95022 IFC Mobile Money Scoping Country Report: Sierra Leone John Ngahu and Janine Firpo Scoping Mission Dates: June 3 to 8, 2012 In the first half of 2012, IFC undertook a series of six mobile financial services (MFS) market scoping studies across Sub-Saharan Africa to identify two countries in which it will provide broad and deep support to accelerate the uptake of branchless banking services. The countries included in this analysis were Rwanda, South Sudan, Liberia, Sierra Leone, Nigeria, and Cote d’Ivoire. These countries were chosen for the study because MFS were nascent, markets were difficult to reach, or other factors presented unique challenges. The Sierra Leone mission was undertaken from June 3rd to 8th, 2012. This deck summarizes the non-confidential findings that were obtained by IFC during the scoping mission. It provides a brief perspective on regulations, financial market, telecom market, and mobile financial service implememations. About The MasterCard Foundation Program IFC and The MasterCard Foundation (MCF) entered into a partnership in January 2012 focused on accelerating the growth and outreach of microfinance and mobile financial services in Sub-Saharan Africa. The partnership aims to leverage IFC’s expanding microfinance client network in the region and its emerging expertise in mobile financial services to catalyze innovative and low-cost approaches to expanding financial services to low-income populations. The Partnership has three Primary Components Mobile Financial Service Microfinance IFC and The MasterCard Foundation Knowledge & Learning see tremendous opportunity to use Through the partnership, IFC will The partnership will include a major agent and mobile banking strategies implement a scaling program for knowledge sharing component to to accelerate the delivery of financial microfinance in Africa. The primary ensure broad dissemination of services to the poor. The partnership purpose of the Program is to results, impacts and lessons learned will (i) work in two nascent markets accelerate delivery of financial from both the microfinance and to accelerate the uptake of services in sub-Saharan Africa (SSA) mobile financial services programs. branchless banking services, (ii) work through the significant scaling up of These knowledge products will with existing providers to build between eight and ten of IFC‘s include topical research, rigorous deployments to scale and improve strongest microfinance partners in the monitoring of project outputs and customer usage rates and (iii) identify region. Interventions will include outcomes and evaluations that factors that lead to robust business product and channel diversification attempt to establish the development models that can be replicated into underserved areas. impact of the intervention. elsewhere to profitably deliver financial services to the poor. Acronyms • AML Anti-Money Laundering • B2P Business-to-Person (transfer) • BoSL Bank of Sierra Leone • CDD Customer Due Diligence • FATF Financial Action Task Force • FI Financial Institutions • FIU Financial Intelligence Unit • G2P Government-to-Person (transfer) • GDP Gross Domestic Product • IMF International Monetary Fund • KYC Know Your Customer • NATCOM National Telecommunications Commission • MCW MasterCard Worldwide • MFI Microfinance Institution • MFS Mobile Financial Services • MFSP Mobile Financial Services Provider • MNO Mobile Network Operator • P2P Person-to-Person (transfer) • POS Point of Sale Terminal • WAMI West Africa Monetary Institute Sierra Leone Executive Summary Overall Mobile Money Readiness 3 (medium on a 2-4 scale where 2 is low and 4 is high) Current Mobile Money Solutions 2 Population: 5.5 million (July 2012 est) Mobile Penetration: Approx 2.73 m unique subscribers, or 50% of adult population Banked Population: 10% has access to formal financial services Remittance % of GDP: Inbound $48 million, 2.3% of GDP Percent under poverty line: 70.2% (2004 est.) Economically Active population: 40% in labor force (2007 est.) Adult Literacy: 35.1% Banks with largest branch networks: Sierra Leone Commercial, Rokel Commercial Bank, Standard Bank Mobile Network Operators: Africell, Comium, Airtel Other comments Support the regulator in developing mobile money regulations. Organize (regional) knowledge sharing events in SL to raise awareness on the opportunities created by mobile money. Provide institutional support to Splash to help them improve their product and service delivery. Support Airtel in rolling out their newly launched Airtel Money service using best practice models for agent network build out, training and management • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Distribution Channel • Mobile Financial Services Landscape • Potential Risks • Appendixes: Interviews Conducted Macro-Economic Overview Key Country Statistics Insights • Population: 5,485,998 (July 2012 est) • SL has experienced substantial economic growth since civil war ended in 2002, but poverty and • Age distribution: 41.8% (0-14 years), 54.5% unemployment remain major challenges (15-64 years), 3.7% (over 65 years) • Financial sector development plan launched in • Urban/rural split: 38% urban 2009 to provide framework for creating a sound, • GDP (PPP): 5.158 billion, 164th globally diversified, well-functioning financial system • GDP per capita (PPP): $900 • Financial system faces major institutional, administrative, legal, and physical challenges • Population below poverty line: 70.2% • There’s very limited distribution infrastructure – • Economically active: 2.2 m (40%) in labor government or private sector owned force (2007 est) • Banking infrastructure is unevenly distributed • Literacy rate: 35.1% with some districts having no banks • Banking penetration: 9-10% of population have • Scoping results show high market demand for access to formal financial services# more efficient financial services indicating • Mobile phone penetration: Approx 2.73 m growth opportunity for mobile money. unique subscribers, 53% penetration • GDP growth accelerated in 2011 and outlook is • Remittance (% of GDP): 2.3%, $48 million positive for 2012/13, mainly driven by mining sector activities and new discoveries. Sources: CIA Factbook Website July 2012; 6 June 2012 conversation with Bank of Sierra Leone, Financial Sector Development project Mobile Financial Services Opportunity A small and inefficient banking sector due for consolidation and innovation 1. Payment system under-developed • No ATM interoperability; domestic payments dominated by cash; limited use of checks and internet banking; no electronic large-value payment system • No legal framework for mobile money, but regulator is open to receiving input 2. Poor infrastructure, security risks, and high cost of cash 3. Being a small market, banks extremely cautious about expanding due to sustainability issues. Mobile financial services presents a good opportunity to explore 4. One MNO recently launched MFS and is positioning itself as a switch for banks. One 3rd party player has been in the market but struggling to establish its niche • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Distribution Channel • Mobile Financial Services Landscape • Potential Risks • Appendix: Interviews Conducted Regulatory Bodies Roles & Responsibilities Additional Information • Charged with establishing and supervising payment systems. Developed a Payment Systems Act in 2009, but it doesn’t mention mobile banking/payments • NATCOM and most market players are Bank of Sierra • Mobile Money Guidelines were drafted by unaware of the draft MFS guidelines Leone the Supervision Department within BoSL • BoSL wants Internal committees to review (BoSL) • Banking supervision technical committee the mobile money guidelines before they presently reviewing the MFS guidelines go to stakeholders • BoSL is faced with capacity challenges and • BoSL estimates completion of regulations has reached out to stakeholders to be by end of 2012 engaged in further developing regulations • Non-bank players currently getting VAS license from NATCOM, but demonstrate their service to the BoSL before being issued with final licence • NATCOM got involved in MFS as a stopgap • Has been licensing MNO’s and 3rd parties measure, while regulations were being National to provide MFS as a value-added service drafted, but clearly wishes for BoSL to take Telecommunica- • No formal working relationship with the ownership going forward tions Commission BoSL to develop regulations or jointly • Capacity at BoSL is limited and there are a (NATCOM) manage MNO and 3rd party mobile money number of initiatives on the table, which providers may deprioritize mobile money Regulatory Framework – Mobile Money Models Current Regulations Implications • SL guidelines do not align with market as it puts banks in a leadership position, yet banks would prefer MNOs to drive business • Only permissible model is many-to-many, • Banks see opportunity in holding float, which could support interoperability managing agent liquidity, and in some cases • Banks must lead, MNOs and 3rd party Mobile extending reach providers can only operate with a licensed Financial • Banks waiting to proceed for (1) regulatory bank partner Services clarity, (2) efficient connection to 3rd party • Although CBSL wants a bank-led model, in Guidelines and/or MNO platforms, and (3) resolution of practice, 3rd party and/or MNOs are security concerns actually driving the business • Due to guidelines, MFS providers can’t move forward as quickly as they would like • Many-to-many model could position MFS providers as switches  Requirement of bank vetting causes delays  Agents must meet set eligibility criteria, and conflicts of interest between bank and have a tax id, and an account with bank mobile money interests Retail Agents  Banks are responsible for vetting all  Agents can only provide the services that are agents, and compliance must be verified explicitly stated in their service agreement on an ongoing basis.  A tax id and bank account can be difficult for  Agents can be non-exclusive prospective agents to get in SL Additional Regulatory Considerations Anticipated Regulations Implications  MFS Guidelines refer to KYC, AML, and  There’s a national ID in SL but not many Customer Due Diligence (CDD)*, however people have one, problem most prevalent in requirements are not clear in document rural areas  Bank KYC requires a valid passport and one  BoSL understands challenges and says new of the following: (1) driver’s license, (2) AML Act will include KYC proportionality KYC/AML national ID card, (3) certificate of Also considering alternative forms of ID incorporation, or (4) voters card  Biometric voters cards are available to  MFS KYC may be more fully defined in a registered voters but not officially accepted new AML act that is under development as a form of ID at this time  There is probably a need for better understanding of different implications of AML and KYC on MFS  As mentioned earlier, many-to-many • Interoperability is seen as critical for the Interoperabilty requirement could create a defacto level market considering its small size, absence of of interoperability between players that established players, and experiences of other partner with single mobile money provider West African nations * CDD is another name for KYC, not additional set of requirements. • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Distribution Channel • Mobile Financial Services Landscape • Potential Risks • Appendixes: Interviews Conducted Financial Sector Overview Sierra Leone Financial Inclusion Players Number Regulatory Body 1 Apex Organizations 2 Commercial Banks 12 Microfinance Institutions 13 Community Banks 6-7 Credit Bureau 1 Service Providers NA Apex Organizations: • Sierra Leone Association of Commercial Banks • Microfinance Investment Technical Assistance Facility • The central bank is currently upgrading its tracking system for credit information with support from IFC (to be an outsourced function by a private company) • Installation of ACH, ACC and real time gross settlement is ongoing as part of the FSD Plan managed by the World Bank and funded by African Development Bank as part of a West African Monetary Institute initiative for selected countries in Africa including Sierra Leone Source: Google images Apex Organizations • Established in the 1970s, the association is a forum for member banks to work together on a co-operative basis, 13 banks are registered members • Leading the process of developing a private national switch, taking ownership of a project that was initiated within the CBSL • Have been working with West African Monetary Institute (WAMI) for the establishment of this system, which has received funding from the IMF. The Sierra Leone Association of project has been delayed due to challenges with WAMI. Commercial Banks • SLACB will own 51% of the switch and the remaining 49% will be owned by the technology provider • Objective was to support MFIs though technical assistance and funding Currently supporting 13 MFIs, which are a mix of NGO and for-profit • The initiative came to an end in August 2012 due to lack of funding for the second phase Microfinance • Biggest challenge facing the MFI industry is the need for more appropriate Investment Technical products. Group lending has also not worked well in SL due to poor cohesion Assistance Facility within groups and a poor repayment culture • Lack of institutional capacity within MFIs is also a major challenge • The MF industry (and the banking industry) is plagued by high NPLs: average weighted PAR>30 for MFIs is 14% and 15% for banks Commercial Banks (subset) Bank Name Owners Customer Base No. branches Gross MFI Date Established Customer Target No. ATMs & POS Portfolio Access Bank* Access Bank Plc, Nigeria 10,000 depositors 4 (3 in Freetown) $4,849.325 November 2007 50,000 in 5 years 4 ATMs, no POS ECOBANK* Ecobank Transnational Inc (100%) 55,000 customers 7 (4 in Freetown) NA 2007 100,000 by YE2012 17 ATMs, 30 POS Sierra Leone Govt of Sierra Leone (100%) 180,000 customers 14 NA Commercial Bank 8 ATMs, No POS February 1973 First International Bank FIB Group Limited, Banjul NA 8 (5 in Freetown) NA June 2002** FIB Limited Gambia NA Guaranty Trust Bank** Guaranty Trust Bank Plc , 7 (4 in Freetown) $ 10,600,000 January 2002 Nigeria International ICB Financial Group Holdings AG NA 6 (4 in Freetown) $12,074,988 Commercial Bank** (100%) NA No ATMs or POS Skye Bank Sky Bank Plc (95%) NA NA $ 3,100,000 NA Sierra Leoneans (5%) NA NA Standard Chartered SCB Holdings (81%) 8,000 3 (2 in Freetown) NA Bank Publicly owned (18%) NA No ATMs or POS 1894 Directors (1%) Union Trust Bank** Sierra Leoneans (100%) NA 12 (6 in Freetown) $ 29,000,000 1995 NA NA United Bank of Africa** United Bank of Africa Group, NA 5 (All in Freetown) July 2008 Nigeria NA NA Sources: ** Banks websites, * Bank interviews during IFC Scoping Mission, June 2012 Microfinance Institutions (part 1) MFI Name Owners/Funders Customer Base Gross MFI Date Establish Active Borrowers Portfolio ARD UNCDF(start-up grant) NA 1,210,411 2008 CORDAID , KIVA, 12,666 BRAC – SLE BRAC International NA 2,723,964 2011 KIVA 21,308 CEDA Sierra Leone NA 143,690 2007 UNCDF 1,640 Finance Salone Union Trust Bank NA 1,650,000 2007 Africap 15,347 GGEM Microfinance UNCDF (start-up grant) NA 489,196 Services Ltd. CORDAID 3,770 2011 HELP NA NA 140,516 2010 NA 1,734 Hope Micro CORDAID NA 1,338,951 2009 World Hope International 20,760 LAPO – SLE LAPO Nigeria NA 869,359 2009 11,322 MMCB UNCDF (start-up grant) NA 384,992 2007 Community-owned 1,754 Source: Mixmarket.org and interviews with Microfinance Investment Technical Assistance Facility (MITAF) Microfinance Institutions (part 2) MFI Name Owners/Funders Customer Base Gross MFI Date Establish Active Borrowers Portfolio Ecobank Microfinance Ecobank NA 3,760,000 Sierra Leone (formerly 2,187 Procredit) 2008 SMT CORDAID NA 1,076,691 2011 Microvest 7,877 YCB UNCDF (start-up grant) NA 59,919 2007 Community-owned 1,154 Source: Mixmarket.org and interviews with Microfinance Investment Technical Assistance Facility (MITAF) Payment Systems Overview • Retail Payment System Infrastructure  Under the oversight of the Banker’s Association, SL’s commercial banks are seeking to establish a privately owned national switch; initiative has experienced delays in obtaining necessary approvals from BoSL  The Bankers Association is considering interconnecting the switch with mobile financial services through a partnership with 3rd Party service provider  There are fewer than 50 ATMs in the country, Ecobank has the largest network with 17 current installations and an expectation of adding 11 more  Also less than 50 POS terminals in the country, 30 of which are deployed by Ecobank. Most POS terminals are located in high-end establishments, usage is low even here  There is a limited number of debit cards and virtually no credit cards in the market, but Access Bank and Ecobank are looking into launching VISA branded cards  Cash is the most prevalent form of retail payments • Credit Bureau  A basic version of this was recently established by the Central Bank, IFC is involved helping them upgrade and privatize this function Financial Sector Development Plan (2009) PRIORITY AREAS PROPOSAL ACTIVITY • Build a strong, competitive and • Modernize the CBSL’s banking • Install a new payment effectively functioning supervision systems architecture with commercial banking system assistance from the AfDB and • Broaden outreach, strengthen West African Economic and • Increase access to finance microfinance and rural credit Monetary Union (WAEMU) governance and supervision, • Improve the mobilization and and address needs of the • Establish a dedicated unit to investment of long-term funds community banks govern all FI levels • Strengthen savings • Restructure and modernize • Establish a permissive and institutions and capital Sierra Leone National Pension enabling environment markets Scheme and legislate for new private pension schemes • Adopt international best practice, through legislative • Implement regulatory reforms and regulatory reforms including those for mobile financial services • Build stability and capacity of financial systems • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Distribution Channel • Mobile Financial Services Landscape • Potential Risks • Appendix: Interviews Conducted Mobile Network Overview Mobile Profile Mobile Operators 4 GSMA & 1 CDMA Mobile Coverage Over 82% Mobile Market Share Mobile Subscribers • 3.025 million SIMS, 10% overlap % Share • Approx 2.72 m unique customers • 49% of total population • 50% of adult population Mobile Players Africell 40% Airtel 33% Comium 24% SierraTel 3% Mobile Network Operators • Part of Bharti Airtel • 1.1 M unique SIMs • First MNO to launch mobile Limited • Covers 80% of the money in SL as of June 2012 • IFC investee country • Offering top-up, money • Operates in 16 African • 33% of market share transfer, bill payments, and markets, all in Sub- • Airtel’s popularity is access to GT Bank, Zenith Bank Saharan Africa perceived to be growing and Ecobank accounts • Mobile money • In partnership with • Second phase of service will launched in 8 of the Splash for air-time involve the use of merchants Bharti Airtel 16 markets recharge for retail purchases • 34% market share • Launched Sierra • 81% geographic • Priority is growing customer Leone in 2005 coverage base, MFS will come next • Israeli company • In partnership with • Customer demand could change • Deployments in Israel, Splash as a channel Comium’s position Cote de Ivoire, Sierra provider for a host of Leone, and Gambia services Comium NOTE: Data not available for Africell and SierraTel because they were not available to meet the scoping team • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Distribution Channel • Mobile Financial Services Landscape • Potential Risks • Appendix: Interviews Conducted Distribution Channel Overview • Infrastructure across Sierra Leone is limited, no large-scale distribution partners were identified • There do not seem to be any companies that are moving goods and money back and forth from urban to rural areas. Most traders make their own arrangements to purchase and move goods to their business locations. • Sierra Leone is a hilly country with an underdeveloped road network. Coupled with the effects of long rainy seasons this can make roads impassable, thus cost of moving goods or cash is very high • The national postal service is non-functional. Years of war led to its collapse. The government has plans to revive it, but it remains largely defunct • The MFI sector is also not well established. MITAF indicated that a few MFIs are closing down due to institutional/capacity challenges as well as poor payment culture which has rendered them unsustainable • Airtel and Splash attest to the fact that agent identification and network build-out is difficult due to the small pool of traders available to choose from coupled with high level of capacity building required to bring them up to speed with the service. • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Distribution Channel • Mobile Financial Services Landscape • Potential Risks • Appendix: Interviews Conducted Splash Splash has been in the market for over 3 years, but is experiencing mixed results • Splash launched in 2009 and was the only provider until June 2012. Their service runs over the networks of all 3 GSM providers in the market – Comium, Airtel and Africell • NATCOM licensed Splash to operate, bank partners separately approved by BoSL • Currently services inc P2P, corporate payroll, loan disbursements/repayments, remote bill pay, and remittances • Will spend about $8M in total to scale SL ops and expand to additional markets i.e. Gambia, Ghana, and Liberia • Using MoreMagic, an STK based platform, which Splash plans to link to banks to move funds between bank accounts and wallets. In discussions with GT Bank, UBA, Sierra Leone Commercial Bank and Ecobank. Ecobank, which uses USSD, raised concerns about their STK platform. • Currently 150 agents, which is 3x SL’s ATM footprint, plans to double and network by YE2012. Agents face serious liquidity challenges coupled with power outages which compromise equipment functionality. • Biggest challenge in growing business has been marketing and user education. As a result, shifting focus to corporate clients (B2B) and more sophisticated services • Approached National Power Authority (NPA) to provide pre-paid recharge vouchers and bill payment services. Users have requested service due to current difficulties with paying bills but NPA management has not yet decided to allow Splash to provide this service Airtel Bharti Airtel is the first MNO to launch mobile money in the Sierra Leone market • Launched service on 21 June 2012, STK based due to the low literacy levels in the country • Plan to build a network of 1,000 agents and 200,000 customers by the end of 2012 • Services include airtime top-up, bill payments, and P2P transfers. GT Bank, Zenith Bank and Ecobank customers can link their bank accounts to Airtel mobile money • Escrow account and MM license is through Zenith Bank. Going forward, Airtel wants to partner with three more banks setting them up as super agents and leveraging their branch and ATM networks • Other partner banks are licensed by the CB and simply furnish copies of their approval license to Airtel • Biggest challenge expected to be product acceptance, particularly given strong cash culture. Some communities actually denounce banking, which impacts big traders Airtel could target as agents • Poor road infrastructure, limited bank networks, illiteracy, and cost/availability of electricity are the other expected challenges • Initial market scoping revealed that P2P transfers were the most prominent opportunity as existing services, such as Moneygram, are deemed too expensive • View Splash as mobile money competitor and as a result, Splash is currently unable to sell Airtel’s airtime • Currently do not foresee any regulatory challenges, and are engaged in a continuous dialogue with the regulator to ensure future compliance and minimize business risks Airtel Money Brochure Source: Meeting with Airtel - scoping mission, June 5, 2012 Other Mobile Operators: Comium • Comium is working with Splash by providing their communication channel and allowing Splash to sell Comium airtime recharge vouchers • Do not see themselves playing in this space, but this could change if demand for the service increases in the market • Presently, focus is on building their customer base especially in densely populated areas of the country Ecobank (in partnership with Airtel) A successful Ecobank/Airtel partnership may define future deployments in Sierra Leone • Ecobank believes mobile money will drive their financial inclusion strategy, and sees it as an opportunity to expand their presence and customer base without building branches countrywide • Considered a Splash partnership, but took a step back due to high security requirements on the bank’s side • When group level partnership was established between Airtel and Ecobank, Ecobank SL partnered with Airtel and launched a mobile banking service in June 2012 • Service will be deployed in three phases: (1) bank centric services, such as balance inquiry, (2) bank-to-bank transactions, and (3 ) international transfers • Ecobank will leverage Airtel agents initially, but also have the option of recruiting their own • KYC is the biggest challenge to uptake, as most of the population lacks a valid form of identification, proof of residence, or an official reference. Would like the BoSL to accept biometric cards as ID and bills as proof of residence • Have not carried out any market study, assuming that the SL market will be very similar to other West African markets. Depending on lessons from their other regional deployments • Assumptions are based on leveraging Airtel for marketing, branding, and customer awareness, therefore accepting lower control over the process Other Financial Institutions • Access has a bias for corporate clients, but also provide loans against salaries as part of their retail portfolio • Growth plans include agency banking, or partnering with Splash or the Post office. Focus would be in rural areas • Prior plans for mobile banking dropped due to high implementation costs • Currently not in MFS space in SL, but the service is available in other markets and the SL bank may get involved in the next 18-24 months. • Open to partnerships with either Splash or an MNO • For them, the ultimate benefit of playing in this space is the opportunity to raise deposits and extend their reach through MNO agents • SC has 3 branches and 8,000 customers, 400 of which are corporate and the rest high end retail. • View mobile money as an opportunity to increase deposits, market size and bottom line. • Began working with Splash to launch a simple money transfer service, but experienced a technical problem when integrating their systems. Sierra Leone • Keen to run a mobile money service, but have not yet established Commercial Bank partnerships Apex Organizations • In discussions with Splash to integrate mobile money capability into the national payments switch that SLACB is leading • The decision to go with Splash based on the fact that they’re small, specialized, local, and already have a good relationship with SLACB Sierra Leone Association of Commercial Banks • Mobile money is not an immediate opportunity for the MFI sector as most MFIs lack basic MIS systems and branch connectivity, those with MIS systems use Loan Performer Microfinance • Splash had approached the MFIs to discuss partnership, but cost was an issue. Investment Technical • An exception is Hope, an MFI that used Splash for loan disbursement and was Assistance Facility happy with the outcome (MITAF) • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Distribution Channel • Mobile Financial Services Landscape • Potential Risks • Appendix: Interviews Conducted Risks • Sierra Leone experienced 11 years of civil war which devastated the socio- economic structure and led to a shortage of skilled labor, structured institutions, and wealth distribution. This situation could compromise the ability of the market to exploit the mobile money opportunity • The BoSL has a capacity challenge coupled with very ambitious plans to introduce regulation, supervision, and infrastructure. Mobile money is not likely to be the highest priority.  These goals are likely more than the bank can handle with current resources  While interested in MFS, there is limited capacity to adequately address the issues • Energy distribution and infrastructure is limited and costs are very high. Only 200,000 businesses and households have electricity, 95% of which are in 5 cities • There is lack of clarity as to who is the primary regulator of mobile money service providers. Banks are licensed by the BoSL while MNOs and 3rd party providers by the NATCOM. This could compromise dispute resolution, service, and market standards • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Distribution Channel • Mobile Financial Services Landscape • Potential Risks • Appendix: Interviews Conducted Interviews Conducted Designation Splash Cash Managing Director Systems Manager Access Bank Managing Director ECOBANK Head cards, E-Product &TB Head, Domestic Bank Manocap Partner Sierra Leone Association of Commercial Banks Executive Secretary/COO Bharti Airtel Head of MCommerce Comium NATCOM Director – Consumer, Industry & Public affairs Director of Engineering Senior Internal Auditor (Central) Bank of Sierra Leone Head, Financial Sector Development Project Sierra Leone Commercial Bank Deputy managing Director Micro-Finance Investment technical Assistance Facility – MITAF Representative Standard Chartered Bank Managing Director