Situation

A banker’s association in an African country was working to implement a new real-time payments system to increase digital financial inclusion and payment in their market. Glenbrook was asked to help review the extent to which existing regulations these goals.  

Approach

Glenbrook collated all relevant regulations. Key categories of regulation included strategy (i.e. national financial inclusion strategies), licensing (i.e. bank, non-bank licensing), competition (i.e. access and pricing), anti-money laundering and counter-terrorism financing (AML/CFT), agents, and consumer protection. We reviewed regulations and rated each on the extent to which it would enable the association’s goals – the launch of a new real-time system to support financial inclusion. We elevated potential regulatory roadblocks and made recommendations for how to move forward.

Glenbrook also reviewed and commented on other draft payment system guidelines.

Impact

The association took two actions to remedy potential regulatory roadblocks 1) they advocated for regulatory updates to their central bank 2) they matured their real-time system rules to enable regulatory gaps, where possible. 

In addition, the final operator guideline included critical updates from the commenting effort that ensured the association’s success. For example, the draft guideline restricted which use cases could be supported by an operator (i.e. B2B); the final guideline allowed all retail use cases to be supported by an operator – in line with the real-time system goals.