Amid the rapid revolution of Ghana’s Mobile Money (MoMo) sector, an expert is making a strong case for the need for commensurate development in regulation to catch up with its rapid growth.
This is the case of banking and financial analyst Dr. Richmond Atuahene, who is calling for a sweeping overhaul of Ghana’s financial regulatory architecture to ensure the country’s booming digital finance ecosystem remains innovative without becoming a source of financial instability.
Building on recommendations by the International Monetary Fund (IMF) and the Financial Stability Board (FSB), Dr. Atuahene argues that Ghana needs a modern regulatory framework that matches oversight to the risks mobile money platforms now pose to the financial system.
He emphasizes that rather than imposing blanket restrictions, he proposes reforms that would close regulatory gaps while preserving the enormous gains mobile money has delivered in financial inclusion.
Regulate the Activity, Not Just the Institution
Central to Dr. Atuahene’s recommendations is what he describes as activity-based regulation, a principle that focuses on what a financial institution does rather than who owns it. Under this approach, if a mobile money operator performs functions similar to a bank, such as holding customer funds or providing credit, it should face comparable regulatory standards.
He argues that the current system, where banks face stricter rules while mobile money operators performing similar financial activities operate under lighter requirements, creates regulatory loopholes and an uneven playing field.
For him, the same financial activity should attract the same level of regulation regardless of whether it is offered by a bank, telecom company or fintech.
Larger Mobile Money Operators Should Face Bank-Level Oversight
Aside from the regulation, he argues that recognising that not all providers pose the same level of risk, and hence recommends a tiered licensing regime in which regulatory requirements increase with the size, complexity, and systemic importance of an institution.
Small payment providers would continue operating under simpler rules, while dominant operators such as MTN Mobile Money would be subject to regulations closer to those governing commercial banks.
This would include stronger capital buffers, full protection of customer funds through regulated trust accounts, stricter liquidity requirements, enhanced corporate governance, stronger cybersecurity standards, and more robust anti-money laundering controls. He also recommends mandatory interoperability to ensure customers can move money seamlessly across networks and banks.
Create Regulatory Sandboxes to Encourage Safe Innovation
Rather than regulating emerging technologies after problems arise, Dr. Atuahene advocates expanding regulatory sandboxes. These controlled environments allow fintech firms to test innovative financial products with real customers under close supervision before receiving full regulatory approval.
He believes the approach enables regulators to understand emerging risks while encouraging responsible innovation instead of stifling it.
Break Down Regulatory Silos
Because mobile money sits at the intersection of banking, telecommunications, payments, cybersecurity, and data protection, Dr. Atuahene says no single regulator can effectively supervise the sector alone.
He therefore proposes stronger coordination among the Bank of Ghana, National Communications Authority, Cyber Security Authority and other financial regulators through mandatory information sharing, joint inspections and coordinated risk assessments.
Such collaboration, he argues, would enable authorities to detect systemic risks earlier and respond more effectively.
Match Regulation to Risk
The banking and financial expert also recommends adopting a risk-based regulatory approach, where supervisory attention is concentrated on activities posing the greatest financial risks.
Instead of applying identical rules to every provider, regulators would allocate more resources to supervising larger institutions and higher-risk transactions while reducing compliance burdens for smaller, lower-risk operators.
According to him, this would strengthen financial stability without discouraging innovation or financial inclusion.
Adopt a “Twin Peaks” Regulatory Model
Looking further ahead, Dr. Atuahene proposes restructuring Ghana’s financial oversight using the internationally recognised Twin Peaks model.
Under the framework, the Bank of Ghana would focus on safeguarding the stability and financial health of banks, insurers and major mobile money operators, while a dedicated Financial Conduct Authority would oversee consumer protection, market conduct and fair competition.
Meanwhile, the Financial Stability Council would monitor risks across the entire financial system, identifying emerging threats before they escalate into broader crises.
Dr. Atuahene believes such a structure would provide clearer institutional responsibilities while strengthening oversight of Ghana’s increasingly interconnected financial sector.
The Bottomline
He maintains that the goal is not to restrain mobile money’s growth, but to ensure that regulation evolves alongside innovation.
As mobile money continues to underpin commerce, payments and financial inclusion across Ghana, he argues that a smarter, risk-based and activity-focused regulatory framework will be essential to protecting consumers, preserving competition and safeguarding the country’s long-term financial stability.
