Mobile Money and Telecom Convergence: Regulatory Interfaces

Cambodia has emerged as one of the more advanced markets in the region for mobile-enabled financial services, with a rapidly growing user base for mobile wallets, remittances, merchant payments and micro-finance products delivered over mobile networks. In 2024 the authorities addressed a series of convergence issues that arise where the same corporate group, or closely related groups, provide both licensed telecommunications services and licensed payment or financial services.

The measures are relevant to mobile network operators that also offer mobile money services, to payment service providers that distribute their products through mobile channels, to banks that partner with telecommunications operators and to over-the-top wallet providers that rely on mobile connectivity for the delivery of their services.

The measures clarify that telecommunications licensing and payment or financial service licensing are separate regimes. A mobile network operator may not, by virtue of its telecommunications licence alone, provide regulated payment or financial services without obtaining the appropriate authorisations from the relevant financial authority. Similarly, a payment service provider that uses mobile channels remains subject to sectoral supervision by the financial authority.

Groups that operate in both sectors are expected to organise themselves so that the activities within each sector are clearly identified, that the responsibilities of each licensed entity are respected and that transactions between related entities are conducted on arm's-length terms. Governance arrangements should ensure that decisions affecting one sector do not compromise obligations owed under the other.

Consumer-facing convergence raises particular concerns. Customers of a converged group may not always distinguish between the telecommunications service and the mobile money service, particularly where both are marketed under the same brand. The measures expect providers to make it clear, in marketing, in onboarding and in ongoing communications, which entity is providing which service, which rules apply and how customers can seek redress in each case.

Bundled offers that combine telecommunications and payment services should be structured so that customers can understand the terms of each component, can opt in or out of individual services and can exercise their rights under both regulatory regimes. Complaint-handling processes should be clearly signposted and should not require the customer to identify the correct entity in advance.

Convergence typically involves data sharing between telecommunications and payment functions, for example to support authentication, fraud prevention, credit assessment and marketing. The measures require that data sharing between entities within a converged group be based on a clear legal basis, that customers be informed of the sharing and its purposes, and that appropriate safeguards be applied to sensitive information such as location data, transaction history and identity documents.

Groups should ensure that consent, where required, is meaningful and that customers are able to withdraw consent for optional data uses. Internal governance should include controls over which staff and systems can access data across the two sectors, so that access is limited to those with a legitimate business need.

Payment services are subject to anti-money-laundering and know-your-customer obligations imposed by the financial authorities and, in some cases, by international frameworks. Where telecommunications channels are used to onboard customers or to deliver payment services, the measures expect providers to align their processes with these obligations. This includes proper identification of customers, screening against relevant lists, monitoring of transactions and reporting of suspicious activity through the designated channels.

SIM registration data, while collected for telecommunications purposes, is not automatically a substitute for know-your-customer procedures required for payment services. Providers should assess how the two datasets interact and should implement additional checks where required by financial regulation.

Converged groups may be in a position to favour their in-house payment or telecommunications services over those of competitors, for example through preferential pricing, bundling, exclusive access to distribution channels or preferential technical access. The measures reflect the concern that such conduct may distort competition in either sector.

Providers are expected to ensure that access to their telecommunications services is offered to competing payment providers on non-discriminatory terms, and that access to their payment services is offered to competing telecommunications providers on similar terms. Regulators in both sectors may scrutinise commercial arrangements to verify compliance with these expectations.

Convergence creates dependencies that can amplify operational risk. A telecommunications outage may prevent access to payment services, and a payment system failure may affect the broader reputation of the telecommunications brand. The measures expect converged groups to consider these interdependencies in their business continuity planning, to conduct joint incident exercises and to have communication protocols in place to inform customers and regulators promptly in the event of significant incidents.

Third-party arrangements such as cloud services, transaction processors and identity providers should be managed with a view to overall resilience, including contractual protections and contingency arrangements.

For converged groups, the measures reinforce the importance of clear internal separation, robust governance and coordinated compliance functions across telecommunications and payment services. Legal, compliance and operational teams should have visibility across both sectors, and boards should receive integrated reporting that highlights convergence-related risks and opportunities.

For competitors and partners of converged groups, the measures provide a basis for demanding fair access, transparent pricing and reliable service. Structured engagement with converged counterparties, supported where necessary by regulator escalation, is more likely to produce durable outcomes than ad hoc complaints.

For consumers and enterprise customers, the measures should improve the clarity of converged offers and the effectiveness of dispute resolution. Contractual arrangements with providers should reflect the customer's own expectations about service quality, data protection and continuity.

Lex Civora advises converged groups, standalone operators and payment providers on the interaction between telecommunications and financial regulation, on governance and compliance design, on the negotiation of commercial arrangements and on engagement with regulators on convergence issues.