The GSMA MMU recently published (3 August) an interview with Mrs Elly Ohene-Adu, Head of the Banking Department at the Bank of Ghana, on the new guidelines for e-money issuers in Ghana. This interview highlighted the risk-based approach the Central Bank of Ghana has decided to adopt on mobile money services.
In 2008, mobile money was considered by the Central Bank of Ghana “as a channel for use by only banks and deposit-taking financial institutions to reach unbanked segments of the population while MNOs were seen as agents making their platforms available to banks to use”. Therefore, mobile money programs had to be driven by the banks, which were not only the e-money issuers, but also the owners of the agent networks and customers.
At that time the Bank of Ghana also decided to push “a “many-to-many” model […] where a group of banks were to partner with a group of MNOs and agents were required to be shared.” After a few years the Bank of Ghana concluded this model was negative for the mobile money adoption as banks were not interested “in extending services to the bottom of the pyramid” but only by keeping “the “float” accounts created by MNOs.” MNOs engaged some initiatives the Central Bank guidelines did not allow and due to the regulation, they limited their investments in mobile money.
In 2013 CGAP revealed the state of financial inclusion in Ghana in comparison to similar countries (Kenya, Tanzania, Uganda) and “the tensions and issues [among actors of the mobile money ecosystem] that stagnated progress within the sector”.
Following several interactions between all the stakeholders the Central Bank of Ghana has developed a new regulatory framework.
The key highlights are
- the abolition of the many-to-many requirement thereby freeing operators from tight and unmanageable relationships;
- allowing MNOs to set up subsidiaries that would engage in the business of e-money supervised directly by the Bank of Ghana and allowing market-led solutions to interoperability;
- the set-up of a three-tiered account structure and related transaction limits satisfying a risk-based approach to KYC and allowing individuals with little or no ID to be included in the formal financial sector;
- security, compliance and consumer protection provisions that afford consumers safeguards against abuse;
- the requirement on float-holding banks to pay interest on the float, and on electronic money issuers to pay not less than 80% of this interest to account holders while keeping the rest for themselves.” The reason behind this guideline was “ MNOs had for years been the drivers of mobile money in Ghana investing significant resources into the sector. They complained of not breaking even and not making significant progress in spite of the investments. This was a way to incentivise them to invest and innovate more to enable the authorities to reach the desired goal of full financial inclusion.
This risk –based approach was taken to enable MNOs to drive mobile money, in turn promoting financial inclusion and developing the number of financial services available to the whole population. The new guidelines were issued on 6 July 2015; the “existing mobile money providers are permitted to apply for a license within six months of the coming into force of the new Guidelines”.