Mobile Money Compliance Solutions for Africa & Asia
AML and KYC technologies for mobile payment platforms and digital wallets in emerging markets
Compliance Solutions for Mobile Money
AML and fraud prevention for mobile payment platforms and digital wallets
Mobile money platforms have revolutionized financial inclusion across Sub-Saharan Africa, South Asia, and Southeast Asia, but they also introduce unique compliance challenges. With millions of daily transactions and a diverse user base, mobile money operators need scalable AML solutions that can adapt to limited customer data while protecting against fraud.
Anqa Compliance provides mobile money-specific compliance tools designed for high transaction volumes and limited-identity environments common in emerging markets, balancing regulatory requirements with financial inclusion goals.
Key Challenges
- Limited Customer Data – Many users in emerging markets lack traditional ID documentation.
- High Transaction Volumes – Processing millions of micro-transactions daily requires scalable monitoring.
- Agent Network Risks – Managing compliance across thousands of agents and distribution points.
- Cross-Border Remittances – Navigating international compliance requirements for money transfers.
- Emerging Regulatory Frameworks – Adapting to rapidly evolving compliance requirements in developing markets.
Our Solutions
- 01Alternative Data KYC – Obtaining identity using non-traditional data points suitable for emerging markets.
- 02Tiered Risk-Based Approach – Compliance policies that scale with transaction values and user activity.
- 03Agent Monitoring & Management – Tools to ensure compliance across agent networks and prevent internal fraud.
- 04Sanctions and Watchlist Screening – Identify sanctioned or blacklisted customers before onboarding.
- 05Offline-Compatible Solutions – Compliance tools that function in areas with limited connectivity.
Mobile Money Regulations by Region
Sub-Saharan Africa
- Kenya: Central Bank of Kenya regulations for M-Pesa and National Payment System Act
- Nigeria: Central Bank of Nigeria's Framework for Mobile Money Services
- Ghana: Bank of Ghana E-Money Issuers Guidelines and Payment Systems Act
- Zimbabwe: Reserve Bank of Zimbabwe Mobile Banking & Payment Systems Regulatory Framework
South Asia
- India: Reserve Bank of India Prepaid Payment Instruments Guidelines
- Bangladesh: Bangladesh Bank Mobile Financial Services Regulations for bKash
- Pakistan: State Bank of Pakistan Branchless Banking Regulations
Southeast Asia
- Philippines: Bangko Sentral ng Pilipinas E-Money Circular for GCash
- Indonesia: Bank Indonesia Regulations on Fund Transfer and E-Money
- Thailand: Bank of Thailand Payment Systems Act for mobile money services
Mobile Money Providers FAQs
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Yes. Mobile money operators are usually classified as financial service providers and are subject to full compliance obligations under local regulations. This includes verifying customer identities (KYC), monitoring for suspicious activity, screening for sanctions and politically exposed persons (PEPs), and maintaining a risk-based compliance programme.
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Providers are expected to verify users with national ID, mobile number registration, and in some cases, biometric or photo verification. For low-risk accounts or limited transaction values, simplified due diligence may be allowed. However, accounts with higher limits or suspicious activity should undergo enhanced checks.
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Many mobile money services operate in regions where formal ID is limited. To stay compliant, providers can:
Use SIM registration databases to cross-verify identity
Work with local agents to collect photo ID or community references
Apply risk-based KYC—using lighter checks for low-risk clients and stronger verification for higher-risk ones
This flexible approach supports financial inclusion while reducing compliance gaps.
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The most common risks include:
Structuring transactions to avoid detection (smurfing)
Use of stolen or fake IDs
Transfers involving high-risk countries or anonymous wallets
Rapid in-and-out cash movement without economic justification
Use of agent networks for layering illicit funds
These risks increase when onboarding is weak or monitoring is manual.
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Risk assessment helps you determine which customers, transactions, or agents require more scrutiny. You should consider:
Who the customer is (e.g. individual vs merchant)
Where they are located (any high-risk regions?)
What kind of activity they’re doing (e.g. domestic vs cross-border transfers)
The goal is to categorize users into risk tiers and apply the right level of controls—from basic KYC to full enhanced due diligence.
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Because mobile money platforms often deal with high volumes and fast transactions, there’s a real risk of unknowingly processing payments for individuals or entities on global sanctions lists. Automated screening helps catch red flags early, ensuring compliance with local and international regulations.
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Red flags might include:
Frequent small transfers just below reporting thresholds
Several accounts linked to the same device or ID
Users who rapidly increase their transaction volume
Attempts to modify or bypass KYC data
Transfers to or from high-risk jurisdictions with no clear purpose
Such cases should be escalated to a compliance officer and reviewed for potential STR filing.
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Small and mid-sized operators don’t need big teams or expensive systems. Tools like Anqa help automate KYC checks, sanctions screening, and risk scoring. You can also train agents with short digital modules and set up a simple policy framework that aligns with your regulator’s expectations.
Ready to streamline compliance for your mobile money firm?
Get in touch to learn how Anqa can help your firm meet regulatory requirements while enhancing client service.