Mobile money is a payment and storage service that uses ‘e-money’—a form of stored value that is not a bank deposit. This briefing note focuses on mobile money provided by non-banks, such as a mobile network operator (the ‘provider’).

In this non-bank model, customers exchange cash for e-money either with an agent or directly with the provider. The customers’ cash (or funds) are held with the provider, and even if the provider deposits these funds with a bank, the funds are not generally protected by the depositor protection provisions that customers enjoy when depositing funds directly with a prudentially regulated bank. This briefing note explores how regulators can protect such customers’ funds from loss in a civil law jurisdiction.