Approval Requirements

Minimum Requirements for a Retail Service Payment Systems Provider

Entities or individuals wishing to register and operate a payment systems switch or such products and services should comply with the RBZ Act [22:15], NPS Act [Chap24:23], Banking Act [24:20], BUP and SML Act [Chap24:24].

Below are additional requirements that should be provided and fulfilled before conducting any operation.


1.    Corporate Governance Issues

  1. Beneficial /Ownership structure
  2. Memorandum and Articles of Association.
  3. Adequate Capital Amount
  4. Net worth statements for directors
  5. Director clearance by Police and credit rating bureau
  6. Organizational structure and proposed names of key office holders
  7. Board and Senior Management profiles

2.    Business Plan

  1. Objectives and mission statement
  2. Business case
  3. System Technology / The system functionalities/process flow
  4. Market Analysis
  5. Financials
  6. Viability and projections


3.    Comprehensive Risk Management Framework

  1. Identify all pertinent risks
  2. Measurement
  3. Mitigating measures
  4. Transactions limits
  5. Controls


4.    Agreements

  1. Service level agreements
  2. Contractual agreements with third parties signed


5.    Clearing and Settlement Modalities

  1. Clearing arrangements
  2. Settlement procedures and processes
  3. Collateral
  4. Rules and procedures
  5. Third party entry and access criteria


6.    Policies and Procedures

  1. Pricing policy
  2. Conflict resolution policy
  3. Customer protection issues
  4. Customer due diligence procedures
  5. AML Policy



7.    Anti-money laundering Requirements(AML)  

  1. ML/TF risk assessment
  2. Beneficial ownership
  3. Politically exposed persons
  4. Customer Due Diligence:
     - Know your customer/employee/customer/agent/partner
  5. Record keeping
  6. Continuous risk assessment of new and existing technological products
  7. Suspicious transaction report
  8. Third parties service level agreements and due diligence


8.    Systems Integrity and Audit Report

  1. System design and architecture
  2. System providers
  3. Capacity and reliability of the system
  4. Pilot tests results


9.    Special requirements for Cross Border payments

  1. Compliance with Exchange Control law
  2. Regulatory Certificate of good standing from country of origin (foreign entity)


10.    Application fees will be guided accordingly from time to time.

11.    NB.

  1. Non banking institutions should partner with a bank of their choice and ensure that the application is submitted through the same bank.
  2. In addition, no pilot tests or live launch of the product should be done without the requisite regulatory approval.