Regulatory Impact on Business Model Choice
Three Choices of Business Model
Depending on the regulatory regime in the given country and the amount of regulatory burden the mobile operator is willing to take on, there are 3 types of business models to choose from:
- Mobile operator acts as a bearer – lowest level of regulatory compliance for operator.
- Mobile operator becomes agent of remittance provider and financial institutions – medium level of regulatory burden for operator.
- Mobile operator becomes a financial institutions – high level of regulatory burden on operator.
| Regulatory Situation | Relevant Regulation | Business Model | Comments |
| Banks are the only entities that process any sort of payments | None | Bearer | The bearer business model is possible without major regulatory compliance problems for mobile operators |
| Mobile operators are allowed to be agents | AML/CFT | Bearer, Agent | Mobile operator retail stores can be used to accept/disburse cash |
| Mobile operators can do payments and e-money |
AML/CFT E-money and payment rules |
Bearer, Agent, Payment Service Providers, E-money | Mobile operator retail stores can be used to accept/disburse cash, store cash to make payments to third parties |
| Mobile operators can get a banking license | Fully fledged banking license requirements | Bank | Mobile operators can offer whole range of services: savings, loans, payments, deposit taking |
For More Information
If you would like more detailed information about these three business model choices, download the GSMA document on Regulatory Impact on Business Model Choice (PDF 74KB), which includes more detail on each business model, as well as a mobile operator checklist for business model choice.
