BoSS Sets Strict USD Caps on Mobile Money

(JUBA) – New transaction limits, licensing requirements and consumer protection rules have taken effect across South Sudan under amendments to the country’s electronic money regulations, introducing tighter operating requirements for banks and non bank digital money providers.

The rules are contained in the Electronic Money Regulation 2017 Amendment 2025 and apply to all licensed financial institutions and non bank electronic money issuers operating in South Sudan.

The framework was issued under the Bank of South Sudan Act 2011 Amendment 2023 and the Banking and Other Financial Institutions Act 2023. It aims to expand access to financial services, improve payment systems, prevent money laundering, limit monopolistic practices and protect customer funds.

Standalone payment system providers must establish separate legal companies for electronic money issuance. Applicants must obtain regulatory approval, submit governance and risk management documents and pay a non refundable filing fee of 65 million South Sudanese Pounds, equivalent to $10,000 at the reference rate of $1 = 6,500 SSP.

The Bank of South Sudan must assess applications within 60 days and provide written reasons where an application is rejected. Providers seeking to renew their licences must apply at least two months before their licences expire.

Digital money systems must maintain availability of at least 99.5%. Providers must notify users immediately when network disruptions occur. They must also keep accurate transaction records, train agents and submit monthly information on agent locations and suspensions to the central bank.

Transaction limits are based on three levels of customer identification.

Tier One accounts, which require simplified identification such as a student or local chief ID, may hold up to 6.5 million SSP, equivalent to $1,000. Daily transactions are limited to 1.625 million SSP, or $250, while the monthly limit is 13 million SSP, or $2,000.

Tier Two accounts, verified using passports or government identity cards, may hold up to 26 million SSP, equivalent to $4,000. Their daily transaction limit is 6.5 million SSP, or $1,000, while the monthly limit is 52 million SSP, or $8,000.

Tier Three accounts for companies and government entities require documents such as tax certificates or bank statements. They may hold up to 65 million SSP, equivalent to $10,000. Daily transfers are limited to 13 million SSP, or $2,000, while monthly transfers may reach 130 million SSP, or $20,000.

Over the counter electronic money transactions are limited to 6.5 million SSP, or $1,000, per transfer.

All digital payment platforms operating in South Sudan must connect to the National Payment System through a licensed switch. The requirement is intended to allow customers to transfer money between different service providers.

Payment systems must process transfers in real time and issue immediate notifications showing transaction reference numbers and fees in South Sudanese Pounds. Customers must also be given free transaction records for transactions less than 60 days old.

Where a transaction fails because of a network problem, the system must automatically reverse the funds. Providers must retain evidence of electronic transactions for at least five years.

Customer contracts must clearly state that electronic money balances are liabilities of the provider and are not bank deposits. Such balances are not guaranteed by the central bank unless they are directly linked to a bank account.

Providers and their agents must keep customer information confidential. Personal data may only be released with customer authorisation, under a court order or following instructions from the central bank.

Providers must comply fully with anti money laundering laws and report suspicious transactions within 24 hours.

Agent networks must operate on a non exclusive basis, allowing agents to work with more than one service provider. Providers remain responsible for selecting, monitoring and supervising their agents and ensuring that they meet operational requirements.

Agents are classified as sub agents or super agents according to their corporate registration and operating capacity.

The central bank will maintain a public online register of agent locations. Providers must submit monthly updates and give at least 30 days notice before moving or closing an agent outlet.

Customer funds must be kept in dedicated trust or special accounts separate from the provider’s operational funds. Trustees must receive approval from the central bank.

Interest earned on pooled trust funds will be distributed for consumer benefit as directed by the monetary authorities.

To reduce concentration risk, electronic money issuers may not hold more than 25% of their total trust funds with a single commercial bank.

The protected balances cannot be attached or seized to settle debts owed by the electronic money provider.

Accounts that remain inactive for three months will be classified as dormant after customers receive a one month advance warning. Blocked accounts can only be reactivated using original identification documents.

Unclaimed funds in blocked accounts will, after a further three months, be transferred to dedicated accounts at commercial banks and held for five years.

If funds remain unclaimed after five years, the remaining money and customer information will be transferred directly to the central bank.

The rules also require providers to protect vulnerable customers, display all transaction fees clearly before charges are made and maintain accessible complaint procedures.

Complaints must be acknowledged within seven days and resolved within seven days. Providers may take an additional 10 days where the customer is informed of the extension.

Customers may escalate unresolved complaints to senior management or refer them to central bank reviewers.

Electronic money providers must submit monthly compliance reports to central bank supervisors by the tenth business day of each month.

Late reports may result in warning letters. Repeated failures can lead to fines of at least 6.5 million SSP, equivalent to $1,000, for each day or violation, as well as business restrictions or loss of a licence.

The rules were signed into effect by Bank of South Sudan Governor Dr Addis Ababa Othow. They require electronic money providers to maintain continuous risk controls, conduct external system audits and ensure strict oversight by company executives.

The new framework places greater responsibility on South Sudan’s digital finance providers to maintain reliable payment systems, protect customer funds and information, comply with financial crime controls and meet reporting requirements.