Could new regulatory guidelines in Bangladesh turn MFS into “nobody’s baby”?

With the recent release of new draft guidelines for mobile financial services (MFS) in Bangladesh, I caught up with payments expert Raihan to get his views on the state of play of the market, possible outcomes from the guidelines and how we may see Bangladesh consumer financial needs better addressed over the next 5 years.


Raihan, to set the scene could you please share a bit about your role in the Bangladesh payments scene?

When I joined Grameenphone in 2006 on completing my studies in the US, these were early days for mCommerce in Bangladesh. We designed it all from scratch - processes for financial operations, reconciliation, the channel commission, payments, fund management and more. Seeing our BillPay service so popular in Bangladesh made it all worthwhile. I then moved to airtel where even in a bank led model we have built an award-winning mCommerce portfolio with specialized products such as micro credit disbursement together DBBL, our banking partner and 13 MFS partners including bKash.

What is the current state of play of the Bangladesh MFS market?

Bangladesh MFS market is now 5 years old. The top 2 operators bKash and DBBL together accounts for an estimated 74% of the market, with bKash leading since launch in 2011. A recent cGAP study estimates that 30% of Bangladeshi adults have used bKash while 4% have used the DBBL service. bKash users are more likely to be active, with 81% account holders active, compared with 67% for DBBL users. DBBL users are more likely to be registered users with 44% registered as compared to 23% for bKash.

As of June 2016, there are 36.2 million mobile banking registered accounts but only 13.3 million are active users. However, this data does not represent the number of unique users of MFS.

What’s behind this success of bKash?

I think this is due to the awareness that bKash was able to create ever since their launch and also their extensive retail reach. In terms of transactions, bKash still leads with over 80% market share although their annual growth in revenue has come down to 50% in 2015 from 81% in 2014.

What challenges do you face regarding user identification, AML and KYC?

OTC (Over-the-counter) continues to be hugely popular in Bangladesh, with 2.5 times more users than registered mobile wallet users. Retailers often transact on behalf of customers and this could create AML/KYC issues.

In 2016 we have started National ID verification process for mobile subscribers as Instructed by our regulators. Fortunately, as 90% or more of the active users of Telecom Services registered their SIMs, this may not impact the revenue and transaction volume of MFS.

Regarding usage pattern, I notice that unregistered users are more likely to use basic money transfer services while registered users also use advanced services including bill payment and mobile top-up. Today an estimated 8% to 15% of mobile top-up is done through MFS.

How is sticking with OTC a drawback to poorer users who only need basic services?

Today almost everyone has access to a mobile phone. Hence a poor person living in the remotest corner of the country can get registered through MFS and enjoy proper financial inclusion with the kind of services that are normally only available over a banking counter. Transacting through someone else’s wallet rather than your own is almost like a “Digital Hundi” or Sending money through the courier service which was actually one of the ways to send money in Bangladesh prior to the launch of MFS.

What was the motivation for new regulatory guidelines for MFS in Bangladesh?

MFS has always been a key focus for the regulators, specially Bangladesh Bank. Despite the rapid development of MFS and the huge potential to grow and reach the remotest corners of Bangladesh to boost financial inclusion, complete financial inclusion via mobile banking has yet to reach its full potential. OTC or unregistered use of MFS is one of the biggest drawbacks of the service.

This is why the Bangladesh Bank has been working towards a revised guideline that can encourage appropriate business models that help the market reach its potential and create a win-win situation for all the entities in terms of equity shareholding. I believe that with a few minor changes, this new guideline could help boost MFS growth and ensure financial inclusion in Bangladesh

So what are the new guidelines, and do they help address the issues?

Here I’d like to discuss two of the major clauses included in the new Draft Guideline:


Clause 4.1

BB shall permit delivery of the following broad categories of financial services by scheduled commercial bank-led Mobile phone based Financial Service (MFS) platforms in Bangladesh.


The scheduled commercial bank-led MFS platforms may have both banks and non-bank entities including Mobile Network Operators (MNOs) as equity holders, subject to banks holding majority beneficial ownership in total equity, no bank or non-bank entity holding more than fifteen percent beneficial ownership in equity, and Beneficial ownership of MNOs in an MFS platform not exceeding thirty percent of its total equity.


In Clause 4.1 we see that it remains a bank-led model as specified by the previous guidelines published in 2011. However, Clause 5.2 requires that no bank or non-bank entity hold equity share more than 15% individually. Banks must have majority ownership and Telcos may not collectively hold more than 30%. This means MFS projects will become nobody’s baby! This potentially creates a huge issue in regards to ownership.

What is the alternative you recommend?

In my view, we should first study what’s happening worldwide and learn from that. We should deploy a model which will be beneficial for the people of the country and will be owned by both Telecom and Banks. Telcos are good at things like branding, marketing campaigns, product management, agent management. Banks are expected to safeguard funds. Hence a model in which each of these players can execute to the best of their capability will be a successful one. My proposal would be that there should not be any restriction on the ownership of MNOs or any other equity holders. We should follow the good examples available across the globe.

Apart from equity participation, in what other ways are Telcos held back due to the guidelines?

There are several other areas where Telcos are not allowed to participate in the current MFS services. For example, Telcos are not allowed to promote the product, brand the product or launch different campaigns to promote MFS services. Telcos are only allowed to offer Telecom Data or talk time) for MFS promotions.

How do you see the market developing as we move towards 2020?

In the next 5 years, I expect the MFS market to be more mature and more compliant. SIM verification and re-registration will be imposed on MFS as well which will eventually limit the OTC usage and encourage use of mobile wallets. More advanced services will be launched so that people start to use MFS for services other than the basic money transfer.

Government already disburses payments (G2P) through MFS. In 5 years from now, I expect P2G to increase in a big way, so that payments including fees and taxes reach the government through MFS. Mobile Top Up usage will increase even more and may reach approximately 50% of total Telecom Top Up value.

MFS providers will further pursue Omni channel strategies, with some already providing the service through apps and the web. MFS services will be offered through other mediums such as NFC and it will not be only limited to USSD, apps or web and launch of 4G services will further boost usage.

Mobile Number Portability will be introduced in the country and, the need of having more than one MFS account with different Telecom operators will gradually decrease.

As stated by Bangladesh Bank, over the last couple of years, we have found that people at the “bottom of the pyramid” have been able to greatly increase their economic activities and that volume is increasing significantly each day. This contribution directly impacts the transactions volume in mobile banking.

Overall I look forward to MFS playing a major role in the growth of GDP of our country.



Ruhullah Raihan Alhusain is a payments professional with over 12 years of work experience in Mobile Banking Field. He graduated from the University of Texas at Arlington with Honors as Bachelor in Business Administration and led the Grameenphone mCommerce Operation Finance team before moving to airtel where he is Head of mCommerce Operations

Bridging the Digital Divide between Banks & Micro, Small and Medium Enterprises


In today’s guest post Sonum Puri of Accenture shares her thoughts on the opportunity in the MSME sector in developing countries and the gap in servicing their needs, reflecting on further work required for financial institutions to address these needs.


image Micro, small and medium enterprises (MSMEs) in developing countries face an estimated financing gap of $2.1 to $2.6 trillion ($3.2 to $3.9 trillion globally)[1]. MSMEs contribute to economic growth and job creation but inadequate access to finance, limits their impact in society.

MSMEs are impeded from accessing formal financial services due to cumbersome KYC and onboarding procedures, poor credit histories and lack of time to travel and queue at bank branches.

Some banks would argue that the processes applied to MSMEs are justified to mitigate high risks (creditworthiness is hard to denote) and as these customers are typically perceived as less profitable, no concerted effort is made to reduce constraints.

However, by failing to address the financial needs of this underserved segment, service providers are potentially missing out on a US$380 billion revenue opportunity[2].


Although microfinance institutions (MFIs) have helped close the credit gap, especially for women entrepreneurs, many do not have the resources, financing capacity and products beyond microfinance to meet the evolving needs of MSMEs (savings/deposits, insurance, pensions, remittances etc.)[3]. In fact some MFIs such as miBanco (Peru) and Bandhan (India) have turned into banks in order to diversify product offerings.

In developing countries, rising affordability of devices is encouraging growth in smartphone adoption, reaching 63% (2.9 billion) by 2020, with the majority running on mobile broadband[4]. Increasing smartphone and internet penetration will enable MSMEs ranging from a small business owner in the Philippines to a garment producer in Indonesia and a smallholder farmer in India to connect to a variety of online digital products and services by clicking a button.

Leveraging digital channels and operations will allow banks to also reduce the cost to serve the MSME market, whilst acquiring new customers and increasing profitability. Yet banks need a compelling digital value proposition, incorporating financial and non-financial needs that will help customers grow their businesses and improve their own welfare and that of their families.

The concept of the ‘Every Day Bank’[5] goes far beyond a transactional relationship to one in which banks will offer a variety of digital services that will increase the daily interactions of MSMEs. But to get to the ‘honey pot’ the sign up procedure needs to be online, fast and simple. Credit decisions need to take minutes, not days. Customers need to be able to conduct their business as efficiently and productively as possible.

Employing a low cost distribution model (using brick and mortar and digital infrastructures) will benefit both banks and MSME clients. Virtual contact centres, loan disbursements and repayments through mobile phones and point of sale (POS) equipped bank staff in addition to using retailers to expand distribution and perform basic banking/customer services, are some of the available options.

Social media platforms can assist banks to prove identity and make better informed credit decisions on customers who may not be regular banking users or have much of a financial track record, but are likely to be on Facebook and have a social media history. Based on the data generated, loan approvals can be turned around very quickly. Similarly mobile phone behavioural data can be utilized to assess credit worthiness.

Digital Services that can help address customer pain points include:

  • Faster onboarding and KYC procedures (online forms, analytics/social media platforms, biometrics, digital signatures and electronic document transmission)
  • Personalised financial services and reporting (pre-approved offers, third party lending analytics, online portal/digital relationship manager, digital supply chain financing and mobile cash pick up)
  • Business administration tools (virtual CFO, single view of customer accounts, cash flow and expense management capabilities and analytical platforms for forecasting)
  • Integrated banking experiences (ability to access services from any device, anytime and switch from one channel to another for account opening, banking products origination and servicing)
  • Connecting to a broader ecosystem (B2B network hub, P2P collaboration tools and access to alternative financing)
  • Solutions to improve products and services (business services and Ecommerce enablement and virtual platforms to gain industry insights and advice)
  • Financial literacy programmes (mobile phone delivered education and training and videos)

The threat of competition from challenger banks, telcos and other disruptive players has led to some banks responding including:

  • ANZ - mobile app to monitor real-time account balances, view current and prior-day transactions and approve or reject payments
  • Maybank - mobile POS service that enables MSMEs to benefit from wireless payment to save time going to bank branches
  • Barclays – remote account opening through an app on smartphones and tablet devices on which customers apply for a personal loan and receive funds in less than 10 minutes
  • CBA – online balance statement, cash flow report and business insights that customers can use to benchmark with competitors

The more innovative banks are even joining forces with the new competition, take for example India’s ICICI bank working with Chinese Ecommerce firm Alibaba to establish an online trade facilitation centre or RBS who is partnering with Funding Circle (online lending marketplace) and Assetz Capital (peer-to-peer lending platform) to provide alternative financing sources.

Neither banks nor any other stakeholders can go it alone. To get to scale and truly build long standing relationships with the MSME segment, collaboration with a range of ecosystem partners is absolutely critical. Cross industry partnerships present an opportunity to offer complementary financial and non-financial products which service providers might not have been able to offer otherwise.

FullSizeRender Sonum Puri is a manager within Accenture's ASEAN digital team. Sonum is committed to helping banks, MFIs, other FIs, telcos, governments and donors use digital solutions to improve front to back end processes, increase operational efficiency and expand financial services in developing countries.

Prior to joining Accenture, Sonum worked as a digital financial services consultant to the UN, providing advisory services to stakeholders creating new product innovations in digital financial services. She has conducted research and analysis, strategy development, agent/staff training and service implementations in the Philippines, Papua New Guinea, Timor-Leste, Sierra Leone, India and Kenya.

Sonum may be reached at








Addressing the mysteries of the Pyramid through mobile financial services

Pyramids have fascinated civilizations for centuries, with the Great Pyramid of Khufu in Egypt today remaining the only one of the Seven Wonders of the Ancient World. While the Egyptian pyramids are most famous, Nigeria, Greece, Spain, India, China, Indonesia and even Europe and the Americas have their share. The unique design and the sheer weight of the stone ensures that the structures do not topple, and there is no question of material at the bottom ever getting displaced. Now in these and other countries mobile financial services are taking off, to address financial inclusion. I was fascinated by C. K. Prahalad’s book “The Fortune at the bottom of the Pyramid” which has been an inspiration to me over the last decade I’ve spent as a practitioner in mobile financial services.

Carol Realini’s work at Obopay has also been inspirational to me, as I had an early opportunity to meet her and follow her achievements in the US, Africa and India. I was therefore delighted when Carol shared with me about the book she and Karl Mehta were writing, “Financial Inclusion at the bottom of the pyramid”. Naturally I wanted to share her story, below – Enjoy!


Carol, great to have you here today, please could you share with us a bit about what motivated you to write this book, and what you hope to achieve?

My interest in Financial Inclusion started in 2002 while travelling in Africa after a company I founded had a successful public offering.

My eyes were opened to—

  • The wonderful entrepreneurial spirit that exists throughout developing countries
  • The lack of infrastructure for participating in global online commerce
  • The lack of infrastructure for making day-to-day living easy. Locals were standing in line all day to just pay their utility bill and small businesses were confined to operating on a cash basis with their customers and suppliers.  
  • The absolute inability of entrepreneurs to scale and grow their businesses.

I became focused on fostering entrepreneurship and the development of new technologies that would empower everyone’s life and work.

The epiphany—

I had never really thought about life without access to affordable financials services. Mobile phones were everywhere and now exceed the world’s population. I realized this could be a game changer for financial services, creating a very different future for all of us. After witnessing the overwhelming poverty and unwieldy payment systems, I knew that mobile banking would be the key to altering how people exchange money, and in turn, create access to financial services where none had ever existed.

To whom do you feel this book will be most useful and why?

Our book primarily targets two audiences: Firstly the FinTech community, as the mobile phone is a key enabler for innovation. Secondly, really I would love for it to reach all people interested in how the world could change for the better. We hope that our book entertains and informs both audiences. It delves deep enough to share new insights with the FinTech community, yet effectively explains the financial services landscape to those who are ready to learn and be inspired. So far reviews have been very positive from both groups. Having been exposed to real-life case studies that are changing the face of financial services, readers from all over are inspired by the global shift that lies in front of us.

You are yourself one of the pioneers, can you share a bit about your story?

2authorstogetherI have founded two companies within the Financial Inclusion sector and I am an active board member for several other companies working in mobility and “mass-market fintech.” My co-author, Karl Mehta founded a global payments company which was later sold to Visa. Throughout that transition he was key mobility executive and now is an active Venture Capitalist  and Founder/CEO of EdCast— a disruptive approach to higher education.

My first company, Obopay was a pioneer in Financial Inclusion and is currently one of the leading providers of mobile money in East Africa. We were early to enter the market and saw first hand the challenges when the infrastructure for identity, settlement, and communications was immature.

Mobile phones are now a mainstay all over the world and many countries in Asia and Africa have sorted out regulations to handle incoming technologies. Smart phones are also scaling very fast, creating more space for innovation.

Once the technological and regulatory landscape was primed, my second company (a US-based faster payments company) scaled quickly and was acquired in under 2 years. I am now on the board of 5 companies all working in this space and help others wherever possible.

In a nutshell, what do we need to get right, for financial inclusion @ BoP to become a reality?

Regulations and infrastructure are key to massive change. Institutional banks and investors also need to embrace innovation. Opening our eyes to including innovation from unexpected places will create more opportunity (for instance, Telcos have become the last mile to the customer for banking). Finally, considering new players in the space with disruptive models can bring a new perspective, and sometimes, a better solution to a problem.

At the end of the day, the financial needs of those at the BoP will not match those who use traditional banking. We need to create products and services that are relevant to each customer and their lifestyle. These will look and behave differently across countries, states, towns, and villages.

We hope our book helps to open the reader’s eyes to what is possible, what is currently working, and where there is opportunity for change. It proves that solutions DO exist—they are just not evenly distributed.

You give a call to action at the end of your book, could you share a bit about this?

If you are inspired to change the world, it is easy to get involved. You don’t have to quit your day job or be a “mover and shaker” within the FinTech community. If every reader made one small shift in their lives to support financial inclusion (start a group, show a preference for companies who are committed to financial inclusion, or join the conversation @SuccessatBOP), we’ll be well on our way to a better place for all.

I have found that once readers realize they already have a voice, they become inspired to create change, whether by one simple action or through massive effort. Either way, I think the book shows how important these initiatives can be. As Jeffrey D. Sachs, Director of the Earth Institute at Columbia University (and generous author of our Foreword) puts it: “The end of poverty is coming our way and this brilliant book explains how and why.”

Carol, Who are the unbanked and could you share about “Financial Nomads”, something I found very interesting when I read your book

Half the world are Financial Nomads. The world population is roughly seven billion. Of these, 4.6 billion are aged twenty or older. They comprise the pool of adults who could be regular customers of a financial services provider—a bank, savings and loan, credit union, or even Wal-Mart. Estimates suggest that of this eligible pool of 4.6 billion adults, over half—2.5 billion—do not use an established and reputable financial services provider. They are financial nomads who either have no access to financial services or use financial services on a casual basis when they need them.”

Apart from income, what are some of the other factors that have an impact on financial inclusion?

Gender, education levels, age, rural or urban life - all of these matter, but especially gender. In developing economies, forty-six percent of adult citizens have bank accounts, but only thirty-seven percent of women do—and this number includes joint accounts held by both husband and wife. In developing economies, this disparity exists at all income levels. In high-income economies, the difference is less and only approaches a four percent difference for poor women.”

Carol, how does this affect me, a middle class individual living in a developed country?

The lack of affordable and adaptable banking services is an issue that should concern everyone, not just the people who are living at the bottom of the pyramid. At its worst, a lack of banking creates a downward spiral of disenfranchisement, widens the gap between rich and poor, encourages outlaw or extralegal behaviour, and inhibits the social mobility that keeps any society vibrant and open. An accessible and reliable banking system helps to create stability and overall prosperity.

We have seen the costs to living at the bottom of the steep pyramid, and the obstacles that keep many hardworking individuals and families from making the long climb to the top. However, the goal of this book is not only to point out the challenges but to draw attention to the real-world solutions that exist today.

How far have we come so far in addressing this issue?

We’ll see that, in many cases, the future is already here; it’s just not equally distributed yet. Innovation is emerging as a patchwork. We’re entering a new era where the world will see a shift from incremental advances in financial inclusion to exponential growth. Part of the revolution in personal finance is driven by global social change: the growing empowerment of women, the rise of stable democratic governments, and the increased recognition of basic human rights. Technology is also a major force; the rise of the Smartphone, improvements in banking infrastructure, cloud computing, social networking, the management of vast amounts of real-time and archival data, mobile technology and networks, and the successful scaling of regional models to national and international scale - are all drivers of change.

Carol thanks so much for taking the time to address this important area and I wish you the very best for the success of your book and this key initiative


Carol Full Avatar

Carol Realini is co-author of “Financial Inclusion at the Bottom of the Pyramid”. An expert in financial service innovation, Carol Realini is a serial entrepreneur and globally-recognized technology pioneer. Attending the World Economic Forum, she led global discussions on alternative banking. Recognized as a top woman in Silicon Valley, she sits on boards and advises financial services and mobile companies.

Apple isn’t interested in payments


Shift Thought recently completed a set of interviews where we spoke to experts from a range of industries and parts of the world to get their gut reactions on the state of the payments industry and what to expect next.

In this post I share highlights of my discussion with Roy Vella, Digital Services Evangelist and Entrepreneur with a rich experience across a wide range of organizations in EMEA and the U.S. Roy reflects on what for him were some highlights of 2014 and shares his thoughts on what to expect this year.


Roy, thanks for your time today. I would like to start by asking what, for you has been the most innovative service you’ve seen over the last year, at the intersection of mobile/ online and financial services?


applepayFor me, Apple Pay has been the most significant. Once again, they did what they do so well. They take something messy and refine it. Just as they did with iPods/iTunes and the iPhone, they’ve created a great customer experience by making a few key changes. Apple tends to be able to take things off the shelf but then simplify and get the experience right.

When they launched the first iPhone, arguably they did it with what could already be bought off the rack in China. It’s not what they deliver but rather how they put it all together, to make it simple, intuitive and delightful. That is the innovation! It is not making something radically new but it’s making something truly simple.


But in order to make it simple, they’ve managed to bring together a lot of different technologies for the first time, to allow a simple “press the button” experience.


True, they had to bring together Passbook, Touch ID, NFC capabilities, encryption, tokenisation and more. Apple is probably going to kill the business proposition of a lot of providers accidentally, even though they don’t actually care about payments. All they care about is bringing together those three things that you, I and everyone need before we leave home: your keys, your wallet and your phone.

Apple simply wants to put it all together. They want to get rid of your wallet. And they’re making progress on this with Apply Pay, the Apple Watch, with their work on access to hotel rooms and security. I’m sure they’re talking to major hotel groups, luxury car manufacturers and others, to make big changes in how people gain access to all sorts of places and things.


What are the pain points that providers encounter when they try to bring out Payments Innovations?


What they find difficult is what Apple does so well. It’s essentially the battle of getting people to adopt something new. That is what Apple is good at – changing consumer behaviour, getting people to change the normal way that they do things.

For any infrastructure play the most difficult thing is that most people don’t want change. And innovation is hard because key stakeholders, regulators and others also often don’t like change.

Actually people often talk about achieving “mainstream adoption” but that’s not what concerns Apple. They want those premium customers. That is their segment. The top 15-20% max really.


But if Apple is solving for the 15-20% premium customers, who is solving for the rest?


Before Apple Pay we had similar solutions on the Android, 9 months to a year earlier! Google, Samsung, PayPal and others offered quite similar services as Apple Pay. But did anyone take notice? We did not see them move the needle – then Apple announces and boom, consumers sit up and we have change.


Who for you are the winners of 2014? Which categories of players impressed the most?


I don’t think mobile operators as an industry were able to do that much. Sure, we’ve heard of various partnerships between banks and operators or other categories. However it was not ground breaking innovations. I believe that both banks and mobile operators have taken a back seat to the big tech services, GAFA, at this point. And they’re all innovating rapidly.

The other group that’s made significant progress over 2014 is the regulators. They’re no longer spending all their time protecting the incumbents. They want more competition, entrepreneurs and a better deal for consumers. This is playing out across the US and Europe, and also worldwide.


Talking about regulations, what’s your opinion of Bitcoin?


I feel that Bitcoin tends to be misunderstood. It is a currency of sorts but more importantly a protocol, the blockchain, but often people are fixated on the first and don’t quite get the second. Reliably moving value between parties, without a middleman, is a brilliant innovation. It is not all about money. It could be any object of value or ownership – it could be a birth certificate or a lease, for example.

No matter what anyone may think, cryptocurrencies are here to stay. It’s impossible to stop them. Saying that you don’t like bitcoin or the blockchain and it should be stopped is like saying your don’t like SMTP or HTTP… it’s merely a technical protocol for value transfer that now exists and won’t simply evaporate as such, even if regulators attempt to quash it.


Yes, banks have not made it easier, with their massive FX scandals and other issues. Do you see this pushing people further toward P2P and innovative new entrants?


Absolutely! Take the example of Transferwise. I think they’ve done a brilliant job shining a light on fees and making things more transparent. Ultimately consumers care about how much they pay and what their receivers get in terms of currency. Transferwise states that in terms of what you put in and how much you get out it’s hard to get a comparable rate. Significantly, Transferwise has gotten their marketing and message right… it resonates with people.


Roy, from your experience at PayPal, it would be good to hear what you think about the PayPal/eBay separation – how’s that going to work out?


We were talking about this way back in 2004. It is something that had to happen, but back then they needed each other tremendously. However staying together is holding them both back now. I know they will be better apart. It’s going to be good for PayPal, sure, but it’s also going to benefit eBay. I think individually they could each have the same valuation as they have together.


You talk about the digital wave and how that is subsuming things - What really changed over 2014 thanks to mobile?


I think 2014 has been all about smartphones achieving deep, mass penetration. This is not just in developed countries but also in the high-growth emerging ones.


What do you foresee for 2015? What’s most exciting?


I think the chip is going into everything. Having all these devices become smart, there is an early adopter phase that is quite exciting. It is not all about payments. Payments must be transparent, just an enabler and it must make everything simpler for consumers and merchants.


Thanks Roy, it’s been a pleasure speaking with you. Wish you the best for 2015 and beyond!



Roy Vella is Managing Director of Vella Ventures Ltd where he offers strategic advice as an expert in the Fintech industry.

Roy is special Advisor to MEF and on the board of several companies. Notable clients include Visa, Vodafone and Lloyds.

Previously Roy was Group Executive, Director of Mobile Financial Services for the Royal Bank of Scotland Group. Roy also has rich experience from his work at PayPal Europe as Director, Mobile Payments for Europe and in Business Development for PayPal Inc. See more at

Mobile Money and Branchless Banking in Nepal

As authorities and developers work hard to help families somehow struggle through the devastating results of the 7.8 magnitude earthquake of April 25 and the second major earthquake of May 12, my thoughts turn to the longer term benefit to be had, in promoting the development of financial services that will help recovery over the next 5 years.




Mobile money clearly has a key role to play in this breathtakingly beautiful country, to help to empower the population in a variety of different ways. Thanks for joining me in reflecting on this, as I share some of our findings from our recent report “Digital Money in Nepal 2014”.

A clear need

The biggest driver of digital money in Nepal is the need for financial inclusion. Of the population of 28.9 million, only around 33.5% are banked, but there are over 18m mobile subscriptions. Mobile phones are therefore a good way to reach people with financial services, with Internet penetration only an estimated 28.9%.

Moving from cash to non-cash, appropriate electronic payments can reduce the cost whilst allowing outreach to poor and remote people in a manner never possible before. But the rate of adoption greatly depends on the actions of government, commercial and development entities in moving payments to the new instruments.

While the Kathmandu area is a hotspot for banking, the concern has been to reach areas outside the valley. While Nepal Rastra Bank (NRB) has set up branch opening policies to promote this (1 branch in Kathmandu after 3 outside the valley), the challenge is to create economically viable, alternate and appropriate services.

Regulations and the challenge of Shadow Banking

In December 2012 NRB issued a circular to allow branchless banking agents and direct how internet- and mobile-based services like branchless banking, mobile banking, internet banking and card services offered by banks and financial institutions (BFIs) must obtain approval.

Where there are needs, services rise up to meet them. NRB is concerned about the rise of shadow banking in the form of unlicensed and unregulated cooperatives and Dhukuti and Hundi services, but in the absence of alternatives, these informal activities play a key role in servicing needs.

Card services are still relatively new, and branches and ATMs are simply not sufficient to reach into the remote areas of the country. Banks in Nepal began to offer online banking and mobile banking for over 10 years now. However while the Class A banks (around 30 in Nepal) were first to launch services, the Development banks (around 90, with an additional 21 Micro Finance banks) and NGOs (around 40) will play a critical role in taking the services in the appropriate manner to where they are needed most.

New mobile wallet and mobile money services are being launched and their success will depend on the partnerships forged, and the extent to which this results in new value-added services.

Why Branchless Banking?

Given the historical and geographical challenges, the share of the population living below the poverty line is still as high as 31.5%, though this has fallen recently driven by the flow of remittances into the country.

Branchless Banking can play a vital role in building a country asset from the vibrant informal economy. Remittance income from the 2 million Nepalese diaspora is crucial for the country, and constitutes an estimated 17.3% of gross domestic product. As money goes digital, more of the informal economy gets reflected on the balance sheet of the country. With an annual remittance inflow of over $14 billion from the 2 million diaspora, it is expected that as much as 90% of remittances may well be informal.

If formal remittances increase, it is a win-win for consumers who get the safety and convenience of receiving money directly into their BB accounts, and the government who see more of the money on the books. Again, as Government disbursements turn digital, much of the spending gets accounted for, driving investments as providers see the hope of viable markets.

The story so far

In June 2012 Laxmi Bank launched Hello Paisa in Kavre and Sindhupalchowk. Hello Paisa provided by Finaccess, is a shared and interoperable managed service provided to BFIs. It uses IVR and SMS to allow money transactions using smartphones. The Hello Paisa network has over seven BFI partners. In 2013 the Prabhu Group network, consisting of more than 3,500 money transfer agents and 1,500 cooperatives nationwide entered an agreement with them to provide end-to-end mobile financial services (MFS) offered by the Hello Paisa Network.

Digital networks indeed play a key role in disbursements, as do the various mobile banking and mobile wallet services, including 14 key services that had launched by the time of our study.

Where next?

Today as people around the world are in solidarity with folks in Nepal, this is an inflection point for the country.

I believe change of the right kind can and should happen, and decisions taken in the next months will critically contribution to this.

Your thoughts

Trends in Mobile Money and Mobile Financial Services – Views from a veteran


The origins of Mahindra Comviva date back to 1999. Since then the company has enabled mobile operators and financial institutions around the world to address opportunities presented by money going digital. As part of Shift Thought’s assessment of the state of the market, it was a real pleasure to speak to Srinivas Nidugondi, to obtain his views on the latest trends and future directions. In this post I share highlights of our discussion on mobile money and mobile financial services.


Srinivas, thanks for your time today. Could you please give us a bit of background about your expertise and your role at Comviva?


imageI head the mobile financial solutions unit at Mahindra Comviva. For four years now, I head the entire commerce portfolio within Comviva. We have 3 verticals that include commerce, content and data, all with the underlying theme of mobility.

Within our horizontal of managed services, our fastest & largest pillar is commerce. I look at the overall opportunity, to grow our operations into a leadership position. I have a background in banking and payments, commerce and smartcards. My last position was at ICICI bank where I was Head of Internet Banking platform and Mobile Banking and worked on the launch of ICICI’s first mobile banking app 8 years ago; further I was involved in a collaborative offering with Vodafone to cater to the unbanked and under banked segments in India.


Could you please give us a brief background about Comviva?


imageWe’ve been around for 15 years, beginning with the Telecom Revolution in India and other emerging markets focussing on products that would help mobile operators, in our capacity as part of the Bharti group.

Our mobiquity® Money solution now has over 50 deployments in 40 countries, enabling over 35 million registered customers to transact approximately USD 13.5 billion transactions annually.

Over the last five years we have streamlined and also broad-based our focus. As a product company we complement Tech Mahindra’s IT services and also obtain access to new geographies, such as our recent forays into North America, Europe and Australia. Further, we have been able to penetrate into Latin America with several deployments on-going across the region.


Could you give us highlights of the kinds of products and services, and the kind of competition you face?


In our mobile financial services unit our philosophy is to leverage mobility, commerce & payment services. What this means is we do not just focus on providing payments solutions but are experts in the whole commerce process. Also we have refocused from mobile to mobility, to cover new devices that I expect will become an active part in the way people transact, for instance through wearables like Apple Watch or Google Glass.

We focus on payments behaviour within each segment that includes consumers, businesses and merchants. So we look at a diverse set of scenarios that range from under banked consumers to evolved consumers to large merchants. We are one of the largest providers for Mobile Money in the world, with services provided to pretty much every major mobile operator.

We are going up the value chain with services such as mobile wallets, mobile payments, and QR codes, BLE, HCE, NFC and Apple Pay and offering these solutions to banks, processors and retail industries apart from the traditional customer base of telecom operators. Our recent customers include banks in the North America and Asia pacific regions as well as a new age retail chain in South America. And further, we are working with a telecom operator in Europe for launching NFC based payments. Our competitors include for instance C-SAM, Toro, Airtag and Monetise.

On the business and merchant side we offer an integrated payment solution payPLUS that allows both large and medium merchants as well as SMEs to use their mobile phones as a POS, and we work with First Data and not just small & medium - there is a market for mobility based for insurance, e-commerce down to small and medium.

We are entering the US through one of the largest processors where competition is different. We don’t really see Square and iZettle as our competition as we don’t go direct to market but rather work with banks and processors. We also face localised competitions such as from Easytap in India.


What are some of the major implementations you’ve been involved in around the world?


We have over 50 mobile money implementations including a number of implementations with Airtel, Orange, Econet Wireless, Grameenphone, Banglalink, Tigo and others. In Bangladesh we are deploying with DBBL, one of the largest banks in the country.

We are working with First Data and other large processors and also with some of the largest banks for HCE, MasterPass. We are with the largest 4G operator in India for Mobile POS and Mobile Wallet. Some of our latest wins include a retailer in Chile, and US work with a processor for mobile POS, and a wallet for a bank in Canada.


In 2014, mobile money service became interoperable in 3 new markets. Could you tell us a bit about how this works and how effective this strategy has proved?


I don’t think every market could be a success. This is a function of multiple factors. In Kenya Safaricom became successful with a position of leader in the mobile business. Now Tanzania is becoming an overall leader in mobile money, but there no one operator has a monopolistic position.

Mobile money has taken off where there is low banking penetration and high mobile penetration. Agents must find it viable. Also the services need to go beyond just P2P or Cash-in/Cash-out. People must not just withdraw cash but make payments through their mobile money account. That is when profitability goes up.

It is also really important to be able to offer remittances. There is a service called Terra that is getting all the operators together for this to make the money flows easier in corridors such as Mozambique to Malawi, Zimbabwe to Malawi and South Africa to Zimbabwe.

If each operator has say a maximum of 40% market share, this means that 60% of the market is excluded, so interoperability is not a luxury but is critical for operators to explore in each market.


What are some of the other trends you observed in mobile money in 2014?


Mobile Money is used in a developmental context, where third party provides bring financial services to people who don’t have access to them.

I observed three key trends in mobile money over 2014.

Firstly, the evolution to cover more services has been recognised to be of huge importance. From cash-in/ cash-out, it is now about enabling every transaction that people have to make. So this is interoperability in the context of payments.

Secondly, there is a focus on interoperability in the context of remittances. We saw a spurt in transactions with Tigo and Airtel making their transactions interoperable in Tanzania.

Thirdly, it’s about how to build a path to offer a full suite of services, not just mobile money. We’ve had to solve for enabling payments, micro-loans, investments and insurance, so as to build a “One-Stop Shop” for all these services.


Did regulations have to change in order to enable these trends and new services added over 2014?


No I think the regulations did allow it, but it was a matter of the maturity level having grown over the last 3 years. As this grows further we’re seeing more such examples in Tanzania, Zimbabwe and elsewhere.


What is the outlook for mobile money going into 2015?


I see an evolution of the services to straddle multiple areas. From over-the-counter and one time transactions it’s now all about the mobile wallet. This needs a better understanding of the end-to-end customer journey and experience.


Srinivas, thanks very much for your time today. It has been a great pleasure speaking to you. I wish you the very best for your success in 2015 and beyond.



Srinivas Nidugondi is Senior Vice President at Mahindra Comviva, based in Bengaluru, India and has led the Mobile Financial Solutions area in Comviva since 2011.

Srinivas brings a keen interest in financial inclusion, especially as enabled by mobile phone and digital channels and has a wealth of experience in banking, payments, Internet and e-commerce. He set up & led the business for online banking and mobile payments in a large multinational bank and has led product management & business development in start-ups and IT product companies.


Charmaine Oak

Author of The Digital Money Game, co-author Virtual Currencies – From Secrecy to Safety

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