In what came as a shock to most, the Reserve Bank of Zimbabwe ordered Simbisa Brands (Private) Ltd to cease operating InnBucks, its rewards and loyalty program (money transfer service) last week.
The RBZ was concerned about the money transfer service part of InnBucks. According to the RBZ, InnBucks did not have the necessary approvals to operate the transfer service they were operating.
Apparently, the RBZ’s first thought was not to shut them down. Instead, they directed them to apply for and obtain the necessary approvals. That was back in November 2021 and so InnBucks had almost half a year to get their stuff in order. I think we can agree that the RBZ was fair if their version of the truth is accurate.
InnBucks responded to the RBZ’s order and shed a little more light on the situation.
To our Valued Customers,
The Press Statement issued by the Governor of the Reserve Bank of Zimbabwe on 20 April, 2022 refers.
InnBucks has been and remains engaged with the regulator in respect of its ADLA license. Regrettably an impasse has occurred in respect of which the Simbisa Board is engaging the regulator with a view of achieving a speedy and amicable resolution.
Pending further statements, we assure you that funds held in the InnBucks accounts remain secure and all product purchases and cash withdrawals will be honoured as per regulations.
Thank you for putting your trust in us.
By order of the Simbisa Brands Limited Board of Directors.
20 April 2022
InnBucks on twitter
Here we see that Simbisa is working to resolve the situation and get back to business. So, I think it’s a matter of when not if InnBucks will be back. I can’t see a scenario where Simbisa will fail to meet the RBZ’s requirements.
Access Forex
Whilst we were still digesting the InnBucks ban, we got blindsided by the suspension of Access Forex. WIth this ban we started wondering what the RBZ was up to. Said Access Forex of the suspension,
Following communication from the Reserve Bank of Zimbabwe concerning our domestic money transfer service, Access Forex will be suspending local money transfers effective Friday, 22 April 2022.
Access Forex
Access Forex assured customers at the time that their cross-border transfers were not affected and that they were working to bring back local transfers.
They have since been given the green light to resume local transfers.
We reached out to the RBZ, the Exchange Director specifically to understand why the sudden bans but are yet to get a response. However, we know what it’s all about.
ADLA licence
From both InnBucks and Access Forex’s communique’s we now know what’s going on in the background.
Simbisa announced that the problem has to do with their ADLA licence. With that revelation, now we know under which law InnBucks is operating or will operate. It is the SI 104 of 2015: Exchange Control (Authorised Dealers with Limited Authority) Order.
The first question then becomes, what is an Authorised Dealer with Limited Authority? The Statutory Instrument clearly lays it out,
A financial services provider not necessarily licensed under the Banking Act but authorised by the Reserve Bank… to carry out small value person to person cross-border cash transfers or buy and sell foreign currency through money transfer systems designated by the Reserve Bank.
SI 104 of 2015
With just that definition, one can clearly see that what InnBucks was doing was different from what an ADLA licence allowed. ADLAs facilitate cross-border cash transfers but InnBucks handled domestic cash transfers. ADLAs buy and sell foreign currency but InnBucks was not in the bureau de change business.
Access Forex had exceeded the limited authority their ADLA licence gave them by processing domestic money transfers.
The abovementioned Statutory Instrument is appropriately titled ‘Exchange Control.’ It really is about the exchange of foreign currency, either through allowing the sending or receiving of money across borders or currency trades.
InnBucks was a money transfer service, maybe not by name but in deed. However the SI which allows for ADLAs defines a money transfer service as,
The business of sending or receiving foreign currency cash between persons resident in Zimbabwe and persons resident in any other country or residence, and includes the buying and selling of foreign currency on a spot basis
SI 104 of 2015
Again, that’s not what InnBucks was. Access Forex was doing more than what they were allowed to. An ADLA licence does not appear to allow for local money transfers.
Domestic money transfers
To be able to process domestic money transfers, a service provider must adhere to the domestic foreign currency transfer framework. Also, they must abide by Anti Money Laundering (AML)/ Combatting the Financing of Terrorism(CFT) guidelines.
This is over and above the requirements to obtain an ADLA licence.
The resolution
Players like EcoCash and OneMoney who followed after InnBucks in the domestic USD remittance space are approved payment systems platforms providing mobile financial services. Steward Remit and BancABC’s City Hopper rely on their banks’ banking licences.
Mukuru throws a spanner in all that. Whilst Mukuru is mostly about cross-border remittances, it also allows for the same domestic USD transfers that InnBucks facilitated. So, one may wonder why InnBucks and Access Forex were suspended but Mukuru was not.
Access Forex was allowed to resume domestic transfers on the 27th of April only 5 days after suspension. In announcing the resumption of city to city transfers they shed more light on the matter.
Based on submissions made to the RBZ we are delighted to advise you, our valued clients that the RBZ has since updated our existing license to also cover local (city-to-city) money transfers, and subsequently, lifted the temporary suspension on the service with immediate effect.
Access Forex
The RBZ updated Access Forex’s licence to cover local money transfers. So, an ADLA licence holder can apply for and get approvals to do local money transfers. The RBZ said that plainly in their communique announcing the suspension of InnBucks.
So, it appears that Mukuru already got the go ahead, hence why they were not suspended. Access Forex got their licence updated pretty quickly and earlier than InnBucks who were suspended first.
We don’t know exactly why it’s taking longer for InnBucks but they mentioned an impasse with the regulator. InnBucks has the full weight of the ZSE-listed Simbisa and one can’t imagine what the hold up is. Whatever submissions Access Forex made are proving to be challenging for InnBucks to make.
The timing
I think we can agree that the RBZ was only doing its job and making sure all was fair in the money transfer business. However, the question becomes, why now?
The RBZ is not opposed to these money transfer services because they get data about the movement of hard currencies in the country. In addition, the RBZ has a reputation of hindering business and innovation that they would like to erase.
So, regarding InnBucks for example, they were willing to give them almost half a year to regularise their licence. The RBZ seemed reluctant to suspend them and so I think there was pressure from other players in the industry who were compliant. I could be wrong but it feels like it.
What do you think about all this? Let us know in the comments below.
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