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A survey conducted by the Bank of Ghana (BoG) on 26 Payment Service Providers (PSPs) that have applied for provisional license has revealed that most of them had no Board Charter in place to guide their activities and the functions of the directors.
Also, there was no evidence of board meetings and oversight on some of these entities.
In some instances, the board as constituted and shared with the Central Bank had not been functional to undertake their fiduciary duties on the institutions at the time of the visit.
Some inconsistences were also noted in key management personnel at post, and the names actually submitted to the Central Bank as part of the licensing application.
Again, some institutions shared critical roles with their group companies. Most of these roles were held by employees who lived in other countries other than Ghana.
The regulator of the banking industry pointed out that staff of the entities had little or no training pertaining to areas such as AML/CFT, provisions of the Payment Systems and Services Act 987, the Bank’s Consumer Recourse Mechanism Guidelines 2017, and cyber security and information security management. Internal control structures of some companies were also inadequate.
The Central Bank undertook the readiness assessment examination on a number of institutions as part of the licensing application review process.
Also, licensing examinations were conducted on PSPs that had been granted provisional licences. The main objective of these examinations was to assess the adequacy of the physical location, security, controls, information technology systems, operational set-up, staffing assessment and corporate governance of these entities.
Readiness Assessment was conducted on two entities, Paystack Ghana Limited and Critical Ideas Limited.
BoG developed supervisory roadmap in 2021 for payment service providers
The Central Bank in 2021 developed a Supervisory Roadmap as part of its effort to operationalise the Supervisory Framework for Payment Service Providers.
The roadmap took account of the reliance on FinTechs in the use of digital technology within the payment ecosystem and the need to use similar tools, such as Supervisory Technology (SupTech), for effective supervision.
It identified the risks within the digital financial ecosystem, and ranked their impact on the entire ecosystem in a Risk Matrix.