Guidelines for Applicants for E-Money Schemes, 2019

The Guidelines for Applicants for E-Money Schemes, 2019, issued by the Reserve Bank of Malawi (RBM), are supervisory guidance that operationalise the licensing of electronic money schemes under the Payment Systems (E-Money) Regulations, 2019 and the Payment Systems Act, 2016. They detail the requirements that prospective e-money issuers, including mobile money operators, must meet when applying for authorisation, providing transparency and a clear roadmap for market entry. The Guidelines apply to any applicant seeking to establish and operate an e-money scheme in Malawi. They set out the application process and the documentation and disclosures the Reserve Bank expects, including details of the applicant's ownership structure and beneficial owners, fit-and-proper assessments of shareholders, directors and senior management, the business plan and financial projections, the proposed scheme design and technology and security architecture, governance and risk-management frameworks, and arrangements for the management of the agent network. Reflecting the underlying Regulations, the Guidelines emphasise the protection of customer funds through trust-account arrangements that fully back the outstanding e-money float and ring-fence customer money from the issuer, together with float and liquidity management. They also address customer due diligence and KYC tiers with corresponding transaction and balance limits, anti-money-laundering and counter-terrorist-financing controls, interoperability, consumer-protection and disclosure expectations (including complaints handling and fee transparency), and reporting obligations to the Reserve Bank. The Guidelines explain how the RBM assesses applications, the possibility of conditional approval and pilot or live-testing arrangements, and the ongoing supervisory expectations once a scheme is authorised. As guidance sitting beneath the E-Money Regulations and the Payment Systems Act, they are the operative how-to instrument for e-money licensing in Malawi and remain in force.

1. 1Operationalise e-money scheme licensing under the Payment Systems (E-Money) Regulations, 2019 and the Payment Systems Act, 2016
2. 2Specify the application process, documentation and disclosures, including ownership/beneficial owners and fit-and-proper assessments
3. 3Require a business plan, financial projections, scheme design and technology/security architecture and governance/risk-management frameworks
4. 4Emphasise customer-fund protection via trust accounts fully backing the e-money float, plus float and liquidity management
5. 5Address CDD/KYC tiers and limits, AML/CFT controls, agent-network management, interoperability, consumer protection and reporting
6. 6Explain RBM assessment, conditional approval and ongoing supervisory expectations