Electronic Money Regulation, 2017 (South Sudan)

The Electronic Money Regulation, 2017, issued by the Bank of South Sudan (BoSS), is the foundational instrument legalising and regulating mobile money and electronic money in South Sudan, one of the world's least-banked countries, where digital financial services are central to financial inclusion and to the delivery of humanitarian and development cash assistance. The Regulation legalised mobile money as a payment method and provided the basis on which the BoSS, alongside the National Communication Authority, licenses mobile money providers. The first services (m-Gurush and Nilepay, with Zain South Sudan) launched under this framework, followed by MTN MoMo and Digicash. Scope and applicability: the Regulation applies to issuers of electronic money and providers of mobile money services in South Sudan. Such providers must be licensed by the Bank of South Sudan to issue electronic money and operate mobile wallets. Core obligations: licensed e-money issuers must safeguard customer funds backing the electronic money issued, holding them in a segregated/trust arrangement equivalent to e-money in circulation, maintain governance, risk-management and operational systems, perform customer due diligence (KYC), observe transaction and balance limits, manage agent networks, ensure transaction security and consumer protection, and comply with AML/CFT obligations and reporting to the BoSS. The BoSS has subsequently recognised mobile money as a legal means of payment for goods and services and has engaged providers (e.g. MTN) on system stability, regulatory compliance and consumer protection. Supervision and enforcement: the BoSS licenses and supervises e-money issuers, may impose conditions and corrective measures, and may suspend or revoke licences for breach. As the central fintech instrument in a low-capacity, conflict-affected jurisdiction, the Regulation underpins the BoSS's strategy to expand mobile money usage and digital financial inclusion. (A more comprehensive national payment system framework continues to develop.)

1. 1Legalises mobile money and regulates electronic money issuance in South Sudan
2. 2Requires a Bank of South Sudan licence (with the National Communication Authority) to issue e-money and operate mobile wallets
3. 3Safeguarding of customer funds backing e-money in a segregated/trust arrangement
4. 4Customer due diligence (KYC), transaction/balance limits and agent-network management
5. 5Transaction security, consumer protection, AML/CFT compliance and reporting to the BoSS
6. 6Mobile money recognised as a legal means of payment; BoSS may condition, suspend or revoke licences