94998 IFC Mobile Money Scoping Country Report: Afghanistan Margarete Biallas, Scott Stefanski, Cherine El Sayed September 2013 • Summary • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Mobile Financial Services Landscape • Distribution Afghanistan Summary Population: 31.1 (Jul 2013 est.) Wireless Teledensity 39%; 69% of adults Remittance % of GDP na (2011) Percent Under Poverty Line 36% (2009) Adult Literacy 28.1% (2010) Economically Active Pop. 48.4% Ease of doing business: 168th of 185 countries (2013) Main banks: 16 licensed banks Number of Branches: 201 Full Service, 174 limited Mobile Network Operators: Roshan (30.1%), MTN (26.6%), AWCC (22.1%), Etisalat (21.1%) Overview of Mobile Banking in Afghanistan: The foundation for a broad push in mobile payments and banking is still under development. Regulations are supportive and clear enough that all four mobile operators have launched or are planning to launch mobile money services, yet questions still remain how parallel e-money transfer and electronic payment guidelines will be normalized and how e-money will be integrated with the conventional financial network and accounts. Roshan and Etisalat have active mobile money solutions; AWCC is participating in a salary payment pilot along with Roshan and Etisalat while MTN is planning a launch that is delayed by system upgrade issues. Aiding efforts to coordinate the sector are the Association of Mobile Money Operators which in part seeks an interoperable mobile money ecosystem, and the Afghan Payment System plans to introduce an interoperable payment switch to include bank and non-bank mobile and card payment and banking initiatives. Key remaining areas in need of development are implementation of planned shared switch infrastructure, expansion of money agents, and more explicit linkages between bank accounts and mobile money accounts. Trust among the populous that has been shaken by an unstable banking sector, requires strengthening through an aggressive outreach campaign. • Summary • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Mobile Financial Services Landscape • Distribution Mobile Banking Market Potential Key Country Statistics Insights • Population: 31.1 million (Jul 2013 est.) • Agriculture represents 60% of total employment • Age distribution: • 80% of Afghan businesses are SMEs • 0-14 years 42.6% • High mobile adoption, geographically fractured • 15-24 years 21.9% country and low banked population all make for a • 25-54 years 29.1% • 55-64 years 3.8% strong demand for mobile banking to succeed. • 65 and older 2.5% • Distrust of the banking system must be • Urban/rural split: 23% urban / 77% rural overcome, possibly to pursuing • GDP (PPP): $34.29 billion, 109th globally recommendations to leverage existing trust networks as part of a go-to-market strategy. This • GDP per capita (PPP): $1,100, 214th globally may include trials to engage the hawala • Population below poverty line: 36% (2009 data) community, health care networks, or less formal • Economically active: 15 million (2004 data), 35% tribal networks. unemployed (in 2008) • Conflict poses significant challenge to promoting • Literacy rate: 28.1% - 57.7% bellow 19 years mobile banking solutions; might suggest need to • Banking penetration: less than 5% work more initially on MIS solutions for • Mobile phone penetration: 69% adults; 12.24 million agriculture and informal trade management as an unique subscribers, 22.4 million active connections easier, virally propagated starting point. • Remittance (% of GDP): data not available Sources: CIA Factbook, Migration and Remittances Factbook 2011, WB; Wireless Intelligence • Summary • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Mobile Financial Services Landscape • Distribution Regulatory Bodies Involved in Mobile Banking, Page 1 Roles & Responsibilities Implications  License, regulate and supervise banks, foreign exchange dealers, money service providers, payment system operators, securities service DA providers, securities transfer system operators. AFGHANISTAN BANK  Establish, maintain and promote sound and  Capabilities of DAB have been limited; bank (DAB) efficient systems for payments, for transfers of securities issued by the State or DAB, and for audits are at a nascent stage. the clearing and settlement of payment  DAB control and delegation of government transactions and transactions in such securities. salary payments to one bank has raised concerns of better need for transparency and for more competition in delivery of banking services to the large government salaried  Collects revenues, both tax and non tax and population. provides services to other government  Challenges to resolving Kabul Bank crisis agency such as Budget formulation, heighten concerns of DAB and government Ministry of Allotment processing, Payments Processing capacity. Finance and submission of annual audited financial statement. Regulatory Bodies Involved in Mobile Banking, Page 2 Roles & Responsibilities Implications Decree 4517 signed by president Karzai in 2002 granted the MCIT statutory authority to Ministry of issue licenses and spectrum frequency Communications • Afghan Telecom owns and leases permits to private investors as well as the and Information telecommunications infrastructure to operators. A power to adopt new policies, laws, Technology perception is this may inhibit technological regulations necessary for establishing a (MCIT) innovation and competitive offerings modern and competitive telecom sector • http://mcit.gov.af/en/page/22 • The Telecom Regulatory Authority of Afghanistan (ATRA) within the framework of the Ministry of Communications and Information Technology (MCIT) was established according to the The Afghanistan Telecommunication Law in 2006. Telecommunicati • ATRA is responsible for regulating the affairs on Regulatory related to the telecommunications sector. The Authority regulatory body functions in an independent, open, objective, transparent, and non-discriminatory (ATRA) manner within the legal framework in the country. • ATRA is committed to implement international best practices and creating a fully transparent regulatory environment in the country Regulatory Framework, page 1 Current Regulations Implications  MSPs are subject to licensing from the DAB in accordance with the DAB Money Service Providers regulation, 2008.  A licensed MSP may operate as an e-money institution (EMI) and engage in e-money transfer with a special license from DAB.  Separate guidelines for banks and NBFIs to serve as EMIs and  An MSP may not accept deposits, grant loans or for non-Fis (i.e. MNOs) to serve as EMIs poses potential engage in FX transactions. competitive risks, may create security gaps, and may stall Mobile Money  An EMI must be a stock corporation and must be efforts to expand financial services beyond simple transfers Issuers capitalized in an amount of at least $1m. and bill payments.  Banks and NBFIs can operate as EMIs and will be  Lack of explicit mandate that mobile wallets and traditional governed by their respective rules and regulations. bank accounts have support for bidirectional fund transfer  MOF issued a regulation to pay salaries of poses challenges to uptake, usage, and expansion of government employees through mobile: money needs services. to be linked to a bank account to get to mobile wallet. It requires that every employee has at least a traditional bank account for salary payments. Roshan is not following that regulation.  The EMI is responsible for carefully screening, selecting, and supervising their authorized E-money agents. Agents  The EMI entity must provide DAB with the list of  Guidelines appear to have flexibility necessary to test prospective businesses or individuals that the entity unconventional approaches to agent networks such as expects to use as its agents including the proposed engaging informal hawala networks. standard contract outlining the rights and responsibilities, contractual obligations, commissions and fees of each party and customers. Regulatory Framework, page 2 Current Regulations Implications It is the responsibility of the EMI entity to ensure that best practices and proper Know KYC/AML Your Customer (KYC) procedures are conducted during such international transactions. • E-money may be used in different forms such as cash card, debit card, electronic mobile wallet or stored value account card. • E-money limited to Afghani (AFN) currency only; • Transfer virtual money from one virtual wallet to another virtual wallet via: i. Peer-to-peer (P2P) or Person-to-person transfer; ii. Bill Payments; Guidelines curiously mandate specific services that iii. Airtime Top-up or Electronic Voucher reload; must be made available including bill payment and iv. Money Transfer or Remittance; mobile top-up. Such mandates could unintentionally Services v. Domestic (within Afghanistan); pose limitations on innovation and give certain vi. International (incoming only initially); competitors natural advantages (e.g. MNOs will have a Allowed cost advantage in offering mobile top-up at attractive The EMI entity, may at its discretion, have a system rates through their service that a third party could not that can provide advance functionalities or provide) interconnect with other payment systems in the future. These advance functionalities may include, but not be limited to: a. Mobile Banking; b. Microfinance; c. Microcredit; d. Micro insurance; e. Others Regulatory Framework, page 3 Current Regulations Implications The maximum money mobile money balance  Threshold accounts for mobile money on an account of a customer at any given time accounts is high compared to other markets Account Limits is AFN 150,000 (~US$2,700). For International and GDP/capita in Afghanistan. Remittance, the maximum amount per mobile  Might be worth considering a lower threshold money transaction is AFN 150,000. account with easier registration requirements.  Current regulations have led to two parallel  Banks are not required to engage with DAB efforts, one by AMMOA and second by the Interbank Payment System but DAB is only Afghan Payment System to investigate and source for settling DAB money. select switching solutions. Subsequent to APS  While interoperability not mandated, two selection of a switch solution and plans to have institutions exist that could facilitate brokering launched by Q1 2014, AMMOA has suspended Interoperability interoperability agreements – the Association its efforts as MNOs (for now) will seek to of Mobile Money Operators of Afghanistan leverage the investment of APS in their switch. (AMMOA) that is a mobile operator  At the solutions/product level, risks are posed in association effectively, and the national that there is no mandate for enabling fund Afghan Payment System that is convened by transfers between wallets and bank accounts  At the agent level, there is room to investigate a DAB and private banks of Afghanistan. third-party managed agent network. Afghan Deposit Insurance Corporation insures Customer  Does not explicitly cover monies held in deposits up to AFN 100,000 per client per Protection escrow for e-money wallet accounts institution. • Summary • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Mobile Financial Services Landscape • Distribution Financial System Overview ~ 97% of Afghanis without access to banking infrastructure Banks Microfinance Institutions Payment Infrastructure • There are 2 public banks, 10 • There is an estimated 309,914 • Afghanistan has approximately 183 private commercial banks and 5 active MF clients served by 6 ATMs and 272 POS terminals. branches of foreign banks. Microfinance institutions • Debit and credit cards are available • Combined the banking sector • 6 Community-based Savings in eight provinces, while ATM has 352 branches, which is very Promoting Institutions (CSPI) also services are only in the capital city little considering a population of Kabul. A total of 71,468 Debit provide micro finance services to /Credit or ATM cards have been 31 million inhabitants. an estimate of 163,694 clients. issued • In the past few years, several • One bank provides MF services: • 476 licenses to Money Service banks witnessed fraud scandals Bank-E-Millie. Providers (MSP) have been issued. with USD 1 billion of funds • Two MFIs take deposits: First Out of these 476 licensed MSPs, embezzled in Kabul Bank alone. Microfinance Bank of Afghanistan 209 are active in Kabul and 191 are As a result there is a general loss and IIFC Group, in addition to the active in provinces (numbers of trust in the banking sector. 6 CSPIs. includes the 152 licensed Hawala dealers) Switching, Clearing & Settlement • APS is the only MSP in Afghanistan, a consortium of commercial banks. It is the company’s shared infrastructure for ATM and POS terminals. There is no centralized switch infrastructure for all cards and online payments. Switch product has been selected (Dutch vendor BPC) and is slated to launch in Q1 2014. • The current Afghanistan Clearing and Settlement System (ACSS) is a web-based system that does not support SWIFT messaging format. The settlement process is only partially automated which makes the system exposed to operational risk. • WB’s Financial Sector Rapid Response Project in Afghanistan has allocated USD 11 million in the modernization of the current National Payment System (NPS) at DAB and at APS: it will include Real Time Gross Settlement, Automated Clearing House and Central Securities Depository as one system at DAB and National card and mobile payment switch at APS . Source: Summary Analysis of Conditions and Performance of the Banking System, Aug.2011, DAB; Afghanistan MF Sector Update Report, Dec. 2012, AMA; Afghanistan MF Association, Sector update, Dec 2012; FSRRP, Aug. 2011, WB. Draft Report on Payment and Securities Settlement System, and International Remittances in Afghanistan, March 2010, WB Bank Snapshot Afghanistan • 89,880 Customers • 45 ATMs • Total Assets = USD 585 Million International Bank • 31 Branches and 5 • n/a POS Terminals • Mobile Banking Available AIB Cash Outlets • POS Licensed • SME Financing services available • 16 ATMs (+15 under • Total Assets = USD 581 Million • n/a Customers construction) • Mobile Banking services available. New Kabul Bank • 112 Branches • No POS Terminals - POS • Belongs to the MOF after the 2010 services are coming soon scandal • Total assets = USD 453 Million • n/a Customers • 15 ATMs (2 in provinces-13 in • Mobile banking services provided as Azizi Bank • More than 70 Kabul) well as gvt salary mobile payments in Branches • No POS Terminals partnership with Roshan • n/a Customers • ATMs n/a • Total Assets = USD 287 Million Bank - E- Millie • 36 Branches (21 in • POS Terminals n/a • Provides MFI services provinces) • Total Assets = USD 210 Million (2010) • n/a Customers • ATMs n/a • Launched electricity bill payment by Pashtany • 21 Branches (9 in • POS Terminals n/a mobile with Etisalat; 100K users to ramp provinces) to 300K • 6 ATMs locations (3 in Kabul) • Total Assets = USD 168 Million • n/a Customers • n/a POS Terminals - POS • Mobile banking services offered &Will be Maiwand • 37 Branches Licensed – some available in doing a pilot to pay teachers salaries at (20 in Provinces) AWCC operator branches one high school in Kabul. • Total Assets = USD 159 Million • ATM services will be launched • SME financing services available • n/a Customers Afghan United Bank • 22 Branches soon. • Mobile Banking to be launched soon & • No POS Terminals mobile electricity bills payments in partnership with Etisalat provided Source: Bankscope; Banks’ Websites; Interview with Jose Mendoza, FAIDA N.B USD Estimates are at current exchange rate (1 USD=54.74 AFS) Microfinance Snapshot Total customer base of about 408,000, with 6 MFIs and 6 CSPIs First Microfinance • 121,614 Customers • Loan portfolio USD 85.1 m • Using M PAISA for loan disbursements Bank • 34 Branches • Savings portfolio USD 13.3 m and repayments. • 19,305 Customers • Loan portfolio USD 9.5 m Finca • 15 Branches • Savings portfolio 0 • 1,865 Customers • Loan portfolio USD 0.7 m • Is using M-paisa for safer loan Mutahid • 6 Branches • Savings portfolio 0 repayment for Roshan Customers. • 8,679 Customers • Loan portfolio USD 8.7 m Oxus • 11 Branches • Savings portfolio 0 • 3,232 Customers • Loan portfolio USD 1 m Hope for Life • 1 Branches • Savings portfolio 0 • 89,848 Customers • Loan portfolio USD 19.9 m IIFC Group • 26 Branches • Savings portfolio USD 4.4 m 6 Community-based • 163,694 • Loan portfolio USD 7 m Savings Promoting Customers Institutions (CSPIs) • Savings portfolio USD 2.2 m • 94 Branches Source: DAB; Afghanistan Microfinance Sector Update Report, Dec. 2012, AMA; Draft Report on Payment and Securities Settlement System, and International Remittances in Afghanistan, March 2010, WB Payment Service Providers • The only payment service provider in Afghanistan, a consortium of commercial banks. • Interoperable banking network connected to the global financial system (according to their APS website.) Afghan Payment • Offers POS procurement and management, ATM driving and acquiring, mobile payment System solutions, card services. • The development of a national electronic payment card switch funded by the World Bank will allow for interoperability of cards and mobile payments. • Network of unofficial brokers /informal couriers that provide money transfer services based on honour system • 152 Hawala dealers are licensed by DAB as Money Service Providers (MSPs) (2010 data) Hawala • One estimate is there are 3-5,000 hawala agents. • It is the less costly and most trusted MSP. According to DAB, Hawala dealers are less expensive than banks, in particular for transfers from the Gulf countries to Afghanistan Source: www.afghanpayments.com ; Draft Report on Payment and Securities Settlement System, and International Remittances in Afghanistan, March 2010, WB Financial Flows - International Remittances • It is estimated that 8.1% of the Afghani population lives abroad mainly in the Islamic Republic of Iran, Germany, the United States, the United Kingdom, Tajikistan, Canada, the Netherlands, Australia, Saudi Arabia, Denmark. • There is 23.3% emigration of tertiary educated people • Starting March 2009, there was a total of USD 142 million in inward remittances and USD 138 million in outward remittances. According to the DAB analysis, the top five inward remitting countries are the United States of America, United Arab Emirates, Germany, Switzerland, Bangladesh and Netherlands, while outward remittances go mainly to the USA, India, Germany, United Arab Emirates and China. • There are two major channels for sending remittances to Afghanistan:  International Money Transfer Operators (MTOs), such as Western Union and MoneyGram.  Local Money Service Providers (MSP): Mainly Hawala dealers. Source: Migration and Remittances Factbook 2011, WB; Draft Report on Payment and Securities Settlement System, and International Remittances in Afghanistan, March 2010, WB Financial Flows - Government • DAB is the banker for Government of Afghanistan (GOA), it operates the government Treasury Single Account. • All payments and receipts are processed manually. • The Ministry of Finance and the GOA operate a computer based accounting system “FreeBalance”. Payment orders are printed out from that system and carried to DAB for processing. Paper-based statements are provided by DAB to the Ministry for reconciliation with “FreeBalance” accounting system. • Likewise, DAB collects revenues such as taxes, customs duties, fines etc. generally via commercial banks and credited to the Treasury Single Account. • There are 150,000 Direct Deposit accounts via MOF Verified Payroll Program (2010 data) There are a total of 480,000 payroll accounts at commercial banks (government and else.) • As part of its Financial Sector Rapid Response Project in Afghanistan, the WB is planning to support the development of electronic Government payments framework by supporting DAB in introducing an Automated Transfer System (ATS) in its National Payment System(NPS). This would allow direct electronic connection between GOA’s “FreeBalance” and DAB’s ATS. Source: Draft Report on Payment and Securities Settlement System, and International Remittances in Afghanistan, March 2010, W B Money Transfer • Afghanis have very limited access to financial infrastructure that is combined with a high level of corruption in the banking sector highlighted by the failure of Kabul Bank in 2010. • There is a wide use of informal courier network for money transfer services based on honor system : HAWALA. • Hawala has been in service for at least 2 centuries. It survived the long years of war and is to date the most trusted payment system available in Source: Mobile Money Afghanistan,2010 IMTFI & Frog Design. Afghanistan. • Banks are now the least trusted channel of payment in the country (note that this diagram is dated just before the 2010 Kabul banking failure) however banks play an important role as agents for International MTOs. • Hawala dealers are major MPS in Afghanistan as they are one of the less costly and most reliable channel for money transfer, less expensive than banks. The most expensive channel is International MTOs. • Despite the fact that M Paisa is the least expensive channel, it is still struggling to overcome issues such as security, weak agents network and wide illiteracy that prevents it from reaching the mass. Source: Draft Report on Payment and Securities Settlement System, and International Remittances in Afghanistan, March 2010, W B • Summary • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Mobile Financial Services Landscape • Distribution Mobile Network Operators 20 million mobile phones lines 65% penetration ratio Close to 100% penetration among st users that are more than 14 years old • 6 million mobile • Aga Khan Fund for Econ. Dev. • Partnered with Vodafone and subscribers (AKFED)- 51.00% (IFC client) Development banks: M Paisa Roshan • Monaco Telecom International Mobile Money transfer (with • 30.1 % market share (MTI) - 36.5% Interactive Voice Response System) • 5.3 million mobile • Multinational Telecom Group subscribers in 21 countries in Africa Asia MTN and ME. Listed in JS Stock • 26.6 % market share Exchange 90% • IFC 9% • 4.4 million mobile • Joint venture with MCIT • Partnered with Maiwand bank – subscribers (20%) and US-based holds POS terminals and AWCC Telephone System performs salary payments • 22.1 % market share International (TSI) (80%) • Has POS with biometric (thumb and photo) • 4.2 million mobile • 100% owned subsidiary of • Partnered with United bank- Use subscribers UAE-based Etisalat mobile to receive and pay Etisalat Telecommunication electricity bills. Expected in • 21.1 % market share Corporation - Multinational March 2013 Source: The State of Telecommunication in Afghanistan, 2012, USAID ; Operators websites; Interview with Jose Mendoza, FAIDA; Afghanistan Mobile Money Dashboard, Feb. 2013, USAID. Mobile Outlook Mobile penetration is estimated to have reached 65%. • The Telecom sector in Afghanistan has witnessed phenomenal growth in the past 10 years. It has been a developmental catalyst for the country by attracting, in 2012, 1.8 billion in total investment, creating 110,000 direct and indirect jobs and making it the largest revenue and tax generating sector in the country. • Roshan is the leading operator - it has received a license in 2003- Etisalat in 2006- MTN in 2005 and AWCC in 2002. • Increased competition led to cheaper and improved quality of services as cost of using a cellular fell drastically: • Sim cards from 250$ in 2003 to less than a dollar now. • Local calls from 18 AFS in 2002 to 3 AFS now. • Making it more affordable and accessible to the base of the pyramid consumers. Source:BMI, NTM Roshan’ s M Paisa mobile money initiative in partnership with Vodafone (though struggling to achieve scale) resulted in a higher level of mobile money awareness & knowledge and in the creation of the Association of Mobile Money Operators in Afghanistan (AMMOA) Telecommunication Infrastructure • Following the massive destruction that occurred during the war in 2001, there has been strong focus on the reconstruction of the national telecom infrastructure. The latter represents the largest chunk of total investments in Afghanistan. • As a result, 4,428 telecom base stations have been erected forming the country-wide microwave network that serves mobile service and wireless connectivity (mainly funded by the four mobile operators.) • In addition 76 telecom base stations are being built in rural areas allocated by MCIT/ATRA from the Telecommunications Development Fund (TDF) under the Universal Access Program (UAP). Source: The State of Telecommunication in Afghanistan, 2012, USAID • Summary • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Mobile Financial Services Landscape • Distribution Transformative Mobile Banking Initiatives • M Paisa is a mobile money transfer service that was launched in 2009. It started initially to pay afghan police officers as to fight corruption from middlemen. • The system gives the opportunity for people with no bank accounts to do basic banking transactions Roshan & such as balance inquiry, cash withdrawals, cash transfer, airtime purchase and MFI loan disbursement Vodafone in and repayments. partnership with • Western Union also signed with Roshan to enable international mobile money transfer. Azizi Bank: • According to their website M-Paisa reached 1.2 million subscribers. It had 50,000 subscribers in 2010. • Uses agents mostly mom and pop shops, however agent’s commission system can be misconceived M-PAISA as bribery. • MFI Mutahid and First Microfinance Bank are also using M-Paisa for safer micro-loan repayments. • Challenges: Lack of scale due to the existence of Hawalas, a general lack of trust in institutions, difficulties to form a reliable agent network and low consumer awareness level about the benefits of mobile money. • Launched in 2012 • Offers: • Cash Deposit (Available Now) Etisalat with • Cash Withdrawal (Available Now) • Cash Transfer (Available Now) Afghanistan • Airtime Top up (Available Now) United Bank: • Bill Payment (Coming Soon) • Merchant Payment (Coming Soon) mHawala • Loan Payment (Coming Soon) • Opening an mHawala account is performed either remotely by the customer over the phone, or in store, on production of a suitable identity document. Where a customer chooses the self registration option no cash in or cash out transactions are supported, meaning that a client must receive a P2P payment to support any purchases he wishes to make. Transformative Mobile Banking Initiatives - continued • Founded in May 2011 by the 4 mobile network operators with the assistance of USAID. • FAIDA* is strengthening the organization by providing technical assistance. Association of • Currently led by Roshan M-Paisa President Zahir Khoja. Mobile Money • 3 out of the 4 operators have mobile banking project underway or are already in the market: Roshan, Operators in Etisalat & AWCC: Afghanistan AWCC ( partnered with Maiwand bank) are working on the implementation of a teacher salary pilot in one school in Kabul that should be launched in July 2013 AMMOA Etilsalat ( partner to Afg. United Bank) have signed up 80,000 “mHawala” client in Kabul to pay electricity bills MTN (new Kabul bank) Uses the fundamo platform which was recently bought by VISA and is still trying to get the platform to work * FAIDA: Financial Access for Investing in the Development of Afghanistan. A USAID initiative that assists the Government of the Islamic Republic of Afghanistan and the private sector in developing the financial sector. Source: Afghanistan Mobile Money Dashboard,Feb.2013, USAID; www.ammoa.org; The State of Telecommunication in Afghanistan, 2012, USAID; Draft Report on Payment and Securities Settlement System, and International Remittances in Afghanistan, March 2010, WB • Summary • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Mobile Financial Services Landscape • Distribution Distribution Segment Known Resources • Roshan – 500 agents for MPaisa • Etisalat – 2,100 agents, 4,000 POS, 1,000 women to be trained with Ministry of Labor Mobile Operators and FAIDA • AMMOA has recruited 800 potential agents to be trained; model of service unclear • Numbers not known however, SMEs constitute 75% of all Afghan formal Retailers enterprise; possible avenue is to examine and leverage product distribution/collection networks for these businesses • Numbers not known but hawala informal Informal Networks money transfer networks are entrenched and trusted despite inefficiencies