1. Global Forum on Remittances and Development 2015
Mobile money wallets and cross-border remittances
Simone di Castri, Director of Advocacy and Regulation, Mobile Money
Milan, 17 June 2015
All material © GSMA 2015.

2.  The GSMA unites nearly 800 of the world’s
mobile operators from 219 countries, as well as
more than 200 companies in the broader mobile
ecosystem.
 The Mobile Money programme equips GSMA
members and policymakers development a
sustainable, sound and inclusive digital
ecosystem scaling mobile money services and
implementing partnerships with other providers.

3. Mobile money: a transformational wallet to that
gives people access to life enhancing services
MOBILE MONEY WALLET
 Customers can sign up for the service
even if they don’t have a bank account.
 Customers can cash-in and cash-out
through a network of transactional agents
outside of bank branches.
 Customers initiate transactions using an
interface that is available on basic mobile
handsets.

4. NUMBER OF LIVE MOBILE MONEY SERVICES FOR THE UNBANKED BY REGION (YEAR END)
 255 deployments
across 89 countries
 Mobile money is now
available in 61% of
developing countries
 MNOs (GSMA
members) lead the
operations of 60% of
the mobile money
services
The mobile money industry continues to grow
 299m registered accounts (203m in 2013)
 103m active accounts (61m in 2013)

5.  16 countries are now home to
more mobile money accounts
than bank accounts.
 In ~10 years, mobile money
providers have established a
network of 2.2 million mobile
money outlets globally.
 In 25 markets, there are more
than ten times as many mobile
money agents as bank branches.
*
NUMBER OF FINANCIALACCESS POINT ACROSS DEVELOPING COUNTRIES (DECEMBER 2014)
Expanding financial access

6. GLOBAL PRODUCT MIX BY VOLUME AND BY VALUE (DECEMBER 2014)
717.2m mobile money transactions monthly, worth USD 16.3bn
 The fastest growth in
2014 occurred in
international
remittance, driven
predominantly by a new
model which uses
mobile money as both
the sending and
receiving channel.
 To date, most of the 64 initiatives the GSMA tracks have taken the form of receiving partnerships with established
Money Transfer Operators (MTOs), e.g. Western Union or MoneyGram. However, only 164,000 MTO based
international transfers were made into mobile money accounts globally in December 2014.

7. Cross border mobile money transfers: a promising new model is emerging
 Cross border mobile money transfers use mobile money accounts as both the sending and the receiving channel.
 Orange Money International Transfer links up Côte d’Ivoire, Mali and Senegal. This is the first implementation between three markets, and an ‘intragroup’, in-house
implementation.
 MTN Mobile Money Côte d’Ivoire to Airtel Money Burkina Faso. This is the first example of cross-group interoperability for IMT, and a more complex implementation involving an
intermediary hub.
 In April, an agreement was made for Vodafone to connect its deployments in Kenya, Tanzania, DRC and Mozambique with MTN’s deployments in Uganda, Rwanda and Zambia.

8. PERMISSION TO OFFER CROSS-BORDER SERVICES
 Most country regulations limit m-money/e-money to domestic services only (though this is beginning to change).
KYC
 Risk of loss of bank account access if KYC is not considered adequate:
 Many banks are pre-emptively terminating relationships with money transfer operators (“de-risking”), particularly those operating in
countries with higher money laundering or terrorist financing risk.
 Banks are de-risking because the US Treasury Department has levied fines on certain banks for inadequate compliance with
AML/CFT obligations. Any bank that transacts in USD can be fined, even if the specific transactions/services in question did not
involve US currency.
 Can providers rely on domestic m-wallet KYC for cross-border payments (in some cases, what is acceptable for domestic may not be
sufficient for cross-border)?
 Can providers offer cross-border services directly via an m-wallet without entering a bank or agent location?
 Are KYC and AML/CFT compliance requirements (customer identification, information accompanying transactions, etc.) in one country
sufficient to meet the requirements in other countries involved in cross-border transactions?
 Can recordkeeping requirements be met through capture of electronic data without requiring an in-person visit to a branch or agent
location?
Regulatory considerations

9. TRANSACTION AND BALANCE LIMITS
 Are limits for domestic m-money sufficient for cross-border?
 Need to ensure that systems account for differences in limits for m-wallet transactions and balances in different countries.
EXCHANGE CONTROL AUTHORIZATION AND/OR REPORTING REQUIREMENTS (IF APPLICABLE)
 Requirements to submit documentation even for low-value transactions will prevent the model from taking off.
 Can basic exchange control reporting (e.g. information on type of transaction) be conducted remotely through capture of electronic
data?
DATA PRIVACY
 Need to ensure that customer data are properly protected when shared with outside providers.
DISCLOSURE AND TRANSPARENCY
 Compliance w customer protection and disclosure requirements (i.e., fees, exchange rates, other terms and conditions) may be difficult
when using a mobile phone interface (particularly with older feature phones).
Regulatory considerations