3. The stock of mobile money deposits and the value of mobile money transactions remain a small percentage of total deposits and transactions respectively, and as such they do not pose any systemic risk to the financial system. There is therefore no basis, at this time for the introduction of special regulations for mobile money transfer and banking services to mitigate systemic risks. 4.
On the other hand, consumer protection concerns are valid, and motivated the Bank of Uganda to adopt the regulatory model in which mobile money operators are required to collaborate with supervised financial institutions and maintain an escrow account with sufficient deposits to cover the mobile money that has been sold to their customers. These conclusions remain relevant today.