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‘teSt and Learn’: deveLoPinG reGULationS that meet marKet and CUStomer needS







• Submitting monthly data on the volume and value of transactions, as well as trust account balances
• Consumer protection mechanisms

• distribution requirements
• Know Your Customer (KYC) standards
• maximum transaction limits

• restrictions on the use of interest.

these requirements are complemented by the providers’ operational policies aimed at making the service sound and safe for customers.
in this context, moral suasion was also instrumental in establishing trusted dialogue between the Bot and the mobile money providers.

issued independently by the Bot to each operator and partner bank, the letters of no objection were intended to be an interim solution.
although they are not public, it is understood that the prudential and market conduct requirements detailed in the letters are similar in
nature for all deployments:

• Safeguarding customer money: mnos are required to use a trust account at a bank and abide by Bot account management stand-
ards. the partner commercial bank would house a trust account, through which the mno could issue electronic value and safely
deposit the equivalent of the float. mnos were only permitted to have one bank partner, and the entire float would be maintained in
the trust account, therefore, the value was backed by 100% liquidity. to use the trust structure, each mno registers a local holding
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company with independent directors to act as a trustee.


Figure 2
The Tanzanian Mobile Money business Model
designed in The ‘leTTers of no objecTion’



banK

pooled TruST AccouNT


TrusTee


cuSTody oF cuSTomer FuNdS
regulATory eNgAgemeNT

‘leTTer oF No objecTIoN’ ANd geNerAl complIANce
producT ANd buSINeSS developmeNT

mArkeTINg AgeNT NeTwork TechNology cuSTomer
mANAgemeNT cAre
brANdINg TrANSAcTIoNAl plATForm
lIquIdITy mANAgemeNT
commuNIcATIoNS (SuperAgeNcy) AcceSS To The hANdSeT



bANk ACTIVITIEs
agenTs
MObILE OPERATOR
ACTIVITIEs
cusToMer jOINT ACTIVITIEs







20. in the draft mobile Payments regulations 2012, this value is defined as “electronic money”.
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