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TRANSCRIPT
Rapid
FSP Mapping
in
South Sudan
Picture: S/NFI Cluster South Sudan
CASH AND VOUCHER ASSISTANCE
M o d a l i t i e s
a n d
M e c h a n i s m sJUNE 2020
C A S H W O R K I N G G R O U P S O U T H S U D A N
0
2
4
6
8
10
12
14
Central Equatoria Eastern Equatoria Jonglei Lakes Northern Bahr elGhazal
Unity Upper Nile Warrap Western Bahr elGhazal
Western Equatoria Abyei
No. of Organizations No of Modalities No of DMs No of FSPs
S T A T E S S U M M A R Y
T h e R a p i d F S P A s s e s s m e n t ( C V A T r a n s f e r M e c h a n i s m s a n d M o d a l i t i e s ) w a s d o n e t o p r o v i d e i n f o r m a t i o n o n t h e F S P c o v e r a g e , m o d a l i t i e s u s e d b y p a r t n e r s , d e l i v e r y m e c h a n i s m s u s e d b y p a r t n e r s , s e r v i c e s a v a i l a b l e i n t h e S o u t h S u d a n .
CentralCentral
EquatoriaEquatoria
EasternEastern
EquatoriaEquatoria
Lakes Lakes
Northern
Northern
Bahr el
Bahr el
Ghazal
GhazalUnity
Unity
Warrap
Warrap
WesternWestern
Bahr elBahr el
GhazalGhazal
WesternWestern
EquatoriaEquatoria
JongleiJonglei
Upper NileUpper NileAbyei
CentralCentral
EquatoriaEquatoria
EasternEastern
EquatoriaEquatoria
LakesLakes
NorthernBahr el
GhazalUnity
Unity
Warrap
Warrap
WesternWestern
Bahr elBahr el
GhazalGhazal
WesternWestern
EquatoriaEquatoria
JongleiJonglei
Upper NileUpper NileAbyei
48%
29%
1%3%
5%
9%
3% 2%
South Sudan
Cash in Envelop (Org/IP)
Direct Cash (FSP)
Smart Card
E-card
Paper Voucher
Agents/Traders
Market Fair / Seed Fair
Other/not mentioned
D EL I VERY ME C HANI SMSUS ED B Y C WG P A RTNERS I N S T ATES
C V A MODALI T I ES US ED BY CWG P A RTNERS I N S T ATES
36%49%
8%
4%
2% 1%
South Sudan
CCT
UCT
Voucher
Hybrid
MPCA
Other/not mentioned
S o u r c e : M o d a l i t i e s a n d M e c h a n i s m s t o o l ( f i l l e d b y o r g a n i z a t i o n s ) , J a n - M a r 5 W s o f F S L , S N F I , C C C M , a n d W A S H c l u s t e r s , W B Q u e s t i o n n a i r e
PARTNERS
T h e s e a r e p a r t n e r s w h o h a s s h a r e d t h e i r d a t a e i t h e r t o C W G o r t o c l u s t e r s f o r f u l l l i s t o f
p a r t n e r s c l i c k h e r e
Organization CCT UCT Voucher Hybrid MPCAOther/not mentioned
Cash in Envelop (Org/IP)
Direct Cash (FSP)
Smart Card / E-
card
Paper Voucher
Agents/Traders
Market Fair /
Seed Fair
AAHI x xAFRAS x x x x x xACF x x x xACTED xAVSI x xCare x xCMA xCWW x x xDRC xFAO x x x xFCA x xGoal x x xHAGI x xIMC x xIOM x x x x xJAMI x x xLWF x x x x x xMalteser x x xNRC x x x xOxfam x x x x xPAH x x xPlan x x xRDAA x xTearfund x x x x xVSF-S x xWHH x x x x x x x x xUNOPS/WB x x x xWVSS x
ORGANIZATIONS - DELIVERY MECHANISMS AND MODALITIES
Source
Modalities and Mechanism tool of
& 5Ws from (Jan to March 2020) of
CentralCentral
EquatoriaEquatoria
EasternEastern
EquatoriaEquatoria
LakesLakes
NorthernNorthern
Bahr elBahr el
GhazalGhazal
UnityUnity
WarrapWarrap
WesternWestern
Bahr elBahr el
GhazalGhazal
Western EquatoriaWestern Equatoria
JongleiJonglei
Upper NileUpper NileAbiemnhom
Akobo
Aweil Centre
Aweil EastAweil North
AweilSouth
Aweil West
Awerial
Ayod
Baliet
Bor South
Budi
Canal
Cueibet
Duk
Ezo
Fangak
Fashoda
Gogrial EastGogrialWest
Guit
Ibba
Ikotos
Juba
Jur River
Kajo-Keji
Kapoeta EastKapoeta
North
Kapoeta South
Koch
Lainya
Leer
Longochuk
Lapon
Luakpiny/Nasir
Maban
Magwi
Maiwut
Malakal
Manyo
Maridi
Mayendit
Mayom
Melut
Morobo
MundriEastMundri West
Mvolo
Nagero
Nyirol
Nzara
Panyijiar
Panyikang
Pariang
Pibor
Pochalla
Raga
Renk
Rubkona
RumbekCentre
RumbekEast
Rumbek North
Tambura
Terekeka
Tonj East
Tonj North
TonjSouth
Torit
Twic
Twic East
Ulang
Uror
Wau
Wulu
Yambio
Yei
Yirol East
Yirol West
8
5
3
5
7
7
11
36
7
7
6
2
8
9
10
7
6
11
2
5
4
6
6
6
6
6
11
3
7
9
9
8
4
8
8
9
1110
11
4
3
6
5
5
6
6
8
9
3
5
5
6
6
3
4
8
10
6
7
8
7
7
8
4
3
10
10
6
5
8
5
6
4
3
6
6
9
9
7
Abyei
Dier for Trade
79
79
16
30
8
55
74
17
40
55
28
FSPs in county
FSPs in StateSimilar FSPsCountyState Administrative Area
F I NANCI AL S E RVI CE P R OVI DERS ( C OUNTY L E VEL )
Agents OTC Cash Dist: in field
ATMs MMT Smart Cards
Alpha Bank
TIAM
Dier for Trade
M-Gurush
NilePay
COOP
LEM
Equity Bank
Galaxy (GSI)
Eco Bank
Opportunity B
Prepaid Cards
Paper Voucher
Other
FSP
Other
O t h e r s e r v i c e s a v a i l a b l e I n S o u t h S u d a n
E-voucher Mobile Banking
A/c opening
IRIS, FR, Biometric
Digital platforms
F S P S E RVI C ES A V AI L ABL E I N S O UTH S UDAN
Source: Nilepay
K N OW Y O UR C US TOMER ( K YC)R E QUI REMENTS
Tier 1 Wallet – with Simplified KYC
Accounts are subject to a maximum balance limit of USD 1,000, anaggregate daily transaction limit of USD 250 and an aggregatemonthly transaction limit of USD 2,000 or its equivalence for SouthSudanese Pounds transactions.
Tier 2 Wallet – with Partial KYC
Accounts are subject to a maximum balance limit of USD 4,000, anaggregate daily transaction limit of USD 1,000 and an aggregatemonthly transaction limit of USD 8,000 or its equivalence for SouthSudanese Pounds transactions.
Tier 3 Wallet – with Full KYC
Accounts are subject to a maximum balance limit of USD 10,000, anaggregate daily transaction limit of USD 2,000 and an aggregatemonthly transaction limit of USD 20,000 or it's equivalent for SouthSudanese Pounds transactions.
Know Your Customer (KYC) regulations, also known as customer duediligence, are designed to combat money laundering, terroristfinancing, and other related threats to the financial system. Theyrefer to the ID checks that financial institutions perform to complywith national financial regulations
Accessibility and security are the main challenges in most location in South Sudan
Accessibility to remote areas with no network coverage and limited transport accessBiometric system have challenges, when it comes to reading finger prints for most of the SSD beneficiaries
Security issues, high delivery charges
SOME OF THE MAIN CHALLENGES REGARDING PAYMENT SYSTEMSREPORTED BY SOME PARTNERS
C A S H V O U C H E R S V E N D O R SHighly manual processes, thus rigorous -- verifying and reconciling documentation takes time
Infrastructural limitation, there is limited to no mobile connection and so does affect on how FSP could function. Some of these locations are prone to insecurity and people fear to put up business
Road accessibility of other remote locations, No airstrip
Challenges in payments assome of the vendors do not have registered Bank Accounts
D I G I T A L P A Y M E N T S : biggest obstacle preventing or slowing down the adoption of digital payments in South Sudan reported by partners are Infrastructural limitation, mobile network coverage, and electricity
What has been the most significant impact of the Covid-19 crisis with respect to making and receiving payments by your organization?
Does your organization have a business continuity plan? Has it
been triggered by Covid-19?
Were your banking partners or financial service providers able to provide services to your organization in a way that ensured physical distancing? How?
Have you been facing shortage of physical currency because of the reduction in flights and movement restrictions?
Has your ability to make and receive payments been affected by movement
restrictions?
Have your payments been affected by the rapidly
increased spread between the official and the unofficial SSD/USD exchange rate?
Org-1 Org-2 Org-3 Org-4 Org-5 Org-6
Not answered
Yes
Yes, we consider limited number of people in receiving of cash
intervention
Yes, some of our filed Offices ran shortage of physical currency because the financial service
provider was not able reach the field Office due to the limited
flights
Yes
No
Yes: Staff are teleworking; essential staff are on the move to
ensure key processes are not stalled
Yes Yes Yes Yes: Yes, there is COVID-19 emergency plan
Implementation modalities were changed. Restricted
movement/access caused delays in implementation
Delays in delivery of cash to the field
Lack of access of service provider to some areas of operation, due to limited
flights/movement
Delayed transfers due to movement restrictions by the
Govt
Conditional programs affected as beneficiaries are prevented from
working together, longer time spent in achieving output, longer
time spent in paying as few people are targeted daily
Making payments to fewer beneficiaries at specified intervals;
working with local leaders; providing relevant information/guidelines to beneficiaries to ensure they adhere
to distancing in meeting points
all social distancing measures are observed in the banking facilities
Partially, only in some locations as bigger towns (Bor, Wau)
Yes
During distributions, we ensure that distribution points are closer
to the beneficiaries and few beneficiaries are targeted daily to avoid overcrowding, ensure staff
use PPE
Yes depending on the financial service provider- those with
networks have been ok, those without networks faced challenges
YesMainly in areas like Akobo, it has
been a challenge with money transfer.
Yes, timely delivery of cash to project location has been affected.
Clearance also takes long time
Yes
No Yes In Akobo mainly Yes This is expected to happen if restrictions are tightened
Our values are set in USD and converted in SSP at prevailing UN rate. Therefore, the real value of cash intended to be received by
the beneficiary is preserved
We have also adopted a flexible monthly transfers based on
prevailing exchange rate as it has parallel change on prices of
commodities
Yes No
Yes, ideally using the bank rate leaves beneficiaries at loss because market prices of goods are based on
parallel black market exchange rates.
COVID-19 IMPACTS
Questions
DELIVERY MECHANISMS, ADVANTAGES AND DISADVANTAGES
Delivery Mechanism Description Possible Provider Some of the advantages Some of the disadvantages
Direct Cash
(Cash in envelops)Cash handed out directly to recipients by the implementing organization.
Implementing organization/
partner
Speed, simplicity, and cost
Flexible if recipients move locations
Security and corruption risks
Often labor intensive, especially in terms of staff time
For recipients a lack of flexibility in when they receive cash and possible long
waiting times.
Cash Over The Counter (OTC)
- in house
Cash delivered to recipients through a formal or informal institution that acts as an intermediary.
Does not require
recipients to hold an account.
Cash over the counter can be provided through range of instruments including Beneficiary payment
lists (BPLS), checks, prepaid cards, mobile codes, biometric or money orders.
Commercial Banks
If cash delivery carries security risks, distributions may be in the form of checks or vouchers
redeemable at a financial service provider. Instead of establishing bank accounts,
beneficiaries are able to safely withdraw cash with a program-distributed check. This
method offers security to the recipients and to the program team and allows for more
accurate distribution of cash.
Very limited bank branches and branch capacities to support a huge number of
beneficiaries as it needs a lot of preparatory work, monitoring, and crowd
control.
Recipient cannot gain access to banking system
OTC (in field)
Money on wheals /
Cash in envelops through FSP staff, partners or
agents
Cash delivered to recipients through a formal or informal institution that acts as an intermediary.
Does not require
recipients to hold an account.
Cash over the counter can be provided through range of instruments including Beneficiary payment
lists (BPLS), checks, prepaid cards, mobile codes, biometric or money orders.
Money transfer agents, post
offices, traders, microfinance
institutions, banks
Local financial institutions may, in some locations, be contracted to deliver cash transfers
directly to beneficiaries at project sites.
Security risk for agency is reduced
Agents may have greater access then agencies to hard to reach areas
One of the most expensive method
Multiple and predictive distributions can pose security risk to FSP
Mobile Money Transfers (Cash and E-
Vouchers)
entails using a basic mobile phone to carry out financial and commercial transactions such
as cash deposits, withdrawals and payments.
Mobile network operator (MNO),
Banks, and technology service
providers
Secure and flexible
Reduce risks to beneficiaries
E-Wallets
Can be accessed through most basic mobile phone
Systems may take time and be complex to establish (multi-party engagement)
Not feasible for areas with no mobile network
Beneficiary (with limited or no literacy) may not be able read the messages for
payments
Smart Cards
(Cash and/or E-Vouchers)
Plastic card with a chip, valid with point-of-sale devices and ATMs, used for cash grants and store
purchases. Can
provide offline transaction authentication when network connectivity is off.
Banks, non-bank financial
service providers,
Bears more information and can be used offline with traders
Highly secure than magnetic strip card and other type of cards
Data integrity
Systems may take time and be complex to establish
Cost and risks of new technology such as smart cards
Local regulations may exclude some people (KYC)
Prepaid Cards
(Cash and/or E-Vouchers)
Plastic card usable at cash machines (automated teller machines or ATMs), used for cash grants and
vouchers. Can
be swiped at point-of-sale devices. Always requires network connection for transaction
authentication.
Banks, non-bank financial
service providers, technology
service providers, microfinance
institutions, post office
As with banks, possible reduced corruption and security risks.
Reduced workload for staff
Greater flexibility for beneficiaries in where and when cash be collected from (i.e ATMs,
PoS, traders)
Systems may take time and be complex to establish
Risks of agents running out of money
Costs and risks of new technology
Store limited data and have minimal security
Local regulations may exclude some people (KYC)
Paper Vouchers with specific security features
Paper vouchers with QR code or other security features
The paper voucher always come with single or multiple denominations
A paper voucher can be value or commodity voucher.
Printer, Publishers, Small service
providers
Quick to distribute and circulate.
East to use by beneficiaries with its visual features
cost of printing and distributing the paper vouchers, as well as the staff time
required to manage and monitor the assistance
Delivering through Bank accounts Opening Beneficiary bank accounts Banks
Help to include beneficiaries into country financial systems.
Individual accounts give beneficiaries maximum control over when they withdraw their
cash. They also afford a measure of security to the beneficiaries (who are not forced to
keep their payments in cash) and the program team (who do not directly handle cash).
additional banking cost to beneficiaries, the logistics of setting up the accounts
(including identification requirements), the trips required to complete
paperwork and the potential discomfort to beneficiaries if this is a new process.
It is important to make sure that this methodology does not exclude some
beneficiary groups, such as illiterate, elderly or youth populations.
KYC requirement can slow the process of opening the bank account
SourcesCDMAT UNHCRMC toolkit on CTPDelivering Money CTP in emergencies
CATEGORY TYPE OF RISK DESCRIPTION (provide a brief description which includes features and examples of risks for CVA)
POTENTIAL IMPACT on CVA Impact Likelihood Weight Possible Mitigation Measures (suggested by partners)
Contextual risk-External Access constraintsFSPs can no longer deliver cash to remote field
locations, due to suspension of domestic flights and inaccessibility by road
Suspension of CVA programming 5 5 25.00
• Potential chartering of flight (if allowed) = cost implication
Programmatic risks Aggravating risk of infection
and/or reduced impact (FSPs)
Financial service providers do not have the capacity to respond to increased demand from beneficiaries (e.g. limited ATMs and remittance agencies)
Beneficiaries cannot access cash or put themselves at greater risk by queuing at
agencies and ATMs 4 4 16.00
• Beneficiaries may not be allowed to queuing, limited number be considered for per distribution • Liaise with local actors to ensure beneficiary safety and security; Avoid pulling out large cash during shopping; avoid social places• Split and spread beneficiaries or consider home delivery • Discuss FSP capacity to respond as a preparedness measure. Organize distributions in line with FSP capacity and resources.
Programmatic risks Exclusion risks As the virus spreads, infected beneficiaries are
sick and cannot access the delivery points Exclusion of the most vulnerable
people from the program 4 4 16.00
• Beneficiaries may not be allowed to queuing or to participate, limit number be considered for per distribution • Continue providing support to the most vulnerable populations through shock-responsive assistance • The most vulnerable should not be excluded from any interventions, in that case, switch to "house to house distributions" • Work with local implementing partners, local institutions, e.g. churches or mosques to do safe home delivery of assistance • Increase attention to targeting, or ensure funding will allow more generous cash now to help those who are vulnerable to prepare. Encourage social shielding and put measures in place to help provide the most vulnerable with supplies being delivered directly. • Identification of an alternative family member/ friend that can receive the transfer on their behalf. If no other options arise, provision of in-kind assistance if appropriate.• Engage with health workers to deliver exclusively to those who cannot access delivery points; make door to door Split and spread beneficiaries• Discuss FSP capacity to respond as a preparedness measure. Organize distributions in line with FSP capacity and resources.
Programmatic risks Aggravating risk of infection
and/or reduced impact
Financial services do not have capacity to respond to increased demand (especially FSPs offering over-the-counter services)
Beneficiaries cannot access cash or put themselves at greater risk by queuing at
agencies and ATMs 4 4 16.00
• Consider changing delivery mechanisms to be less public, Advise beneficiaries to access banks during working hours; Avoid suspicious and storage faces• Discuss security with FSPs as a preparedness measure and include additional security requirements into costing. Organize distributions in line with FSP capacity and resources. • Split and spread beneficiaries or consider home delivery
Programmatic risks Operational risk (FSP)Financial service providers increase the cost of
services to compensate for new prevention and security measures
Prohibitive cost limits or does not allow continued use of the financial
service 4 3 12.00
• Increase the cost limits to continue to use the financial services • Consider affordable services; priorities needs and preferences• have framework agreements with FSP • Advocate for reasonable regulations with FSPs and authorities • Discuss FSP costing models as a preparedness measure. Organize distributions in line with FSP capacity and resources.
Programmatic risks unintended consequences-Increasing risks of infection
The use of cash, vouchers, cards, ATMs, PoS contributes to infected surfaces, long lines
Cash transfer programmes inadvertently contribute to the spread
of the virus 3 3 9.00
• Increased focus on hygiene, use of CVA to increase awareness raising, split beneficiaries in groups w. separate distribution points or even deliver to homes to avoid long lines. Ensure implementing partners and FSPs follow hygiene instructions. • Engage with Risk Educators to communicate risk; Collaborate with Protection, WASH and Health Partners on awareness and messaging, ensure all stakeholders have the understanding of how to disinfect areas properly and the IEC materials on preventive measures. • Consider ways to reduce risk around cash handling/distribution, for example, by using digital means or local payment agents • Develop, promote and follow relevant guidelines and protocols that would mitigate against this risk.
Programmatic risks Aggravating risks of theft and
violence
With an increase in insecurity, ATMs or withdrawal points become areas of risk for robbery, assault, etc.
Increases risk of theft or violence due to withdrawal of money
3 3 9.00
• Money should be paid by the financial service provider to avoid fraud by the staff and reduce risks of theft • Reduce the amount on single transfers but increase on frequency of Cash Transfers (where applicable)• FSP bears the risk for loss until they distribute it, problem might be that FSP will stop its service in case of theft• NGO can involve RRC for support• Consider changing delivery mechanisms to be less risky• Discuss security with FSPs as a preparedness measure and include additional security requirements into costing. Organize distributions in line with FSP capacity and resources• Train beneficiaries on safe cash storage and cash management; observe strange behaviours and movement
SOME OF THE RISKS FROM SOUTH SUDAN CVA RISK MATRIX - COVID 19(Developed with the support of CashCap and contribution from NRC, Plan International, CGA, Titi Foundation, DCA, Malteser-International, CWW, AAHI, CINA and World Bank) in March 2020
Protection Risks: When identifying and analyzing the delivery mechanism aprotection lens should be applied and mainstreamed.• PIA: A PIA is a process for assessing the impacts on privacy of a project, policy,
programme, product or service and, in consultation with stakeholders, fortaking remedial actions as necessary in order to correct, avoid or minimize thenegative impacts on data subjects.1Budgeting the hidden costs (i.e. transactioncosts if these are being taken by the agency, currency fluctuations etc.)
• GDPR: gives individuals the right to decide when they no longer want theirdata to be processed.
• GBV Risks: consider GBV risks before selecting the delivery mechanisms
Counterparty risk (FSPs or other private sector counterparts not fulfilling theircontractual obligations)Geography vs. liquidity (in remote geographical areas there may not be sufficientcash liquidity to fulfill all the transfer amounts if they are for e.g. being provided bysmall traders acting as agents, if a lot of people use it on the same day)Lost or diverted funds (this links to the cash going astray somehow and can happeneven when an automated system is in use)Making payment to beneficiaries (can be security risks with some deliverymechanisms such as cash in envelopes)
• Failure to comply with organisational or donor processes, which may in turn
ultimately lead to expenditure being deemed ineligible during an audit
• Corruption or bias in awarding contracts
• Contract doesn’t adequately detail required deliverables / differing
understanding or expectations between the organisation and service provider
of contract provisions and requirements may result in poor service to
beneficiaries
• Service providers seeking to charge excessively high fees as the market is not
competitive
• Service providers unable to deliver as per the terms of their contract, oftenresulting in failing to deliver to beneficiaries
• Complaints and Feedback Mechanism: FSP call center not able to providequality service to humanitarian communities, issue of staff, local language,context specific channels are not used.
GENERAL RISKS AND
CONSIDERATIONS
Risks related to working with FSPs
BENEFICIARY DATA PROTECTION
Data protection is defined as the systematic application of a set
of institutional, technical and physical safeguards that preserve
the right to privacy with respect to the collection, storage, use,
disclosure and disposal of personal data. Personal data include
all information that can be used to identify data subject, which in
the case of humanitarian cash-based intervention means our
programme beneficiaries.
o The image shows the key steps in the cycle for data protection.
This illustrates that this is not a one-time consideration – there
are different elements which need to be addressed, which will
correspond with various stages in the project cycle. We’ll come
back to this in an exercise at the end of the session.
o In humanitarian programming data protection means that data
from beneficiaries should only be used in the way it was
intended, and that beneficiaries are aware of how their data is
used. Beneficiaries should provide consent before data is
collected, and only data necessary for programming purposes
should be asked for. Beneficiaries should not feel like they did in
this exercise where data was being collected and shared and they
were not sure why or for what purpose.
1. RESPECT: Organisations should respect the privacy of beneficiaries and
recognise that obtaining and processing their personal data represents a
potential threat to that privacy.
2. PROTECT BY DESIGN: Organisations should “protect by design” the
personal data they obtain from beneficiaries, either for their own use or
for use by third parties for each cash or e-transfer programme they initiate
or implement.
3. UNDERSTAND DATA FLOWS AND RISKS: Organisations should analyse,
document and understand the flow of beneficiary data for each cash or e-
transfer programme they initiate or implement within their own
organisation and between their organisation and others and develop risk
mitigation strategies which might be required to address any risks arising
from these flows.
4. QUALITY AND ACCURACY: Organisations should ensure the accuracy of the
personal data they collect, store and use, including by keeping information
up to date, relevant and not excessive in relation to the purpose for which
it is processed, and by not keeping data for longer than is necessary.
5. OBTAIN CONSENT OR INFORM BENEFICIARIES AS TO THE USE OF THEIR
DATA: At the point of data capture, beneficiaries should be informed as to
the nature of the data being collected, with whom it will be shared, who is
responsible for the secure use of their data and be provided with the
opportunity to question the use made of the data and withdraw from the
programme should they not wish their personal data to be used for the
purposes described
6. SECURITY: Organisations should implement appropriate technical and
operational security standards for each stage of the collection, use and
transfer of beneficiary data to prevent unauthorised access, disclosure or
loss and in particular any external threats should be identified and actions
taken to mitigate any risks arising
7. DISPOSAL: Organisations should not hold beneficiary data for longer than
is required unless they have clear, justifiable and documented reasons for
doing so otherwise data held by the organisation and any relevant third
parties should be destroyed
8. ACCOUNTABILITY: Organisations should establish a mechanism whereby a
beneficiary can request information about what personal data an
organisation holds about them, and mechanisms to receive and respond to
any complaints or concerns beneficiaries may have about the use of their
personal data
P R I N C I P L E S F O R T H E S E C U R E U S E O F P E R S O N A L D A T A I N C A S H A N D
E - T R A N S F E R P R O G R A M M E S
CALP PROTECTING BENEFICIARY PRIVACY CDMAT - UNHCRCWG Nigeria
WORLD BANK SCOPING STUDYMobile Money Ecosystem in South Sudan
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CELL PHONE COVERAGE
The following data is drawn from REACH’s January 2020 AoK data collection
https://www.impact-repository.org/document/reach/241d4913/REACH_SSD_Communication-Modality-Preferences_FINAL.pdf
ASSESSING SERVICE PROVIDERS
Payments landscape scoping (national and local) – this is to develop a good understanding of the
landscape and options available for cash transfer delivery, both at a national and local level. Note
that sometimes this will be referred to as a “delivery market assessment.” The methodology used
for collecting and analysing this information is likely to include the following:
o Desk review: There are online databases that can be used - the World Bank’s Global Findex
Database and GSMA’s https://www.gsmaintelligence.com/. The GSMA is a trade body that
represents the approximately 800 mobile operators. Their intelligence website requires registration
but offers free access to basic metrics about mobile network coverage and mobile money access at
national levels. There may be other existing secondary data about a specific country or location that
can be sourced also.
o Key informant interviews: this would need to be preceded by a mapping of stakeholders and
contacts. This might include local FSPs, community organizations, implementing agencies also
implementing cash transfers, donors and government agencies supporting cash transfers
Part of this data collection process is at a macro level, relating to the wider operating environment,
for example:
o Population demographics (e.g. bank account holders, mobile phone use, users of remittance
agencies, etc.)
o National bank system (e.g. ref. their role in the structure of the country’s financial system and
economic stability)
o Regulatory environment (this is critically important - regulations can affect ID requirements, the
types of bank account available to beneficiaries, and how much cash can be transferred at one time)
o Infrastructure (e.g. transport/road network, electricity, phone coverage, bank branches, ATMs, etc.)
o Competition (e.g. range of service providers, this might affect negotiation of costs)
You’ll also need more detailed data for specific service providers. Aspects to include here are:
o Services provided
o Coverage
o Previous experience
o Time to delivery
o Service cost
o Support required
o User requirements (e.g. ID, KYC)
o Security measures
o RisksCaLP
CRITERIA TO SELECT ANY
DELIVERY MECHANISM:
Appropriateness: What DM is suitable as per the context?
Feasibility: Is it possible to implement this DM considering the context, risks and other
operational constraints related to DM? In this part, especially, you will need input from
colleagues across the organization who understand the financial, logistical and practical
concerns with each delivery Mechanisms (DM).
Effectiveness: Can the use of DM meet its objective? It may be possible to evaluate the
cost-effectiveness of different interventions, as in how much does it cost to get to the
humanitarian objective by this particular modality and delivery mechanism. In the US
Government’s Modality Decision Tool, this criteria is referred to as “Objective.”
Efficiency: Can the DM be rolled out on time to be effective? How long it will take from
planning phase to encashment? How long will it take to deliver? Also, there is a cost-
efficiency angle to this question. What would be the cost per beneficiary? How efficient
are the different modality and delivery mechanisms and combinations? In the US
Government’s Modality Decision Tool, this criteria is referred to as “Cost.”
Training to beneficiariesThe best delivery mechanism is preferred delivery mechanism which is accessible (socially,
physically, and financially) to the communities. If you choose to work with a financial
service provider, make sure that beneficiaries receive basic financial skills training to use
the selected Delivery mechanism, as well as a detailed description of all fees associated
with the delivery mechanism and requirements for accessing the assistance.
Physical access: Some older, sick or disabled disaster affected people may have
mobility issues. Keeping this in mind, organisations can pick a different delivery
mechanism (e.g., Help Age in Ukraine used postal service as it could be delivered
directly to the door of the beneficiary) or increase the number of distribution
points.
Illiteracy: Will community be able to understand the ICT material? Will they be
able to use new technologies?
Social Access: Conflict between host communities and refugees/IDPs, Women
mobility, Ethnic groups access to assistance, social cohesion, exclusion of persons
with disability or other groups.
Financial Access: Cost to beneficiaries
Some Vulnerabilities to be considered
Identify existing FSPs considering
local, national and global FSP
options (including traders)
Scope out the infrastructure environment
in the operating context to
understand what means are currently
used to transfer cash
Identify the regulatory
considerations in the
operating context to
understand the effect on
how beneficiaries can access
cash
Document the characteristics
of potential CBAs: size;
frequency of transfer;
required speed of delivery; scale-up;
population type and
implication for ID; population
location (rural/urban); likely level of
contextual risk;
organisational risk
Account for beneficiary
financial literacy,
technology familiarity and
preferences
Allow for a convenient,
familiar, flexible, and
low cost delivery
system for beneficiaries,
while upholding safety and
delivery preferences
Links from the PQ tool box (Financial Service Provider (FSP) assessment and contracting)
FSP options for delivering CBA are mapped, alongside the infrastructural and regulatory environment
Key Actions for FSP assessment as per Programme Quality Tool Box (Click here to the guiding
documents and tools)
Guiding Documents:
Mercy Corps E-Transfer Implementation Guide (pdf)
Mercy Corps E-Transfer Implementation Guide (webpage)
The delivery guide - Scoping the Humanitarian Payments Landscape
ELAN Mobile Money Assessment and Contracting guide
UNHCR Cash Delivery Mechanisms Assessment Tool
CaLP Protecting Beneficiary Privacy Principles and operational standards for the secure use of personal data in cash
and e-transfer
ELAN's Data Starter Kit TipSheet 3 Know Your Customer (KYC) Regulation
Tools for (FSP assessment, selecting delivery mechanisms, Contracting FSPs and ensuring privacy and data protection)
IFRC/ICRC CiE Toolkit M2_2_1_2 Household level cash questions template
IFRC/ICRC CiE Toolkit M2_2_1_1 Community level cash questions template
IFRC/ICRC CiE Toolkit M2_4_1_1 Assessing FSP topics and sources template
IFRC/ICRC CiE Toolkit M2_4_1_2 Assessing FSP Capacity Checklist
IFRC/ICRC CiE Toolkit M2_4_1_3 Mapping service providers template
Mercy Corps E-Transfer Implementation Guide Annex 3: Analyzing E-transfer Service Provider Capacity
Mercy Corps E-Transfer Implementation Guide Annex 10: Compliance and fraud concerns in E-transfers
IFRC/ICRC CiE Toolkit M3_1_3_1 Comparing CTP modality & mechanism
IFRC/ICRC CiE Toolkit M3_1_3_3 Advantages & disadvantages CTP mechanisms
IFRC/ICRC CiE Toolkit M4_3_1_1 Mobile money requirements checklist
IFRC/ICRC CiE Toolkit M4_3_1_2 Value card requirements checklist
IFRC/ICRC CiE Toolkit M4_3_1_3 E-transfer requirements checklist
IFRC/ICRC CiE Toolkit M4_3_1_4 Assessing mobile money template
IFRC/ICRC CiE Toolkit M4_3_1_5 Assessing service providers checklist
Mercy Corps E-Transfer Implementation Guide Annex 3: Analyzing E-transfer Service Provider Capacity
USAID Nethope Making the Journey from Cash to Electronic Payments Service provider capacity assessment in Step 5:
Selecting a SP
IFRC/ICRC CiE Toolkit M4_3_3_1 IFRC Standard contract template
IFRC/ICRC CiE Toolkit Vouchers Box: 2_2. Contract Template [FOR VOUCHERS]
Mercy Corps E-Transfer Implementation Guide Annex 8 E-cash Contract Checklist [FOR E-CASH]
IMPORTANT L INKS
Banks MFIs Mobile Money Remittance Post Offices
• No of Banks in the country
• No of total branches in the
country
• No of ATMs in the country
• Capital adequacy ratio
• Non-performing loans
• Return on assets
• Bank soundness rank (WEF –
world economic forum)
• Leading commercial bank in the
country
• Market dominated by bank type
(local or foreign)
• Major challenges in the banking
sector
• Internet banking
• Development and trends
• IMF statement on banking
sector
• Licensing by central bank
• Customer defined in legislation
• Maximum credit amount defined
in legislation
• Permitted use of funds defined
in legislation
• MFI good practices available in
the country
• Number of operators
• Leading MFI by number of active
borrowers
• Years in business ("oldest MFI")
• Number of active borrowers &
services provides
• Population served
• Developments and trends in the
sector
• Government or international
donor funding available for MFIs
• IMF article IV/ CGAP comment
on the financial
solvency/reliability
• Licensing by Central Bank
• Bank-led model of licensing
• Liquidity and/or solvency-
related requirements for non-
bank e-money issuers
• Regulation of agents
• No of Mobile Money providers
• Major MM provider
• Presence of leading international
players
• Years in business ("oldest MM")
• Received remittances via phone
• Services provided
• Developments and trends in the
sector
• MM good practices available in
the country
• Transparency and
professionalism of information
publication (e.g. website, annual
reports)
• CO judgement of sector
reliability
• Licensing by Central Bank
• Number of operators
• Major remittance company by
network size/depth (number of
branches/agents)
• Presence of leading international
players
• Agent coverage (in comparison
to other types of FSPs' access
points)
• Remittance share of GDP
• Remittance share of GDP 10
year trend
• Remittance origin
• Remittance cost
• Received remittances via money
transfer operator
• Developments and trends in the
sector
• Role of informal remittance
market
• CO judgement of sector
reliability
• Postal company name
• Number of branches
• Post office coverage (compared
to other types of FSPs)
• Branches per 100,000 people
• Services provided
• Number of services listed above
• CO judgement of sector
reliability
WFP FINANCIAL SECTORIAL ASSESSMENTS ( MaFA)
E x a m p l e s f r o m W F P M a c r o F i n a n c i a l a s s e s s m e n t ( M a F A )
WFP SELECTION OF FINANCIAL SERVICE PROVIDERS (MIFA)
Micro Sector Checklist
• Questions about FSP’s:• Assets, reserves, audit
opinion• Geographic presence• Operational capability
• Outcome• Weighted score
HACT Checklist
• Questions about Partner’s:• Business practices• Internal controls• Risk management
• Outcome• NOT Pass/Fail• Assessment of
Partner’s strength• Potential risk for WFP
Financial Strength Assessment & Risk
Scores
• Detailed analysis of:• Credit rating• Audit opinion• Key financial ratios
• Outcome• Overall rating/conclusion• Recommendations, i.e.
Performance Bond
NGOs, Partners, Governments
Financial Service Providers (banks)Mobile Operators
People receiving cash as payment for creating
new assets in Warrap State.
Source: WFP_SouthSudan twitter
Company profile
Implementation of mandatory policies defined by regulatory bodies
Financial soundness
Experience
References of previous projects
Skills
Geographic coverage
MICRO SECTOR CHECKLIST
E x a m p l e s f r o m W F P M i c r o F i n a n c i a l A s s e s s m e n t ( M i F A )
T h e C a s h W o r k i n g G r o u p S o u t h S u d a n a c k n o w l e d g e s u p p o r t f r o m i t s c o l e a d s ( W F P a n d I O M ) , O C H A , I M W G , C l u s t e r s ( F S L , S N F I ,
C C C M , W A S H a n d P r o t e c t i o n ) , C W G P a r t n e r s ( R E A C H i n i t i a t i v e , W o r l d B a n k , A A H I , A C E M , A C F , A C T E D , A F R A S , A V S I , C A R D , C a r e ,
C A W D C , C M A , C W W , D A R O , D R C , D R D A , F A O , F C A , G L O B A L A I M , G o a l , H A G I , H D C , H E L P O , H L S S , I M C , J A M I , L C A D , L W F , M a l t e s e r ,
N P A , N R C , N R D O , O x f a m , P A H , P l a n , R C D I , R D A A , S A A D O , S T O , T e a r f u n d , T O C H , U N H C R , V S F - S , W C D O , W H H , W V S S , U N O P S ) a n d
F S P s ( A L P H A B a n k , T I A M , G a l a x y , D i e r f o r T r a d e , E q u i t y B a n k , C O O P , L E M , E c o B a n k , O p p o r t u n i t y B a n k N i l e p a y a n d M - G u r u s h )
T h i s m a p p i n g e x e r c i s e w a s d o n e t h r o u g h t h e t e c h n i c a l s u p p o r t o f C A S H C A P .
ACKNOWLEDGMENT
CWG Coordinator
Ali MANSOOR
CashCap Advisor
IOM Co-leads
Afsar KHAN
Operations Officer – ES/NFIs
WFP Co-leads
Aikins MACBANSAH
CBT Team Leader
F o r Mo r e i n f or mat ion c o nt act
Cash Working Group South Sudan