Checklist

Customer protection policy and procedures

AML/CTF policy and procedures
Model contract
6.3.1 Business plan that contains at least:
brief analysis of the country’s economy with particular focus on the financial system;

operational and financial viability of the intended mobile and agent banking services for at least three years;

pricing strategy including the initial transaction fee and charges that takes into account the sustainability of
the mobile and agent banking service and the affordability of the service to the wider market

products and services to be offered, target markets, regional distribution and coverage of the service; and

agency arrangement to be used, technology service to be deployed, fee sharing arrangement, stakeholders
and their respective role in the delivery of the service, impact of the services in improving financial service
accessibility

6.3.2 Operational Policy and Procedure Manual containing at least:

responsibilities of the board and senior management of a financial institution in relation to the new services;

organizational structure of the mobile and agent banking functions and associated responsibilities

details of products and services to be offered such as product features, fees and charges, and transaction
limits for the product;

detailed narrative description and work flow diagram of the services to be provided (including registration,
account opening; cash in transactions, fund transfer/remittance, cash out procedures)

accounting procedures and recording of transactions

agent management where applicable;

internal control procedures

manner of reporting; and

complaint handling and redresal system

6.3.3 Risk Management Policy and Procedure containing at least :

description of the inherent risks such as operational risks, reputation risks, legal risks and liquidity risks and
specific policies, processes and systems that are in place to manage these risks; and

notwithstanding the provision stated above, description of the inherent risks and the specific policies and
processes that are in place to deal with risks shall specifically adresss risks emanating from customer, agent,
technology service provider, mobile network operator and financial institution perspective

6.3.5 Board minutes showing the board of directors of specific financial institution has reviewed and
endorsed the mobile and agent banking services to be provided.
6.3.4 Agent due diligence policy and procedure and declaration of agent suitability assessment signed by a
chief executive officer or chairperson of board of directors of a financial institution as set out under article
9.3 of these directives.

6.3.6 Penalty matrix that shall be imposed on agents for possible violations of agreements and malpractices.

Agreement entered with third parties including technology service providers and telecom companies.

Such other information as may be requested by the National Bank.

6.3.7 Feasibility study
6.3.8 Fee structure (Pricing ) policy and procedures
Status
Draft
Drafted
Not started
drafted.

Draft proposed. To be adjusted and improved with Finance support

Stated in the document. But we shall define a concrete pricing model that will submit
within the policy manual

drafted.

drafted. Should be clearly stated. Do we use or not fingerprint? Printer for receipt? Is is
provided by wasasa ou afforded by the agents? All that should be clarified

Drafted. To be reinforced

drafted.

drafted

drafted

to be completed

the agent management policy that will propose should address issues reated to a)
agent recruitment/selection approach, b) agent onboarding, training and contract,
c)compliance and performance management, d) technology safety and fiability, e)
sustainability of agent network, f)exclusivity vs interopability for agents, g) liquidity
management, h) customer protection at agent.
the section drafted should be reinforced based on the above

What are the existing internal control procedures for branches?

quartely quantitative and qualitative report? Or bi-annual? Or annual?

Complaint management process (dispute management procedure)

drafted

not clearly stated in the draft

to be done

procedure to be draft. I'll work on it

procedure to be draft. I'll work on it

the agreement with the solution provider

To be implemented in january 2021