Integrity in Mobile Phone Financial Services : Measures for Mitigating Risks from Money Laundering and Terrorist Financing

This working paper explores strategies to identify and manage potential money laundering (ML) and terrorist financing (TF) risks in mobile financial services (m-FS). Using fieldwork in seven economies as a basis, the paper provides guidance on the best means of assessing perceived versus actual ML and TF risks, and then identifies specific measures to mitigate the actual risks. The paper concludes with recommendations that aim to promote a regulatory balance to foster an enabling environment for business while minimizing ML and TF risks that hinder its sustainability. The paper identifies four risk factors in m-FS and appropriate mitigation responses. The risk factors are anonymity, elusiveness, rapidity, and poor oversight. Anonymity is the risk of not knowing a customer's actual identity, and it can be diminished through enhanced know-your-customer procedures and identification tools. Elusiveness is the ability to disguise mobile transaction totals, origins, and destinations. It can be diminished through transaction limits and enhanced customer profiling, monitoring, and reporting. Rapidity is the speed with which illicit transactions can occur. Its risk is checked by flagging certain types of transactions and managing risks of third-party providers. The fourth type of risk is poor oversight, which can be mitigated by transparent guidelines on mobile services, clearer licensing, regulation of providers, and effective risk supervision within bank and non-bank m-FS providers.