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Safeguarding Funds Stored in Mobile Money Systems | Research by Jonathan Greenacre

24 September 2020

By Jonathan Greenacre, Former Hitachi Fellow, The Hitachi Center for Technology and International Affairs, The Fletcher School of Law and Diplomacy, Tufts University


We need new thinking for the protection of customers’ funds stored in mobile money systems. That new thinking should focus on four key regulatory issues: appropriate governance tools for trusts instruments, legal instruments civil law countries can use in the place of trusts, potential systemic risk that can arise through collapse of a major mobile money firm (MM firm), and crisis management tools that can address such a collapse. And we need that new thinking now because of the rapidly growing size of mobile money sectors. Initially launched in 2004, there are now over one billion mobile money accounts in 95 developing countries, processing a combined $US2 billion in transactions every day.

These are the findings from a recent project at the Fletcher School. From 1 August 2018 – 31 August 2020, the Bill and Melinda Gates Foundation funded a research project at the Fletcher School which was designed to examine new thinking in regulatory frameworks across nine ‘focus countries’: Bangladesh, Kenya, India, Indonesia, Nigeria, Pakistan, Tanzania, Ethiopia and Uganda. The Fletcher School hired Jonathan Greenacre to work on this project under the supervision of Professor Jenny Aker.

Additional detail on these findings are contained in this briefing paper available at Fletcher Leadership Program for Financial Inclusion’s website:


About the Author: Jonathan Greenacre conducted the body of this work as a Hitachi Fellow at the Fletcher School. He is a scholar and lawyer who conducts and research and provides advice on the regulation of fintech.