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Our glossary of terms that the CBN (Central Bank of Nigeria) used in the Regulatory Framework for Mobile Money Services in Nigeria, July, 2021 (the “Mobile Money Framework”), should narrow the knowledge gap among stakeholders in financial technology services.

Concise Summary

  • Meaning of mobile money services
  • Aim of mobile money framework
  • Changes that CBN’s PSB regulation introduced into the Mobile Money Framework
  • New concepts or terms such as pull-based or push-based transactions and their meaning

Mobile money services are Short Message Service based mobile banking also known as USSD. SMS is a text messaging service component of most telephone, Internet, and mobile device systems that uses standardized communication protocols that enables mobile devices exchange short text messages

Mobile money services are very different from mobile banking although both are accessed on mobile devices. Mobile banking rides on internet-enabled mobile device-based application or software while mobile money services leverage on consumer’s airtime only.

Mobile Money Framework seeks to deepen mobile money services, set technical and business requirements aimed at enhancing consumers’ confidence. A CBN’s financial inclusion magic wand.

Telco-led mobile money services that was prohibited in the Mobile Money Framework are now permitted mobile money model under the August 2020, Guidelines for Licensing and Regulation of Payment Service Banks in Nigeria (the “PSB Regulation”).

Nigeria recently reaped the fruits of the PSB Regulations. In April, 2022, MTN as the parent company of MOMO Agents announced that Yello Digital Financial Services has received CBN’s PSB lincence.

We note that the PSB Regulation forbids a PSB that include MOMO agent form including or adding any words that links it to the parent company.

– We submit that reference to words under the PSB Regulation should include registered or unregistered brand colours and other trade representation otherwise the reason for the prohibition may be defeated.

Terms under the Mobile Money Framework

  • 3DES: Triple Data Encryption Standard: is a symmetric-key block cipher, which applies the DES cipher algorithm three times to each data block.
  • 3DES: Triple (3) Data Encryption Standard: is a symmetric-key block cipher, which applies the DES (data encryption standard) cipher algorithm three times to each data block.
  • Bank-led model: is a model where a bank or a consortium of banks, alone or together with other CBN approved entities delivers banking services using mobile payment system. The lead initiator must not a bank or a consortium of banks.
  • Infrastructure providers: include entities that provide payment software or application or services such as switching, processing and settlement. – Settlement means inter-bank settlement.
  • Infrastructure providers: include entities that provide payment software or application or services such as switching, processing and settlement. – Settlement means inter-bank settlement.
  • Interoperability: is any situation in which payment instruments belonging to a given scheme may be used in systems installed by other schemes.
  • Inter-Scheme Operation: are mobile payments consummated across 2 different schemes by various participants.
  • Inter-Scheme Settlement: provides net positions of transactions across schemes to the inter-bank settlement system. This helps to resolve the finality of payment for services consummated across two different Schemes by participants.
  • Intra-Scheme Operations: are mobile payments consummated within a service provider’s scheme.
  • Issuer: an entity that receives payment in exchange for value distributed in the system and which is obligated to pay or redeem transactions or balances presented to it.
  • IVR: Interactive Voice Response is a technology that allows humans to interact with a computer-operated phone system through the use of voice and DTMF tones input via a keypad.
  • Nominee Account: means MMO’s settlement accounts with DMBs under a custodial arrangement. – MMO’s customers are the beneficial owners of a nominee account.
  • Non-bank led Model: allows an entity specifically licenced by CBN to deliver mobile money services to consumers. The lead initiator must not be a deposit money bank (“DMB”) or mortgage bank.
  • Participants: include Regulators (CBN and NCC), mobile money operators, infrastructure providers, consumers and mobile money agents.
  • PCIDSS: Payment Card Industry Data Security Standard is an information security standard for entities that handle branded credit cards from the major card schemes. The PCI Standard is mandated by the card brands but administered by the Payment Card Industry Security Standards Council.
  • Pull-based account transactions: are debits in any bank account through a mobile money solution or application. – Account holder must authorize a pull-based transaction through a verifiable mode before the transaction is consummated.
  • Push-based account transactions: are credits to a bank account through a mobile money solution or application.
  • Re-loadable stored value: allows a stored-value card to perform transactions on any device or software that can access the stored-value card.
  • RTGS: CBN’s Real Time Gross Settlement (RTGS) System that effects settlement of transfer among banks on real time and gross basis.
  • STK: Systems Tool Kit is a physics-based software package from Analytical Graphics, Inc. that allows engineers and scientists to perform complex analyses of ground, sea, air, and space platforms, and share results in one integrated environment.
  • Telco-Led model: means any entity licenced under the CBN’s PSB Regulation to deliver approved mobile money services.
  • USSD: Unstructured Supplementary Service Data may be referred to as “quick codes” or “feature codes”. A communications protocol used by GSM cellular telephones to communicate with the mobile network operator’s computers


Fintech lawyers that include Solicitors and advocates; developers; law enforcement agents; regulators; and service providers across the mobile money service value-chain and the judiciary ought to understand the terms used in the Mobile Money Framework as well as any other legislations.

In the recent past, we represented a client whose bank account with UBA was depleted because the client’s lost his mobile phone. The fraudsters who accessed the client’s UBA account through UBA’s USSD banking exceeded the prescribed daily limit under the CBN’s USSD Regulation.

In the client’s scenario above, UBA’s USSD was also accessed through Paystack and Fluterwave. UBA thinks that it did not exceed the daily limit because transactions occurred on its USSD *919# as well as on Paystack and Flutterwave front-ends.

A case of multiple access to UBA’s USSD *919# only. UBA’s position apparently contradicts how these multiple accessibilities of banking platforms are designed to operate.

Knowledge base in the fintech must be continually improved upon.

Osita Enwe heads our Fintech, Education, and Agribusiness law practice groups



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