HOW TO BECOME A SUPER AGENT
Emmanuel Ohiri
Underwriter || Risk Management || Corporate & Commercial Lawyer || Contracts || Compliance
Super Agents are responsible for monitoring and supervising the activities of Mobile Money Operators (Agents) in Nigeria. They essentially monitor the effective compliance with set limits, and establish prudential measures including on-site visits, to ensure Agents operate strictly within the requirements of the law, guidelines and the contract. Super Agents are required to set up a platform to enable them communicate with and have visibility of their Agents' transactions through integration with Nigeria Inter-Bank Settlement System.
According to the CBN's Regulatory Framework For Licencing of Super-Agents in Nigeria, any institution that wishes to be licensed as a Super Agent must submit an application for approval to the CBN. The application shall be submitted to the Director, Banking & Payments System Department, Central Bank of Nigeria, Abuja. All applicants are required to supply information to the CBN as may be required from time to time.
To obtain a Super Agent licence from the CBN, an applicant must satisfy the following requirements:
- Must be a company with an existing business, operational for at least 12 months;
- Must be registered with the Corporate Affairs Commission (CAC);
- Must have a minimum Shareholders’ Fund of N50 million;
- Must obtain a reference letter from a Financial Institution (FI) as part of its documentation for licence;
- Must have a minimum of 50 Agents.
Also, all applications for Super Agent licence must have the following information enclosed:
- Board Approval;
- Certificate of Incorporation;
- The company’s profile and functional contact e-mails, telephone numbers, office and postal addresses;
- Memorandum & Articles of Association;
- Shareholding structure of the Company;
- Return on Allotment of shares and Particulars of Directors;
- CVs of Board and Management of the Company;
- Organogram of the Company;
- Feasibility Report;
- Information Technology Policy of the Company;
- Enterprise Risk Management Framework;
- Contingency and Disaster Recovery Plan (Business Continuity Programme);
- A document outlining the strategy of the shared agent network including current and potential engagements, geographical spread and benefits to be derived;
- Qualifying criteria for engaging agents e.g. outreach, competence, integrity and other related qualities;
- Draft Service Level Agreements (SLAs) with sub-agents and FI Agent Banking Contract;
- Risk management, internal control, operational procedures and any other policy and procedures relevant to the management of an agent banking arrangement.
- Procedures for KYC and AML/CFT compliance;
- Fraud detection plan and standard of care;
- Consumer protection policy and procedure.
For more information, please visit: https://www.cbn.gov.ng/out/2015/bpsd/regulatory%20framework%20for%20licensing%20super-agents%20in%20nigeria.pdf