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Digital financial services


Our work includes:

Proliferation of communications devices and liberalisation of financial regulation is opening a flood of new digital financial payment systems, digital credit and other products. These are contributing to important gains in financial inclusion in many countries.

We assist policy makers, regulators and service providers in designing, applying and navigating the regulatory ecosystem, on issues such as licensing and market entry, prudential financial regulation, interoperability, use of customer data, agent networks, competition and access to the telecom platform.

Recent activities include:

Studying digital international remittances in the Malaysia-Philippines corridor for CGAP, including regulatory policy and market development.

Identifying and assessing national and regional competition regulatory issues in East Africa for CGAP relating to a proposed regional mobile money interoperability scheme.

Advising the Competition Authority of Kenya, the World’s leader in mobile financial services, in two market enquiries, one into competition in retail banking (including mobile banking), and the other into competition issues in the provision of telecom services for provision of mobile financial services.

Advising a major international services provider on regulatory policy and liberalisation of the digital financial services market in Bangladesh.

Advising a European Government on introduction of mobile money services in a region of Europe.

Advising the Ugandan Competition Commission in a review of the telecom platforms (USSD and SMS) used for mobile financial services.

Studying competition bottlenecks in mobile financial services in Tanzania and Uganda for the Bill & Melinda Gates Foundation.


We seek to bring the latest in expertise to our clients as they navigate complex interrelated issues involving financial, telecommunications and competition regulation.

In 2017, Rory led a capacity building training session on competition in digital financial services, focusing on network effects and interoperability issues at the Financial Inclusion Global Initiative (FIGI) of the World Bank, International Telecommunication Union, Bank of International Settlements and Bill & Melinda Gates Foundation in Bangalore, India.

In 2016, Rory authored and presented a wide-ranging paper Digital Financial Services: Regulating for Financial Inclusion at the ITU’s Global Dialogue on Digital Financial Inclusion, part of its Global Symposium for Regulators.

In 2016, Rory co-authored the GSMA paper, Regulatory and policy trends impacting Digital Identity and the role of mobile, which examines regulatory issues related to digital identity, including data protection and privacy, particularly in financial services.

In 2016, Jason authored a study on the regulation of mobile credit services, published in the African Journal on Information and Communication. He presented this to the ITU’s Digital Financial Services Focus Group in Dar es Salaam, Tanzania and the Competition Law and Economic Regulation Conference at the University of Nairobi Law School in 2016.

In 2016, Rory co-authored a study on digital financial services in Uganda published in the African Journal on Information and Communication, including an assessment of the market and the regulatory environment.





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