98
Protecting Mobile Money against Financial Crimes
Box 3.13
Examples of APs Managing Retail Outlet Risks In Kenya, Safaricom requires retail outlets to pass an AML test to ensure their familiarity with integrity issues and procedures. Zain verifies the business permits of retail outlets through lawyers and notaries, and it performs random on-site visits by “mystery shoppers”.a In Peru, financial institutions are obligated to train their retail outlets on KYC and other CDD obligations. In the Philippines, Globe Telecom requires all retail outlets to undergo an accreditation process led by a committee comprising representatives from its finance, legal, business operations, and information technology departments. In the Russian Federation, payment agents are required to register with the Federal Financial Monitoring Service (FFMS) for AML purposes and to have their internal control rules approved by FFMS before accepting payments. In addition, all transactions processed by retail outlets go through the operator’s information technology system and will be subject to AML/CFT rules. In Zambia, the central bank reviews applications to ensure that retail outlet personnel are adequately trained in front-end procedures (including KYC) and allows the provider to monitor its retail outlets. Source: World Bank research. a. Mystery shoppers are Safaricom employees who visit retail outlets for monitoring purposes, pretending to be customers.
Table 3.2 Example of the Evolution of Retail Outlets’ Regulation in Brazil, Various Years Year
Resolution and description
Before 1999 Only banks can have retail outlets and only in places where there are no bank branches. Services allowed: – loan applications – credit and personal data analysis Subagents are not allowed. 1999 Resolution CMN 2640/99 Additional services allowed: – receipt of account-opening applications (original documents should be analyzed by bank staff ) – deposits and withdrawals (subject to CBB’s authorization) – bill payments (continued)