Proportional Risk-Based AML/CFT Regimes for Mobile Money. A Framework for Assessing Risk Factors and Mitigation Measures

Abstract

This paper examines various aspects of the FATF Recommendations and other relevant guidance documents to provide a practical illustration of the elements that should be incorporated in a risk-based assessment of mobile money products. We also identify examples of countries where a proportional AML/CFT framework has been implemented through regulations that are effective, efficient, and not unduly burdensome.

This publication also draws on the results of a GSMA survey of 37 mobile money providers conducted between March and May 2015, which revealed several emerging approaches to mitigating and managing money laundering and terrorist financing risks. The survey results demonstrated that providers are using a variety of policies, processes, and practices to identify and verify the identities of their customers; screen, train, and monitor staff and agents; track and monitor transactions; and address suspicious transactions.

The purpose of this publication is to:

- Help regulators understand the risks posed by mobile money services and the measures mobile money service providers are taking to mitigate these risks, both of which can help to inform the design of efficient and proportional AML/CFT regulations; and - Help assessors understand mobile money services and the risks and risk mitigation measures to inform the mutual evaluation process

Keywords: mobile money, digital financial services, regulation, aml, cft, fatf, anti-money laundering, terrorist financing, risk-based assessment, rba, mutual evaluation, financial inclusion, financial integrity, kyc, due diligence, customer due diligence