Telecom Compliance in Africa & Asia

Telecoms are increasingly involved in services that intersect with financial systems, like mobile wallets, airtime transfers, and data payments. Regulators now expect telcos to perform customer verification (KYC), monitor usage for suspicious behavior, and ensure that services are not being used to support fraud, terrorist financing, or sanctions violations.

Riskier activities include:

• Mobile money and wallet integrations

• SIM registration and re-registration processes

• Airtime reselling and international top-up services

• Bundled payment offerings (e.g. phone loans, bill pay)

• Cross-border communications linked to remittance or crypto activity

These services often involve fast, anonymous transactions and are vulnerable to exploitation.

Most regulators require telecoms to:

• Verify the identity of customers during SIM card activation

• Collect and store national ID or biometric data

• Link each number to a real, verifiable user

• Periodically re-verify dormant or legacy users

Some countries also require telcos to conduct KYC on agents, vendors, or distributors

Telecoms must ensure they are not:

• Offering services to sanctioned individuals, companies, or governments

• Routing calls or data through high-risk jurisdictions

• Supporting platforms or partners under international restrictions

Screening subscribers, partners, and payment platforms against global sanctions lists is increasingly expected.

Examples include:

• Multiple SIMs registered to the same ID or device

• Sudden spikes in usage or international calling patterns

• SIM swapping activity linked to financial fraud

• Agents registering large numbers of customers with similar details

• Top-up or transfer patterns that mimic layering

Telecoms are often the first point of detection for fraud networks and digital financial crime.

Telcos should regularly assess:

• Customer risk profiles (e.g. location, usage, services accessed)

• Channel risk (e.g. agent vs direct onboarding)

• Third-party integrations (e.g. fintech, crypto, content platforms)

• Geographic risk based on country coverage and roaming partnerships

This helps determine where to apply enhanced checks, monitoring, or service restrictions.

If the telecom is offering financial-like services—such as wallets, bill payment, or stored value—they may fall under financial regulations and be required to file STRs with the local Financial Intelligence Unit (FIU). Even if not mandated, some regulators encourage voluntary reporting when fraud or financial crime is suspected.

Key strategies include:

• Automating KYC checks during SIM onboarding

• Integrating real-time sanctions screening across systems

• Training staff and agents on red flags and fraud indicators

• Using compliance tools like Anqa to centralize data and reporting workflows

• Running periodic internal audits to flag vulnerabilities in customer data or vendor practices