Executive Summary of Mobile Money Recommendations
1.It is possible to have a mobile payments sector and ensure high AML/CFT standards

2.If mobile payments are to be launched prudently, the following regulatory foci will allow a successful trajectory:

• Define e-money and regulate its issuance and transfer
• Further support a practice of dynamic AML/CFT and fraud modeling
• Support the development of proportional approaches to KYC/CFT
• Articulate which entities will enable banks to expand their account opening and/or transactional reach
• Ensure that relevant consumer regulations are amended to enable consumer recourse and litigation
• Develop a protocol for coordinating the activities of all regulators