Mobile money operators have to hold, in an escrow account in their partner financial institution, the equivalent in value of all the mobile money that they have sold to their customers. This means that the mobile phone operators, which are not licensed financial institutions, cannot themselves intermediate the funds that they have mobilised through the sale of mobile money.
The parties must be able to reconcile the balances of the escrow account and the mobile money accounts. –  Once approval is obtained, mobile money is treated as a financial institutions business regulated under the FIA.