M-PESA, Kenya’s mobile phone-based money 

transfer service, exploded onto the scene in 

2007. In just three years, it has attracted over 9.5 

million customers, in a country with only 8.4 million 

bank accounts. Every month, more than US$320 

million flows through M-PESA in person-to-person 

transfers, and the numbers keep rising. By nearly all 

accounts, M-PESA has been an admirable success 

and has expanded access to basic financial services 

to millions of underserved Kenyans.1 M-PESA has 

captured the world’s attention not only because 

of its success, but also because it is offered by an 

unlikely financial services provider—Safaricom, 

Kenya’s largest mobile network operator.

The success of Kenya’s M-PESA has raised the 

question of how most effectively to regulate 

nonbanks (See Box 1)—most notably mobile network 

operators (MNOs)—who contract directly with 

customers to issue electronic value against receipt 

of equal funds (“e-money”).2

MNOs like Safaricom are well-placed to reach 

customers with affordable financial services due to 

their existing customer base, marketing capabilities, 

physical distribution infrastructure, and experience 

with high-volume, low-value transactions (e.g., the sale 

of airtime) (Ivatury and Mas 2008). Yet, despite these 

advantages, regulators are often reluctant to permit 

MNOs to directly contract with customers for the 

provision of financial services. Taking money from the 

public, even for purposes of effecting payment rather 

than for saving, is uncomfortably close to accepting 

public deposits—an activity almost always reserved 

for prudentially regulated financial institutions, such 

as commercial banks. Funds kept with such banks3

are protected by strict prudential requirements (and 

related supervision) to ensure systemic stability and 

deposit security, and these same requirements would 

typically apply to electronic value issued by banks in 

exchange for deposited funds.4

Nonbanks are rarely subject to the kind of prudential 

regulation that apply to banks, so when nonbanks 

issue e-money, regulators are understandably 

concerned about ensuring adequate protection for 

customer funds. 

In recent years, however, policy makers around the 

world have noticed how nonbank e-money issuers 

could significantly promote financial services among 

low-income populations. Perhaps as a result, a 

number of policy makers around the world have 

issued regulations expressly permitting nonbanks to 

contract directly with customers for the issuance of 

e-money.5 From Afghanistan to the Philippines, West 

Nonbank E-Money Issuers: 

Regulatory Approaches to 

Protecting Customer Funds

1 According to Vodafone, a parent company of Safaricom, at least 50% of current M-PESA users are unbanked. 

2 In this Focus Note, “e-money” refers to electronically recorded value issued against the receipt of equivalent value. The electronic value, once 

issued, may be redeemed for cash, transferred between customers, or used by a customer to make payments to merchants, utility companies, 

and other parties. E-money may be issued by banks or nonbanks, but the term is used herein to refer to electronic value issued by nonbanks.

3 The term “bank” as used in this Focus Note refers to any supervised and prudentially regulated financial services institution that is commonly, 

but not always, a bank.

4 E-money issued by regulated financial institutions is not always subject to the same prudential protections (such as deposit insurance) 

afforded deposits.

5 A number of other countries, such as Kenya and Cambodia, have not issued e-money regulations but have nevertheless permitted such 

nonbank models on an ad hoc basis through “no objection” letters, conditional approvals, or other means.

No. 63

July 2010

Michael Tarazi 

and Paul Breloff

o

u

o
2

Africa to the European Union, jurisdictions around 

the world have adopted regulation that enables a 

leading role for nonbanks—while mitigating the risks 

presented by the involvement of a service provider 

that is not subject to full prudential regulation. 

This Focus Note reviews global regulatory 

approaches to protecting customer funds in 

the context of nonbank e-money issuers. Most 

every regulatory approach includes provisions 

for “fund safeguarding”—the requirement that 

nonbanks maintain unencumbered liquid assets 

equal to the amount of issued electronic value—

and other measures to ensure availability of funds 

when redeemed by customers against electronic 

value. Some regulatory approaches also include 

“fund isolation”—the requirement that the funds 

underlying issued e-money be insulated from 

institutional risks of claims by issuer creditors, such 

as claims made in the case of issuer bankruptcy.6

6 This Focus Note focuses on those regulatory measures that are intended primarily to protect customer funds in schemes involving nonbank 

issuers. However, other regulations not discussed here may be intended at least partly to protect customer funds. For example, minimum 

initial capital requirements found in some regulations may screen out unfit service providers or ensure an adequate financial cushion in event 

of trouble, mitigating the risk of provider failure or bankruptcy. Similarly, regulation in Afghanistan requires service providers to post bond 

as a condition of launching, in part to cover potential customer claims. Finally, some regulators require service providers to offer e-money 

services as a sole business line or from a separate legal entity to facilitate regulator supervision and to insulate the e-money business from 

institutional risks posed by other activities.

Box 1. Bank-based versus nonbank-based

The term “nonbank” refers to a nonprudentially regulated institution. (See Christen, Lyman, and Rosenberg 2003.) 

While the distinction is often made between bank-based and nonbank-based models of branchless banking, the reality 

is less binary: both banks and nonbanks typically play roles in any branchless banking scheme. In a bank-based model, 

customers have a direct contractual relationship with a licensed financial institution (even though a customer may 

deal exclusively with nonbank agents who conduct transactions on the bank’s behalf). In a nonbank-based model, the 

customer does not have a direct contractual relationship with a licensed bank, and instead exchanges cash for electronic 

value recorded in a virtual account on the server of a nonbank, such as an MNO or an issuer of stored-value cards. (See 

Lyman, Pickens, and Porteous 2008.) While this distinction is still useful in delineating two different legal models, it 

should be clarified that even in bank-based models, there is still typically an active role for nonbanks—and vice versa. 

The graphic below gives a sense of the range of ways banks may be involved in branchless banking schemes. 

Bank-Based Model Nonbank-Based Model

Bank(s) offer 

individual accounts 

that can be used 

through bankmanaged branchless 

channels

CAIXA (Brazil)

XacBank (Mongolia)

Bank(s) offer 

individual accounts 

accessed through 

nonbank-managed

agent networks and/or 

technological

platforms

EKO (for SBI in India)

SMART (for 21 banks 

in the Philippines)

Bank issues electronic 

value which is 

purchased from bank 

and redistributed by 

nonbank directly to 

customers.

Orange Money (Cote 

D’Ivoire, Senegal and 

Mali)

Nonbank issues 

electronic value and 

holds matchingvalue assets in 

pooled account in 

regulated bank.

Safaricom (M-Pesa 

in Kenya)

Globe (GCASH in 

the Philippines)

Bank Involvement in Branchless Banking Models
3

Fund Safeguarding

Fund safeguarding measures are aimed at ensuring 

that funds are available to meet customer demand 

for the “cashing out” of electronic value. 

Liquidity

In countries that have permitted nonbank issuance 

of e-money, regulators have typically addressed 

fund safeguarding concerns by requiring that 

such issuers maintain liquid assets equivalent to 

the total value of the customer funds collected 

(i.e., the total value of electronic value issued and 

outstanding, also known as the “e-float”).7 Liquid 

assets are most often required to be maintained 

as accounts with a prudentially regulated bank 

but sometimes they may be maintained as other 

“safe assets,” such as government securities, 

although such securities may not always be as 

liquid as bank accounts.8 Liquidity requirements 

exist in Indonesia, Afghanistan, the Philippines, 

Cambodia, Malaysia, India (in connection with 

prepaid payment instruments), and others. (See 

Table 1.) In Kenya, where applicable regulation is 

currently being drafted, Safaricom maintains fund 

liquidity by placing collected cash in prudentially 

regulated banks pursuant to a prior agreement with 

the Central Bank of Kenya (CGAP 2010).

Restrictions on Use

Liquidity requirements are sometimes reinforced 

by restrictions on the use of customer funds by the 

nonbank issuer—for example, by prohibiting issuers 

from using the funds to finance operating expenses. 

In Malaysia, for example, issuers are expressly 

prohibited from using such funds for any purpose 

other than “cashing out” against electronic value or 

executing funds transfers to third parties pursuant 

to customer request. Other limitations on the use of 

customer funds are more indirect. The Philippines 

expressly prohibits nonbank issuers from engaging in 

the extension of credit, effectively ensuring customer 

funds are not endangered through intermediation by 

an entity that is not fully prudentially regulated. 

Diversification of E-Float Fund Holdings

Funds held in prudentially regulated banks are 

not risk-free, as has been painfully proven by the 

recent financial crisis. When banks fail, they cannot 

always pay their depositors, often leaving smallvalue depositors to pursue recovery through 

deposit insurance schemes. In countries with weak 

banking sectors there is an even greater risk of bank 

failure coupled with the possibility that no deposit 

insurance exists. However, even where deposit 

insurance exists, the value of pooled accounts held 

7 Note that this is a more stringent requirement than imposed on deposit-taking financial institutions, which are typically subject to reserve 

requirements mandating only some small portion of overall deposits to be kept in liquid form (typically cash) to satisfy potential depositor 

claims. This difference in treatment reflects a fundamental difference among banks, nonbank service providers, and their respective business 

models. A bank’s business is predicated on the ability to intermediate capital, i.e., take money from those who have it and provide it (in loans 

or other products) to those who need it. Nonbanks, on the other hand, are expressly prevented from intermediating deposits and thus must 

make money in other ways, such as transaction charges, lowered airtime distribution costs, and reduced customer churn.

8 In West African countries under the jurisdiction of the Banque Centrale des Etats de L’Afrique d’Ouest (BCEAO), regulation also permit

funds to be invested in securities issued by registered companies. (See Table 1)
4

Table 1: Nonbank E-Money Issuers: Global Approaches to Protecting Customer Funds*

Fund Safeguarding Restrictions on Fund Use Isolation Measures Other Risk Mitigants

Afghanistan(Amendment to the Money Service Providers Regulation to Extend Regulatory Oversight to E-Money Institutions, 25 November 2009)

At all times, an e-money issuer must maintain liquid assets to at least 100% of e-float. (Section 2.5.5.1)Liquid assets consist of the sum of AFN-denominated banknotes and coins, held in a trust account at a banking organization (full-fledged bank licensed or permitted by Da Afghanistan Bank. (Section 2.5.5.1)

Liquid assets must be held in trust account at a banking organization (full-fledged bank licensed or permitted by Da Afghanistan Bank). (Section 2.5.5.1)

If total electronic value liabilities are greater than AFN 250 million, no more than 25% of liquid assets can be held at a single banking organization. (Section 2.5.5.2)If total electronic value liabilities are less than AFN 250 million, the e-money issuer is expected to observe prudent diversification of its liquid assets across financial institutions. (Section 2.5.5.3)

BCEAO(Instruction No. 01/2006/SP (31 July 2006) Relative a l’Emission de Monnaie Electronique et aux Etablissements de Monnai Electronique)

E-money issuers shall maintain investments of an amount at least equal to their financial liabilities related to debt representing the e-money issued and only in assets listed below:a) Cash deposits in a bank

b) Bonds issued by the central 

government or its entities or by the central bank

c) Securities (i) other than those 

referred to in point b above and (ii) issued by companies licensed by the Regional Council of Public Saving and Capital Markets, other than companies that have qualifying equity in the e-money issuer concerned or which must be included in the consolidated accounts of those enterprises.

(Article 18.1)

Commercial activities of e-money issuers are limited to the provision of services related to the issuance, the provision or management of e-money, and the storage of data on electronic devices on behalf of other corporations. (Article 9)

Indonesia(Bank Indonesia Regulation Concerning Electronic Money, No. 11/12/PBI/2009, 13 April 2009)(Circular Letter Concerning E-Money, No. 11/11/DASP, 13 April 2009)

In the case the issuer is an institution other than a bank, managed float funds must be placed with a commercial bank in the form of a deposit account consisting of savings account, current account, and/or time deposit account.

Issuer can use float funds only in the interest of liability fulfillment for e-money holders. Float funds may not be used for financing activities beyond the liabilities toward the respective holders such as financing issuer operations. (Circular Letter, Section VII.H.3)

License required only if float totals or is expected to total 1 billion IDR (approx. US$110,000). (Circular Letter, Section VII. B.1.a)
5

“Float funds placed at a commercial bank... must total 100% of the funds derived from sales proceeds of electronic money that represent the Issuer’s liability towards e-money holders...” (Circular Letter, Sections VII. H.1 &2)

Malaysia(Guideline on Electronic Money BNM/RH/GL -16-3, July 2008)

To avoid commingling of funds, the funds collected from users should be deposited and managed separately from the issuer’s working capital funds. (Article 10.1)Large E-money Issuer (MYR 1 million or more for six consecutive months)An issuer of a large e-money scheme should deposit the funds collected in exchange of the e-money issued in a trust account with a licensed institution. Such funds can be used only to refund to uses and effect payment to merchants. (Article 10.2(b))Funds may be invested only in high-quality liquid ringgit assets that are limited to deposits made with licensed institutions, debt securities issued or guaranteed by the Federal Government and Bank Negara Malaysia, Cagamas debt securities, and other instruments as may be specified by Bank Negara Malaysia. (Article 10.2 (c))Small E-money IssuerAn issuer of a small e-money scheme shall place funds collected in exchange for the e-money issued in a deposit account with a licensed institution, separated from its other accounts, and should be managed by the issuer in a matter akin to a trust account arrangement. The funds deposited can be used only to refund users and effect payment to merchants, and the funds shall not be invested in any form of assets other than as bank deposits. (Article 10.3)

Issuers of large e-money schemes who are unable to restrict their activities to e-money business only shall deposit and maintain an additional 2% of their outstanding e-money liabilities in the trust account at all times. (Article 10.2(f))An issuer of e-money shall not use the money collected to extend loans to any other persons. (Article 13.1(ii))

Philippines(Circular 649, 9 March 2009)

The e-money issuer should have sufficient liquid assets equal to the amount of outstanding e-money issued. The liquid assets should remain unencumbered and may take any of the following forms:1. Bank deposits separately 

maintained for liquidity purposes

2. Government securities set aside 

for the purpose 

3. Such other liquid assets as the 

BSP may allow. (Section 5.D)

E-money issuers shall engage only in the business of e-money and other activities related or incidental to the business of e-money such as money transfer/remittances. An existing entity engaged in activities not related to the business of e-money but wishing to act as an e-money issuer must do so through a separate entity duly incorporated exclusively for such purpose. (Section 5.B)Nonbank e-money issuers shall not engage in the extension of credit. (Section 5.C)

*Information in this table is based in part on unofficial English translations of relevant regulation. It is not intended as legal guidance or opinion, and reference should always be made to the original text.
by nonbank e-money issuers is typically much larger 

than deposit insurance coverage limits, leaving the 

issuer and customers more exposed in the case of 

bank failure. Afghan regulators sought to minimize 

the risk of bank failure by requiring that when any 

e-money issuer’s e-float exceeds a specified amount, 

no more than 25 percent of the cash funds backing 

such float may be held in a single financial institution. 

No regulations outside of Afghanistan expressly 

require such diversification as protection against 

bank failure, though the trustee of the M-PESA trust 

account in Kenya independently chose to minimize 

risk by dividing the cash backing M-PESA’s e-float 

among more than one bank. 

Fund Isolation

Liquidity requirements, coupled with other 

restrictions on use, may prove to be effective 

mechanisms for fund safeguarding.9 However, funds 

may still be at risk if the customer’s ownership of the 

funds is unclear.

While funds can be safeguarded in accounts of 

prudentially regulated institutions, such funds are 

often pooled and held in the name of the issuer—

not in the name of the customers. Therefore, the 

nonbank issuer is often the legal owner of the 

accounts, thereby making the underlying funds 

vulnerable to claims by the issuer’s creditors if the 

issuer goes bankrupt or if accounts have been used 

as collateral to secure specific debts of the issuer. 

In Kenya, M-PESA customers are isolated from 

creditor claims and other ownership threats by 

the use of a trust account that is administered by 

a third-party trustee and held for the benefit of 

M-PESA customers. However, other jurisdictions, 

particularly those jurisdictions where trust accounts 

do not exist, do not provide the same protections. 

Indonesia, for example, mandates certain fund 

safeguarding measures but the bank accounts 

holding the funds are in the name of the nonbank 

issuer. This is also the case in practice in Cambodia, 

although Cambodian regulators are reportedly 

considering regulation to replicate the protections 

afforded by the trust account structure in Kenya. 

Malaysia requires that customer funds be deposited 

and managed separately from the issuer’s working 

capital funds but while such separate management 

facilitates supervision of an issuer’s compliance with 

fund safeguarding requirements, it (like in Indonesia 

and Cambodia) does not isolate customer funds 

from claims by the issuer’s creditors. 

Even when nonbank issuers successfully isolate 

customer funds, mechanisms are needed whereby 

customers can retrieve funds in the event of issuer 

failure or other event requiring mass conversion of 

electronic value into cash. 

Emerging Issues

E-money models are still in their infancy. As these 

models gain traction and expand, other regulatory 

6

9 Another safeguarding measure is insurance. The European Union (EU), for example, permits safeguarding of funds through insurance

EU Directive 2007/64/EC permits nonbank e-money issuers in lieu of liquidity provisions, to insure or comparably guarantee the funds

backing e-float in an amount payable in the event that the nonbank issuer is unable to meet its financial obligations. EU Directive 2007/64

EC, Article 9.1(c) incorporated by reference from Article 7.1 of EU Directive 2009/110/EC (2009). Insuring deposits is not a safeguarding

measure adopted so far in developing countries.
7

challenges will arise, including (i) whether to treat 

e-money as savings products (rather than as simply 

funds transfer) and (ii) how to level the playing field 

among different kinds of entities offering similar 

services.

E-Money Platforms as Savings Products

E-money and other branchless banking services in 

developing economies have demonstrated their 

potential to bring millions of unbanked customers 

into the financial system. At present, the use of 

e-money is mostly limited to making payments. The 

hope is that e-money’s reach will eventually include 

other financial services, chiefly savings, which may be 

of even more benefit to customers. Consequently, 

regulators may soon confront questions about 

whether e-money accounts should enjoy the same 

benefits and protections as bank accounts. These 

include the following questions:

•	 Should e-money issuers be permitted to pay

interest on e-money accounts? Most regulatory 

authorities consider the payment of interest 

a feature of a bank deposit and consequently 

ban interest payments on e-money in an effort 

to clearly delineate between banking activity 

and payment services. However, this distinction 

between payments and banking activity is of 

questionable legal merit. Because deposit taking 

is often an activity reserved for prudentially 

regulated and licensed banks, regulators and 

nonbank e-money issuers have embraced the 

argument that nonbank e-money issuance is 

simply a payment mechanism and not a bank 

deposit. However, collecting repayable funds 

from the general public is arguably a “deposit” 

regardless of whether it is collected by a bank 

or payment services provider (Tarazi 2009). As 

e-money is increasingly used as a savings vehicle, 

and as there is evidence that customers desire to 

earn interest,10 regulators may be forced to reevaluate perceived risks and reconsider permitting 

nonbank e-money issuers to pay interest11 earned 

on pooled accounts.12

•	 Should the funds backing the e-float be covered

by deposit insurance schemes? In most developing 

country frameworks, e-money is not considered 

a deposit and, thus, is not covered by deposit 

insurance. This is the case, for example, in Filipino 

and Afghan regulation. However, as discussed, 

to the extent underlying customer funds are 

kept in bank accounts, such funds are exposed 

to the risk of bank failure. Even in circumstances 

where deposit insurance exists, the value of 

pooled accounts is often much higher than the 

applicable deposit insurance coverage limits. As 

10 The additional service most desired by M-PESA users (38%) is “earning interest” (Pulver 2009).

11 Some regulators have argued that it is important that any payment of interest be simply a “pass through” from the bank where pooled 

accounts are held to the end user. Such regulators fear that permitting an e-money issuer to pay interest or interest equivalent on its own 

could encourage e-money issuers to make unsound investments with its working capital (or pooled customer funds if such pooled funds 

are not adequately isolated) in order to pay out competitive rates of interest. However it is unclear why paying interest would encourage 

unsound investment any more than any other cost of the issuer. And provided the funds backing the e-money float are adequately 

safeguarded and isolated, the risk to end users is arguably minimal.

12 As interest accrued on the trust account established for M-PESA customers, Safaricom negotiated with Kenyan regulators to be able to 

use the interest for charitable purposes. Kenyan authorities did not allow the interest to be passed through to the customers whose funds 

actually earned the interest for fear that the payment of interest would make M-PESA a banking service rather than a payments service, 

requiring Safaricom to obtain a bank license and be subject to full prudential regulation.
8

electronic value offerings grow in volume and 

popularity, and as evidence mounts that e-money 

schemes are increasingly being used as savings 

vehicles,13 regulators may want to consider 

extending deposit insurance protection at the 

level of individual customer e-money balances 

or alternatively raise the ceiling for pooled 

accounts.14 Many developed countries already 

provide such deposit protection. The United 

States, for example, expressly characterizes the 

funds underlying stored-value cards as “deposits” 

covered by deposit insurance as long as such 

funds are placed in an insured institution (FDIC 

2008).

Level Playing Field

As new business models emerge and nonbank actors 

enter the financial services market, regulators are 

challenged to create a regulatory scheme that, to the 

extent possible, levels the playing field for service 

providers regardless of legal form. For example, 

Kenya’s banking agent law holds banks legally liable 

for their agents, but nonbank e-money issuers like 

Safaricom are not similarly liable. The discrepancy 

arguably disadvantages banks though some argue 

that the higher level of bank liability is justified since 

bank agents can engage in a fuller array of financial 

services, whereas M-PESA is considered simply a 

funds transfer/payments mechanism. 

Countries such as the Philippines, Nigeria, and 

Afghanistan attempt to create level playing fields 

by regulating e-money as a service, pursuant to 

a single regulation and under a single regulator 

(as opposed to regulating the different service 

providers based on legal form). Nevertheless, these 

countries do include separate provisions in relevant 

e-money regulation aimed at addressing the risks 

presented (such as fund safeguarding) by nonbank 

participation in the e-money sector.15

Conclusion

The arrival of mobile telephony and innovative 

technology is forcing regulators to re-evaluate their 

rules for financial service provision. Nonbanks like 

MNOs may be well-placed to dramatically expand 

the reach and range of financial services for the poor 

and unbanked. The challenge is to craft policies 

and regulations that mitigate the risks to customer 

funds without stifling the dynamism, creativity, and 

potential of these new actors. 

Forward-thinking regulators in several countries 

have crafted innovative approaches to meet this 

challenge. Policies related to fund safeguarding 

and isolation allow regulators to meet their goals of 

customer protection and financial inclusion. 

Enabling the entry and leadership of nonbanks 

need not be a threat to the central role of banks in 

13 In the Philippines, an estimated 10% of unbanked users save an average of US$31 (one-quarter of their family savings) in the form of

e-money (Pickens 2009). In addition, nearly a third of banked customers in Kibera, Kenya, keep a balance in their M-PESA account, and a 

fifth of the unbanked interviewees in Kibera use M-PESA as a substitute for informal methods of savings, especially keeping money at home. 

See Morawczynski and Pickens (2009).

14 On the other hand, deposit insurance is usually funded by premiums paid by participating financial institutions, which typically pass thes

costs along to their customers. Thus, inclusion of e-money issuers in a deposit insurance system may make their services slightly more 

expensive.

15 Creating a level playing field is often complicated by regulatory overlap and the risk of coordination failure between relevant authorities or 

even between different departments of the same government institution. For example, the banking supervision department of a central bank 

may prohibit banks from engaging in an activity that is permitted to MNOs by the payments department of the same central bank.
emerging market financial systems. Indeed, we are 

already witnessing how nonbank-based models like 

M-PESA may actually liberate financial institutions 

to innovate over the “rails” laid down by MNO 

pioneers—a recent partnership between Safaricom 

and Kenya-based Equity Bank launched M-KESHO, 

a product using M-PESA’s platform and agent 

network to provide an expanded set of banking 

services—interest-bearing accounts, loans, and even 

insurance. Such partnerships may very well mark 

the next phase of branchless banking, cementing 

the role of nonbanks in the delivery of a full array of 

financial services to those currently underserved by 

traditional banking models. 

9
10

References

CGAP. 2010. “Research Note on Regulating 

Branchless Banking in Kenya, 2010 Update.” http://

www.cgap.org/gm/document-1.9.42400/Updated_

Notes_On_Regulating_Branchless_Banking_Kenya.

pdf 

Christen, Robert, Timothy Lyman, and Richard 

Rosenberg. 2003. Guiding Principles on Regulation

and Supervision of Microfinance. Consensus 

Guidelines. Washington, D.C.: CGAP.

FDIC Financial Institutions Letters. 2008. “Insurability 

of Funds Underlying Stored Value Cards and Other 

Nontraditional Access Mechanisms, New General 

Counsel’s Opinion no. 8.” Washington, D.C.: FDIC, 

13 November.

Ivatury, Gautam, and Ignacio Mas. 2008. “The Early 

Experience with Branchless Banking.” Focus Note 

46. Washington D.C.: CGAP

Lyman, Timothy, Mark Pickens, and David Porteous. 

2008. “Regulating Transformational Branchless 

Banking.” Focus Note 43. Washington, D.C.: CGAP, 

January.

Morawczynski, Olga, and Mark Pickens. 2009. 

“Poor People Using Mobile Financial Services: 

Observations on Customer Usage and Impact from 

M-PESA.” Brief. Washington, D.C.: CGAP, August. 

http://www.cgap.org/gm/document-1.9.41163/BR_

Mobile_Money_Philippines.pdf

Pickens, Mark. 2009. “Window on the Unbanked: 

Mobile Money in the Philippines.” Brief. Washington, 

D.C.: CGAP, December 2009. http://www.cgap.

org/gm/document-1.9.41163/BR_Mobile_Money_

Philippines.pdf. 

Pulver, Caroline. 2009. “The Importance and Impact 

of M-Pesa: Preliminary Evidence from a Household 

Survey.” Kenya: FSD Kenya, June.

Tarazi, Michael. “E-Money Accounts Should Pay 

Interest, So Why Don’t They?” Blog post. http://

technology.cgap.org/2009/03/17/e-moneyaccounts-should-pay-interest-so-why-dont-they/

The authors of this Focus Note are Michael Tarazi and Paul Breloff of CGAP. The Technology Program at CGAP works to expand financial 

services for the poor using mobile phones and other technologies and is co-funded by the Bill & Melinda Gates Foundation, CGAP, and the 

U.K. Department for International Development (DFID).

The suggested citation for this Focus Note is as follows:

Tarazi, Michael, and Paul Breloff. 2010. “Nonbank E-Money Issuers: Regulatory Approaches to Protecting Customer Funds.” Focus Note 63. 

Washington, D.C.: CGAP, July.

No. 63

July 2010

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