In one of my previous articles, i explained the Regulatory Framework governing International Money Transfer Operator (IMTO)Services  in Nigeria as well as its scope in terms of permissible and non-permissible activities.

In this article, the topic will be International Mobile Money Remittance services, a sub-category of Mobile Money Operators (MMO) in Nigeria and the focal points treated therein will be :-

– The Regulatory Framework governing IMMRS

– The permissible and non-permissible activities allowed for IMMRS

– The recognized participants in an IMMRS venture

– The licensing requirements for IMMRS

What is the Regulatory Framework governing IMMRS in Nigeria?

IMMRS licensing and operation in Nigeria is governed by the Central Bank of Nigeria which maintains a Regulatory oversight through the Banks and Other Financial Institutions Act (BOFIA) and mainly the CBN Guidelines on International Mobile Money Remittance Services in Nigeria 2015(or ‘the guidelines’) with the following objectives:-

– The provision of minimum standards and requirements for the operation of International funds remittance over/via mobile services in Nigeria.

– The specification of delivery channels for offering International funds remittance over mobile devices in a cost-effective manner.

– The provision of an enabling environment for International funds remittance over mobile devices in the Nigerian economy.

– The provision of broad guidelines for the implementation of processes and flows of International Money Transfer services, from initiation to completion.

What are the permissible and non-permissible activities for IMMRS in Nigeria?

Permissible Activities

– Inbound remittances via Mobile phone transfers & other hand held devices to persons resident in Nigeria & foreign visitors in Nigeria.

– Outbound Person-to-Pereson remittances from Nigeria to beneficiaries in other countries for purposes of family maintenance and personal expenses.

Non-Permissible Activities

– The facilitating of transactions or rendering remittance services for corporate customers.

Who are the participants in an IMMRS venture?

A typical IMMRS scheme in Nigeria is made up of the following participants :-

– Banks 

– Mobile Network Operators

– Infrastructure Providers

– Consumers

What are the licensing/authorization requirements for IMMRS in Nigeria?

Institutions seeking to venture into IMMRS will have to send through their lawyer an application for an authorization to the Central Bank of Nigeria which may be granted as long as:-

– The applicant holds a Mobile Money Operators license (this is a license category also governed by the Central Bank of Nigeria, you can consult your lawyer on how to secure this type of license).

– The applicant, if a foreign-based entrant, is a registered corporate entity licensed over there to engage in monetary transfer activities.

– The applicant has a net worth of $1 Billion (strictly for Foreign applicants).

– The applicant is established in at least 20 countries in with at least 10 years experience.

– The applicant is in a partnership with an authorized dealer bank in Nigeria.

– Foreign-based companies seeking to render IMMRS services in Nigeria need not be licensed by the Central Bank of Nigeria but must obtain an approval from the CBN to operate in Nigeria. 

– Institutions seeking IMMRS licensing have to be preferably registered as Consortiums and in addition to the main application to the CBN for authorization have to submit the following:-

a). Evidence of the formation of the consortium that will deploy the IMMRS project (a Certificate of Incorporation).

b). The consortium’s profile & functional contact details.

c). A shareholding structure of the Consortium.

d). Statutory CAC forms for Returns on Allotment of Shares as well as Particulars of Directors.

e). CVs of the board of directors/management of the Consortium.

f). A Business plan of the Consortium.

g). The IT policy of the Consortium.

h). The Enterprise Risk Management Framework of the Consortium.

i). The Contingency & Disaster Recovery Plan(Business continuity programme) of the Consortium.

j). Draft agreements with the following:-

– Technical partners

– Participating banks

– Switching companies

– Merchants

– Telecommunications companies

– Any other party

k). Project deployment plan

l). Evidence of payment of a non-refundable application fee of 1 Million Naira.

What are the operational requirements for IMMRS Operators in Nigeria?

IMMRS operators in Nigeria must :-

– Be issued with a unique code by the Nigerian Interbank Settlement by NIBBS. 

– Be issued a unique short code by the Nigerian Communications Commission.

– Ensure that its Telecommunications equipment is the type approved by the Nigerian Communications Commission (NCC).

– Register users of the scheme based on Tech standards and the requirements of the guidelines.

– Ensure “Know – Your – Customer” (KYC) requirement compliance in its user registration process.

Conclusion :- It is hoped from the above write-up that a clearer understanding of the Regulatory Framework governing International Mobile Money Remittance services as different from International Money Transfer Services has been achieved going forward.

I watched a video on how some lawyers destroyed registration booths during the Nigerian Bar Association (NBA) conference – and carted away registration materials: “Nigerian lawyers go on rampage, destroying registration booths and conference bags at NBA conference last night August 23..

“According to reports, the lawyers had gathered to collect conference bags which had hindered them from collecting other conference materials. The lawyers became impatient over the slow pace at which they were being attended to. Some of them forcefully reached out to get the bags containing the conference materials and this led to chaos that saw the registration booths being destroyed.”

We condemn this attitude exhibited by the supposedly learned men. But this is not typical: Nigerians live on the mindset of scarcity and that has remained our problem. We always think things will never get to us. And that is the reason we cut corners, fight and mess up things. Even the demons of corruption are rooted therein: steal for the great grandkids since before they are born, everything would have gone. But for experienced lawyers to do this, it means Nigeria is fading faster than some of us might have thought.

Those days in FUTO, we used to “fight”, bulldoze, etc just to pay the N25 school fees. The question remains: why must you fight to do that? In reality, it makes no sense why a student will push and be pushed to pay school fees. Then, go to motor parks: check what happens there. The bus has 14 seats and 7 people are waiting, yet, those 7 will push to board.

I do hope the Nigerian Bar Association issues small penalties to these lawyers. We cannot have angry lawyers in Nigeria. The woman in Akwa Ibom who locked up Inibehe Effiong is enough evidence!

https://youtu.be/4cln4pzzt_s

Comment: Prof, if college was such a great investment, they wouldn’t need to freeze payments or forgive debt [in America]. It just signifies that university tuition is ridiculously overpriced. A degree should help one find a job and should be cheap and easy to pay off [edited for clarity].

My Response:  The problem is that people have made university education or going to school to be about money. Initially, it was about the liberation of the mind. The argument that university education is overpriced [no debate there] misses the point. Obama was carrying student loans into White House because he preferred to serve his community as a community organizer instead of picking a big job as a Harvard Law graduate.

He could have earned $400k per year and paid off the loan. But he chose not, living on nothing for years. What Biden is saying is this: there are many people that are helping to build America in Goodwill, Teach for America, non-profits, etc using their education, but do not earn much to pay down student loans. Obama’s Harvard education was useful even though he did not use it to pile $$$. Forgiving loans for people like Obamas who chose to serve over $$ does not hurt the nation.

While we hope the cost of education goes down, we must not be tripped that education is designed just to pile cash and make money. If you have finished paying yours, congrats. But that does not mean some do not need help because some among them preferred to serve in areas that would not have put them in ways to pay their debts. 

When you see those Harvard grads joining Teach for America for $45k, you show them respect because they’re leaving behind potential $150k to help kids in rural America to learn. If the government wants to assist them, that is noble.

Comment on Feed

My Comment 1: What of those who do not go for university education. Why should the tax payer subsidize those who get university education at the expense of those who do not?

My Response 1: That reasoning in my opinion assumes public policy does not have an offset. If everyone does not go to college, we will not have doctors, engineers, etc who make the society function. While everyone will have zero debts, we will also not have hospitals. The guy who did not attend college benefits because data shows that most of them are those who receive food stamps (poverty), use emergency healthcare (they have no insurance), rehab (drunks and drugs), etc.

In other words, the government spends 7x whatever the college guy could have received from loan support/forgiveness through many free services designed to support them. This does not mean that everyone who skipped college turned out to need support but many in this freebies are non-college educated in America.

So, those arguments are weak, statistically, for public policy. Go to any city, check those lining up for free government grocery, most are non-college educated. That is the “student loan debts” forgiveness for them. That government is waiving $10k for a doctor with a $300k loan must not be muddled. That doctor took personal economic risk to help many who will turn out in emergency wards for freebies (sure, they have $0 debt)!

NB: people, this is an academic debate, I am not attacking anyone who did not go to university.

Comment 1-2: This assumes I support those freebies.

Response 1-2: “This assumes I support those freebies.” -You do. Everyone is covered by emergency services like fire service, ambulatory in case of accident, no-deposit emergency services, etc. When an ambulance picks someone on a highway after an accident, and saves that person, without that accidented person first negotiating contracts and fees, that is freebie. The value of saving a life cannot be compared to any money that person has in the bank. Everyone benefits from society.

The difference is that they come in many forms. President Trump made that case against Bezos of Amazon. He noted that Amazon was declaring $billions while the post office shipping its items was losing $billions. But US was fine, offering ecommerce firms freebies to keep rural and urban America growing. Bezos has made it clear: without the freebies from USPS, Amazon would not have succeeded.

Freebies in America come in many ways. If you become a black farmer in America today, you get $millions because Biden wants to diversify it. But a white farmer may complain. That is fine. The white farmer possibly gets freebies in another way. The problem is thinking the freebies must have the same form.

Comment 2: Prof, don’t you think the American capitalist system may collapse if they short-circuit the system?

That is, who then maintains the schools and other institutions? I believe the taxpayers will have to cushion that effect. If so, won’t individual taxes run high?

Again, is this student loan relief not about the November mid term elections. Remember, Osibanjo also shared TRADER MONEY just before the 2019 election. Is this any different considering that Joe Bidens rating is very low?

My Response 2: Take time on American democracy. Michigan received a bailout from George Bush who saved their jobs. But many were not happy that the government had to bail them out. In the end, they voted against the same government which bailed out their big companies and kept their jobs. Biden will lose many votes for doing this, by the same people who benefited in many areas!

This student bailout is nothing – poor people receive freebies (free healthcare, free grocery, free housing, etc). If you think giving those will give you votes, you are dreaming. Have you noticed that the more Biden stimulates and spends, the more unpopular he becomes? That differs from the Nigerian version where you can buy people with freebies!

Comment 3: I don’t blame the person that commented. Many of us have been misled about the purpose of education because universities are being advertised as a get rich scheme. That’s why some people are now saying that school is a scam because they were misled during enrollment. This is also the reason why people are no longer enrolling in trade schools where practical information for problem solving are being taught.

As educators, we might need to start teaching people about the purpose of education before getting into the real subject. As one of my professors said, “education is not a guarantee that you will be rich, it only increases your odds.” When we see education as a meal ticket, we lose its purpose. Education is for the liberation of the mind, enlightenment, and learning to gain access to information. The information you gain from school will not make you rich, it’s the application of information that can make you rich.

BIW – Biden is Working As He Writes off Student Loans