 Note For Committee

 Loan closure possible for agent?

 Type of loan allowed for agent to collect
 Loan in arrears (penalty)?
 Receipt for agent when deposit and withdraw from his float
 Is the receipt given to client by agent one copy or two copy
 Marketing material
 Marketing types
 Marketing budget
 Incentive for staff and agent during the pilot
For IT
How agent control his float account
WASASA MFI

Agency Microfinance Training

 Objective of The Training
Upon the completion of this course, Participants will be
able to:-
aware that they might need to provide additional training
to new agents on using the transaction device, such as a
point-of-sale (POS) .
Describe features of Agent Banking
Distinguish conventional banking and Agent Banking
Identify unique characteristics of Agent Banking
Describe benefits and key challenges of digital banking.
understand the MFS agency business
Introduction and context of the project
In June 2017, Wasasa kicked off its digital finance
project with a Market study supported by PAMIGA
This project was in line with the business strategy of
Wasasa, as the board and management planned to
promote financial inclusion in its RSF (Rural Services
Finance) branches that serve the rural communities.
With this strategy, the market study identified three
main solutions that meet not only the business
strategy for Wasasa, but also clients. These are
categorized into three main solutions.
Phase 1 – tablets/POS by internal agents
Phase 2 – tablets/POS external agents
Phase 3 – Mobile microfinance
 Description of Project
A vast majority of Ethiopian lives outside the formal
banking network and
deprived from essential financial services
 like payments and remittance facilities
 savings, loans and insurance services and
 subjected to unfair money lending practices.
 Access to affordable, sustainable and secure financial services
increasing income and reducing vulnerability for the poor
Bringing more people, and more money, into the formal financial
system overall economic growth and development, and
increased stability in developing the Ethiopian economy.
 The National financial Inclusion Phase II project proposes to design
and launch a mechanism to ensure maximum possible financial
inclusion in the country.
 This initiative will also facilitate formulation of the necessary
enabling environment for the relevant stakeholders such as banks,
telecommunication operators, financial and regulatory authorities,
content providers, citizens and SMEs.
Objectives of the Training
Training Topics
 Introduction
 Agent management
 Awareness on Wasasa Agent Microfinance policy
Agent Microfinance Operation Policy
Agent due diligence
AML/CTF and Risk management
Customer protection
PART I- INTRODUCTION

 Definition of Terms
 DFS
 Financial inclusion
 Agency microfinance/ Agency Micro financing
 E-float
 Due Diligence
 Agent
Digital Financing
 Is the delivery of traditional financial services digitally, through
devices such as
computers,
tablets and
smart phones. Digital finance has the potential to make financial
services accessible to underserved populations in areas that lacked
physical infrastructure for these services.
 It is a concept that expresses the effects of new technologies in the
field of finance that provide ease of use, speed, and low cost in
accessing financial services.
Financial Inclusion
 Financial inclusion is defined as the availability
and equality of opportunities to access financial
services.
It refers to a process by which individuals and
businesses can access appropriate, affordable,
and timely financial products and services.
Financial
Inclusion
 Agent Bank/ Micro financing
Is a kind of branch less Micro financing which is
significantly cheaper alternative to conventional branch-
based Micro financing that allows financial institutions
and other commercial players to offer financial services
outside traditional bank premises.
 It was introduce in Brazil for the first time
 Successful in different country like Kenya and Uganda
three participants
 principal or the bank,
 agent and
 customer.
 the bank will make an agreement with the agent to serve the
customer through the agent on commission base transaction.
The 1st Agency microfinance Directive was in acted in
Ethiopia In 2012 by directive no. FIS/02/2012
Agent Bank has started in 2014 by Dashen Bank
having the first place
 but it’s United Bank was with deep engagement to the
market.
the financial institution shall be fully responsible and
liable for all actions and omissions of its agent and this
responsibility shall extend to actions of the agent.
Agent means
 a person that engaged in commercial business
activity and has been contracted by Wasasa to
provide the financial service on its behalf in a
manner specified in NBE directives (FIS/02/2021)
Agent MFs Value Proposition/ Why Agent MF??

For Customers
For Agent
For Wasasa
 For Customers
 Convenience
 Time saving
 Cost Saving
 For Agent
 Increasing their income with additional revenue through
commission paid by Wasasa
 For Client acquisition ( through cross selling to walk in
clients of Wasasa)
 Increase Foot trafic
 To reinforce brand / Visibility
 To increase customer loyality (one stop shop)
 Capacity in liquid management and Book keeping
 For Wasasa
 cost savings and growth opportunities. The agent
microfinance channel contributed to cost reductions in
the following areas
 Cash-handling: the agent network contributed to a
reduction in costs associated mainly with transportation,
insurance and dealing with fake bills.
 Branch operational expenses: Due to less client traffic
at branches, able to reduce the number of tellers, which
lowered the operational costs of branches.
 Transactions:
 Study shows, conducting a transaction at an agent was 25% percent less
expensive than at a teller.
 Another realized a 17% cost savings per transaction when using agents
for deposit mobilization.
 agent microfinance to be a more cost-effective way to improve both
market penetration and expansion
 Deposit mobilization: Through deposit mobilization, FI can benefit from
the difference between the lending and savings interest rates –
 also known as intermediation - and use a cheaper source of funds to
support lending activities. By including intermediation in its financial
calculation, an FI can strengthen profitability and the business case for a
digital service.
Product and Services offered Per NBE Directives
NBE directive FIS-02-2020 allow
Opening of electronic account
CiCO
Cash disbursement of loan approved and loan
repayment
Payt of bill and services ( salaries, social benefit)
Local money transfer
OCT
Balance inquiries
Electronic mini statement
Collection of document in relation to acc opening, loan appli,
including CDD/AMLCTF
Customer education
Registration for account-opening
Account information
Cash–in (saving deposit and loan repayment)
Cash-out Transaction
Wasasa may extend its current service delivered through
conventional branch to be delivered through an agent.
However, to start with, Wasasa will deliver the following
product for the customers via agency microfinance
services:
CICO
Customer registration
Balance enquiry
Customer education
Agent Management

Customer
Agent Selection
Support

Agent Mgmt Agent Training

Agent
Monitoring
Compensation
Liquidity
Mgmt
Agent selection
Selecting Agents Carefully considering
the qualities they need in agents based on the service and
what agents are required to do.
Balancing the application process to adequately screen
prospective agents, while not making the process overly
time consuming.
Getting Agents Started. Create contracts for agents,
decide who will install and maintain equipment, and
ensure that agents are well trained.
What to look for in a potential agent?
 Paying Agents. Aside from determining the overall amount to pay
agents, providers need to answer at least five questions on how to
pay the agents.
 Managing Liquidity. Providers need to determine who provides the
capital for the service and how the critical but time-consuming and
expensive task of rebalancing will be done.
 Ongoing Monitoring and Management. Effective monitoring is
essential to ensure consistent customer experience.
 Reducing Impact of Fraud, Theft, and Abuse. Providers must be
aware of the vulnerabilities in their service and find ways to minimize
these.
 Agent Training

 Topics to include in training curriculum are as follows:

 Agent responsibilities and contractual obligations
 KYC regulations and customer registration requirements
 Information on how to conduct transactions
 Troubleshooting technology/equipment
 Customer relationship management
 Fraud identification and management
 Bookkeeping and maintenance of records
 Cash and e-float management
 Consumer protection laws.
Paying Agents
Agents are a key component of
marketing, implementation and customer service,and
should be treated and managed as end customers
themselves.
This includes paying them
well,
on time, and
 in a way that the funds are easily accessible.
five key questions are discussed that providers should
address when setting agent commissions.
What is the balance of registration versus transaction
commissions?
Which transactions should agents get paid for?
How should commissions be calculated?
How often should agents be paid?
Managing Liquidity
 For any branchless microfinance service to succeed and
to get agent management right
customers must be able to get cash when and where they
want it.
 Agents must have a sizeable sum of money and e-float
to begin with and
must continuously balance the cash and e-fl oat.
Dedicating capital to the business and constantly
rebalancing stocks of cash are expensive and time
consuming tasks.
Main goal of liquidity management is to achieve a
perfect balance of having neither too much nor too
little cash in the system to:
 Ensure that customer transaction requirements are
met quickly; and
 Check that there is not too much cash in the field,
as there are carrying costs of unproductive cash
and higher risks of theft, loss or even fraud, with
higher cash balances sitting with agents.
Liquidity management in case of Wasasa
What is liquidity?
Liquidity management is a process that entails having
cash (float) and electronic money (float) when
customers ask for it and it is used to effectively and
efficiently serve customers
This account therefore determines (and limits) the
amount of business an agent can handle on a daily basis,
whether deposits or withdrawals.
.
 Float management
 Float management actually takes two forms:
Float Management: Electronic Value
E-money transactions between agent and a customer requires that
the agent has cash value in their e-float acount.
As the agent provides financial services throughout the day, the cash
amount on their pos fluctuates up and down, depending on whether
they are accepting funds or paying out.
 When the amount in the agent’s e-float is used up, the agent
cannot perform additional services and needs to refill their account.
If the agent does not have an account linked to their e-float, this
means they need to make a trip to the branch to transfer cash
into e-float account.
 Liquidity Management: Physical Cash
 The other form of liquidity management relates to physical cash.
 Customers who are seeking to make cash deposits into their
regular acc.or to withdraw cash from their accounts will go
to agents. With cash-in transactions,
customers deposit their money with agents.
While cash-out transactions result in customers seeking to
withdraw funds via agents.
 Components of Liquidity Management
Initial Float Requirements:- it’s the upfront capital to
start the business
Float Planning:- a Process used to pre-determine how
much float the agent requires on a day-today basis in
order to effectively serve customers.
 Under here there is a rule which determines an agent’s
float on the next day to be based on today’s pay out and
deposit. The rule is called ax stock rule. Eg 1.5x rule
 ax stock rule?
It is a premise that an agent needs to have ax (a times)
previous days’ outflows [cash or e-money], in stock, to
effectively serve customers on the next working day.
Example: If today, the Agent pays out (withdrawals) a
total of 50,000br& facilitates (deposits) worth 100,000br;
he will need to have cash=50,000 x a = ------br the next
day in order to effectively serve customers
- The same applies for e-money = 100,000 x a = br. So he
needs to ensure his phone -----br to enable trading the next
day.
 Rebalancing of Float: -Rebalancing requires one to sell
or purchase electronic value; converting cash into e-
money and/or e-money to cash. Converting of cash & e-
money is done through branches.
 Some Agents may require daily re-balancing. Branch
provide immediate conversion.
 For Discussion
 Today one of the Agent under Asela branch pays out (withdrawals) a total
of 50,000br& facilitates (deposits) worth 100,000br. In order to effectively
serve customers the next day how much e-float and physical cash he will
need to have?
To illustrate this point:If today agent A has provided cash-outs of Br
100,000 and has accepted deposits or cash-ins worth Br 50,000, she needs
to have cash worth 100,000 x 1.5 = 150,000 the next day to effectively
serve customers.
The same applies for e-money:Br 50,000 * 1.5 = 75,000. So, she needs to
upload her agent wallet with Br 75,000.
Thus, the total working capital she will invest is Br 150,000 + 75,000 =
225,000 for the next day, if today she has done business worth Br150,000.
Agent E-float establishment and replenishment
procedures
Once the agent is selected, trained, and entered into a
contract with Wasasa,
She or he is expected to deposit a float amount to handle
customer transaction.
All the transactions handled by an agent depends only on the
availability of E-float balance on the account of the agents
 The
Cash
agent'sine-
customer
float Parallely the
gives cash to balance customer's
the agent and reduces regular
exchanges by the account
regular amount of balance
account increases
the
transactio
Cash Out
customer agent
n receives
made
withdraws e-money and
cash and his e-float agent pays
transfers balance out cash and
money from increases by customer
the regular the amount of recieves cash
Acc to the the transaction
agent made
 Depending on the relative volumes of cash-in or cash-
out transactions in any given day,
 the agent can become either
cash-rich, with too much cash on hand, or
 cash-poor.
 In the latter case, the agent does not have enough
cash to provide the customer with the full amount
of their withdrawal request.
 Often customers return the following day to obtain their
money.
 Unlike electronic liquidity issues that can be managed
remotely via bank transfer or master agent transfers,
cash liquidity can only be managed physically
if the agent either has too much cash on hand,
increasing security risks, or not enough cash on
hand to handle customers withdrawal requests, then
there needs to be a movement of physical cash.
This either has to take place via the agent going to the
branch or having someone, such as the SCO, bring
cash. Therefore, agents must manage their float by going
to their nearby branches.
Before starting operations agent shall fulfill the following:
provides required documents to open an account.
The agent carefully fills account opening form, with the help of the
branch officer.
The credit and savings officer informs the agent about the features
and benefit packages of the products.
The agent deposits the float cash specified in the contractual
agreement at Wasasa’s branch.
The limit for the float amount and cash on hand shall be specified
in the contract based on capacity of the agent and institution policy.
The cash on hand replenishment and deposit to the float balance
shall be specified
Procedures how agent make transaction with Wasasa’s customers
 A customer will come to the agent outlet to deposit or withdraw money with
their ID No. or Pass book
 inform the amount desires to deposit or withdraw
 Inform the account type they need to transact on
 The agent check as the account they need to transact on is allowed
 The agent Check for network availability
 The agent will count the cash and log to the system by entering
customer’s account number, select deposit from the menu, enter the amount
collected, and narration;
 For withdrawal authenticate customer biometrics
 the system will credit or debit the customer account and print a receipt or
send SMS message to the customer (whichever is applicable).
 The agent print the receipt in two copies and give one receipt for customer by
taking the manual signature on the remaining receipt
When agent needs E-float
Agent call saving and credit officer
Saving and Credit officer request the
branch manager to collect cash
Tellers check from the system the amount
of e-float balance from the system
The branch manager approve SCO to
collect e-float from agent for
replenishment
SCO go to agent out let and collect e-
float by delivering receipt for e-float cash
collected from agent
Branch manager and teller follow up for
e-float deposit
When agent needs Physical
cash
 Saving and Credit officer request the
branch manager for liquid cash
replenishments for agent
 Branch manager check and approve
cash advance for SCO to deliver for
agent
 Tellers record the advance document
and give the approved cash to SCO
 SCO deliver the physical cash for the
agent
 The agent receive cash from the SCO
by signing on Wasasa cash receipt
voucher
For Discussion
What is the role of Branches to manage the liquidity and
other operational activities for agent microfinance?
1. Tellers
2. Branch Managers
3. SCO
4. Among this who did you think play the leading role?
Agent monitoring
Monitoring the activities of an agent is essential for any
agent microfinance/microfinance initiative, because
if the services are not monitored effectively, issues and
problems can quickly arise,
then customers may lose confidence in the service,
and they may stop using it completely.
by definition, agency microfinance/Microfinanceing
involves agents who are outside the direct control of the
FSP, and this necessitates even higher levels of
monitoring and supervision.
There are typically four levels of monitoring for Agent:
Operational, day-to-day monitoring in which the branch staff visit
agents (and a customer sample) to check compliance;
Internal audit and control is a more structured process that takes place
periodically, e.g. quarterly, and based on clear and pre-defined criteria
(often through a scoring/checklist mechanism);
Customer service call lines should also be available for customers (or
agents) to call-in if there are issues. Customer Service Groups can also
be proactive and make calls to customers to measure satisfaction; and
MIS data and reports should provide the first level of monitoring in
which inconsistency can be more closely examined on the ground by
branch and head office staff.
The information collected from these mechanisms
should not only drive improvements in the field, but also
improvements in induction and refresher trainings,
updates to the processes, and risk mitigation for the
entire system.
Marketing and Communication
Why Marketing? because
many customers do not have access to traditional marketing media,
such as televisions, newspapers, etc.;
 Agent microfinance services interventions have very small
marketing budgets, and below-the-line (BTL) types of marketing
carried out at or near the agents location can be effective in this
context;
Agent microfinance services is a new delivery channel business and
may take several questions, demonstrations and visits to convince
customers to actually adopt the new service; and
agents can become the first points for customer service and share
their own experience with the service.
customers have a limited understanding of technology and
almost all agent microfinance services are technology driven. As
a result, most agent microfinance solutions have the potential to
be viewed with suspicion and mistrust.
Another factor that should be considered is that the target
customers for agent-microfinance differ from that of
conventional banks.
These customers are usually illiterate with little exposure to
formal microfinance services. They are more prone to becoming
victims of fraud or misrepresentation.
In this context, it is very
important that the policies and procedures are
communicated clearly and in a concise manner.
The medium of communication needs to be appropriate
to the geography and the target audience.
The language and the medium used should be something
to which the customers understand and relate.
The agents are also an internal customers to which the
solution needs to be marketed / explained to for
acceptance and adoption.
since the agents are also responsible for customer
acquisition and convincing customers to use the
accounts.
The agents are also interested to understand the benefits
of agent microfinance model provide them (such as
incentives, etc).
 Target Market: The promotional strategy needs to be
customized for the target market.
For instance, it could be different for rural and urban
markets.
 For rural markets along with normal promotional
tactics, meetings with social groups, such as village
councils and SHGs.
The major components in a marketing strategy are the message,
sales strategy, media used, promotional material and timing of the
campaign.
  Should focus on customer benefits
 Should be tailored to requirements of target
segments and the geography
 Focused on simple communication of costs and
The Message terms
 Promote experimental learning by stressing case
and low cost of access for balance conformation
and fees incurred
Sales strategy/
Media used
Promotional
material
Timing
 Wasasa Agent Microfinance Policy
Awareness
Operation policy
Agent Due Diligence
Customer Protection
Risk Management and AMLCFF
Operation Policy
 Transactions, Systems and Technology
All transactions involving deposit, withdrawal, payment,
or transfer of cash from or to an account shall be real time;
To ensure that Agent microfinance transactions are
carried out with devices which are technically fit,
Wasasa is required to ensure that such equipment is able
to:
Transmit transaction information in code;
Carry out electronic transactions on real time basis;
Allow handling under different user profiles for
administration, maintenance and operation;
d. Reverse or correct transactions due to error posting by
attaching the originally issued receipt only and reissue by
the correct mount;
Electronic receipts or acknowledgements such as SMS
acknowledgement are permissible’
Do not allow a transaction for an agent once the agent
exhausts his daily cash limit or tries to perform an illegal
or unauthorized transaction;
Generate an audit trail;
Process or generate durable transactional documents or
receipts. Electronic receipts or acknowledgements such as
SMS acknowledgement are permissible’
Do not allow a transaction for an agent once the agent
exhausts his daily cash limit or tries to perform an illegal
or unauthorized transaction;
Shall at all-time monitor the safety, security and
efficiency of the equipment being used to prevent any
tampering or manipulation by any person;
shall put in place systems that at a minimum address the
following issues:
 Physical (keepings the system safe by allowing only
authorized individuals in to the system) and logical security
(protecting the computers and data from unauthorized access)
of infrastructure;
Availability of services;
Data confidentiality and integrity;
Encryption of PIN and electronic transactions;
Customer accountability and non-repudiation on transactions;
 Error messaging and exception handling;
Activities of the agent are constantly monitored to
ensure full compliance with these Rules & Regulations
and the terms and conditions specified in the agency
contract.
Ensure that the scope and coverage of the internal audit
function has been expanded to commensurate with
complexity and risks inherent in agent activities and that
the Audit department is properly staffed with personnel
having sufficient technical expertise to perform their roles
Product and Services offered
Registration for account-opening;
Deposits and withdrawals of saving;
Loan disbursements and repayments (which have
the same process as deposits/withdrawals since
they go through a savings);
Account information;
 CICO Transaction Limits
To keep the Compliance with regulators and National
policies including the risk that happens with provision of
Agent microfinance services Wasasa establish limits for
CICO transactions
The limits shall be prudent and bear in relation to the
volume of cash moved by the agent and the risks
associated with the agent’s locality for conducting agent-
microfinance business.
 The other Weekly and monthly transaction will be in
Compliance with NBE Directives.
 From Saving product agent is not allowed saving
product that needs contract (PTD) or One time deposit
 No withdrawal is possible for FT with contract
 All loan products with in their limits
In general, the maximum number and value of
transactions for client at agent Microfinance outlet
should not exceed the limits specified in this Table :
Organizational Structure of the Agent Business
The distribution channel strategy shall expect to be
deployed for agent Microfinance services is using branches
as the foundation for the agency microfinance model that
would soon be deployed utilizing the hub-and-spoke model
 a distribution method in which a centralized "hub" exists,
in which agents are recruited, trained and managed by a
branch (i.e., agents are attached to and managed by a
branch, the branch as a “hub” and the agent as a “spoke”).
A team at the head office carries out capacity-building for
the branch office staff.
 Also, there is a central unit at the head office to
coordinate back-office operations.
 To use this hub and spoke model, Wasasa develops its
own agent network by recruiting its own agents from
among parties such as
grocery stores, small businesses, or branded individuals
located outside the branch in a busy area.
 With this option, Wasasa is solely responsible for
identifying, recruiting, training, monitoring and
managing agents through its branch offices.
 Thus, branches likely have a critical role in the agent network
structure, directly participating in the selection and supervision
of agents.
 The existing clients also can be used as agents, as they already
have a history with the institution, and it can be a way to
incentivize them.
Agent 4 Agent 1
Branch

Agent 3 Agent 2
Who is an agent????????
The existing clients also can be used as agents, as
they already have a good history with the institution
and it can be a way to incentivize them.
 Shops. Pharmacy
 Grocery
 Cooperatives (primary & Union)
 Supermarket
 Commissions and Fee structure
Agents will be paid for every transaction which they
facilitate, which, in most deployments, are cash-in,
cash-out, and customer registration.
The agents’ commission and fee structure outlines a
tiered system.
Wasasa shall
 Establish a fee, charges and commission structure for
the agent microfinance services. Such structure Specify
fees, charges and commission payable to the agent for
each services category and cost of the customer;
 Ensure that the agent should not collects fees, charges
and commission payable from customer at agent outlet;
 Ensure any deductions from customers’ account must be
informed by sending SMS to customers’ registered
mobile number if applicable.
Fees paid by customer
Internal Control Procedures
In order to prevent fraud and detect errors, the
main goal of agent management is to run it in
such a way that results are positive, that is, the
generation of institutional capital that provides
security for its clients.
This is achieved through ensuring the quality of
the services offered. To ensure quality It is
necessary to institute policies which will allow:
An adequate selection and hiring of an agent, their training and
compensation.
Restriction of agent activity.
Assign each agent or agent outlet a unique identification number.
Assign each agent or agent outlet to a specific parent branch.
Display a list of agents at the agents’ respective parent branch.
Ensure that the technological infrastructure supporting agent
Microfinance runs effectively.
Agent shall not ask any charge to the customers for its services,
the charge imposed on the customer for the service shall be
deducted from their account by the system.
An agent cannot provide any financial products or services
other than Wasasa’s products and services that are stated in
the contract entered with Wasasa.
An agent is not allowed any transaction by off-line.
Agents are not allowed to appoint another sub-agent to
provide microfinance services on their behalf.
An agent does not deal with loans and financial appraisal.
Apart from the above restrictions for any sort of
transactions an agent must abide by Wasasa accounting
policies and procedures.
Agent Due Diligence
Agent Due Diligence
Due Diligence meaning
Is a process or effort to collect and analyze information
before making a decision or conducting a transaction so a
party is not held legally liable for any loss or damage.
Wasasa shall ensure
Handling regular due diligence on continuous basis
throughout each relationship.
Agents are well established, enjoying a good
reputation and have the confidence of the
population in their areas of operation;
The degree of due diligence shall be matching
with the level of risk and complexity of the agent
relationship;
Proper AML/CFT monitoring processes exist for
agent microfinance.
Carrying out the business activity on an ongoing
basis;
Permanent resident (ID/Passport);
Ability to meet commitment with customers
under an adverse situations;
knowledge and ability to handle Technology
based financial services;
Loan defaulter can not apply for agent ship
Ability to perform his/her responsibility
properly.
Ability and skill to understand agent users
guide.
 Initial due diligence

An agent shall :
Be a person including a legal person engaged in any
commercial activity and have a permanent address;
Have a valid business license (for an entity requires
license) or is engaged in any commercial activity which is
accepted by the community and the law;
Have no criminal record in matters related to finance or
fraud;
Have the necessary funds, and readiness to
carry out
an agency business service efficiently and
safely;
Have good integrity and reputation among the
community; and
Any other matter which negatively and
positively has an impact on the person.
 Regular due diligence
The ongoing due diligence obligation is to carefully
examine the transactions carried out over the course of
the business relationship; this obligation includes
During regular due diligence Wasasa shall ensure:
Agents are able to carry out real time transactions;
All transactions involving deposit, withdrawal, payment or
transfer of cash from or to an account shall be real time and
performed on a customer demand;
Check for any legal responsibility against the agent is
imposed, and confirm for the place of operation is the
same with contract;
Check for the signage naming and placement;
Checking agent is collecting any fee, regularly
communicating costs of the customer, and available all
the time
The agent liquidity level and customer handling status;
and
Whether the agent is working under the regulation of
the country (NBE and FIC).
Customer Protection
Consumer Protection
As trust is the single most necessary ingredient for the
growth of agent microfinance,
 Appropriate consumer protection systems against risks
of fraud, loss of privacy and loss of service shall be put
in place for purposes of establishing trust among the
consumers of agent microfinance services.
As a minimum, Wasasa shall comply with the following requirements
at all times: :
 Agents shall issue receipts for all transactions undertaken through
them;
 Where an agent acts as a receiver and deliverer of documents, an
acknowledgement shall be provided for all documents received or
delivered by the agent to or from the customer;
 A channel for communication of customer complaints to the
institution shall be provided;
 Provide dedicated customer care telephone lines for lodging
complaints by customers;
 Establish a complaints redressal mechanism and ensure proper
communication of this mechanism to customers;
 Disclosures and Transparency
Wasasa shall
 provide the customers all information related to the services
and products offered.
 Such information shall be clear, simple, accurate and
comprehensible so as to allow customers to know implied
benefits and risks transparently and clearly without any
trouble from the customer’s side to obtain such information;

The information submitted to customers contain a
clarification of customers’
 rights and obligations and
 details of prices, charges and commissions collected by
each branch for each service or product, as well as a
clarification of the benefits.
An agent shall disclose to the customers in a Visible
place on the agent’s premises:
 The name of Wasasa MFI and its logo;
 A list of services offered by the agent;
 A written notice to the effect that if the system is down, no
transaction shall be carried out;
 The list of charges or fees applicable for each service that are
payable to the institution by the customers, but not through agent;
 A dedicated call center through which customers can contact the
compliant focal person, name, telephone numbers and location of
the person’s branches/Regional offices/Head offices to which the
customers reports agent activities.
Financial Awareness and Education
Wasasa shall
Carry out sensitization of its agents, customers and its agent
microfinance business to the public. This shall be through
public awareness campaigns, brochures and other programs as
the nature of the products may require;
ANTI-MONEY LAUNDERING AND RISK MANAGEMENT
POLICY
Anti-money Laundering/Counter Financing Terrorism
 Money laundering is an act of using agent
Microfinance services to mask criminally derived
proceeds as if they are legitimate assets by
circulating it in the formal money circulation
channel using agent Microfinance services.
 Wasasa’s agent microfinance shall
i. Prevents its transaction services from facilitation for
money laundering and funding of terrorism (ATF);
Comply with AML and ATF proclamations and practices;
Implementing operational control for the action of agents and
any other organizations/3rd parties using an agent
microfinance system ,
as failure to do so adversely impact the company and
business;
Follow proper KYC for onboarding on agents and partners as
per the NBE directives;
 In place consistent control to deter AML and CTF by
monitoring all transactions;
In place proper reporting template and channels for reporting
of suspicious transactions for internal and external parties;
Not engage with organizations /entities that are blacklisted
for any financial services;
Provide education and training ( new and refreshing)
periodically on AML and CTF policies and practices for all
stakeholders (staff, agents, and partners);
Incorporate obligation of AML and CTF on the contractual
agreement when contracting with agent and others;
Apply the policies on all agents at different hierarchies on agent
microfinance services and transactions ( registration, deposit,
withdrawal and other services);
Define daily, weekly and monthly transaction limits and/or
balance to prevent any money laundering / Financing terrorism
issues. Those limits shall be set up for both customers and agents;
Report to the institution (FIC) within twenty four hours, all
suspicious activities that come to the agent’s knowledge; Transact
agent deposit strictly as per the transactional limits prescribed by
the institution;
Enhanced Due Diligence in the case of large, complex or
unusual transactions and transactions with Politically Exposed
Persons;
Withhold transaction movement of any suspiciously reported
individuals or institutions as per the report received/identified
from the supervisory body.
 Risk Management
 Objectives of the Agent microfinance’s Risk Management
are:
 To ensure that all the current and future material risk
exposures of the agency microfinance will be identified,
assessed, quantified, appropriately mitigated, minimized and
 To enable compliance with appropriate regulations,
wherever applicable, through the adoption of agent
microfinance risk mgmt policy.
RISK IDENTIFIED excel
Potential agent microfinance risks
credit ,
operational ,
legal,
liquidity, and reputational risks.
The use of retail agents also potentially raises special concerns regarding consumer
protection which also deserve attention. In order to assess and mitigate these risks,
Wasasa shall
a. Conduct a risk assessment of every agent and assign a risk score i.e. low, medium
high to each agent;
b. Review initial risk scoring of the agent on a periodical basis in the light of results of
ongoing monitoring and document the reason(s) for revision in risk scoring of the
agent (if required);
c. Review the assigned operational limits such as transaction number and volume etc.
to each agent that commensurate with his risk scoring;
Design the system to automatically stop the transaction if
tried beyond the assigned limit;
Implement measures to control operational risks by including
article(s) in the contract for establishing the liabilities of the
agent;
Devise a list of early warning signals and corrective
measures to ensure proactive agent risk management;
Devise all product programs, procedure manuals etc.,
keeping in mind the implications for operational risk and
liquidity risk for agents;
Discussion
Please mention specific risks derived by the three
participants of agent microfinance business due to using
agent to deliver the financial and other non financial
services for the customer.
 At 2026, I would say that we
probably have 1 million people
that’ll be using day-to-day Wasasa’s
services, independent of branches!
GALATOMAA!!!
“ Ignoring technological change in a financial
system based upon technology is like a mouse
starving to death because someone moved
their cheese”
Skinner