Andrew Zerzan

Mobile Money is a booming industry in an increasing number of countries worldwide. The project results from increased demand for guidance and technical assistance from governments after the 2008 publication of an exploratory paper, Integrity in Mobile Phone Financial Services, which discussed mobile money and the application of international anti-money laundering (AML) and combating the financing of terrorism (CFT) standards. For most, how to craft a regulatory regime that expands access to financial services to the poor through the development of mobile phone financial services, but compliant with AML/CFT standards remains elusive. Specific AML/CFT regulations related to mobile money have not been issued in many jurisdictions, mainly due to the lack of awareness of the risks these services can pose if the right controls are not in place. Because the international standards for AML/CFT, the Financial Action Task Force’s 40 + 9 Recommendations were designed and issued well before mobile money technology and business models became prevalent, even developed countries have begun to face challenges with their regulation. The project team aims to provide practical guidance to jurisdictions and the Industry on how to draft regulations and internal guidelines that allow them to comply with AML/CFT standards with enough flexibility for mobile money to thrive. Specifically, the paper (1) takes stock of new AML/CFT regulations and practices relevant to Mobile money, (2) design guidelines for drafting AML/CFT regulations that cover mobile money and (3) propose examples of best practices for the Industry to include AML/CFT in their own business model.

Explores several technologies for moving money and identifies possible terrorist financing risks and measures taken to tackle them.

Governments are challenged to make an innovation-friendly climate while simultaneously ensuring that business development remain sustainable. Criminal use of the technology--terrorist financing and money laundering--challenges long-run business viability via risk of massive investment flight and public distrust of new players entering the market. Sustainable business models are those that base regulation on a careful risk-based analysis. This study identifies the perceived risks and compares them with the actual level of risk for each category of mobile phone financial services. The comparison reveals that the perceptions do not weigh up to the reality. Based on fieldwork in seven locations where the technology has taken off, this paper finds that providers apply measures that are consistent with international standards to combat money laundering and terrorist financing. It identifies the sometimes non-traditional means the industry uses that both mitigate the risks and are in line with good business practices. Acknowledging that mobile phone financial services are no riskier than other channels, governments are called to treat them as an opportunity to expand access to finance.