FinTech Company License And Registration Applications in Ghana

Financial technology, also known as fintech, is an economic industry composed of companies that use technology to make financial services more efficient.

Licensing Requirements

1. Company profile

Before applying for a licence, the FinTech company must be a company incorporated under the laws of Ghana and must provide an overview of the company and attach the registration documents from the Registrar General’s Department.

2Governance

The company registration documents should include the profile of shareholders indicating their respective percentage shareholding, nationality, copies of share certificate of the company attestation from a notary public confirming ultimate beneficial owner(s) with 10% or more of total share ownership and voting rights, profile of the Board of Directors and key management personnel required by Act 987, the organisational structure and profile of promoters where applicable.

  1. Business Plan

In addition to the company registration documents, the following information is required; business overview, market analysis, products and services to be offered with transactional limits, on-boarding process and fees or charges where applicable as well as five years financial projections for the proposed business.

  1. Systems and Technology

The following Information, Communication and Technology (ICT) Systems are to be employed:
• ICT Architecture diagram highlighting Security and Control
• ICT Policy Framework
• ICT Security and Control (including Transaction Monitoring Tool, Fraud Monitoring and Detection Tool and at least two-factor Authentication
• Business Continuity Programme (including Disaster Recovery Plan)
• Data Protection Certificate
• ISO 27001-2013 and PCI DSS certification and Certificate of Compliant where applicable
• EV-SSL Tool where applicable

  1. Enterprise Risk Management

There should be risk and mitigation measures covering operational, market, liquidity, money laundering, fraud, credit and funding risks where applicable, business impact assessment and an anti-money laundering / combating financing of the Terrorism (AML/CFT) policy.

  1. Consumer Protection Policy

The Consumer Protection Policy should be guided by the Consumer Recourse Mechanism Guidelines for Financial Service Providers (2017) and Act 987.

Licence Categories and Permissible Activities

Dedicated Electronic Money Issuer

The permissible activities under this category include recruitment and management of agents, creation and management of wallet, P2P On Net/Off Net, cash-in and cash-out, wallet based domestic money transfers (including transfers from bank accounts), investment, savings, credit, insurance and pension products (partnership with banks and duly regulated institutions), mobile money merchant acquiring and termination of inbound International Money Transfer.

Payment Service Provider Scheme

Permissible activities for this category are domestic card brand associations (e.g. Gh-Link) and switching and routing of payment transactions and instructions.

Payment Service Provider – Enhanced

The permissible activities include all permissible activities for PSP – medium licence and in addition, marketplace for financial services offered by duly regulated financial service providers, merchant acquiring and merchant aggregation, payment processing, printing and personalisation of EMV cards, inwards international remittances services, provision of 3rd party payment gateway services and limited use closed loop virtual cards (funded via refunds, rewards and user’s other accounts).

Payment Service Provider – Medium

The permissible activities include connecting to an Enhanced PSP to offer, all permissible activities for PSP – standard licence, payment aggregation (connected to Enhanced PSP), biller or merchant aggregation, POS deployment, printing of non-cash payment instruments, mobile payment apps (with liability shift).

  1. Payment Service Provider – Standard

Permissible activities include connecting to an Enhanced PSP to offer mobile payment applications (liability shift on PSP enhance).