Dispute in Uganda over Mobile Money Monitoring Continues

A fierce dispute exists over how government should be allowed to monitor mobile money in Uganda, a huge business which had a value in excess of UGX trillion (US $11.79 billion) at the end of 2016.

Prior to 2017, Uganda had limited regulation and monitoring of mobile network operators, relying primarily upon a system of self-declaration. The explosive growth of mobile money highlighted the country’s needs for financial sector regulation such as fraud, anti-money laundering, countering the financing of terrorism and cybersecurity. In addition to allegations of underreporting its revenues, MTN was also victim of a substantial UGX 10 billion mobile money fraud in 2015 in spite of having several years of prior warnings.

In 2017, Ugandan President, Yoweri Museveni, created the country’s new Intelligence Network Monitoring System (INMS), a multi-billion monitoring technology implemented which was expected to cover voice and data. The Uganda Communications Commission (UCC) notified mobile network operators that it should also provide access to INMS to the Uganda Police. Objecting to the directive were MTN and Airtel, the country’s largest mobile network operators.

Airtel responded in a letter to the UCC highlighting several issues which primarily concerned the business secrecy of its customers. According to Airtel, Section 5 (1)(u) of the Uganda Communications Act, which empowers the UCC to “establish an intelligent network monitoring system to monitor traffic, revenue and quality of service of operators”, is limited to voice and data traffic. Mobile money services are regulated by the Bank of Uganda. And furthermore, the Airtel was unaware of any law or regulation which should grant access beyond the UCC such as to the Uganda Police.

Exacerbating tensions of the needs for financial sector monitoring were allegations in the press about MTN underreporting volumes of its mobile money platform in its self-declarations to government. These amounts have a bearing upon how much money the company would be obligated to contribute to universal service obligations.

But while systems such as the INMS may be seen as invasive, there is also hope that the monitoring technology will also expedite the ending of SIMbox fraud, which costs MNOs an estimated US $10 million monthly.


  • Oketch, Martin Luther. “Hundreds tap into mobile money as transactions hit Shs44 trillion”, Daily Monitor, 29 March 2017, available at http://www.monitor.co.ug/Business/Prosper/Hundreds-tap-mobile-money-transactions-hit-Shs44-trillion/688616-3866590-101bimu/index.html
  • Morawczynski,Olga. "Fraud in Uganda: How Millions Were Lost to Internal Collusion", CGAP, 11 March 2015, available at http://www.cgap.org/blog/fraud-uganda-how-millions-were-lost-internal-collusion
  • Kiyonga, Derrick and Mwesigwa, Alon. "MTN was warned of likely mobile money fraud in 2009", The Observer, 5 February 2015, available at http://observer.ug/business/38-business/36522-mtn-was-warned-of-likely-mobile-money-fraud-in-2009
  • Matsiko, Haggai. "Fight over Shs44 trillion mobile money", The Independent, 26 February 2018, available at https://www.independent.co.ug/fight-shs44-trillion-mobile-money/3/
  • Agbugah-Ezeana, Fumnanya. "Artel, MTN fend off Ugandan regulator's intrusion into $12bn Mobile Money revenue". The Nerve, 1 March 2018, available at http://thenerveafrica.com/14855/mtn-airtel-uganda-communications-commission-in-mobile-money-battle/


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