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White Paper: Mobile Money Transfer
International Remittance Considerations for Mobile
Network Operators
February 2013
Mobile Money Transfer
GSMA White Paper
Mobile network operators (MNOs) are becoming
increasingly interested in offering international
remittances, often as a new transaction type added
to an existing mobile money service currently
providing domestic transactions. This paper reviews
the international remittance market, the opportunity
for MNOs, and the technical, legal, commercial,
and operational considerations for any new player
to this market. The paper also introduces Mobile
Money Transfer, an open business model developed
by the GSMA to accelerate MNO market entry and
participation in a meaningful and value adding role.
Summary
International Remittance Considerations for Mobile Network Operators
Introduction1
Benefits of International Remittances  2
International Remittance Service Structure 3
	 1. Sending Agent 3
	 2. Intermediation Service  3
	 3. Receiving Agent  3
Key Regulatory Considerations 5
Foreign Exchange Considerations 6
International Remittances Service Design  7
	 MTO or Direct Connection 7
	 Enhanced Customer Due Diligence  7
	 Unregistered Recipients  7
	 Exchange Rate and Quotation  7
	 Sending International Remittances  7
	 Receiving International Remittances  8
	 Real Time Transactions  8
	 Reporting Requirements  8
	 Business Processes  9
	Service Evolution  9
Impact on Mobile Money Agents 10
Customer Marketing Considerations 10
Selecting International Remittance Partners  11
A Common Approach to International Remittances 12
References  12
Contents
1
Mobile Money Transfer
GSMA White Paper
International remittance is a substantial and growing
market worldwide. Global transaction value is
expected to reach $615 billion by 2014, and around
75% of the remittance flow will be from high-
income countries to emerging markets(1)
. In addition
to these official figures, unofficial remittances
are estimated to be at least 50 per cent larger than
recorded flows(2)
. It is a business opportunity that
many mobile network operators (MNOs) are keen
to explore, particularly those with a live domestic
mobile money service. Indeed some MNOs already
have an active international remittance service, or
are seeking to launch soon. In the MMU’s global
mobile money adoption survey, which gathered data
from 78 different live mobile money deployments in
2012, over 20% of these mobile money services were
already offering international remittances.
In this paper, we explore how will benefit after  the
word  business of MNO participation in international
remittance business for all participants in the
ecosystem:
„„ Customers will benefit from the convenience of
sending and receiving international remittances
directly from/to their mobile handset.
„„ MNOs will derive direct revenues from
international remittance transactions, as well as
indirect benefits from reduced customer churn;
they will also benefit from an uplift in revenue
as recipients use these funds to perform other
financial transactions from their mobile wallets.
„„ Financial services partners, such as money transfer
operators (MTOs) which offer conventional
money transfer services (usually through agents
such as forex bureaux, banks and post offices), will
benefit from an extended reach into the MNO’s
customer base, creating an uplift in transactions,
and (for some) an opportunity to offer additional
financial services.
„„ National financial regulators with imperatives
to increase financial inclusion and legitimacy
can leverage the reach and transparency of
information and communications technology that
is a characteristic of mobile(3)
to turn a substantial
proportion of a grey market legitimate.
A successful approach to mobile-enabled
international remittance requires collaboration
amongst these ecosystem participants. In addition,
the international remittance sector is mature. By
contrast, the mobile money sector is relatively new
and there are no industry standards for best practice
in technical delivery or service operation. The MTOs
to which most mobile money services will connect to
provide mobile international remittances have well
established technologies, procedures, and business
rules with which the mobile money services must
interact.
This paper lays out the key considerations for any
MNOs considering provision of an international
remittance service.
Mobile Money Transfer (MMT), an open business
model developed by the GSMA is a proposed
industry solution that will accelerate MNO
participation in international remittances in a value
adding role that will benefit all stakeholders. It
is assumed that the MNO will already operate a
domestic mobile money service, so henceforth we
can use the term mobile money operators (MMOs).
By adopting this term, we can extend the definition
to entities that do not operate a mobile network.
Introduction
2
International Remittance Considerations for Mobile Network Operators
MMOs providing international remittance services will derive a range of benefits;
Sending Market Benefits Receiving Market Benefits
IR transaction fee, potentially including a share of any
foreign exchange benefit
Potential share of the international remittance transaction fee
and any foreign exchange benefit
Increased value in the mobile money bank account
(although this may only be for a short period prior to
overnight settlement following a customer remittance)
Injection of money into the mobile money bank account,
increasing the interest income (where applicable) and making
more e-money available with which customers can perform
fee generating transactions, such as withdrawals
Increased utility of the mobile money service Operational cost saving by getting funds into the customer
account without the direct cost of agent deposit fees
Increased utility of the mobile money service
The benefits to the customer of using their mobile money account for international remittances are similar to
those for domestic remittances:
„„ Reduced cost of transacting: Market experience suggests that mobile money transactions tend to be
competitively priced compared to the alternatives.
„„ Easy access to agent outlets: A large agent network, established for a domestic service, makes it much more
convenient for senders to put cash into, or recipients to withdraw cash from, their mobile money accounts.
„„ Fast, simple transactions: It is relatively fast and easy to send or receive money via mobile.
„„ Secure transactions: mobile money services are safer than informal means of money transfer.
„„ Reduced reliance on cash with its associated risks(4)
.
Domestic mobile money services have become successful based upon combinations of these elements. They
are no less appealing for international remittance transactions, particularly in emerging markets where the
conventional payments infrastructure can be limited.
Benefits of International Remittances
3
Mobile Money Transfer
GSMA White Paper
There are three basic components in the provision of
international remittance services:
1. Sending Agent
An organisation which takes funds from the “sending
customer” in the country of origin and transfers
them. Conventional international remittance services
use an agent of an MTO and are typically forex
bureaux, post offices, bank branches, and approved
retail outlets. MMOs acting as sending agents for
international remittances can do this by providing a
menu item on their customers’ handset.
2. Intermediation Service
An organisation which provides connectivity
(switching) between sending and receiving
organisations. Their service includes clearance and
settlement between correspondent banks in both
countries. In addition, they usually provide the
foreign exchange (or forex) infrastructure. There
are currently many MTOs providing this service.
Some offer an end-to-end service with agents in both
sending and receiving countries. Others provide a
hub which connects independent agents in both
countries. Some international banks also provide this
service. Many MTOs specialise in specific remittance
corridors.
Some MMOs may choose to provide the MTO
function themselves to reduce costs, particularly
when there is a close relationship between the agents
in both countries, for example when two MNOs in the
same corporate group wish to provide international
remittances; however, they still need to source the
forex (both rates and settlement) via conventional
means.
International Remittance Service Structure
3. Receiving Agent
An organisation that receives the funds from an
MTO and delivers them to the “receiving customer”.
Conventional international remittance services use
the same agents for sending and receiving funds.
MMOs acting as receiving agents for international
remittances can do this by transferring the funds
directly to a customers’ mobile money account.
MMOs wishing to participate in international
remittances can choose between several business
structures. In most markets they must decide
whether they wish to participate as MTOs for sending
or for receiving remittances. In some markets, there
may be sufficient traffic to support both sending
and receiving funds, but this is not common(5)
.
It is probable that for the foreseeable future the
correspondent leg of the transaction, whether
sending or receiving, will mainly be provided by a
conventional MTO agent, although as mobile money
services develop worldwide, it is likely that there
will be increasing numbers of transactions between
MMOs acting as MTO agents.
The MMO must decide whether to partner with one
or more MTOs or to provide the service in-house,
although an in-house service will still access forex
services via a specialist third party, usually a bank.
These decisions will determine the operational
structure, as illustrated in Figure 1.
Figure 1: Organisations Involved in the International
Remittances Service
MTO
MMO
SENDER RECIPIENT
1) Send via conventional MTO agent and receive into MM account
MMO RECIPIENTSENDER
2) Send from MM account and receive from a conventional MTO agent as cash
MMO
SENDER
MMO
RECIPIENT
3) Send from MM account and receive into MM account
MTO AGENT
MTO AGENT
OR
MTO
FOREX
MTO
4
International Remittance Considerations for Mobile Network Operators
The types of operational structure fall into the
following three groups:
1) Send via MTO agent and receive into mobile
money account: The sender uses a conventional
international remittance service to put funds in. The
recipient receives these funds into his mobile money
account.
For example, a sender in Saudi Arabia may use Western Union
to send money directly to a Filipino recipient G-CASH or
Smart Money account.
2) Send from mobile money account and receive
via a conventional international remittance service:
The sender uses his account to send funds. Banked
recipients have the money delivered to their bank
account; unbanked recipients are instructed to collect
cash at an MTO agent.
For example, a sender in Malaysia may use his CelcomAircash
account to send money to a recipient in Indonesia who
collects his cash at the local post office.
3) Send from mobile money account and receive into
mobile money account: The sender uses his sending
country mobile money service to send funds to a
recipient. The recipient receives these funds directly
into his local mobile money account.
For example a sender in Japan can transfer e-money from his
NTT DoCoMo account to a recipient Smart Money account in
the Philippines.
It is often a legal requirement that the funds
moved between two countries by any international
remittance service are accompanied by a “real”
movement of currency between the two participating
markets as settlement within a reasonable timeframe.
It is normally the responsibility of the MTO to ensure
that reconciliation and settlement between all parties
takes place. The MTO also administers periodic
settlement of any outstanding fees or commission
between parties.
5
Mobile Money Transfer
GSMA White Paper
Whilst there are no international laws that regulate
international remittance services, all countries are
subject to international standards agreed between
governments and to international regulatory
principles which they are expected to reflect in their
domestic legislation. The most important set of
standards are the Financial Action Task Force (FATF)
recommendations(6)
.
In addition, the Committee for Payments and
Settlements (CPSS) and the World Bank (WB) have
set out some general principles for international
remittances which incorporate regulatory
recommendations. Since the CPSS works under the
auspices of the Bank for International Settlements
(BIS) these are known as the WB-BIS Principles(7)
.
An MMO seeking to provide international
remittances must investigate the domestic regulatory
environment. Much of the regulation developed
in recent years applies to domestic mobile money
services as well as to international remittances
and so should be familiar(8)
. Most of the FATF
recommendations apply to governments and
legislators, but some of them apply directly to MTOs
and thus by association to the participating MMOs.
The main regulations, which are in addition to any
specific domestic controls, can be summarised as
follows:
„„ MMOs must establish procedures to ensure
they know their customers. For international
remittances this implies a requirement that the
MMO confirms that its service partners also
comply. Know your customer (KYC) procedures
vary widely between countries.
„„ The due diligence required for domestic mobile
money services also applies, including transaction
monitoring, customer checks against watch-lists
and screening for politically exposed persons.
Appropriate actions must be taken as required.
„„ MMOs must carry out due diligence on all of
their international remittance partners, including
MTOs and other intermediary service providers.
This must include:
„„ Assessing the reputation of the institution and
the quality of its supervision.
Key Regulatory Considerations
„„ Assessing its anti-money laundering (AML)
and combating the financing of terrorism (CFT)
controls.
„„ Obtaining approval from senior management.
„„ Understanding each party’s responsibilities.
„„ The MMO will be subject to similar due diligence
checks by their international remittance partners,
and must have procedures in place to support this.
„„ TheMMOisrequiredtobelicensedby,orregistered
with, the domestic regulatory authorities.
„„ Any agent for the MMO must be licensed or
registered, and the MMO must maintain an
accurate list of agents.
„„ It is probable that the domestic financial regulator
will require that the MMO be subject to an AML/
CFT-specific risk assessment, and as a result of any
findings require additional measures to manage
and mitigate those risks.
„„ MMOs in higher-risk countries, or who are
engaged in international remittances with
higher-risk countries, must carry out enhanced
due diligence checks for both registrations and
transactions. Additional countermeasures may
be required as advised by their national financial
regulator.
MMOs should review all recommendations relating
to international remittances with their national
financial regulator to ensure that they meet their
obligations prior to launch.
6
International Remittance Considerations for Mobile Network Operators
Foreign exchange, or forex, is the process by which
money in one currency is exchanged for a similar
value in another, according to a published exchange
rate. Forex traders buy and sell a currency at different
rates, and the difference between the rates is the
“spread”. Financial institutions including banks and
MTOs will seek to profit from exchanging currencies
by exploiting the spread and also by charging
commission. The buy and sell prices, and therefore
the spread, are not fixed by any central authority, but
are a reflection of the transaction value. Forex traders
who deal in millions of dollars every day will benefit
from a small spread, whilst retail customers will
pay a much larger spread. The exchange rate of the
service for the customer can be improved, and thus
its competitiveness enhanced, by agreeing a small
spread with the forex provider.
The MMO may be able to negotiate a share of the
revenue arising from the spread with their forex
provider, unless local regulation prevents this. Other
forms of revenue depend upon whether they are
acting as sending or receiving MTO agents.
Foreign Exchange Considerations
7
Mobile Money Transfer
GSMA White Paper
International Remittances Service Design
The MMO has a number of decisions to make about
the user experience and how their international
remittance service should operate.
MTO or Direct Connection
The service design depends upon the type of
international remittance service required. If the
MMO needs a single or very limited number of
connections, it may be appropriate to consider a direct
relationship between sending and receiving agents,
with forex managed for example by an international
bank. However, it will normally be the case that one
or more MTOs will be engaged, in order to achieve
scale across multiple partners in many markets. The
MTOs will have a set of technical and operational
requirements for integration to the mobile money
service, although these may need some modification
depending upon the service design.
Enhanced Customer Due Diligence
Customer due diligence (CDD) and KYC procedures
vary widely between countries, and may be “tiered”
if domestic regulations allow, so that a customer’s
registration tier is determined by the quantity
and quality of KYC data gathered. A customer’s
transaction and account balance limits are then
governed by their registration tier. In some markets
all international remittance customers are required
to have higher tier registrations – that is, higher
quality KYC data must be gathered. International
remittances transaction values are significantly
higher than domestic remittances, so for both sending
and receiving markets it may be necessary for the
MMO to gain additional KYC information about
their customers and increase their registration tier
so that their accounts are able to receive the required
funds.
Unregistered Recipients
It is common in many markets for some recipients
of domestic remittances to be “unregistered”; that
is, they do not have a mobile money account, and
simply receive a Short Message Service (SMS) or
“text” voucher which they can use to cash out at an
agent. Although the FATF recommendations appear
to prohibit unregistered customers from receiving
international remittances, it is sometimes permissible
if the recipient presents suitable identification data
at the time of withdrawal. If a sender attempts to
send funds to an unregistered customer, there are
a number of options that can be designed into the
service, including declining the transaction. A
more satisfactory response is for the mobile money
service to advise the customer that he has been
sent money and that, if he registers, the funds will
be automatically transferred to his mobile money
account. As some recipients are unable to register for
a range of reasons, it is also necessary to provide the
option that he can collect his money by conventional
means at an MTO agent.
Exchange Rate and Quotation
For any foreign currency exchange, the sender must
be made aware of the exchange rate used to convert
from a specified amount in his home currency to the
net amount that will be provided in the destination
currency. Therefore the first part of any transaction
must be to provide this quotation by an appropriate
mechanism. This may be a manual process, such as
requesting the information from a call centre; the
information could be provided on line for customers
with suitable access; or the MMO may provide a
handset application that the customer can use to
request the information (for example by SMS) before
starting the transaction. Alternatively, it may be
given as the first part of the transaction, providing
that it can be cancelled before completion if the
customer dislikes the quotation.
Sending International Remittances
After the quotation the sender can choose to proceed
with the transaction using his mobile money menu.
International remittances transactions tend to require
more information about the recipient than just
the mobile number (MSISDN) used for domestic
transactions. Depending upon local regulation, the
sender will usually need to provide a name, and
in many case an address and/or other personal
information. Entering this level of detailed text on
a simple handset can be inconvenient and prone to
error. Further, depending upon the Mobile Money
(MM) channel used, this can present technical
problems – for example, senders, particularly the less
literate, may experience “time out” whilst entering
the additional data; and many USSD services do not
currently support text, only numbers.
8
International Remittance Considerations for Mobile Network Operators
Ideally the sender should be able to register the
recipient details in advance, by means of some
process that is outside the transaction itself, and
during a transaction simply choose the correct
recipient from their registered list of recipients. This
registration process may be performed by a customer
care representative or MM agent, or by the customer
on line or using a handset application.
Receiving International Remittances
Registered mobile money recipients should receive
an SMS or some other notification of the in-bound
remittance confirming the transaction details
including country of origin. The funds should enter
their account and immediately be available for use.
Unregistered recipients may need to register before
they can receive their funds, or visit an MTO agent
for cash.
Real Time Transactions
Mobile money customers expect transactions to
happen in real time. This can be achieved simply in
a closed loop, domestic mobile money system where
all the money is in one bank (control) account, but
for international remittances the “real” money does
not reach the receiving MMO bank account until
after overnight clearance and settlement. In a typical
model, the sending MMO would remove the funds
from the sender’s account in real time, and would be
expected to transfer them to a separate mobile money
“IR receipt account”. These funds are aggregated
for transfer each night, when the money in the bank
is transferred to the MTO / correspondent bank
account.
The receiving MMO can simply design their service
such that there is a delay in the recipient getting
access to their money, though this may not meet
customer expectations, since the funds transfer may
take several days. A common alternative is for the
receiving MMO to pre-fund an “IR funding account”
within their mobile money service, from which the
recipient is paid in real time, with the e-money in this
account being regularly replenished as the settlement
funds reach their bank account.
Whilst there is some cost associated with pre-
funding, the commercial risks are low and can be
managed using established banking practices, as
correspondent bank transfers are well established
and regulated.
Reporting Requirements
As well as the standard reports needed to run the IR
business, local regulation may require an additional
number of IR-specific reports, such as reconciliation
between the MM IR service, the MTO, and the inter-
bank settlement amount. Separately, IR transactions
must be monitored for suspicious activity, and
anything anomalous reported to the proper domestic
authorities.
9
Mobile Money Transfer
GSMA White Paper
Business Processes
IR business processes will be in addition to any
existing domestic MM service procedures. Some new
IR processes will be required, such as reconciliation
and settlement between the MMO and MTO;
reconciliation between the IR transactions in the MM
service and the funds moved to or from the MM bank
account; revenue share procedure; and administering
changes to forex rates.
Service Evolution
As the international remittance service will
undoubtedly evolve over time, it needs to be future-
proof as far as possible for the addition of new
markets, MTOs, use cases, and even new services
such as overseas bill payment and vouchering. As the
smart phones adoption grows, the user experience
can be improved, particularly for senders who may
have difficulties with a text based interfaces.
Figure 2: Transaction Between Accounts During a Mobile-to-Mobile International Remittance Transaction
SENDING BANK
SENDING MMO
RECEIVING BANK
RECEIVING MMO
SENDING COUNTRY RECEIVING COUNTRY
SENDING BANK
COLLATERAL
ACCOUNT
RECEIVING BANK
COLLATERAL
ACCOUNT
1. e-money moved to IR
receipt account
2. Instruction sent to
receiving MMO
3. e-money moved from IR
funding account
4. e-money removed and
bank instructed to debit
receiving bank collateral
account
5. Funds moved to
receiving bank
collateral account
6. e-money created and
moved to IR funding
account
REAL TIME
TRANSACTIONS
OVERNIGHT
CLEARANCE
10
International Remittance Considerations for Mobile Network Operators
Mobile money agents are not directly involved with
or affected by international remittance transactions,
but there are some indirect implications for them. The
most important is liquidity. International remittances
transactions tend to be substantially higher in value
than domestic transfers. Consequently, international
remittance customers place a far greater burden on
the agent cash flow: in sending markets the agents
need more e-money to service the sender’s deposits,
whilst in receiving markets the agents need extra
cash for recipients to withdraw. As the service
grows, the liquidity of the agents must be monitored
and carefully managed. The principles of agent
management are much the same as those required
for a domestic service(8)
.
Another potential impact may be the need to
enhance the KYC information about an international
remittance customer. If tiered registration is new
to the market, mobile money agents performing
this service will need to be trained and processes
created for collecting and forwarding customer
documentation.
It may be decided in some sending markets that the
agent should perform the transaction on behalf of the
customer. This may be due to practical limitations
in senders entering the required information on
their handset, due to either technical or literacy
constraints. In this case, the international remittance
sending service and business case would need to be
redesigned.
The task of marketing international remittances to
customers is complicated by the need to inform
and educate in both the sending and receiving
markets. It is normally the senders who choose the
remittance service, as they both initiate and pay for
the transactions, though this may not be the best
route for recipients. For MMOs in sending markets,
the customer needs to be made aware of the service,
how to access it and how to use it. They also need
reassurance that the recipient will be able to gain
access to their funds, so it will probably be necessary
to provide communication and education in the
receiving markets. Typically the diaspora of senders
is a subset of the total customer base, and may not
be fluent in the local language. If the MMO is in a
receiving market, the task becomes more challenging,
as they need to communicate their service to senders
in a country in which they may have no business
presence. Further, as mobile money is a relatively
new business sector, the sender overseas may be
unaware of the recipient service.
Many MMOs rely on the MTO to market the service
in the “other” market, although with largely limited
success to date. There are other ways that the
marketing challenges can be tackled:
„„ In sending markets, the geographical distribution
of a diaspora is likely to be different from the
general population distribution. Market research
could include call record analysis to identify
pockets of potential senders for regional marketing
initiatives. By targeting communities by their
country of origin, advertising may be delivered
in their native tongue. Many migrant workers
in some markets are unbanked, so the benefits to
them of using the mobile money service to send
money home is greater.
„„ In receiving markets, the target customers are
more likely to be distributed across the country.
Using permission based marketing methods, call
records may identify customers more likely to
be recipients of IR, and they can be targeted for
awareness and education about the IR service,
and to influence their senders to send directly to
their MM account. Incentives for the recipients
whose senders use the service might include, for
example, free airtime, and free calls to the sending
country.
Impact on Mobile Money Agents Customer Marketing Considerations
11
Mobile Money Transfer
GSMA White Paper
Partners may be MTOs, MMOs in other markets,
and other financial organisations such as banks.
Choosing suitable partners for an international
remittance service depends upon the objectives of the
service, for example: whether the main opportunity
is to send or receive; which are the priority markets;
and which MTO agents within each market will
provide the required reach. The range of potential
partners and the complexity of the relationships
can be illustrated in a stakeholder map, such as that
presented in Figure 3.
Figure 3: Stakeholder Map
If an MMO perceives significant and immediate
opportunity in multiple markets, it is likely that
partnering with an MTO is the best solution unless
the MMO belongs to a group with a presence in each
of these markets. If they have this presence or if
requirement is more limited, for example connecting
two MM services owned by the same group in
different countries, an in-house solution may be
developed using a hub. However, in most cases
it is expected that an MTO will be used for forex,
connectivity, and financial settlement.
Selecting International Remittance Partners
Agencies
Bank Branches
Post Offices
Western Union
Agents,
Moneygram
Agents,
others
MNOs
Vodafone
Celcom
Qtel
Etiasalat
others
Retail Banks
Russian Standard
Bank,
DBS,
others
Hubs
Ericsson
MFIC
BICS
EDCH
others
Switches
MasterCard
MoneySend
others
Agencies
Bank Branches
Post Offices
Western Union
Agents,
Moneygram
Agents,
others
MNOs
Digicel
Globe GCash
MTN
Vodafone
others
Retail Banks
Russian Standard
Bank,
DBS
others
Forex and Settlement
Barclays
Citibank
Standard Chartered
others
MTOs
Western Union
Moneygram
others
Funds In Domestic Service IR Hub / Link Domestic Service Funds Out
12
International Remittance Considerations for Mobile Network Operators
This paper describes a complex and well-established
international remittance market into which many
MNOs are considering entry. Few MNOs are
currently active in this space and many that are
planning to launch services have limited experience
in the range of specialist capabilities required. To
assist MNOs to launch mobile enabled services, the
GSMA has developed “Mobile Money Transfer”
(MMT) an open business model which includes:
„„ MMT Toolkit: a collection of resources to assist
MNOs in strategic decision making and practical
implementation of new services.
„„ MMT Specifications - procedures and technical
interface specifications to enable MNOs and
international remittance partners to connect in an
efficient manner. MMT Specifications is supported
by GSMA Working Groups to ensure that this
industry solution is evolves in line with market
requirements.
For more information about these resources or about
participation in international remittances business in
general, please contact: mmt@gsma.com.
A Common Approach to International Remittances
1) World Bank Migration  Development Brief 18 [WB-MDB 18: April 23, 2012].
2) IMF publication: Remittances: Funds for the Folks Back Home http://www.imf.org/external/pubs/ft/fandd/ basics/
remitt.htm.
3) Mobile Money: Enabling Regulatory Solutions. GSMA Mobile Money for the Unbanked (MMU), January 2013.
4) Mobile Money: Enabling Regulatory Solutions. GSMA Mobile Money for the Unbanked (MMU), January 2013.
5) The World Bank T4 Remittance Estimates 2010.
6) “International Standards on Combating Money Laundering and the Financing of Terrorism and Proliferation - the
FATF Recommendations”, FATF, 16th February 2012.
7) “General principles for international remittance services”, World Bank and BIS/CPSS, January 2007. Available at
http://www.bis.org/publ/cpss76.pdf.
8) Mobile Money: Enabling Regulatory Solutions. GSMA Mobile Money for the Unbanked (MMU), January 2013.
Images kindly supplied by GSMA Mobile for Development.
References
For further information please contact
mmt@gsma.com
GSMA London Office
T +44 (0) 20 7356 0600
February 2013

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Mobile Money Transfer : International Remittance Considerations for Mobile Network Operators (GSMA)

  • 1. White Paper: Mobile Money Transfer International Remittance Considerations for Mobile Network Operators February 2013
  • 2. Mobile Money Transfer GSMA White Paper Mobile network operators (MNOs) are becoming increasingly interested in offering international remittances, often as a new transaction type added to an existing mobile money service currently providing domestic transactions. This paper reviews the international remittance market, the opportunity for MNOs, and the technical, legal, commercial, and operational considerations for any new player to this market. The paper also introduces Mobile Money Transfer, an open business model developed by the GSMA to accelerate MNO market entry and participation in a meaningful and value adding role. Summary
  • 3. International Remittance Considerations for Mobile Network Operators Introduction1 Benefits of International Remittances 2 International Remittance Service Structure 3 1. Sending Agent 3 2. Intermediation Service 3 3. Receiving Agent 3 Key Regulatory Considerations 5 Foreign Exchange Considerations 6 International Remittances Service Design 7 MTO or Direct Connection 7 Enhanced Customer Due Diligence 7 Unregistered Recipients 7 Exchange Rate and Quotation 7 Sending International Remittances 7 Receiving International Remittances 8 Real Time Transactions 8 Reporting Requirements 8 Business Processes 9 Service Evolution 9 Impact on Mobile Money Agents 10 Customer Marketing Considerations 10 Selecting International Remittance Partners 11 A Common Approach to International Remittances 12 References 12 Contents
  • 4. 1 Mobile Money Transfer GSMA White Paper International remittance is a substantial and growing market worldwide. Global transaction value is expected to reach $615 billion by 2014, and around 75% of the remittance flow will be from high- income countries to emerging markets(1) . In addition to these official figures, unofficial remittances are estimated to be at least 50 per cent larger than recorded flows(2) . It is a business opportunity that many mobile network operators (MNOs) are keen to explore, particularly those with a live domestic mobile money service. Indeed some MNOs already have an active international remittance service, or are seeking to launch soon. In the MMU’s global mobile money adoption survey, which gathered data from 78 different live mobile money deployments in 2012, over 20% of these mobile money services were already offering international remittances. In this paper, we explore how will benefit after  the word  business of MNO participation in international remittance business for all participants in the ecosystem: „„ Customers will benefit from the convenience of sending and receiving international remittances directly from/to their mobile handset. „„ MNOs will derive direct revenues from international remittance transactions, as well as indirect benefits from reduced customer churn; they will also benefit from an uplift in revenue as recipients use these funds to perform other financial transactions from their mobile wallets. „„ Financial services partners, such as money transfer operators (MTOs) which offer conventional money transfer services (usually through agents such as forex bureaux, banks and post offices), will benefit from an extended reach into the MNO’s customer base, creating an uplift in transactions, and (for some) an opportunity to offer additional financial services. „„ National financial regulators with imperatives to increase financial inclusion and legitimacy can leverage the reach and transparency of information and communications technology that is a characteristic of mobile(3) to turn a substantial proportion of a grey market legitimate. A successful approach to mobile-enabled international remittance requires collaboration amongst these ecosystem participants. In addition, the international remittance sector is mature. By contrast, the mobile money sector is relatively new and there are no industry standards for best practice in technical delivery or service operation. The MTOs to which most mobile money services will connect to provide mobile international remittances have well established technologies, procedures, and business rules with which the mobile money services must interact. This paper lays out the key considerations for any MNOs considering provision of an international remittance service. Mobile Money Transfer (MMT), an open business model developed by the GSMA is a proposed industry solution that will accelerate MNO participation in international remittances in a value adding role that will benefit all stakeholders. It is assumed that the MNO will already operate a domestic mobile money service, so henceforth we can use the term mobile money operators (MMOs). By adopting this term, we can extend the definition to entities that do not operate a mobile network. Introduction
  • 5. 2 International Remittance Considerations for Mobile Network Operators MMOs providing international remittance services will derive a range of benefits; Sending Market Benefits Receiving Market Benefits IR transaction fee, potentially including a share of any foreign exchange benefit Potential share of the international remittance transaction fee and any foreign exchange benefit Increased value in the mobile money bank account (although this may only be for a short period prior to overnight settlement following a customer remittance) Injection of money into the mobile money bank account, increasing the interest income (where applicable) and making more e-money available with which customers can perform fee generating transactions, such as withdrawals Increased utility of the mobile money service Operational cost saving by getting funds into the customer account without the direct cost of agent deposit fees Increased utility of the mobile money service The benefits to the customer of using their mobile money account for international remittances are similar to those for domestic remittances: „„ Reduced cost of transacting: Market experience suggests that mobile money transactions tend to be competitively priced compared to the alternatives. „„ Easy access to agent outlets: A large agent network, established for a domestic service, makes it much more convenient for senders to put cash into, or recipients to withdraw cash from, their mobile money accounts. „„ Fast, simple transactions: It is relatively fast and easy to send or receive money via mobile. „„ Secure transactions: mobile money services are safer than informal means of money transfer. „„ Reduced reliance on cash with its associated risks(4) . Domestic mobile money services have become successful based upon combinations of these elements. They are no less appealing for international remittance transactions, particularly in emerging markets where the conventional payments infrastructure can be limited. Benefits of International Remittances
  • 6. 3 Mobile Money Transfer GSMA White Paper There are three basic components in the provision of international remittance services: 1. Sending Agent An organisation which takes funds from the “sending customer” in the country of origin and transfers them. Conventional international remittance services use an agent of an MTO and are typically forex bureaux, post offices, bank branches, and approved retail outlets. MMOs acting as sending agents for international remittances can do this by providing a menu item on their customers’ handset. 2. Intermediation Service An organisation which provides connectivity (switching) between sending and receiving organisations. Their service includes clearance and settlement between correspondent banks in both countries. In addition, they usually provide the foreign exchange (or forex) infrastructure. There are currently many MTOs providing this service. Some offer an end-to-end service with agents in both sending and receiving countries. Others provide a hub which connects independent agents in both countries. Some international banks also provide this service. Many MTOs specialise in specific remittance corridors. Some MMOs may choose to provide the MTO function themselves to reduce costs, particularly when there is a close relationship between the agents in both countries, for example when two MNOs in the same corporate group wish to provide international remittances; however, they still need to source the forex (both rates and settlement) via conventional means. International Remittance Service Structure 3. Receiving Agent An organisation that receives the funds from an MTO and delivers them to the “receiving customer”. Conventional international remittance services use the same agents for sending and receiving funds. MMOs acting as receiving agents for international remittances can do this by transferring the funds directly to a customers’ mobile money account. MMOs wishing to participate in international remittances can choose between several business structures. In most markets they must decide whether they wish to participate as MTOs for sending or for receiving remittances. In some markets, there may be sufficient traffic to support both sending and receiving funds, but this is not common(5) . It is probable that for the foreseeable future the correspondent leg of the transaction, whether sending or receiving, will mainly be provided by a conventional MTO agent, although as mobile money services develop worldwide, it is likely that there will be increasing numbers of transactions between MMOs acting as MTO agents. The MMO must decide whether to partner with one or more MTOs or to provide the service in-house, although an in-house service will still access forex services via a specialist third party, usually a bank. These decisions will determine the operational structure, as illustrated in Figure 1. Figure 1: Organisations Involved in the International Remittances Service MTO MMO SENDER RECIPIENT 1) Send via conventional MTO agent and receive into MM account MMO RECIPIENTSENDER 2) Send from MM account and receive from a conventional MTO agent as cash MMO SENDER MMO RECIPIENT 3) Send from MM account and receive into MM account MTO AGENT MTO AGENT OR MTO FOREX MTO
  • 7. 4 International Remittance Considerations for Mobile Network Operators The types of operational structure fall into the following three groups: 1) Send via MTO agent and receive into mobile money account: The sender uses a conventional international remittance service to put funds in. The recipient receives these funds into his mobile money account. For example, a sender in Saudi Arabia may use Western Union to send money directly to a Filipino recipient G-CASH or Smart Money account. 2) Send from mobile money account and receive via a conventional international remittance service: The sender uses his account to send funds. Banked recipients have the money delivered to their bank account; unbanked recipients are instructed to collect cash at an MTO agent. For example, a sender in Malaysia may use his CelcomAircash account to send money to a recipient in Indonesia who collects his cash at the local post office. 3) Send from mobile money account and receive into mobile money account: The sender uses his sending country mobile money service to send funds to a recipient. The recipient receives these funds directly into his local mobile money account. For example a sender in Japan can transfer e-money from his NTT DoCoMo account to a recipient Smart Money account in the Philippines. It is often a legal requirement that the funds moved between two countries by any international remittance service are accompanied by a “real” movement of currency between the two participating markets as settlement within a reasonable timeframe. It is normally the responsibility of the MTO to ensure that reconciliation and settlement between all parties takes place. The MTO also administers periodic settlement of any outstanding fees or commission between parties.
  • 8. 5 Mobile Money Transfer GSMA White Paper Whilst there are no international laws that regulate international remittance services, all countries are subject to international standards agreed between governments and to international regulatory principles which they are expected to reflect in their domestic legislation. The most important set of standards are the Financial Action Task Force (FATF) recommendations(6) . In addition, the Committee for Payments and Settlements (CPSS) and the World Bank (WB) have set out some general principles for international remittances which incorporate regulatory recommendations. Since the CPSS works under the auspices of the Bank for International Settlements (BIS) these are known as the WB-BIS Principles(7) . An MMO seeking to provide international remittances must investigate the domestic regulatory environment. Much of the regulation developed in recent years applies to domestic mobile money services as well as to international remittances and so should be familiar(8) . Most of the FATF recommendations apply to governments and legislators, but some of them apply directly to MTOs and thus by association to the participating MMOs. The main regulations, which are in addition to any specific domestic controls, can be summarised as follows: „„ MMOs must establish procedures to ensure they know their customers. For international remittances this implies a requirement that the MMO confirms that its service partners also comply. Know your customer (KYC) procedures vary widely between countries. „„ The due diligence required for domestic mobile money services also applies, including transaction monitoring, customer checks against watch-lists and screening for politically exposed persons. Appropriate actions must be taken as required. „„ MMOs must carry out due diligence on all of their international remittance partners, including MTOs and other intermediary service providers. This must include: „„ Assessing the reputation of the institution and the quality of its supervision. Key Regulatory Considerations „„ Assessing its anti-money laundering (AML) and combating the financing of terrorism (CFT) controls. „„ Obtaining approval from senior management. „„ Understanding each party’s responsibilities. „„ The MMO will be subject to similar due diligence checks by their international remittance partners, and must have procedures in place to support this. „„ TheMMOisrequiredtobelicensedby,orregistered with, the domestic regulatory authorities. „„ Any agent for the MMO must be licensed or registered, and the MMO must maintain an accurate list of agents. „„ It is probable that the domestic financial regulator will require that the MMO be subject to an AML/ CFT-specific risk assessment, and as a result of any findings require additional measures to manage and mitigate those risks. „„ MMOs in higher-risk countries, or who are engaged in international remittances with higher-risk countries, must carry out enhanced due diligence checks for both registrations and transactions. Additional countermeasures may be required as advised by their national financial regulator. MMOs should review all recommendations relating to international remittances with their national financial regulator to ensure that they meet their obligations prior to launch.
  • 9. 6 International Remittance Considerations for Mobile Network Operators Foreign exchange, or forex, is the process by which money in one currency is exchanged for a similar value in another, according to a published exchange rate. Forex traders buy and sell a currency at different rates, and the difference between the rates is the “spread”. Financial institutions including banks and MTOs will seek to profit from exchanging currencies by exploiting the spread and also by charging commission. The buy and sell prices, and therefore the spread, are not fixed by any central authority, but are a reflection of the transaction value. Forex traders who deal in millions of dollars every day will benefit from a small spread, whilst retail customers will pay a much larger spread. The exchange rate of the service for the customer can be improved, and thus its competitiveness enhanced, by agreeing a small spread with the forex provider. The MMO may be able to negotiate a share of the revenue arising from the spread with their forex provider, unless local regulation prevents this. Other forms of revenue depend upon whether they are acting as sending or receiving MTO agents. Foreign Exchange Considerations
  • 10. 7 Mobile Money Transfer GSMA White Paper International Remittances Service Design The MMO has a number of decisions to make about the user experience and how their international remittance service should operate. MTO or Direct Connection The service design depends upon the type of international remittance service required. If the MMO needs a single or very limited number of connections, it may be appropriate to consider a direct relationship between sending and receiving agents, with forex managed for example by an international bank. However, it will normally be the case that one or more MTOs will be engaged, in order to achieve scale across multiple partners in many markets. The MTOs will have a set of technical and operational requirements for integration to the mobile money service, although these may need some modification depending upon the service design. Enhanced Customer Due Diligence Customer due diligence (CDD) and KYC procedures vary widely between countries, and may be “tiered” if domestic regulations allow, so that a customer’s registration tier is determined by the quantity and quality of KYC data gathered. A customer’s transaction and account balance limits are then governed by their registration tier. In some markets all international remittance customers are required to have higher tier registrations – that is, higher quality KYC data must be gathered. International remittances transaction values are significantly higher than domestic remittances, so for both sending and receiving markets it may be necessary for the MMO to gain additional KYC information about their customers and increase their registration tier so that their accounts are able to receive the required funds. Unregistered Recipients It is common in many markets for some recipients of domestic remittances to be “unregistered”; that is, they do not have a mobile money account, and simply receive a Short Message Service (SMS) or “text” voucher which they can use to cash out at an agent. Although the FATF recommendations appear to prohibit unregistered customers from receiving international remittances, it is sometimes permissible if the recipient presents suitable identification data at the time of withdrawal. If a sender attempts to send funds to an unregistered customer, there are a number of options that can be designed into the service, including declining the transaction. A more satisfactory response is for the mobile money service to advise the customer that he has been sent money and that, if he registers, the funds will be automatically transferred to his mobile money account. As some recipients are unable to register for a range of reasons, it is also necessary to provide the option that he can collect his money by conventional means at an MTO agent. Exchange Rate and Quotation For any foreign currency exchange, the sender must be made aware of the exchange rate used to convert from a specified amount in his home currency to the net amount that will be provided in the destination currency. Therefore the first part of any transaction must be to provide this quotation by an appropriate mechanism. This may be a manual process, such as requesting the information from a call centre; the information could be provided on line for customers with suitable access; or the MMO may provide a handset application that the customer can use to request the information (for example by SMS) before starting the transaction. Alternatively, it may be given as the first part of the transaction, providing that it can be cancelled before completion if the customer dislikes the quotation. Sending International Remittances After the quotation the sender can choose to proceed with the transaction using his mobile money menu. International remittances transactions tend to require more information about the recipient than just the mobile number (MSISDN) used for domestic transactions. Depending upon local regulation, the sender will usually need to provide a name, and in many case an address and/or other personal information. Entering this level of detailed text on a simple handset can be inconvenient and prone to error. Further, depending upon the Mobile Money (MM) channel used, this can present technical problems – for example, senders, particularly the less literate, may experience “time out” whilst entering the additional data; and many USSD services do not currently support text, only numbers.
  • 11. 8 International Remittance Considerations for Mobile Network Operators Ideally the sender should be able to register the recipient details in advance, by means of some process that is outside the transaction itself, and during a transaction simply choose the correct recipient from their registered list of recipients. This registration process may be performed by a customer care representative or MM agent, or by the customer on line or using a handset application. Receiving International Remittances Registered mobile money recipients should receive an SMS or some other notification of the in-bound remittance confirming the transaction details including country of origin. The funds should enter their account and immediately be available for use. Unregistered recipients may need to register before they can receive their funds, or visit an MTO agent for cash. Real Time Transactions Mobile money customers expect transactions to happen in real time. This can be achieved simply in a closed loop, domestic mobile money system where all the money is in one bank (control) account, but for international remittances the “real” money does not reach the receiving MMO bank account until after overnight clearance and settlement. In a typical model, the sending MMO would remove the funds from the sender’s account in real time, and would be expected to transfer them to a separate mobile money “IR receipt account”. These funds are aggregated for transfer each night, when the money in the bank is transferred to the MTO / correspondent bank account. The receiving MMO can simply design their service such that there is a delay in the recipient getting access to their money, though this may not meet customer expectations, since the funds transfer may take several days. A common alternative is for the receiving MMO to pre-fund an “IR funding account” within their mobile money service, from which the recipient is paid in real time, with the e-money in this account being regularly replenished as the settlement funds reach their bank account. Whilst there is some cost associated with pre- funding, the commercial risks are low and can be managed using established banking practices, as correspondent bank transfers are well established and regulated. Reporting Requirements As well as the standard reports needed to run the IR business, local regulation may require an additional number of IR-specific reports, such as reconciliation between the MM IR service, the MTO, and the inter- bank settlement amount. Separately, IR transactions must be monitored for suspicious activity, and anything anomalous reported to the proper domestic authorities.
  • 12. 9 Mobile Money Transfer GSMA White Paper Business Processes IR business processes will be in addition to any existing domestic MM service procedures. Some new IR processes will be required, such as reconciliation and settlement between the MMO and MTO; reconciliation between the IR transactions in the MM service and the funds moved to or from the MM bank account; revenue share procedure; and administering changes to forex rates. Service Evolution As the international remittance service will undoubtedly evolve over time, it needs to be future- proof as far as possible for the addition of new markets, MTOs, use cases, and even new services such as overseas bill payment and vouchering. As the smart phones adoption grows, the user experience can be improved, particularly for senders who may have difficulties with a text based interfaces. Figure 2: Transaction Between Accounts During a Mobile-to-Mobile International Remittance Transaction SENDING BANK SENDING MMO RECEIVING BANK RECEIVING MMO SENDING COUNTRY RECEIVING COUNTRY SENDING BANK COLLATERAL ACCOUNT RECEIVING BANK COLLATERAL ACCOUNT 1. e-money moved to IR receipt account 2. Instruction sent to receiving MMO 3. e-money moved from IR funding account 4. e-money removed and bank instructed to debit receiving bank collateral account 5. Funds moved to receiving bank collateral account 6. e-money created and moved to IR funding account REAL TIME TRANSACTIONS OVERNIGHT CLEARANCE
  • 13. 10 International Remittance Considerations for Mobile Network Operators Mobile money agents are not directly involved with or affected by international remittance transactions, but there are some indirect implications for them. The most important is liquidity. International remittances transactions tend to be substantially higher in value than domestic transfers. Consequently, international remittance customers place a far greater burden on the agent cash flow: in sending markets the agents need more e-money to service the sender’s deposits, whilst in receiving markets the agents need extra cash for recipients to withdraw. As the service grows, the liquidity of the agents must be monitored and carefully managed. The principles of agent management are much the same as those required for a domestic service(8) . Another potential impact may be the need to enhance the KYC information about an international remittance customer. If tiered registration is new to the market, mobile money agents performing this service will need to be trained and processes created for collecting and forwarding customer documentation. It may be decided in some sending markets that the agent should perform the transaction on behalf of the customer. This may be due to practical limitations in senders entering the required information on their handset, due to either technical or literacy constraints. In this case, the international remittance sending service and business case would need to be redesigned. The task of marketing international remittances to customers is complicated by the need to inform and educate in both the sending and receiving markets. It is normally the senders who choose the remittance service, as they both initiate and pay for the transactions, though this may not be the best route for recipients. For MMOs in sending markets, the customer needs to be made aware of the service, how to access it and how to use it. They also need reassurance that the recipient will be able to gain access to their funds, so it will probably be necessary to provide communication and education in the receiving markets. Typically the diaspora of senders is a subset of the total customer base, and may not be fluent in the local language. If the MMO is in a receiving market, the task becomes more challenging, as they need to communicate their service to senders in a country in which they may have no business presence. Further, as mobile money is a relatively new business sector, the sender overseas may be unaware of the recipient service. Many MMOs rely on the MTO to market the service in the “other” market, although with largely limited success to date. There are other ways that the marketing challenges can be tackled: „„ In sending markets, the geographical distribution of a diaspora is likely to be different from the general population distribution. Market research could include call record analysis to identify pockets of potential senders for regional marketing initiatives. By targeting communities by their country of origin, advertising may be delivered in their native tongue. Many migrant workers in some markets are unbanked, so the benefits to them of using the mobile money service to send money home is greater. „„ In receiving markets, the target customers are more likely to be distributed across the country. Using permission based marketing methods, call records may identify customers more likely to be recipients of IR, and they can be targeted for awareness and education about the IR service, and to influence their senders to send directly to their MM account. Incentives for the recipients whose senders use the service might include, for example, free airtime, and free calls to the sending country. Impact on Mobile Money Agents Customer Marketing Considerations
  • 14. 11 Mobile Money Transfer GSMA White Paper Partners may be MTOs, MMOs in other markets, and other financial organisations such as banks. Choosing suitable partners for an international remittance service depends upon the objectives of the service, for example: whether the main opportunity is to send or receive; which are the priority markets; and which MTO agents within each market will provide the required reach. The range of potential partners and the complexity of the relationships can be illustrated in a stakeholder map, such as that presented in Figure 3. Figure 3: Stakeholder Map If an MMO perceives significant and immediate opportunity in multiple markets, it is likely that partnering with an MTO is the best solution unless the MMO belongs to a group with a presence in each of these markets. If they have this presence or if requirement is more limited, for example connecting two MM services owned by the same group in different countries, an in-house solution may be developed using a hub. However, in most cases it is expected that an MTO will be used for forex, connectivity, and financial settlement. Selecting International Remittance Partners Agencies Bank Branches Post Offices Western Union Agents, Moneygram Agents, others MNOs Vodafone Celcom Qtel Etiasalat others Retail Banks Russian Standard Bank, DBS, others Hubs Ericsson MFIC BICS EDCH others Switches MasterCard MoneySend others Agencies Bank Branches Post Offices Western Union Agents, Moneygram Agents, others MNOs Digicel Globe GCash MTN Vodafone others Retail Banks Russian Standard Bank, DBS others Forex and Settlement Barclays Citibank Standard Chartered others MTOs Western Union Moneygram others Funds In Domestic Service IR Hub / Link Domestic Service Funds Out
  • 15. 12 International Remittance Considerations for Mobile Network Operators This paper describes a complex and well-established international remittance market into which many MNOs are considering entry. Few MNOs are currently active in this space and many that are planning to launch services have limited experience in the range of specialist capabilities required. To assist MNOs to launch mobile enabled services, the GSMA has developed “Mobile Money Transfer” (MMT) an open business model which includes: „„ MMT Toolkit: a collection of resources to assist MNOs in strategic decision making and practical implementation of new services. „„ MMT Specifications - procedures and technical interface specifications to enable MNOs and international remittance partners to connect in an efficient manner. MMT Specifications is supported by GSMA Working Groups to ensure that this industry solution is evolves in line with market requirements. For more information about these resources or about participation in international remittances business in general, please contact: mmt@gsma.com. A Common Approach to International Remittances 1) World Bank Migration Development Brief 18 [WB-MDB 18: April 23, 2012]. 2) IMF publication: Remittances: Funds for the Folks Back Home http://www.imf.org/external/pubs/ft/fandd/ basics/ remitt.htm. 3) Mobile Money: Enabling Regulatory Solutions. GSMA Mobile Money for the Unbanked (MMU), January 2013. 4) Mobile Money: Enabling Regulatory Solutions. GSMA Mobile Money for the Unbanked (MMU), January 2013. 5) The World Bank T4 Remittance Estimates 2010. 6) “International Standards on Combating Money Laundering and the Financing of Terrorism and Proliferation - the FATF Recommendations”, FATF, 16th February 2012. 7) “General principles for international remittance services”, World Bank and BIS/CPSS, January 2007. Available at http://www.bis.org/publ/cpss76.pdf. 8) Mobile Money: Enabling Regulatory Solutions. GSMA Mobile Money for the Unbanked (MMU), January 2013. Images kindly supplied by GSMA Mobile for Development. References
  • 16. For further information please contact mmt@gsma.com GSMA London Office T +44 (0) 20 7356 0600 February 2013