About Mobile Money

MTN Mobile Money is a fast, simple, convenient, secure and affordable way of transferring money, making payments and doing other transactions using a mobile phone. The service is offered by MTN in partnership with 10 banks. You can use MTN Mobile Money to send and receive money, top-up MTN airtime, pay bills (DStv, ECG Postpaid, MTN Postpaid, School fees, etc.), buy & pay for insurance, pay for airline tickets and other goods and services. No need to travel far or wait impatiently to receive or send money. Register with a valid photo ID today and enjoy the ease and convenience this service offers.

What you get

  • Pay your bills online or through your phone.
  • Recharge your credit easily.
  • Transfer money to your loved ones without going to the bank.
  • It’s secured and it’s fast.

MTN Mobile Money is a service provided by MTN in partnership with banks. This service operates through authorised Merchants who will facilitate the service on behalf of the partner banks. There will be certain regulations and terms and conditions to adhere to.

Find out how to use Mobile Money in our Support section. For further assistance, call 111.

Terms and Conditions

1. The Agreement

When you open a Mobile Money Wallet you must know the terms and conditions ("rules") for using your Wallet. You need to understand each clause of the rules set out in this document. You are required to keep these rules as they are a binding agreement between you and us, Scancom Limited (MTN GHANA) and Partner Banks. When you apply for a Mobile Money Wallet you agree to these rules.

2. What We Mean

The following definitions relate to these terms and conditions:

2.1 "Cell phone" means a GSM terminal connected via a GSM radio link to the MTN telecommunications network.

2.2 “Credit” means depositing funds in your Wallet.

2.3 "Debit" means the movement of funds out of your Wallet.

2.4 "GSM" means the global system for mobile communications as defined in the European Technical Standards Institute's list of specifications.

2.5 "Merchant" means any registered business entity that is authorised to engage in the sale and distribution of Mobile Money products and services and or accept Mobile Money as payment for goods & services offered.

2.6 "Mobile Money Website" refers to the website address https://196.201.56.109

2.7 "Mobile Money" means the financial services product offered by us being a transactional banking Wallet.

2.8 "MTN Ghana" means Scancom Limited.

2.9 "Pack" means the collection of the User Manual, schedule of fees, other documents and advertising material given to you upon registration.

2.10 “Partner Banks” means Ecobank Ghana Limited, Fidelity Bank Limited, Guaranty Trust Bank Ghana Limited, Stanbic Bank Ghana Limited, Cal Bank Limited, Merchant Bank Limited, Zenith Bank Ghana Limited, United Bank for Africa Ghana Limited, Access Bank Ghana Limited,Agricultural Development Bank and any other Bank that may be signed on to the Mobile Money Service from time to time.

2.11 "PIN" means personal identification number being the secret code you choose for your cell phone.

2.12 "POS" means a point of sale device which is used for Mobile Money transactions.

2.13 "Services" means the services provided by us relating to your cell phone to enable you to use Mobile Money.

2.14 "SMS" means a short message service consisting of a text message.

2.15 "User Manual" means a document describing Mobile Money and its functionality.

2.16 "Wallet" means your Mobile Money transactional account which is accessed primarily through your cell phone.

2.17 "Wallet holder" means the individual in whose name the Mobile Money Wallet is registered.

2.18 "we" or "us" or "our" means MTN Ghana and Partner Banks.

2.19 "you" or "your" means the Wallet holder.

3. Mobile Money Concept

3.1 Mobile Money enables its users to do money transfers, deposit and withdraw money and top up airtime from their phone or from any Mobile Money authorized merchant.

3.2 Mobile Money users will be informed of any additional feature that may be offered in the future on Mobile Money.

4. Mobile Money Wallets

4.1 Mobile Money Wallets are opened and owned by Partner Banks and this service is currently reserved to MTN Ghana customers only. To become a Mobile Money user, MTN Ghana customers will be subject to requirements from Partner Banks. The Mobile Money user commits himself/herself to use Mobile Money only on MTN GHANA network unless otherwise notified by MTN Ghana.

5. Application for Wallet

5.1 You can only apply for a Wallet if you are an active MTN Ghana subscriber. Only Ghanaian citizens with a valid ID document may apply for a Mobile Money Wallet.

5.2 Foreigners wanting to benefit from this service may be required to provide evidence of residence, in the form of a resident permit or any other legal documentation to that effect.

5.3 Persons below the age of 18 (minor) cannot open a Mobile Money Wallet. A person above the age of 18 may however open a Wallet to be held in trust for a minor.

5.4 Persons below the age of 18 (minor) cannot open a Mobile Money Wallet. A person above the age of 18 may however open a Wallet to be held in trust for a minor.

We require your personal details and certain information before a decision is made on your application. You must provide complete and accurate information.

5.5 We may decline your application at our sole discretion.

5.6 We will verify your identity and may refuse to open a Wallet for you if we are not satisfied with proof of your identity.

5.7 Your Wallet will be held by a Partner Bank.

6 Fees and Other Charges

6.1 You pay fees when you use your Wallet. A list of these fees is available from Partner Banks’ branches, Authorised Mobile Money Merchants and MTN Service Centres, by contacting our Call Centre on 111 or by accessing the Mobile Money website.

7. Transacting

7.1 To manage your money safely there are transactional and daily limits on your Wallet. You can increase or reduce these limits by contacting our Call Centre on 111 subject to the restrictions placed in terms of paragraphs 7.5 and 7.6.

7.2 You may access the available funds in your Wallet at any time using your cell phone and the Internet. While we will make every reasonable attempt to provide the Services in accordance with the User Manual, we provide the Services "as is" and without any warranties.

7.3 You must authorise your transactions with your secret PIN, which you create when you register, or by such other method we may prescribe from time to time.

7.4 Any use of or transactions concluded through the Mobile Money website are subject to the terms and conditions on the website, as may be amended by us from time to time.

7.5 Non-Wallet holders shall not transfer or make any payments that exceed GHC 200.00 per day. Wallet holders shall not withdraw, transfer or make any payments that together exceed GHC 1,000.00 per day. Should you exceed any of these limits, your transactions will be declined and you will need to visit any Partner Banks’ branch or selected MTN Ghana outlet with your valid ID document as well as proof of your residential address.

7.6 In addition to 7.5, the balance on your Wallet may at no time exceed GHC 10,000.00. Should your balance, at any time, exceed GHC 10,000.00, no withdrawals, transfers or payments may be effected against your Wallet and you will need to visit any Partner Banks’ branch or selected MTN outlet with your valid ID document as well as proof of your residential address.

7.7 We may verify and confirm any record of a deposit into your Wallet. Our records will be taken as correct unless the contrary is proven.

8. Security and Unauthorised Use

8.1 The user selects a confidential Personal Identification Number during registration. This PIN is mandatory for the use of all Mobile Money features in such a manner that no transaction could be effected without entering and validating this PIN. The user has three (3) attempts to enter the right PIN. If the user enters the wrong PIN on his/ her third attempt, the Mobile Money wallet will be disabled.

8.2 You are responsible, for keeping your PIN secret and for all transactions that take place on your Wallet with your PIN and you indemnify us against any claims made in respect of such transactions. Your PIN shall not be communicated to anyone, must be kept in a very confidential manner and should in no case be written on any document. The user must ensure this PIN is always composed out of sight of any individual.

8.3 If at any time you believe or know that your cell phone or PIN has been stolen or compromised, you can call us immediately on 111. We will block the PIN as soon as we reasonably can. You will remain responsible for all transactions that occur until your PIN is blocked.

8.4 Should you dispute that any purchase or withdrawal debited to your Wallet was authorised by you, you will have to prove it was not authorised.

8.5 We can accept your telephonic instructions without your written confirmation. We use authentication questions and/or voiceprint to confirm your identity when you call our Call Centre. These methods give us your authorisation to execute your instructions.

8.6 You are responsible for protecting your computer against computer viruses when you use the Internet to access our Mobile Money website and Internet banking facilities. We are not liable for any computer program or code that may originate from our systems and you indemnify us against any claims made in this regard.

9. Statements

9.1 You may upon payment of a prescribed fee request a statement print out from us showing all the transactions on your Wallet. You must check each statement as soon as you receive it and inform us within 30 days of the date of the statement if you think that a statement is not correct. If you do not do this within this timeframe you hereby waive the right to dispute any transactions reflected on the statement or to recover any losses from unauthorised transactions reflected on the statement.

9.2 You can use your cell phone to request a balance or mini statement on your Wallet or alternatively you may print out your statement from the Mobile Money Website.

10. Closing Your Wallet

10.1 We will close your Wallet on receiving a request from you.

10.2 We can close your Wallet, restrict activity on your Wallet or suspend access to your Wallet if in any way we know or suspect your Wallet is being used fraudulently, negligently or for illegal activities or if we must do so to comply with the law.

10.3 We can close your Wallet if we believe that you are in breach of these terms and conditions, are trying to compromise our systems or are unreasonably interfering with any Services provided by us.

10.4 We may choose at any time to close your Wallet to protect our interests.

10.5 We may close your Wallet if you do not use your cell phone and Wallet for a period of 9 months, except where your contract for your cell phone is still valid.

10.6 If you are no longer an MTN subscriber we may close your Wallet.

10.7 If we close your Wallet in terms of this clause 10 you must ensure that all debit orders linked to this Wallet are removed within 30 days as these debit orders will be declined after this period and neither the Partner Banks nor MTN will accept any liability resulting from these declined debit orders.

10.8 We will not be responsible to you for any direct, indirect, consequential or special damages arising from any act or omission by us or any third party for whom we are responsible, whether arising in contract, delict or statute, if we close or suspend your Wallet in terms of this clause 10.

11. Failure or Malfunction of Equipment

We are not responsible for any loss arising from any failure, malfunction, or delay in any POS, cellphone networks, and cell phones, the Internet or terminals or any of its supporting or shared networks, resulting from circumstances beyond our reasonable control.

12. Notices

12.1 The address you supply on your Mobile Money Registration Form is regarded as your chosen address where notices may be given and documents in legal proceedings may be served. You must notify us immediately should your physical, postal, email address or cell phone number change.

12.2 We are entitled to send any notice to an email address specified on your application. This communication will be regarded as having been received by you, unless the contrary is proved. This clause pertains to customers who have completed the Mobile Money Registration Form.

12.3 Any correspondence that we send to you by post will be considered to have arrived within seven days of posting and any correspondence that we send to you by fax or email will be considered to have arrived on the day that it was sent.

12.4 We are entitled to send information to you via SMS to the contact cell phone number supplied on your application form and as amended from time to time. These SMSs are for information purposes only. 12.5 You should send any legal notice to us at our chosen address:
Ridge Towers
6th Avenue, Ridge
P.O. Box TF 281,
Trade Fair, Accra

12.6 You acknowledge and agree that this agreement will be regarded as having been entered into in Accra and any breach of this agreement will be considered as having taken place in Accra.

13. Consents and Conduct of the Wallet

13.1 You, the Wallet holder, consent to us:

13.1.1 making enquiries about your credit record with any credit reference agency and any other party to confirm the details on this application;

13.1.2 providing regular updates regarding the conduct of the Wallet to the credit reference agencies and allowing the credit reference agencies to in turn make the record and details available to other credit grantors.

14. Fraud Prevention

14.1 You, the Wallet holder, consent to us:

14.1.1 Carrying out identity and fraud prevention checks and sharing information relating to this application with the Ghana Police or any fraud prevention or security agency;

14.1.2 providing details to the Ghana Police or any fraud prevention or security agency of any conduct on your Wallets that gives us reasonable cause to suspect that the Wallets are being used for improper purposes; and

14.1.3 you understand and agree that the record of this suspicion will then be available to other members of the Ghana Police or any fraud prevention or security agency should they carry out credit or other checks on your name.

15. General

15.1 We may at any time amend these terms and conditions by notice in writing sent to you. Any amendment will not constitute a novation of this agreement.

15.2 You shall not vary any of these terms and conditions.

15.3 You agree that we may sue in any court of competent jurisdiction.

15.4 A favour or concession we may give you will not affect any of our rights against you.

15.5 These terms and conditions are governed by Ghanaian law.

15.6 We may allocate any money received from you or held on your behalf to settle any outstanding balance on your Wallet. Should you default on your Wallet while at the same time having a credit balance due and payable on any other Wallet with Partner Banks, we have the right to apply set-off on the affected Wallets.

15.7 You must notify us if you are under an administration order, sequestration or any other form of insolvency.

15.8 You must pay all our expenses in recovering any amounts you owe us including legal fees.

15.9 A certificate signed by any of our managers (whose appointment need not be proved) showing the amount you owe us is sufficient proof of the facts stated on the certificate, unless the contrary is proved.

15.10 We will not be responsible to you for any indirect, consequential or special damages arising from any act or omission by us or any third party for whom we are responsible and whether arising in contract, statute or tort.

15.11 You are responsible for your connection to the Internet and all costs associated with that same connection.

15.12 You must notify us immediately of any change of your details in your application.

15.13 You agree that your information, including your personal information, your telephone conversations with our call centre and your transactions will be recorded and stored for record keeping purposes for 5 years from date of closure of Wallet.

15.14 We are obliged by law to regularly update your personal particulars, such as your current residential address and contact information. We may contact you from time to time in this regard.

15.15 All copyright, trademarks and other intellectual property rights used as part of our Services or contained on our documents are owned by Mobile Money or its licensors. You agree that you acquire no rights thereto.

15.16 You accept that all transactions effected on your cellphone are subject to other Terms and Conditions available on our website or from our call centre.

15.17 Your Mobile Money Wallet may not be transferred to any mobile telecommunications network operator other than MTN without the consent in writing of MTN.

16. Sanctions

 

16.1 Any abusive and/or fraudulent usage of a Mobile Money wallet and any false declaration may be punished by the laws in place in Ghana.

 

16.2 Any abusive and/or fraudulent usage of a Mobile Money wallet and any false declaration may also lead us to suspend temporarily or indefinitively rights to access to Mobile Money services.

16.3 Any cost engaged by us in recovering transactions and undue payments made by the wallet user will be borne by the user.

16.4 Any fee that could not have been debited from the user’s wallet due to a fraudulent usage will be recovered with an additional legal interest rate.

16.5 Any transaction or action from the user on its Mobile Money wallet triggering a malfunction of the system and requiring a technical intervention will be charged to the user.

Bank of Ghana

NOTICE TO BANKS AND SAVINGS AND LOANS COMPANIES

NOTICE NO. BG/GOV/SEC/2008/21

GUIDELINES FOR BRANCHLESS BANKING

Branchless Banking (BB) represents a significantly cheaper alternative to conventional branch-based banking that allows financial institutions and other commercial actors to offer financial services outside traditional bank premises by using delivery channels like retail agents, mobile phones etc. BB can be used to substantially increase the financial services outreach to the un-banked communities.

These guidelines are being issued as part of the broader strategy to create an enabling regulatory environment to promote branchless banking. The primary audience of these guidelines is deposit-taking financial institutions (bank and non-bank) desirous to undertake branchless banking. However, as financial institutions cannot take on BB without the help of other market players like telecom companies, technology service providers, agents etc., these guidelines are also helpful for other parties to understand their roles and responsibilities.

Objectives

The guidelines for branchless banking set out by the Bank of Ghana are aimed at achieving a number of objectives:

  • Promoting financial inclusion without risking the safety and soundness of the banking system.
  • Extending core banking services to the domain of everyday transactions.
  • Ensuring that the common platform for the payments and settlement system (e-zwich) established for deposit taking financial institutions (FIs) extends to branchless banking.
  • Ensure that banking services provided under branchless banking are provided by regulated deposit-taking financial institutions or their agents.
  • Ensure compliance with Ghana’s Anti-Money Laundering Act as well as the Anti-Money Laundering and Financing of Terrorism (AML/CFT) standards as set by the Financial Action Task Force (FATF).
  • Ensure a wide participation of deposit-taking financial institutions (i.e. banks and non-banks) including commercial banks, rural banks, savings and loans and microfinance institutions in the provision of branchless banking services.
  • Ensure that all branchless banking transactions are cleared through the settlement system.
  • Ensure that all customers using branchless banking services can be uniquely identified.

Scope

  • These guidelines are applicable to deposit-taking financial institutions (herein after collectively referred to as financial institutions or FIs).
  • Activities outlined in these guidelines as branchless banking cannot be offered by any person or institution other than deposit-taking financial institutions (FIs).
  • All FIs desirous to offer branchless banking services may do so in line with these guidelines.
  • These guidelines do not, in general supersede or revoke any of the existing Laws, rules & regulations unless specifically stated. Further the scope of any such relaxation of rules and regulations will be limited to Branchless banking only and shall not extend to cover any other banking activity

Branchless Banking Models and Activities

Branchless banking is only allowed to be undertaken by licensed deposit-taking financial institutions (bank and non-bank) or their agents. Furthermore, all customers of FIs undertaking BB activities must be uniquely identified.

Branchless banking can be done using agents like Telcos, Fuel distribution companies, Merchants, Post Office, etc. and using technologies not limited to mobile phone (like GPRS, POS terminals etc.).

In each case customer account relationship must reside with some FI and each transaction must hit the actual customer account.

Model For Ghana

As stated above, only the FI-led model of branchless banking is allowed and may be implemented in different ways. Firstly, it can be implemented either by using agency arrangements or by creating a partnership between a FI and Agent company (e.g. Telco).

Further, while mobile phone banking which makes up for large part of branchless banking can be implemented by using a number of models1, to ensure maximum connectivity and outreach as well as interoperability, the Many-to-Many Model is the only permissible model in Ghana. Exclusive partnerships are not allowed. This model offers the maximum connectivity and hence maximum outreach and is closer to the desired situation where all FIs and all telcos should be able to entertain each other’s customers (Just like the existing ATM network being developed in the country where customer of any bank will be able to use ATM of any other bank).

Under this model, FIs and Telecom operators are expected to join hands to offer mobile banking services to the public with central processing of transactions through the Ghana Interbank Payment and Settlement System (GhIPSS) which will:

i) settle all transactions on real time basis or through a regulated clearing arrangement,
ii) store all proofs of transactions and
iii) provide a day end reconciliation to all member FIs.

In this regard, all new switches, ATMS, Points of Sale (POS), card or mobile phone payments products issued or deployed by banks and deposit taking financial institutions must be e-zwich compliant or interfaced with the e-zwich platform.

Furthermore, prior approval must be obtained from the Bank of Ghana for the deployment of new switches, ATMS, Points of Sale (POS), card or mobile phone payments products.


1These models include: One-to-one (1-1) Model: In this model one FI offers mobile phone banking services in collaboration with a specific Telco. As a consequence, the services may only be offered to customers using mobile connection of that specific telco. This model can be JV-based or implemented through specific agency agreements between the telco and the bank. It offers greater customization, good service standards, possibility of co-branding and co-marketing. On the other hand, it lacks in outreach as it is limited to the customers of one telco and one FI only. This model is not permitted.

One-to-many (-∞) Model: In this model a FI offers mobile phone banking services to customers using mobile connection of any Telcos. This model offers the possibility to reach to any bankable customer who has a mobile phone connection. But this model has several limitations in that all telcos may not be ready to offer the bank a priority SMS pipe to enable it to provide quick services which are of essence in mobile phone banking. Further, the FI needs to bear all advertising/marketing expenses. Another serious drawback of this model is that it may require the FI to rely upon its own branch network for product distribution and cash-in-cash-out services etc. This model is not permitted.

Permissible Activities

Under these guidelines, the following products/services may be offered.

  • Opening and maintaining a BB Account. A BB account is an account opened and operated by a customer with a bank. Banks may associate such account a particular branch or to a centralized branchless banking unit. Account capabilities/limits are commensurate with the level of customer due diligence (CDD) and KYC procedures the customer has undergone. Risk basked KYC and CDD structure is explained in the relevant section of these guidelines.
  • Account-to-account Fund transfer: Customers may transfer funds to/from their BB account from/to their other pre-registered accounts (current/saving bank accounts, loan limit accounts, credit card accounts etc.)
  • Person-to-person Fund Transfers; Customer can transfer funds from their account to BB or regular accounts of other customers of same or some other bank (depending on the model capabilities).
  • Cash-in and Cash-out: Customers may deposit and withdraw funds to/from their BB account using a variety of options including bank-branch counters, ATM machines and authorized agent locations.
  • Bill Payments: A BB account can also be used to pay utility bills (e.g. Gas, Electricity, Phone etc.)
  • Merchant Payments: Customers can use a BB account to make payments for purchases of goods and/or services.
  • Loan Disbursement/Repayment: FIs, particularly Microfinance institutions may use BB accounts as a means to disburse small loan amounts to their borrowers having BB accounts. The same accounts may be used by customers to repay their loan installments.

Anti Money-Laundering

All FIs and their agents must comply with the Anti-Money Laundering Act (2008) as well as the international standards set by the FATF. These require:

  • Adequate customer due diligence (KYC) be undertaken on all new accounts and on one-off cash transactions over designated thresholds. This requires identifying the customer and verifying the customer’s identity.
  • Financial service providers to keep detailed transaction records for at least five years.
  • Financial institutions to report suspicious transactions promptly to the AML/CFT authority.
  • Special attention to threats that may arise from new technologies that may favor anonymity.
  • Policies and procedures be in place to address specific risks associated with non-face to face business relationships and transactions.
  • Customers using BB applications should be uniquely identified. This means that FIs should be able to trace BB transactions to particular customers. In this regard mobile phone SIM cards will have to be registered by the FI.

Agents-assisted Banking

The true power of branchless banking cannot be unleashed until some trusted third parties are involved in performing some of the activities that are traditionally performed in bank branches by bank staff. Use of the word agent in this context does not include third party service providers who provide certain technical services to banks, such as provision of transaction processing system. For the purpose of these guidelines we distinguish between agents and service providers. Though the term ’agent’ in this context does not include third party technology service providers, there is no restriction on a third party technology service provider to become a basic banking agent provided it meets the criteria for becoming an agent.

Role of Agents

Agents may perform any or all of the following functions depending on the agency agreement and agent type as detailed in the following sections.

  • Opening of BB Accounts.
  • Cash in/Cash out.
  • Bills Payments. (Both from registered BB customers as well as from walk-in customers of any utility company).
  • Loan disbursement/Repayment Collection. (Without involving into loan marketing/approval functions).
  • Funds transfers

BB Agents cannot be involved in marketing, sales of any other products of the bank (including but not limited to consumer banking products, liability products etc).

One Agent can provide services to multiple banks provided he (the agent) has a separate service level agreement with each bank. Alternately, banks may organize their agent network using open architecture so that they may entertain other banks’ customers using infrastructure provided by one bank.

Agents may not alter/change charges/fees structure provided by the bank in any way. All charges have to be pre-agreed between the bank and the agent and should be clearly communicated to the customers.

Banks/agents may choose to brand their agent network under any brand name. However use of words like Bank, financial intermediary, microfinance bank or any other word suggesting that the agent is itself an FI, is not allowed.

Agent Structure

Agents may be one of three basic types.

Super Agents: These may be organizations having well-established owned or franchised retail outlets, or a distribution setup. These will be responsible for managing and controlling subagents. These may include fuel distribution companies, Post Office, courier companies, chain stores etc.

Direct Agents: These may include large to medium sized stores etc., which have a separate agency/service level agreement with the FI.

Sub Agents: These are the branches/outlets or agents not directly controlled by the FI on a day-to-day basis. These will be managed by a super agent. However, these must have a similar service level agreement with the super agent as the super agent will have with the FI.

Agent Due Diligence 

Use of agents in BB exposes FI to significant operational and reputational risks. Efficient and foolproof Agent Due Diligence (ADD) procedures must exist to mitigate these risks.

FIs are responsible for having clear, well documented ADD policy and procedures. These procedures, at minimum, should contain new agent take on procedures (NATP), initial due diligence and regular due diligence checks to be performed at specified intervals and a list of early warning signals and corrective actions to ensure proactive agent management. ADD should clearly specify roles and responsibilities of various functions in the bank with respect to agent management.

NATP should clearly define various agent types and minimum agent selection criteria for each type.

Banks should ensure that proper AML/CFT monitoring process exists for branchless banking, necessary actions to be taken by agents in this regard are well communicated to the agents and the agents’ compliance of the same is monitored.

Agency Agreement

The FI shall submit a Service Level Agreement (SLA)/Agency Agreement (AA) (duly signed by concerned parties), and any amendments thereto, detailing the functions/activities to be performed, the respective responsibilities of the bank and its agent and a confidentiality clause.

The senior management of the FI remain responsible for maintaining an effective system of internal control and for providing active oversight of the agent’s activities/functions.

There shall be a contingency plan to mitigate any significant disruption, discontinuity or gap in agent’s function, particularly for high-risk areas.

The written engagement contract or service level agreement with the agent shall, at a minimum:

  1. Define the rights, expectations and responsibilities of both parties;
  2. Set the scope of, and the fees/revenue sharing structure, the work to be performed by the agent;
  3. State that the outsourced services are subject to regulatory review and that Bank of Ghana inspecting officers shall be granted full and timely access to internal systems, documents, reports, records and staff of the agent;.
  4. State that the agent will not perform management functions, make management decisions, or act or appear to act in a capacity equivalent to that of a member of management or an employee of the FI;
  5. Specify that the agents must ensure safe-keeping of all relevant record, data and documents/files for at least five years; or alternately, such record is shifted to the FI at regular pre-specified intervals which will then ensure safe-keeping of this record for at least 5 years.
  6. State that all information/data that the agent collects in relation to branchless banking services, whether from the customers or the FI or from other sources, is the property of the FI, and the institution will be provided with copies of related working papers/files it deems necessary, and any information pertaining to the institution must be kept confidential; and
  7. Establish a protocol for changing the terms of the service contract and stipulations for default and termination of the contract.

Agent Development

The essential spirit of Branchless Banking is financial inclusion. BB aims at putting the national resources to the productive activities and directing financial resources to areas where the same are most needed. In line with this spirit the FIs are required to plan and act for long term development and prosperity of their agents. This requires close coordination/collaboration with agents; providing them opportunities to learn more, to become more efficient and; a fair pricing mechanism for the services provided by the agents.

Use of Third Party Service Providers

As opposed to the BB agents, third-party service providers can provide services related to technological infrastructure etc. They have no direct contact with BB customers and do not perform activities that are attributed to BB agents.

A proper service level agreement must be put in place for all third-party service arrangements.

Payment Service Infrastructure (for Merchants)

PROPOSED GUIDELINES FOR SETTING UP PAYMENT SERVICES INFRASTRUCTURE FOR BRANCHLESS BANKING 

Introduction
The following guidelines are proposed for deposit taking financial institutions seeking permission to set up a platform for payment services. This is to ensure the orderly development of the payment system in the Country.

Many to Many Model

A proposal to establish a platform for branchless banking shall be submitted to the Bank of Ghana for approval by a group of at least three (3) banks. This is in conformity with the many to many model under the branchless banking guidelines. The banks may act alone or in conjunction with a system supplier. The proposal would have to indicate that the banks could generate the critical mass of patrons that would ensure viability of the product.

Customer Identification and Know Your Customer (KYC) Principle
Users of branchless banking products should be customers of regulated deposit taking financial institution who have also met the Bank of Ghana’s KYC requirements. For mobile banking services, non bank account holders can engage in transactions not exceeding GH¢50.00 per transaction but not exceeding GH¢200.00 a day.

Bank Based Transaction
All branchless banking products can only be deployed through collaboration with banks.

Pin Based Cards
Cards that are pin based would have to demonstrate reliability and credibility of security features.

Technical and Financial Feasibility

  • technical feasibility and financial viability of the branchless banking system
  • quality of risk management and measurement techniques
  • existence of fraud and forgery determination and prevention mechanisms
  • quality of security infrastructure
  • appropriateness of system rules and regulation
  • agreements between parties in collaboration
  • any other issue that the Bank of Ghana may consider pertinent to the establishment and operation of the branchless banking system

Transactions Settlement
For purposes of clearing and settlement among banks on a common switch/payment system platform, the participating banks should agree on the clearing arrangement among themselves subject to approval by the Bank of Ghana. Settlement shall be over Central Bank funds through GHIPSS. The Bank of Ghana shall exercise oversight responsibilities over these systems.

Interoperability
Any switch or payment system platform set up by banks or banks in conjunction with service providers must be interoperable with the ezwich platform.

Outsourcing
In deploying mobile banking applications, point-of-sale devices and smartcards for payment services, deposit taking deposit taking financial institutions may outsource the business to agents like Telecommunication Companies, Retail Outlets and Postal Service Providers.

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