity,” August 2009, available at http://www.cgap.org/publications/amlcft-strengthening-financial-inclusion-and-integrity. CGAP, “Protecting Branchless Banking Consumers: Policy Objectives and Regulatory Options,” http://www.cgap.org/publications/protecting-branchless-banking-consumers.United Nations Conference on Trade and Development (UNCTAD), “Mobile Money for Business Development in the East Africa Community: A Comparative Study of Existing Platforms and Regulations,” UNCTAD, 2012, available at http://unctad.org/en/PublicationsLibrary/dtlstict2012d2_en.pdf.Marina Solin and Andrew Zernan, “Mobile Money: Methodology for Assessing Money Laundering and Terrorist Financing Risks,” GSMA: Discussion Paper, January 2010, available at http://www.mymms.nfcmobilemoneysummit.com/mobilefordevelopment/wp-content/uploads/2012/06/amlfinal58.pdf.Beth Jenkins, “Developing Mobile Money Ecosystems,” IFC, 2008, available at http://www.hks.harvard.edu/m-rcbg/papers/jenkins_mobile_money_summer_008.pdf.(Great chart on page 8 on stakeholders and their assets/capabilities, incentives, roles, and constraints.)BFA (for Better Than Cash Alliance), “The Journey Toward ‘Cash Lite’: Addressing Poverty, Saving Money and Increasing Transparency by Accelerating the Shift to Electronic Payments,” Better Than Cash Alliance, 2012, available at http://betterthancash.org/wp-content/uploads/2012/09/BetterThanCashAlliance-JourneyTowardCashLite.pdf.Tim Hatt, Martin Harris, and Adam Wills, “Scaling Mobile for Development: A Developing World Opportunity,” GSMA: Mobile for Development Intelligence, Interim Report, April 2013, https://mobiledevelopmentintelligence.com/insight/Scaling_Mobile_for_Development:_A_developing_world_opportunity.Claire Pénicaud, “State of the Industry: Results from the 2012 Global Mobile Money Adoption Survey,” GSMA: Mobile Money for the Unbanked, available at http://www.gsma.com/mobilefordevelopment/wp-content/uploads/2013/02/MMU_State_of_industry.pdf. 

Transcript

  • 1. Mobile Money Cautious Optimism 1
  • 2. What is “mobile money?” • No fixed definition exists. Some describe it as a “service” for accessing financial services. • Here, we talk of it as a type of “electronic money:” – Simplified: mMoney is money in digital form accessed through a mobile phone. – A bit more detailed: mMoney is an electronic store of monetary value that is used and accessed through a mobile phone that is: • accepted as a means of payment; • mirrored by an equivalent store of money held by a regulated bank in trust; and • redeemable for cash. 2
  • 3. So what can you do with mMoney? Technically speaking, mMoney allows: – Transfers - person-to-person, domestic and international – Payment transactions - bill payments, merchant payments, micro-insurance premium payments, airtime top-ups, online payments, ticketing, loan repayments – Disbursement transactions - bulk payments, including salary payments, government-to-person payments, and loan disbursements – Conversion transactions - transactions converting money between digital and hard forms, such as cash-in and cash-out transactions and transfers between bank and mobile money accounts. – Administrative transactions - PIN resets and balance inquiries 3
  • 4. In other words, w/ mMoney you can… In terms of utility and value-added services, it allows you to: – Send money to friends and family – Pay merchants for goods – Receive payments from customers for goods – Make utility payments for water and electricity – Pay taxes – Receive salary, pension, welfare, and emergency payments – Receive a loan disbursement and make loan payments – Receive insurance disbursements and make premium payments – Access fee-for-service products, such as solar power (mKopa), clean water, and health or agriculture information – Receive payments from and make payments to business suppliers 4
  • 5. Why does mMoney matter to economic development? At a macro-level: – mMoney ecosystems enable a means to dramatically deepen financial inclusion; – achieve inclusive economic growth; and – reinforce efforts to increase the financial system’s stability, integrity, and level of protection offered to users of financial services. – Notable statistics: • Higher use of electronic payments (cards, etc.) has contributed on average to an 0.8 percent increase in GDP (Moodys) • Each ICT-sector job created leads to 2.42 additional jobs in other sectors in Latin America (WEF) • Mobile financial services in Pakistan have contributed to rise in financial inclusion from 20% to 41% (Boston Consulting Group) 5
  • 6. At a micro-level: – Protects Against Income Shocks: • In Kenya, negates affect of negative income shocks (equivalent in value to 3-4% of annual household income) – Yields Income Growth and Time Savings: • In Nigeria, mobile-based social transfers saved time equal in value to grain necessary to feed five people for a day • Income growth attributed to the use of mobile: 19% for potato farmers in India, 29% for grain traders in Niger, and 36% for banana farmers in Uganda – Allows Safe Money Transfers In Challenging Environments: • In Sudan, 92% of adults w/ mMoney have no bank account. • In Somalia, average number of transactions is higher than global average, with P2P alone accounting for 23 per month Why does mMoney matter to economic development? 6
  • 7. Why USAID Supports e-Payments and Mobile Money Foster cost savings and improve aid efficiency Increase transparency and reduce leakage and waste Reduce security risks to program staff Improve access to financial services for the poor and unbanked Catalyze development of new and innovative financial products for the poor and unbanked 1 2 3 4 5
  • 8. mMoney has grown fast & a lot • Esp. in East Africa – 4 countries have more mMoney accounts than bank accounts • Worldwide… – 190 mMoney deployments exist (41 new in 2012) – In 28 countries, more mMoney agent outlets than bank branches – 6 have had more than 1m active users 8
  • 9. But growth has been uneven • GSMA’s 2-tier landscape (14 fast-growing deployments across 10 countries) • Fast-growers tend to: – Focus on 1 or 2 key services made possible by mMoney – Invest adequately in tech platform and agent network – Partner effectively w/ stakeholders (clear objectives, roles, etc.) 9
  • 10. What’s unique about M-PESA’s success in Kenya? 10
  • 11. M-PESA: “the moon and stars align” • MNO led – Safaricom, Vodafone affiliate • Highest market share of 4 MNOs • Loyal customer base • DFID incentivizes with matching grant Initiators • Rural/Urban Spread 78%/22% • High mobile penetration 74% • Low bank access 19% • Cultural norm of sending money to family • Payment channel most used: bus on 8% paved roads Market Context 11
  • 12. Traditional money transfer channel in Kenya! 12
  • 13. Initial Keys to Success Trustworthy Brand Proper Pricing Robust Agent Channel 13
  • 14. How it Works in a Nutshell http://youtu.be/nEZ30K5dBWU 14
  • 15. M-PESA Key Statistics - 5,000,000 10,000,000 15,000,000 20,000,000 25,000,000 30,000,000 35,000,000 40,000,000 45,000,000 50,000,000 Total Population Adult population <15 M-PESA customers 30 day active customers Population compared to M-PESA customers Total Population Adult population <15 M-PESA customers 30 day active customers 2012 Population data, IndexMundi 2013 M-PESA data, Safaricom 69% of the adult population are M-PESA customers 15
  • 16. More M-PESA Products 16
  • 17. Kenyan Journey to Digital Financial Inclusion, 2013 • 23 mn+ mobile money users or 74% adult pop • 31% Kenyan GDP transacted through MM • US$ 29.3 average value per transaction • US$1.6b (142b Kshs in MM transactions in April 17
  • 18. Highlights: Kenya’s Regulatory Transition 2006: Safaricom approaches CBK 2007: CBK issues "letter of No Objection” (not a bank product) 2009: CBK permits 3rd party agents 2010: M-Kesho bank products permitted with Equity Bank 2011: Ntl bill grants CBK power of oversight over payment systems 2013: CBK consults public on E-money regulations 18
  • 19. M-KESHO vs. M-SHWARI • Launched May 2010 • Offers interest bearing savings and micro-loans • Associated bank: Equity Bank Key Differences: • Equity, retail bank w/strong brand ambitions (rivaling Safaricom) • Full fledged bank account without limits on balance • Higher fees on transfers between M- PESA and M-KESHO accounts • Launched Nov 2012 • Offers interest bearing savings and micro-loans • Associated bank: Commercial Bank of Africa (CBA) Key Differences: • CBA, corporate bank w/no low end retail market and no branding ambitions • Without retail presence CBA relies on Safaricom KYC thus not a full- fledged bank account – transactions are thus limited – only doubling M-PESA balance • No fees on transfers between M- PESA and M-SHWARI accounts 19
  • 20. Increasing Financial Inclusion with Effective mMoney Regulatory Framework 20
  • 21. Key Players: Financial Action Task Force (FATF), 1989 Revised in 2013, presents “FATF Standards that are relevant when promoting financial inclusion and explicit the flexibility that the Standards offer, in particular the risk-based approach (RBA), enabling jurisdictions to craft effective and appropriate controls.” 21
  • 22. Key Players: G20, 1999 G20 Toronto Summit June 2010, issues Principles for Innovative Financial Inclusion: • Principle 8: Emphasizes proportional framework. • Principle 9: Emphasizes support for appropriate, flexible, risk- based framework; agents; e-money; interoperability. 22
  • 23. Key Players, Alliance for Financial Inclusions (AFI), 2008 Signed in 2011 by 80+ institutions agreeing to make commitments in 4 broad areas to increase financial inclusion including “implementation of a proportional framework” of regulations . “Balancing Integrity and Inclusion” 23
  • 24. Bank vs. Non-Bank Models of MM Bank based Clients have claim to value indicated in mobile money system Value is linked to individual retail accounts in core banking system (may or may not be “real time”) Bank utilizes funds in accordance with regulations, i.e. they intermediate Funds are “as safe” as the bank is sound provided the two systems are adequately integrated Non-bank based Clients have claim to electronic value Electronic value is issued by non-bank, and is usually backed 100% by one or more bank accounts Funds must be clearly delineated as property of customers and not of issuer Funds may not be used by non-bank, but Funds may be used by banks in accordance with regulations and terms Funds are “as safe” as the bank is sound provided the 100% backing is controlled and maintained 24
  • 25. Broad Regulatory Issues: Prudential & Systemic Issues Safety of funds Transaction speed and security Settlement procedures Anti Money Laundering (AML)/Combatting the Financing of Terrorism (CFT) Customer Due Diligence/Know Your Customer 25
  • 26. Key Regulatory Issue: Anti Money Laundering (AML)/Combatting the Financing of Terrorism (CFT) Consensus proposes a risk-based approach proportionate to perceived risk Contrary to cash, mobile transactions provide electronic records Monitoring continues to put limits on transactions regarding suspicious activity, volume, frequency, number of accounts 26
  • 27. Key Regulatory Issue: AML/CFT “Little evidence thus far of money laundering or terrorist financing using mobile money: There have been no cases of money laundering through mobile money services in countries where these services have thrived, and there have been no reports of terrorist financing. World Bank research indicates that, so far, mobile money has been of little interest to criminals or terrorists compared to other payment channels such as cash or the Internet. Although no payment system can be 100% free of abuse, it is important to gather data that measures the attractiveness of a particular system to criminal activity.” Simone di Castri, “Mobile Money: Enabling Regulatory Solutions,” GSMA: Mobile Money for the Unbanked, February 2013 27
  • 28. Key Regulatory Issue: Customer Due Diligence (CDD)/Know Your Customer (KYC) Consensus proposes a risk-based approach proportionate to perceived risk Where customer data cannot be reliably verified, apply alternative risk mitigation measures Example: in Fiji, people lack national identity cards, MNOs and agents allowed to use a “referee letter” to verify customer identity 28
  • 29. Key Regulatory Issue: CDD/KYC “Specifically, if mobile money is to contribute to financial inclusion, regulators have to consider that the average mobile money customer, particularly the unbanked, maintains a low account balance, conducts relatively small transactions, and, in many countries, lacks a permanent address and/or government-issued identification. The average value of peer-to-peer (P2P) transfers is US$35 per transaction.” Simone di Castri, “Mobile Money: Enabling Regulatory Solutions,” GSMA: Mobile Money for the Unbanked, February 2013 29
  • 30. Key Regulatory Issue: New Challenges to Consumer Protection Distance btwn Providers & Customers Third Party/Agent Roles Tech Solutions for data security & privacy Transparency on redress mechanisms & pricing 30
  • 31. Key Regulatory Issue: Consumer Protection Mechanisms Agent role to be clearly defined and agents monitored and liable to maintain funds and customer privacy Dispute resolution policies and procedures robust for call center support, claims of loss or fraud Transparent pricing and real time confirmation of transactions 31
  • 32. Key Regulatory Issue: Third Parties & Agent Networks To achieve financial inclusion banks & non-banks need to outsource to lower costs (KYC, collection & disbursement) Most regulators allow provider & third parties to negotiate freely, but require roles & responsibilities to be clearly and contractually defined based on set standards Provider is liable for selecting, training, and monitoring agents with mitigating procedures proportionate to risk 32
  • 33. What people are saying… On creating a level playing field to leave the choice to users: “From the regulator’s perspective, the concerns involved in allowing mobile operators to offer payment services can be easily addressed. In fact, there is not a trade-off between the participation of financial intermediaries and mobile operators. [...] In the end, by allowing all types of participants, the financial regulator leaves the market to figure out what works best, and the customers will benefit from the result.” Narda Sotomayor Head of the Microfinance Analysis Department Superintendencia de Banca, Seguros y AFP, Peru 33
  • 34. What people are saying… On mobile money and monetary policy: “Although electronic money has become more important in some countries, the impact of these developments on the composition of the monetary base is considered negligible thus far. Moreover, even if the usage of electronic money were to expand massively, there would still be various ways in which central banks could preserve a tight link between electronic money and central bank money and to keep control over short-term rates. Most central banks therefore judge that the influence of innovations in retail payments on monetary policy is neutral or of low importance.” Working Group on Innovations in Retail Payments Committee on Payment and Settlement Systems Bank for International Settlements (BIS) 34
  • 35. mMoney ≠ Bitcoin • mMoney – Regulated by gov’t/central bank – Tied to gov’t-backed currency – Use requires registration, due diligence, and systems for monitoring suspicious activity – Use produces multiple transaction records • BitCoin – Unregulated – Decentralized, P2P network virtual currency – Exists in parallel to gov’t- backed currency – Anonymity possible 35
  • 36. Sources Sources Referenced: 1. Safaricom Ltd, FY 2013 Presentation, http://www.safaricom.co.ke/images/Downloads/Resources_Downloads/FY_2013_Results_Presentation.pdf 2. Ignacio Mas and Amolo Ng’weno, Bill & Melinda Gates Foundation, 2009, “Three keys to M-PESA’s success: Branding, channel management and pricing”, http://www.gsma.com/mobilefordevelopment/wp- content/uploads/2012/03/keystompesassuccess4jan69.pdf 3. The Kenyan Journey to Digital Financial Inclusion and infographic, GSMA, 2013, http://www.gsma.com/mobilefordevelopment/mmu- releases-infographic-on-the-kenyan-experience-with-mobile-money 4. FATF, “Anti-Money Laundering and Terrorist Financing Measures and Financial Inclusion, 2013, http://www.fatf- gafi.org/topics/financialinclusion/documents/revisedguidanceonamlcftandfinancialinclusion.html 5. Alliance for Financial Inclusion, “Bringing Smart Policies to Life, The basics: Mobile phone financial services”, 2010 http://www.afi- global.org/policy-areas/balancing-integrity-and-inclusion 6. Simone di Castri, “Mobile Money: Enabling Regulatory Solutions,” GSMA: Mobile Money for the Unbanked, February 2013, available at http://www.gsma.com/mobilefordevelopment/wp-content/uploads/2013/02/MMU-Enabling-Regulatory-Solutions-di-Castri-2013.pdf 7. PFIP/UNCDF, “Some thoughts on mobile money regulation” internal presentation prepared for Bank of Papua New Guinea, 2011. 8. G20, Toronto Summit, 2010, “Principle of Financial Inclusion” http://www.g20.utoronto.ca/2010/to-principles.html 9. Maya Declaration signed in 2011: http://www.afi-global.org/maya-declaration 10. Ignacio Mas and Tonny Omwansa, NexThought Monday - A Close Look at Safaricom’s M-Shwari: Mobile, yes, but how ‘cool’ is it for customers?, December 10, 2012, http://www.nextbillion.net/blogpost.aspx?blogid=3050 36
  • 37. Sources Additional Sources Available: 10. USAID, “Mobile Financial Services Risk Matrix,” 2010, http://www.gsma.com/mobilefordevelopment/wp- content/uploads/2012/06/mobilefinancialservicesriskmatrix100723.pdf. 11. CGAP, “AML/CFT: Strengthening Financial Inclusion and Integrity,” August 2009, available at http://www.cgap.org/publications/amlcft-strengthening-financial-inclusion-and-integrity. 12. CGAP, “Protecting Branchless Banking Consumers: Policy Objectives and Regulatory Options,” http://www.cgap.org/publications/protecting-branchless-banking-consumers. 13. United Nations Conference on Trade and Development (UNCTAD), “Mobile Money for Business Development in the East Africa Community: A Comparative Study of Existing Platforms and Regulations,” UNCTAD, 2012, available at http://unctad.org/en/PublicationsLibrary/dtlstict2012d2_en.pdf. 14. Marina Solin and Andrew Zernan, “Mobile Money: Methodology for Assessing Money Laundering and Terrorist Financing Risks,” GSMA: Discussion Paper, January 2010, available at http://www.mymms.nfcmobilemoneysummit.com/mobilefordevelopment/wp-content/uploads/2012/06/amlfinal58.pdf. 15. Beth Jenkins, “Developing Mobile Money Ecosystems,” IFC, 2008, available at http://www.hks.harvard.edu/m- rcbg/papers/jenkins_mobile_money_summer_008.pdf. 16. (Great chart on page 8 on stakeholders and their assets/capabilities, incentives, roles, and constraints.) 17. BFA (for Better Than Cash Alliance), “The Journey Toward ‘Cash Lite’: Addressing Poverty, Saving Money and Increasing Transparency by Accelerating the Shift to Electronic Payments,” Better Than Cash Alliance, 2012, available at http://betterthancash.org/wp-content/uploads/2012/09/BetterThanCashAlliance-JourneyTowardCashLite.pdf. 18. Tim Hatt, Martin Harris, and Adam Wills, “Scaling Mobile for Development: A Developing World Opportunity,” GSMA: Mobile for Development Intelligence, Interim Report, April 2013, https://mobiledevelopmentintelligence.com/insight/Scaling_Mobile_for_Development:_A_developing_world_opportun ity. 19. Claire Pénicaud, “State of the Industry: Results from the 2012 Global Mobile Money Adoption Survey,” GSMA: Mobile Money for the Unbanked, available at http://www.gsma.com/mobilefordevelopment/wp- content/uploads/2013/02/MMU_State_of_industry.pdf. 37