The industry's considered view on the principles that should guide the development of digital payments in The Gambia, covering interoperability, common standards, fraud controls, consumer protection and inclusion, with recommendations for policymakers.
Purpose
This paper sets out the considered view of the member banks of The Gambia Bankers' Association on the conditions needed for digital payments to grow safely, efficiently and inclusively. It is intended to inform dialogue with the Central Bank of The Gambia, government and other stakeholders, and to explain the principles that guide the industry's own investment and cooperation in this area.
The Association is not a regulator. The Central Bank licenses, regulates and supervises banks and oversees the payment system. Nothing in this paper is intended to anticipate or substitute for its decisions. Rather, it offers the perspective of the institutions that operate many of the accounts, channels and settlement arrangements through which payments flow.
Background
Customers increasingly expect to pay and be paid instantly, at low cost and through the channel of their choice, whether a mobile application, internet banking, a card, an agent or a branch. Businesses expect to receive payments reliably and to reconcile them easily. Government expects to collect revenue and make transfers efficiently.
Meeting these expectations depends on more than the capabilities of any single institution. A payment usually passes between at least two providers, and its speed, cost and safety depend on the shared rules, infrastructure and standards that connect them. Where those connections are weak, customers face fragmented services, higher costs and greater exposure to fraud.
Key principles
Interoperability
Payments should reach any account. A customer of one provider should be able to pay a customer of another as easily as a customer of the same provider. The industry supports interoperability across banks and, under appropriate rules, between banks and other licensed payment service providers, using shared infrastructure where it reduces duplication and cost.
Common standards
Shared standards lower cost and risk. Common messaging formats, account and proxy identifiers, technical interfaces and operating rules allow providers to connect once and serve many counterparties. Standards should be aligned with international practice where practicable, so that systems can evolve and, over time, connect across borders.
Fraud controls
Security must keep pace with speed. Faster payments are also faster for fraudsters. Strong customer authentication, transaction monitoring, the sharing of information on fraud typologies and clear procedures for freezing and recovering funds should be built into the system from the outset, not added after losses occur.
Consumer protection
Customers need clarity and redress. Customers should be told clearly what a payment will cost, when it will arrive and what to do if something goes wrong. Responsibilities between providers for errors, disputes and unauthorised transactions should be defined in advance, so that customers are not passed from one institution to another.
Inclusion
Digital should widen access, not narrow it. Services should work on basic devices and in areas with limited connectivity, be usable by customers with limited literacy, and be supported by agent and branch networks for those who need assistance. Pricing should not exclude low-value users.
A level playing field
Similar activities, similar rules. Where banks and non-bank providers offer comparable payment services, they should be subject to comparable requirements on safety, consumer protection, anti-money laundering and data protection, proportionate to the risks involved.
Recommendations
In the industry's view, the following measures would support a secure and interoperable payments environment. They are offered as a basis for dialogue rather than as a fixed agenda.
- Develop and publish a shared roadmap for payment system interoperability, prepared in consultation with banks and other licensed providers, setting out priorities and sequencing.
- Adopt common technical and messaging standards for interbank and provider-to-provider payments, with a transparent process for maintaining and updating them.
- Establish industry-wide operating rules that allocate responsibilities for settlement, errors, disputes and fraud recovery between participating providers.
- Support a structured mechanism for sharing fraud intelligence among providers, subject to appropriate data-protection safeguards.
- Apply proportionate, risk-based customer due diligence to low-value accounts and wallets, so that onboarding remains accessible while higher-risk activity receives closer scrutiny.
- Ensure that requirements on safety, consumer protection and AML/CFT apply consistently to all providers offering comparable services.
- Invest jointly in public awareness of payment safety, so that customers recognise and report scams.
- Review fee and pricing structures across the payment chain periodically, so that they remain sustainable for providers and affordable for users.
The industry's commitments
Member banks recognise that these outcomes depend on their own conduct as much as on public policy. Through the Association, they intend to:
- participate constructively in the design and testing of shared payment infrastructure;
- apply agreed standards consistently and on agreed timetables;
- share information on emerging fraud patterns through appropriate industry channels;
- maintain clear complaint and dispute procedures for payment customers; and
- support financial-literacy work on the safe use of digital payments.
Next steps
The Digital Banking & Payments Committee will continue to coordinate the industry's engagement on digital payments, including responses to any consultation issued by the Central Bank. Member banks and other stakeholders wishing to comment on this paper may contact the Secretariat.
This paper reflects the Association's position at the date of publication and will be reviewed as policy, infrastructure and technology develop.