Bank-only Licensing Model For E-money Issuance

Overview

ROLE IN DELIVERY OF E-MONEY SERVICEWHO PLAYS THIS ROLE?
BANKNON-BANK
License to issue e-money
 
 
Direct communication with regulator to request authorization for, e.g., new services or revised transaction limits
 
 
Contractual agreement with customer
 
 
Branding of e-money service
 
 
Delivery of e-money service (directly and/or through agent network)
 
 
Safeguarding customer funds
 
 
Licensing Models

Advantages & Disadvantages

Advantages

  • Banks already licensed and supervised by financial authority.
  • May already have sophisticated risk management and AML/CFT systems.
  • Can use e-money as a stepping stone to additional banking services.

Disadvantages

  • Banks may be unable to establish a viable business case for poor and rural population segments.
  • May lack understanding of unbanked and underserved market.
  • Few examples of major contribution to financial inclusion.
Bank Only

Country Examples

Bangladesh

bKash (bank subsidiary)

South Africa

FNB eWallet