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3�2 MNO led business model
In an MNO led model, in parallel with the traditional role of providing the communications network, the MNO
also undertakes the bulk of the financial roles and thus will issue the e-money, manage the agent network and
the customer relationship and is the payment service provider. The MNO manages a wide DFS agent network
that registers DFS users and receives physical cash from them in exchange for e-money on behalf of the MNO.
Depending on financial regime, the MNO may be required to collaborate with a partner bank in which the DFS
agents will deposit the physical funds collected from the customers on behalf of the MNO. The e-money issued
by the MNO is backed by the funds in the trust or escrow account in the partner bank, examples are, M-PESA
by Safaricom, Airtel Money, and MTN Mobile Money.

Figure 3 - MNO led business model

Mobile Network Operator
User Partner Bank
DFS Customer, Communications network &
merchant, services provider, Escrow/Custody account
business, NGO Payment Service Provider,
DFS agent manager &
e-money Issuer

3�3 Model with Mobile Virtual Network Operator
In some implementations, there is Mobile Virtual Network Operator (MVNO) that provides the telecommunica-
tions services required for DFS. The MVNO may be either independent or owned by a bank. An example is Equi-
ty Bank in Kenya, which owns Equitel, an MVNO that extends the bank’s financial services to its mobile network
customers in the form of mobile money. MVNOs make use of the infrastructure provided by an MNO, but will
offer their customers a different range of telecom services including digital financial services. Airtel, which is an
MNO, provides the wireless network infrastructure for Equitel.

Figure 4 - MVNO Model

User Mobile Network Mobile Virtual Network Bank
Operator Operator
DFS Customer, Communications E-money Issuer
merchant, Communications Services Deposit Holder
business, NGO Infrastructure Provider Provider

3�4 Hybrid Model
In a hybrid model, the critical roles are shared between the bank and MNO. They may involve a third party in
the ecosystem who provides services that are not provided by either the MNO or the bank. For example, a third
party could own the agent network and also plays the role of the payment service provider. Example is the Visa
Qiwi wallet

12 Digital Financial Services Security Assurance Framework