CSBF Instruction n° 003/2017 relative au fonctionnement des comptes de cantonnement (Instruction on the Operation of Trust Accounts)

CSBF Instruction No. 003/2017 is an implementing instruction issued by Madagascar's Commission de Supervision Bancaire et Financière (CSBF) under Law No. 2016-056 on Electronic Money and Electronic Money Establishments. It governs the operation of the trust (segregation) accounts, comptes de cantonnement, that electronic money establishments must maintain to safeguard customer funds and guarantee the backing of electronic money in circulation. Scope and applicability: the Instruction applies to all authorised electronic money establishments (EME) in Madagascar. It requires each EME to hold customer funds corresponding to issued electronic money in a dedicated trust account at a credit institution, separate from the EME's own resources, so that those funds are ring-fenced and protected. Core obligations centre on the integrity of the e-money float. The Instruction requires that the balance of the trust account equal, at all times, the total value of electronic money in circulation in the EME's network (full 1:1 backing), and prescribes how the account is to be operated, reconciled and reported. It addresses the permitted use of trust-account funds, the prohibition on using customer funds for the EME's own account or for lending, periodic reconciliation between e-money outstanding and trust-account balances, and the reporting of those balances to the CSBF. It also addresses the protection of customer funds in the event of the EME's failure, ensuring depositors' claims are met from the segregated account. Supervision and enforcement: the CSBF monitors compliance through reporting, reconciliation statements and audit, and may sanction an EME that fails to maintain adequate backing or misuses trust-account funds. Together with CSBF Instruction No. 002/2017 on licensing, this Instruction gives operational effect to the customer-fund-protection objectives of Law No. 2016-056 and is fundamental to confidence in Madagascar's mobile money and e-money system.

1. 1Requires each electronic money establishment to hold customer funds in a dedicated trust account (compte de cantonnement) at a credit institution, segregated from its own resources
2. 2Full 1:1 backing: trust-account balance must at all times equal electronic money in circulation
3. 3Prescribes operation, periodic reconciliation and reporting of the trust account to the CSBF
4. 4Prohibits use of customer funds for the EME's own account or for lending
5. 5Protects customer funds, ring-fenced from the EME's estate, in the event of failure
6. 6CSBF monitors via reporting/reconciliation/audit and may sanction inadequate backing or misuse