The Reporting of Suspicious Activity by Mobile Money Service Providers in Accordance with International Standards: How Does It Impact on Financial Inclusion?

Among the obligations which countries are required to impose upon their financial institutions under the Financial Action Task Force’s (FATF) 40 Recommendations is the obligation to report suspicions of money laundering. This Article discusses the impact that a reporting regime such as that set up in the United Kingdom in response to FATF requirements is likely to have should it be set up in developing countries seeking to regulate mobile money services. This Article argues that certain features of the U.K. suspicious activity reporting regime make it unsuitable for wholesale adoption into such a context. A one-size-fits-all approach by the FATF in establishing suspicious activity reporting obligations is likely to reduce the accessibility, affordability and attractiveness of mobile money services, thus impacting negatively upon the goal of financial inclusion