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BUILDING RESILIENCE IN COMPLEX CRISIS FINANCIAL SERVICE ASSESSMENT REPORT
2019
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BRICC - Financial Service Providers Assessment Report
Table of Contents
GLOSSARY 2 EXECUTIVE SUMMARY 3 BACKGROUND: 4 PURPOSE: 4 METHODOLOGY 5 KEY FINDINGS: 10 ANALYSIS 12 REGULARITY REVIEW / RECOMMENDATIONS 18 CHALLENGES AND LIMITATIONS: 19 CONCLUSION AND RECOMMENDATIONS: 20
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BRICC - Financial Service Providers Assessment Report
GLOSSARY ACF Action Contre la Faim BOA Bank of Agriculture BRICC Building Resilience in Complex Crises CARM Community Accountability and Response Mechanism CBN Central Bank of Nigeria COOPI Cooperazione Internazionale CCT Conditional Cash Transfer CTP Cash Transfer Program DEC Development Exchange Centre DRC Danish Refugee Council EFCC Economic and Financial Crime Commission E-Platform Electronic Platform EU European Union FCMB First City Monument Bank FGD Focus Group Discussion FAO Food and Agricultural Organization of the United Nations FSP Financial Service Providers FSPA Financial Service Providers Assessment FGD Focus Group Discussion Globacom Global Communications Limited IBTC Investment Banking & Trust Company ICRC International Committee of the Red Cross ICT Information and Communications Technology INGO International Non-Governmental Organization KII Key Informant Interview LGA Local Government Area MEAL Monitoring Evaluation and Learning MC Mercy Corps MFI Microfinance Institutions MMO Mobile Money Operators MMT Mobile Money Transfer MNO Mobile Network Operators MTN Mobile Telephone Network NGO Non-Governmental Organization POC People of Concern POS Point of Sale PWDs People with Disabilities SCUML Special Control Unit on Money Laundering SIM Subscriber Identity Module SMS Short Message Service SCI Save The Children International TORs Terms of References UBA United Bank for Africa UCT Unconditional Cash Transfers
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BRICC - Financial Service Providers Assessment Report
UN United Nations UNOCHA United Nations Office for the Coordination of Humanitarian Affairs WFP World Food Program YESSO Youth Employment and Social Support Operation
EXECUTIVE SUMMARY: In December 2019, under the leadership of the Mercy Corps, an FSP assessment was conducted to identify a viable modality for delivering financial assistance to Programme Participants targeted under the Building Resilience in Complex Crises (BRICC) programme, A European Union (EU) funded Program in 6 Local Government Areas (LGAs) of Damaturu, Potiskum, Gujuba, Gulani, Geidam, and Yunusari. The assessment also seeks to identify potential service provider(s) for humanitarian assistance through Cash Transfer Programming. The consortium comprised of Mercy Corps, COOPI International and Danish Refugee Council as Consortium partners.
The assessment will also help in identifying the most efficient and effective cash transfer options available in these areas of operation and recommend the best mechanism for the delivery of cash transfers to vulnerable conflict-affected Households.
Some of the excerpts from the assessment: - Cash in envelope (cash on counter) has been the most preferred delivery mechanism by elderly women, men, and young girls due to access issues; - Six Mobile Money Operators in Damaturu with their agents are willing to work in the BRICC Local Government Areas of intervention, - Five commercial banks/MFI who have previous experience in Cash Transfer Programming, couple of them have potential to come into terms - there are four E-platform service providers operating within Yobe State. However, two of them are already having partnership with the BRICC consortium members (RedRose and Nagis) – and these are the most viable service providers observed as per their structure, operational and technical capacity and remote management skills - Commercial Bank has also expanded their network from main cities to small towns with increased dependency on Mobile Money Agents - The Commercial Banks mostly rely on agents for outreach; to whom they provide POS machines for the delivery of cash to remote locations, - The banks also have static and mobile agents who are local and with good financial capacity but with limited structure and formal business ethics. These cash out agents are mostly mobile and have the ability to move to areas where there are shortages of Mobile Money Agents. Considering the coverage of the Mobile Money Operators per location; Damaturu and Potiskum being largely urban areas, have Airtel, MTN and Globacom. Gujba, Geidam and Gulani have only Airtel mobile services with irregular occurrence while there is no network in Yunisari 1 There are around 5000 to 6,000 (formal and informal) Cash out/Mobile Money Agents in the state who are being directly and indirectly contracted by the Government, NGOs, MMT companies and
1 This calculation is based on the information provided by different actors; randomly calculated about the numbers of agents in different parts of Yobe 3
BRICC - Financial Service Providers Assessment Report
Banks for humanitarian response and government programs. Indirect engagement with these mobile Money Agents in program implementation will be helpful to expedite the cash out process; assuring that robust monitoring measures are in place during the implementation, vis-à-vis EFCC compliance and regulations are taken in to consideration The assessment also gathered information from three implementing partners that have previous experience of Implementing CTP (WFP, ACF and Save the Children) in Yobe State. Contracting with different service providers for one task remained a lesson learned. It has been encouraged to shoulder responsibility to one service provider, develop strong monitoring system and ensure the compliance and avoid the risk of delays and mismanagement, increased exploitation and fraudulent acts by Mobile Money agent
BACKGROUND: The BRICC consortium was launched in April 2019 with the aim of building the resilience of 26,875 households comprising 6,719 men, 6,719 women, 6,719 male youth, and 6,718 female youth in 6 Local Government Areas (LGAs) of Yobe state. BRICC is a three-year Programme funded by European Union (EU) and implemented by a consortium comprising the lead agency Mercy Corps (MC), Danish Refugee Council (DRC) and COOPI. The Programme will build the resilience capacity of households exposed to shocks and stresses induced by conflict, climate change and other adversities in Yobe state. The programme’s resilience strategy will lead to the implementation of diverse yet interrelated technical approaches that will restore and reinforce the absorptive, adaptive and transformative capacities of individuals, households, communities and governance structures in Yobe state. Some of the technical approaches to be implemented include the transfer of cash to households, promotion of savings groups, providing technical assistance to the state and local government structures on social protection, training of community structures on conflict management and mitigation, strengthening farmer groups and associations and facilitating their access to input and output markets and entrepreneurship development and start-up support for youth. In the transfer of cash to households and providing technical assistance on social protection the BRICC programme intends to establish linkages and collaborate with existing financial service and safety net providers in Yobe that have experience and capacity in cash transfer and safety net activities. This assessment generates awareness and evidence in the results of the analysis conducted against the primary and secondary sources related to the financial services and safety net providers and help the program to choose the most viable options of delivery mechanism and service providers This assessment also considers the most preferred transfer modality by program participants bearing in mind safety, efficiency, user friendliness and the modality that gives room for little or no extortion.
PURPOSE: The results of the assessment will be used to identify, prioritize and recommend options that are most effective, timely, efficient and safe to transfer un/conditional cash to programme participants. The specific objectives of the assessments are to:
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BRICC - Financial Service Providers Assessment Report
● Identify existing FSPs in Yobe state and determine the types and features of financial services and products that they offer including cash transfers, savings and loans products and the modalities through which these are provided ● Identify existing safety-net providers and determine the types, features and delivery channels they use in providing safety nets to communities in Yobe state ● Determination of the types, status and penetration of infrastructure used by FSPs in the delivery of cash transfers and financial services to communities in Yobe state ● Establish the end user level of awareness, knowledge, usage, satisfaction and preference of modalities used to deliver cash transfers and financial services by FSPs in Yobe state ● Analyze the identified existing FSPs delivering cash in Yobe state and recommend the most effectives options to be considered for use by the BRICC programme considering the number, value, frequency, efficiency and purpose of transfers, flexibility, risk and geographical coverage ● Analyze identified existing safety net programmes and recommend those that should be considered for referral and transitioning linkages of household caseloads by the BRICC programme considering alignment of target groups, purpose and location
METHODOLOGY In consultation with the BRICC consortium partners; Mercy Corps led the entire process for this assessment; from Scope of Work (SoW) development to report finalization. The Mercy Corps (MC) developed the Scope of Work (SoW) along with the assessment tools; reviewed by consortium partners and approved by the BRICCs director to have subjective technical insights; ensuring that these are contextualized and adhere to the policy and processes of operations with an insight view of security situation. Each consortium partner dedicated around 3 team members to participate in the assessment process and received a detailed orientation and contributed in the planning phase. Based on the secondary data, mapping of different service providers in the area was completed and finalized the data collection plan. Each agency covered the geographical location. This assessment used Focus Group Discussion (FGDs) and Key Informant Interviews, to cover the different types of services providers; including Mobile Money Agents, Regulators and Coordinators, Community leaders and market Union, Financial service Providers, Banks, INGOs and UN agencies, and Government Line departments (Social Safety Nets) The assessment was carried out across 30 communities in 6 Local Government areas. A total of 18 KIIs and 36 FGDs were conducted within the study area. Primary data collection took place between November, 2019 and January 2020 which was facilitated by 3 consortium partners.
Assessment team: The team members mentioned below participated in the assessment basically from Programs and M & E. The operations team was also available to provide the needed support in terms of staff movement.
S# Name Designation Organization 1 Irimiya Nuka Ghamba Livelihoods Team Leader DRC 2 Tahiru Ali Garba M&E Officer DRC
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BRICC - Financial Service Providers Assessment Report
3 Alhaji Umar Naatala M&E Assistant DRC 4 Abubakar Abdu Yahaya MIS Officer COOPI 5 Joseph Bolaji M&E Officer COOPI 6 James Kim Gyang Cash and Livelihoods Officer Mercy Corps 7 Ruth Abana Cash and Livelihoods Assistant Mercy Corps 8 Jacobs Tumba Platform and Vendor relation Officer Mercy Corps 9 Luke Bartimaeus Bityong Platform and Vendor relation Manager Mercy Corps
Research Scope The following research questions were addressed in this report: ● What are the existing FSPs in Yobe state, the type and features of financial services and products they offer including cash transfers, savings and loans products and the modalities through which these are provided? ● What is the capacity and experience of a financial Service Provider to facilitate cash-based interventions at the Local Government and Community Level and what delivery mechanisms are the most used? ● What are the existing safety-net providers, the type, features and delivery channels they use in providing safety nets to communities in Yobe state? ● What are the type, status and penetration of infrastructure used by FSPs in the delivery of cash transfers and financial services to communities in Yobe state? ● Are there any specific groups that are at risk of being excluded from accessing financial assistance due to the lack of identification papers, bank accounts, or electronic communication mechanisms? ● What is the speed and cost of delivering cash transfers? ● What are institutions’ resilience to change in context, what risks are likely to arise, and what mitigation and monitoring protocols are in place? ● What contextual factors will influence the feasibility of each cash delivery modality?
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BRICC - Financial Service Providers Assessment Report
Table of data collection: The total number of interviews conducted against the planned number of assessments are tabulated below:
S# Category on intervention Expected number of Interview Target
1 KII with Regulators/Coordinators YESSO/NASSCO, Budget and Planning, EFCC, State Cash 6 Transfer Office. 2 KII with Financial Service Providers Access bank, FCMB, Union Bank, UBA, First Bank, Yobe 9 MicroFinance Bank, Development Exchange Centre, Bank of Agriculture and Stanbic IBTC Bank. 3 KII with Mobile Money Operators Airtel, MTN, Cellulant, Visual ICT, Globacom, 5
4 Focus Group Discussion with community Elderly men, Elderly women, Youths men, Youths women (At 24 Least one Person with Disability is in each of the Groups) 5 INGOs/UN WFP, Save the Children, UNOCHA, Care International, CRS, 8 ACF, ICRC, FAO 6 Community Leaders/Local Government Damaturu, Geidam, Yunusari, Gujba, Gulani, Potiskum. 12 Information Officer. 7 Traders Union Damaturu, Geidam, Yunusari, Gujba, Gulani, Potiskum. 6
8 FGDs (Male Youths, PWD) Damaturu, Geidam, Yunusari, Gujba, Gulani, Potiskum. 6
9 FGDs (Female Youths, PWD) Damaturu, Geidam, Yunusari, Gujba, Gulani, Potiskum. 6 10 FGDs (Adult Male, PWD) Damaturu, Geidam, Yunusari, Gujba, Gulani, Potiskum. 6
12 FGDs (Adult Female, PWD) Damaturu, Geidam, Yunusari, Gujba, Gulani, Potiskum. 6
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Secondary data review For secondary data review, two sources of information have been used to extract the information which relates to the FSPA assessment, first one the internet (google), and second secondary source of data collection is available reports including on previous assessment conducted in the North-East of Nigeria
Following key factors have been reviewed considering the scope of assessment:
● Outreach ● Cash transfer Mechanism ● Acceptability of financial services by target population ● General requirements ● General credibility of institutions
2 Outreach and sectoral coverage Coverage Sectors and MPCG (CVA) No of N FSPs, o N No of PSPs, of Shel Pr o. Stat Delivery Platfor D FS Ed ter ot LGA of ERL MPC e mechanis m o S u & ect O ms provid n NFI ion rg ers o (M+N) rs DAMATUR 3 1 3 2 1 Yobe U Yobe GEIDAM 2 1 1 1 2 Yobe GUJBA 10 4 2 3 5 3 1 Yobe GULANI 6 3 2 3 3 4 Yobe POTISKUM 3 3 4 2 1 Yobe YUNUSARI 2 1 1 1 1
3 Delivery Mechanism and CVA Modality No of Service No of FSPs, provider Delivery Data from Delivery PSPs, LGA Modality reported Mechanisms FSPs mechanis Platform by CWG ms providers partners (M+N)
2 This data is referred from FSP Assessment conducted by Cash working group – BAY states in 2019 3 This data is referred from FSP Assessment conducted by Cash working group – BAY states in 2019 `8
BRICC - Financial Service Providers Assessment Report
Cellulant (1) DAMATUR DEC (1 Br, 2 Voucher Smart Card Vendors 1 3 U agents) Traders GEIDAM Voucher Smart Card Vendors 1 1 Cash in Envelope RedRose Cash Cash through United GUJBA 4 2 Vouchers agents Bank of Bank A/c Africa Smart Cards Redrose Smart Card Cash United GULANI Cash Through 3 2 Voucher Bank of Agent Africa Cellulant (1) DEC (1 Br, 3 Cash in agents) Cash Envelope POTISKUM Vendors Traders 3 4 Vouchers Smart Card Dzidiya Animal Bank A/c farm (3 Br, 10 Agents) YUNUSARI Voucher Smart Card Vendors 1 1
Design, Tools and Development and Planning This began with the development of the Terms of Reference (TOR) for the activity. The tools for the assessment were adopted from the Mercy Corps standardized FSP assessment tools. Each of the consortium partners nominated two staff who had 2 days of planning meetings where they contextualized the tools to best suit the objective of the assessment and the areas to be covered by each of the partners.
Data collection: The data collection process began after a team orientation. The composition of team took into account the representative of all consortium partners (MC, DRC and COOPI) In order to seek the appointments and have interviews as per given time schedule, the team approached the different stakeholders, the data collection process took longer than expected. The initial plan for data collection was developed up to 4 weeks, but it took around 4 months to complete the process of data collection due to several unavoidable reasons, including; a) Maiduguri-Damaturu road closure due to security caused limited the operational access, b) MC field operation suspension,
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BRICC - Financial Service Providers Assessment Report
c) numerous formalities posed by the institutions, d) delays in securing appointments from government authorities some government institution lingered the appointment process but it never confirmed. e) Lingered authentication of the service availability of mobile networks in the current geo zone, the field teams coordinated and physically confirmed the functionality of mobile services to avoid any barrier for decision making.
Ethical considerations Before meeting, conducting interviews for the collection of data, the assessment team coordinated with the target population/audience for the appointment seeking to have the data collection process pre-consented, pre-informed and un-interrupted
As the part of protocol in Yobe state; Field team also reached out to the Local Government Information Officers and got facilitated for the process of seeking appointments and conducting FGDs and KIIs with the community leaders at field level
KEY FINDINGS: Outreach LGA Network Services Damaturu Airtel, MTN, Globacom Calls and internet service Potiskum Airtel, MTN, Globacom Calls and internet service Gujba Airtel (weak and irregular signals) Calls only Geidam Airtel (weak and irregular signals) Calls only Yunisari No Mobile network ?????? Gulani Airtel (weak signals) Calls only
Service ● Mobile companies are providing the commission-based services of mobile money transfer, electronic voucher with a limited outreach and structure available at main and small towns and villages for services. ● Commercial banks, and Money Transfer companies (Cellulant and Airtel) are functional in the main cities like Damaturu and Potiskum and providing the services of cash transfer through cheque, including mobile money (by using the existing network of MMT companies), commercial banks, General requirements ● ID Card and Voter card are the requirement for the account opening at the Bank in case MCN approach and contract with them then bank can waive this prerequisite ● As per Fe/Male youth FGDs conducted in Geidam and Younisari; it is learned that most of them having government recognized ID cards (ID Card and Voter card), more than 60% have mobile phones and are able to read and write mobile phone messages. To transfer the money; they use Bank and POS for the subject.
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BRICC - Financial Service Providers Assessment Report
● About 75% of the Adults (females and males) either prefer direct cash payment or through banks while about 80% of the youths prefer payment through MMTs, direct Cash or Bank payment Acceptability and accessibility ● It has been observed that generally communities in Yobe are reluctant to allow their female households members (Young Girls/women) to the nearby markets ● 80% elderly women, men and young girls prefer cash in envelope over MMT due to long process and mobility issues ● There is a wider acceptance of electronic/digital Transfer among young male groups of the target geographical zone, considering the reduced travel, time and cost and helps to get the transfer withdrawal/redeemed within their area. ● UBA Bank agents are stationed in the target LGAs, and they have also been providing mobile financial services in remote locations when needed.
Commercial Banks ● Due to the insecurity in the North-east Nigeria, most of the Banks in Yobe State only have branches in Damaturu and Potiskum which are the two largest and safest towns in Yobe State. ● The banks mostly provide services through their designated cash out agents in remote communities of the state with POS machines. ● Most of the commercial banks interviewed at the course of the assessment indicated willingness to deliver cash directly to the agents in communities of intervention while few indicated the agents will need to come to the State capital to obtain cash. regulatory compliance to be consulted at the time of the expression and contracting
Beneficiary Preference LGAs Preferred Modality of CTP Knowledge of social safety net Adult( male Youth ( Adult( male Youth ( /Female) Male/female /Female) Male/female Damarturu Prefer Cash in Prefers cash in Keke Napep Benefited from envelope envelope (tricycle), sewing N-power machines, schools fees, (fertilizers subsidy at N3,000) Potiskum Based on the Familiar with No or limited Aware of responses of Mobile money knowledge on Government most Adult male transfer and prefer social safety net intervention like and female, they this methods but participated Trader money but preferred cash in in previous NGOs claimed only few envelopes intervention benefits Gujba Adult male Physical Cash or None None preferred Cash in bank envelope while the female preferred Voucher
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BRICC - Financial Service Providers Assessment Report
Gulani Prefer Cash in Bank and Vouchers None None envelope Yunusari Prefer Cash in Prefer Cash in None Yes, we benefited envelope envelope from N-Power Geidam Prefer Cash in Prefer Cash in None Yes, we benefited envelope envelope from N-Power
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BRICC - Financial Service Providers Assessment Report
ANALYSIS Following the completion of the data collection process, entry and cleaning, analysis were done by Mercy Corps Cash team and shared with consortium partners for final review to ensure qualitative information has been correctly incorporated.
Banks (Commercial, MFIs and Agriculture)
UBA Access Bank Union Bank DEC (MFI)
B ● Issues debit card to beneficiaries ● Has a special account ● Products designed to ● Due to limited e that can be used at any POS (TEER ONE) for low target low income or scale of work n Machine. income customers poor customers (Microfinance), e DEC has limited ● Work both on and offline. ● Can reach out to ● They have Union Korrect options for fi beneficiaries in remote Dai-Dai accounts for ● Emphasize the use of Biometrics beneficiaries’ c areas savings (Low income and appropriateness i poor customers) ● Can create an account for ● This account is a Participants at no cost for the considered as private r purpose of Cash Transfer and the account and can be used y account can be used after the for personal purpose A activity. p p r o p r i a t e n e s s
● Agents structure available in BRICC ● Have agents in all areas ● Branches in Damaturu, DEC has only one C targeted communities / of implementation. Potiskum and Gashua, office in intervention areas and well tested Damaturu. They o by other humanitarian actors ● Preferred working with ● agents in the 30 deploy their staff v Airtel due to wider communities of instead the agents e ● Willingness to deploy need based coverage in remote areas intervention and are in the entire state r agents for effective service (MMT) willing to send more a delivery. agents where payments ● Have at least 4 agents in are going to be made g every LGA e
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BRICC - Financial Service Providers Assessment Report
C ● Charges 3.8% of total transfer ● Will confirm the price to ● Commission charges to MC acquire services o value and it is negotiable based on be charged at the stage be communicated the from DEC at the s caseload. of procurement after time of quotation by the rate of 2.7%, while t with headquarters. zonal offices currently DEC is ● No additional logistic cost for reviewing the e sending agents on follow-up on ● No additional logistic rates; so no such f absentees cost for sending agents information f to communities of provided e intervention c ● Have discount for large t volume of payments i v e n e s s
A ● Ready to work with E-platform ● Have partnered with ● Have a strong IT Good knowledge b Service Providers. Airtel (MMO) supporting management, security working in remote il cash disbursement and Fraud control. and insecure ● Have a sufficient number of cash through Money wallet. locations i out agents and flexible to move ● Have Capacity to enroll a t agents to any location of cash ● Frequently train staff on large number of y Transfer fraud control. beneficiaries within 24 t hours. ● Have a strong IT management, ● Needs a minimum of 24 o security and Fraud control. hours notification to S commence disbursement c ● Ready to work in areas they do not a currently have an agent structure l e - U p a n d I n t e r n 14
BRICC - Financial Service Providers Assessment Report a l c o n t r o l s
P ● 5 years’ experience working with ● Knowledge implementing ● In partnership with Bank ● Working with MC r ICRC and IFRC/NRCS on CTP in cash transfers in areas of of Agriculture since 2015 i Damaturu, Potiskum, Buni Yaddi, intervention. Fika, Geidam and Yunusari. ● Working with o ● Uses POS and Partners Government’s program r with mobile Money on MDGs E Service Providers. ● Have experience in CTP x in Adamawa and Zamfara p e r i e n c e w i t h H u m a n i t a r i a n S e c t 15
BRICC - Financial Service Providers Assessment Report o r
● Can provide either POS or use the ● In partnership with Airtel ● Licensed to provide ● organizations E-platform. and can provide SIM financial services cards to beneficiaries at ● Able to provide Cash based on no cost. ● Have a digital requirement Technology that supports B ● Wide agent network CTP e ● Dedicated staff for timely addressing of complaints during ● TEER 1 account for low n Cash out. income customers e fi ● Needs 2 days notification t ● Archive Transactions for 10 years. s ● Willing to return for follow-up.
● Can create account for beneficiaries at no cost, with no identification document
L ● Crowd Management during Cash ● Only partners with Airtel ● System works only online ● Poor IT system Disbursement. i ● ● Limited staff m i ● Does not have t delivery digital platform a t ● Lacks internal i controls o ● Rely on client n Cash Transfer s strategy/system
B Although banks are not having wider structure in the rural settings; but their agents provide financial service in the remo e where beneficiaries get verified and assisted in one go and this reduce their transportation time and expense and avoid r n e fi c i a r y P r e f e
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BRICC - Financial Service Providers Assessment Report
r e n c e
Mobile Money Operators Description Airtel MTN Globacom Cellulant ● Mobile network is available ● Regular training of ● Limited outreach ● Use POS terminals i in most of the area (refer agents via different and network in beneficiaries have Beneficiary the table mentioned above channels the prepaid cards. for outreach) ● Render Financial geo-intervention ● Do not have Appropriate ness ● Have partnership with Access literacy training to area presence in the are Bank program ● No partnership but willing to participants via SMS with any agent or increase their bank outreach Beneficiary ● Most Preferred mobile ● Not experienced ● Not well known in ● Not known in the Preference network by community with MTN services the area area members ● Wider MMT mobile network ● Strong platform ● Limited coverage ● Licensed by CBN to coverage in all locations of that aligns with CTP in areas of deliver digital Yobe state strategies intervention. Financial Services ● Have agents and are willing ● Partnered with ● System works off an to send agents to areas of Access Bank for CTP online. intervention and have 1392 ● Have cash out agent Coverage ● Licensed by CBN to provide agents in Yobe state who offer financial and CTP ● Licensed by CBN to services, loans, Structure/ provide CTP saving to clients system ● Agents offer a ● Have dedicated variety of services program officers wh including deposit, are presently in withdrawals, Cash North-east Nigeria transfer, and bank transfer and bill payments. ● Customizes reports. Cost ● To confirm price at the stage ● To confirm price at ● To confirm price ● Charges/fee based effectivene of procurement the stage of at the stage of on Percentage of ss procurement procurement disbursement
Ability to ● Have toll free line for CARM ● Have specialized ● Willing to deploy Scale-Up ● Staff experienced in CTP staff that deals on agents to areas of and Internal ● Have worked with local CTP intervention controls agents
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BRICC - Financial Service Providers Assessment Report
● Have ability to ● Uses digital wallet scale up due to for CTP activities their contract with ● Partner with banks Access Bank and where agents have 1392 local agents in accounts the Yobe ● Need only a day notification ● Client will have a dash board for viewing transaction globally ● Have toll free line for CARM
● Experience working in Hard ● No previous ● Have previous Not reported to reach/insecure, remote experience on CTP experience in CTP Prior locations in Yobe having partnered Experience ● Vast experience in mobile with Eco bank in with Money transfer(CTP) delivering cash in Humanitari ● In Partnership with Access Yola, Adamawa an Sector Bank for WFP Cash Assistance State. in Yobe state using Mobile Money
● Has the largest coverage in ● Unredeemed ● They are Willing ● Multiple levels of the intervention area transfers are to train authorization on ● Will provide training to their reversed to the beneficiaries on E-platform for agents about the cash out or funder agency financial internal control proposed by the agency within 30 days. education system ● Have digital Benefits statement of account to show transactional activities ● Sends notifications to beneficiaries via SMS where there is network ● One of the humanitarian ● Have limited ● Globacom is only ● Cellulant require partner indicated fraud network coverage in involved in the advance amount to related issues by agents areas of operational be deposited in the Limitations ● Agents created artificial intervention. service delivery account that BNF to liquidity issues in the area to ● Storage of eg text messages, redeem extort from beneficiaries. reports/data alert etc ● Follow up depends on distribution attracts contract agreement extra cost 18
BRICC - Financial Service Providers Assessment Report
● Concerned about ● Does not allow security challenges multiple levels of in Geidam, Gujba, authorization Gulani and ● Not flexible to Yunusari. partner with other Digital platforms ● System does not work offline
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BRICC - Financial Service Providers Assessment Report
Mobile Money Agents 4 There are around 5,000 to 6,000 local Cash out agents in the Yobe state, mainly stationed in the Damaturu and other small and large towns, due to humanitarian response; the local traders and investors have jumped into this business and grabbed the business opportunity and learned the skills and earned the experience. Most of them have worked with INGOs, banks and Mobile Money Operators for assistance provided by Public institutions and Humanitarian Agencies it is advised not to have contract with these individual outlets but with a company; who is directly responsible for the overall business, monitoring and reporting
Additionally, there are certain limitations of working with Local Cash out agents (formal/informal) in relation to their fraudulent acts and exploitation behavior robust sensitization, orientation on Good Business practices and Ethics, strict contractual compliance, field team monitoring and facilitation process and regular PDM will help to mitigate the said risk
REGULARITY REVIEW / RECOMMENDATIONS EFCC is the regulatory body actively operational in the country and have been closing working with and monitoring the humanitarian agencies. Following key points are prescribed by the regulatory body for reporting of currency and cash-based transactions required under Nigerian laws.
1. The Special Control Unit Against Money Laundering (SCUML) as well as Federal Ministry of Industry, trade and investment, in line with the provision of the “Money Laundering (Prohibition) Act (TPA)” 2011 (as amended) and Federal Ministry of Industry, Trade and Investment (designation of Non-Financial institutions) 2013 and 2016 respectively, requires designated non-financial institutions to report all currency transactions of N5,000,000 and above, in case of an individual or N10,000,000 and above, in the case of a body corporate within seven (7) days from the date of transaction. 2. The laws also require designated non-financial institutions to report all cash-based transactions in excess of $1,000 or its equivalent within seven (7) days to SCUML through its online platform. 3. Accordingly, Mercy Corps, being a registered and designated non-financial institution, in compliance with above requirements in clause A and B of this document is obliged to report all transactions to SCUML. 4. By signing this document, the vendor/contractor/service provider unconditionally allows Mercy Corps to share necessary data and documents with SCUML and the “Economic and Financial Crimes Commission (EFCC). 5. Vendor/contractor/service provider also agrees to allow SCUML and EFCC the unconditional access to his bank account(s), account books and daily ledger with regard to the amount paid against this contract.
Some of the key documents related to donors, Nigerian Government, humanitarian principles/standards and donors’ regulations
4 This calculation is based on the information provided by different actors; randomly calculated about the numbers of agents in different parts of Yo be
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Protection and Privacy Policies: Government Agencies: - National Drug Law Enforcement Agency (NDLEA) - Economic and Financial Crimes Commission (EFCC) - The Central Bank of Nigeria (CBN) - The Nigeria Police Force (NPF). - Nigerian Customs Service (NCS). - Federal Ministry of Communications and Digital Economy - Nigerian Data Protection Regulation - REGULATORS PERSPECTIVE ON PERSONAL DATA AND PRIVACY OF USERS – Nigerian Communication Commission - National Information Technology Development Agency (NITDA) - Federal Ministry of Communications and Digital Economy
Donor - Humanitarian Principles - SPHERE standards - Know your Customer – Tip Sheet
CHALLENGES AND LIMITATIONS: ● Given the sensitivity of certain information in the assessment tools, some of the respondents were not comfortable discussing some key issues, related to cultural impediment, mobility issues, access and control over resources ● Securing appointments with most of the regulatory agencies was difficult due to the bureaucratic processes in operation in such organizations. The team had to visit several times for an interview to be conducted, this has contributed in extending the period of the assessment beyond the initial planned period. ● Due to the above-mentioned challenges, data collection was extended by one and a half months compared to what was initially planned. ● The data related to Mobile companies and Banks has been collected from the state level offices, which either have limited information to provide or were not authorized to share due to hierarchical issues, they pledged to provide the remaining information after having consent and approval from their main offices, but that remained un-provided This prolonged the process caused delays ● During the interviews; it has also been observed that some of the information was also not shared due to their competitive advantage / confidentiality e.g. service charges, commission fees to local vendors etc... and team was suggested that this information will be provided at the time of bidding ● Data related to Social Safety Nets remain a key challenge and no significant information was gathered by the team
CONCLUSION AND RECOMMENDATIONS: The Delivery Mechanism of Cash Transfers through mobile money and E-vouchers using E-platform service providers and Banks have been established as the most appropriate option in
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BRICC - Financial Service Providers Assessment Report
the light of the results of the findings of this assessment. These modalities seemed to be viable and adapted to the context of a volatile security situation limiting large gatherings
Recommendation for banking services ● UBA is flexible to work with any Platform recommended/provided by a client and can be linked to NAGIS platform – earlier some partners in the country were able to connect it with other platforms as well. Additionally; UBA Bank has a network of local cash out agents (the business model) and working relationship with Cash out Agents need clarification at the time of contracting interest
● Access Bank has experience in this Mobile Money Transfers and E-Voucher Program, they have also partnership with MTN and Airtel Mobile Co. as well
● UBA bank has customized pro-poor products and have tech-sensitive systems and internal controls, some information is yet to be provided by them to better understand their competitiveness and added advantages
Recommendations for Mobile Money Operators ● MTN - Have agents in Damaturu, Geidam, Gujba, Gulani, Potiskum and Yusufari, in total have 898 agents in Yobe State.
● MTN and Airtel can be the preferred networks for MMT partnership. They must be invited at the time of procurement so that organization will be able to get the quality and concrete information
● Social Safety Net program related information has remained limited, it is learned that private sector is yet to be engaged in the service delivery
● Visul ICT has a great potential to physically verify the systems which are reported, they have the largest number of agents (5644) available in the Yobe state with strong systems and structure
Recommendations for Mobile Money agents These Cash out agents can play a pivotal role in the delivery mechanism for humanitarian response and government Social Safety net program; in order to have direct/indirect partnership, following key areas are recommended
- Clarification of role and responsibilities (even in case there is not direct contractual agreement) and read out the legal clauses related to fraud, corruption and kickbacks - Clear guidance and training on the operationalization and processes follow-up and highlighting the consequences in case of any mis-leading actions - Well sensitized about the good business ethics, - Encouraged to be registered mobile money outlets and work in proper fashion for future perspectives
Recommendations for regulatory adherence ● Host government (Government of Nigeria) strictly suggests all the humanitarian organizations to adhere to the prevailing regulations under the EFFC and relevant
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BRICC - Financial Service Providers Assessment Report
ministries – certain links and guidelines provided above should be followed religiously to maintain mutual respect.
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BRICC - Financial Service Providers Assessment Report
Contact details of interviewees Name of Contact Person Designation Contact details Organization / Institution Airtel Mohammed Khalid Idris Area Sales Manager Mobile: +234 8037474368 Potiskum, Yobe Email: mohammed.khalid@ MTN Mustapha Otaru Manager Channel Mobile: +234 8032004076 Development - North Email: Mustapha.otaru@mt Globacom John Uwem Area Sales Manager Mobile: +234 8055572373 Email: uwem.john@glowor
Cellulant Olalekan Oladele Manager - Business Mobile: +234 8092900881 Engagement Social Email: [email protected] Development Sector
Visual ICT Ejike Mojekwu CEO Mobile: +234 8034038700 Email:Ejike-mojekwu@virt UBA Bank Mohammed Buhari Abukur Branch Manager Mobile: +234 8039491664 Email: Mohammed.Abukur Union Bank Ibrahim Bukar Gasma Group Head North East Mobile: +234 8033489070 Email: igbukar@unionbank Access Bank Abdullahi Lawan Shettima Assistant Branch Mobile: +234 7068844837 Service Manager Email: [email protected] FCMB Idriss Adamu Arzika Relationship Manager Mobile: +234 8069521946 Email: idriss.arzika@fcmb. DEC Helen Abah Manager Micro Credit Mobile: +234 9032265814 Unit Email: abahhelen1982@gm
Bank of Agriculture Mr Buba Adamu Anishi Assistant Manager Mobile: +234 8081089385 Email: adamububaanishi@y Yobe Microfinance Umar Buba Zarma Acting M.D Mobile: +234 8036303598 Bank Email: yobemicrofinance.bank@ya Ministry of Budget Alhaji Babaji D. Galadima Permanent Secretary Mobile: +234 8024381299 and Planning Yobe State Ministry of Email:bgaladima79@gmail. Budget and Planning YESSO Alhaji Baba Bukar Project Accountant Mobile: +234 8036197751 Email: bgabubakar@gmail. UNOCHA Humanitarian Affairs Mobile: +234 9033870108 Daniel Soro Officer Email: [email protected] WFP Raymond Panum Program Assistant CBT Mobile:07038068450 Email:Raymond.panum@w
ACF Abdul Shakoor Khushk Sen. Project Manager Mobile: +234 07011032365 Email: Babajide John Abubakar snrpmffp@ng-actionagains
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BRICC - Financial Service Providers Assessment Report
Area Project Manager Mobile: +234 7015914264 Email: areamgr-da@ng-actionagai FAO Musatapha Goggobe Field Officer Mobile: +234 8034824464 Email: mustapha.goggobe@ Mobile: +234 9086400300 Save the Children Wangari Wanjau Field Manager – Yobe Email: Wangari.Wanjau@savethec FCMB Agent Usman Mohammed Director F&U Mobile: +234 8038745074 (F&U communication communication Email: mamman19375@gm Solution ) Solution
FSP Agent Abdulllahi A. Mohammed Secretary Khabnur Fish Mobile: +234 7032151136 KHABNUR FISH FARM Farm Email: maikano010@gmail. FSP Agent - Suleiman Umar Bubaram CEO Mobile: +234 9069189012 GABAAWU Associates Email:[email protected] LTD FSP Agent - Ahmed Bukar Sheriff Managing Director Mobile: +234 8063426780 Bushaha NIG LTD Email:busahaseasonthree@ Damaturu
FSP Agent - Nuhu Mohammed Tikau M.D/CEO Mobile: +234 8032038668 JAIZ Communication Email: jaizcommnigltd@gm NIG LTD Damaturu FSP Agents - Mai Mobile: +234 8022368836 Limanti Global Bukar Liman Gujba Email: Resources Gujba CEO limantiglobalresources@gm FSP Agent – Mobile: +234 8068186100 AR-Raudah Geidam AR-Raudah CEO Email: Damaturu LGA Grema Dauda Baba Zau LGA Information Mobile: +234 8024908228 Information officer Officer Email: gremababazau@gma Potiskum LGA Hussaini Audu LGA Information Mobile: +234 8031831857 Information officer Officer Email: hussainiaudu@gmai Gulani LGA Musa Bamai CDO/ Acting LGA Mobile: +234 8022817151 Information officer Information Officer Email: Gujba LGA Ibrahim Babagana Umar LGA PPA. Acting LGA Mobile: +234 8025574919 Information officer Information Officer Email: Geidam LGA Mobile: +234 8029541798 Information officer Kaumi Mohammed Goggbe CDO Geidam Email: Yunusari LGA Mohammed Wakil LGA Information Mobile: +234 9079987828 Information officer Officer Email: Damaturu - Nayinawa Ajiya Kalli District Head Nayinawa Mobile: +234 8034162570 Community Leader Email: Potiskum – Yerimaram Gambo Yerimaram Wakilin Hakimi - Mobile: +234 9030405629 Community Leader Yerimaram Email:
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BRICC - Financial Service Providers Assessment Report
Gulani - Bara Lawan Husseini A Bara Community Leader Mobile: +234 7011561152 Community Leader Bara +234 7010716110 Email: Gujba – Buni Yadi Mohammed Lawan Goma Ngomari Buni Yadi Mobile: +234 7082666011 Community Leader Email: Geidam – Ashekeri Lawan Bako Kachalla Community Leader Mobile: +234 8085194260 Community Leader Ashekeri Email:
Yunusari – Mozogum Lawan Jalo Community Leader Mobile: +234 9033927819 Community Leader Mozogum Email: Traders’ Alhaji Usman Muazu Traders’ Union Mobile: +234 8062254948 Union/Market Chairman Damaturu Email: alhajiusmanmuazu@ Chairman – Damaturu LGA Traders’ Alhaji Nasiru Mato Traders’ Union Mobile: +234 8088844636 Union/Market Chairman Potiskum Email: Chairman - Potiskum LGA
Traders’ Mallam Saleh Trader Traders’ Union Mobile: +234 9070810819 Union/Market Chairman Gulani Email: Chairman - Gulani Traders’ Alhaji Bakale Gonimi Traders’ Union Mobile: +234 8020863635 Union/Market Chairman Buni Yadi Email: Chairman - Gujba Gujba Traders’ Alhaji Bakale Gonimi Traders’ Union Mobile: +234 8029541798 Union/Market Chairman Geidam Email: Chairman - Geidam Traders’ Muda Hamza Traders’ Union Mobile: +234 8066047955 Union/Market Chairman Yunusari Email: Chairman - Yunusari
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