Key: Irregularity Ranking
Ranking 1 |
|
Ranking 2 |
Serious irregularity likely to affect profitability and likely to adversely affect the reputation and customer goodwill of M-PESA. |
Ranking 3 |
Procedural irregularities unlikely to harm Safaricom’s profitability or raise regulatory compliance issues or cause loss of customer goodwill. |
Offence ranking; depending on the severity/frequency offence
# |
Rank |
Irregularity |
Ranking |
Penalty |
Grave Irregularities | ||||
1 |
1 |
Breaking down of deposits to earn more commission |
Offence 1
|
Claw back of commissions unjustly earned.
Mandatory Suspension of offending outlets for 3 months
Suspension of all Agent’s outlets for 1 months. |
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|
|
Offence 2 |
Termination of agency contract
Claw back of commissions unjustly earned.
Blacklisting of Agent & its principal officers
Criminal charges for fraud/ theft/obtaining by false pretences;
Civil proceedings for fraud/restitution if clawback is not possible. |
2 |
1 |
False Registrations to earn undeserving commissions |
Offence 1
|
Claw back of commissions unjustly earned.
Mandatory Suspension of offending outlets for 3 months
Suspension of all Agent’s outlets for 1 months. |
|
|
|
Offence 2 |
Termination of agency contract
Claw back of commissions unjustly earned.
Blacklisting of Agent & its principal officers
Criminal charges for fraud/ theft/obtaining by false pretences;
Civil proceedings for fraud/restitution if clawback is not possible; |
3 |
1 |
Not providing float despite customer giving cash/e-money
Giving customer less cash/e-money than what is due to them |
Offence 1 |
Termination of agency contract.
Reimburse customer. Safaricom to transfer from Agent float Criminal charges for fraud/theft/obtaining by false pretences;
Blacklisting of Agent & its principal officers |
4 |
1 |
Charging customers for registrations
|
Offence 1
|
Warning letter
Reimburse customer. Safaricom to transfer from Agent float
Suspension of offending assistant/outlet for 3 months |
|
|
Charging customers for transactions |
Offence 2 |
Reimburse customer. Safaricom to transfer from Agent float
Suspension of all Agent outlets for 3 months |
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|
Charging customers for SIMEX above normal price |
Offence 3 |
Termination of agency contract |
5 |
1 |
Withdrawing customer float without their consent
Asking for customer M-PESA PINS
Fraudulent SIM swap to defraud MPESA customers
Apparent Collusion with criminals to facilitate withdrawal of stolen float |
Offence 1 |
Termination of agency contract
Reimburse customer. Safaricom to transfer from Agent float
Criminal charges for fraud/theft/obtaining by false pretences;
Blacklisting of Agent and its principal officers |
Non-Compliance with CDD, AML & CTF & Customer Protection Irregularities | ||||
6 |
2 |
Not using Identification when registering customers |
Offence 1 |
Warning letter and suspension of offending assistant/outlet for 1 month |
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|
Registration forms not duly filled and signed |
Offence 2 |
Suspension offending Agent outlets for 1 months |
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|
|
Offence 3 |
Suspension of all Agent’s outlets for 1 months
Suspend offending outlet for 3 months |
7 |
2 |
Agents transacting without seeing customer IDs
Agents accepting copies of IDs |
Offence 1
|
Warning letter
Suspension of offending assistant/outlet for 1 week
|
|
|
Agents accepting non-authorized identification |
Offence 2 |
Suspension offending Agent outlets for 1 months |
|
|
Assistants signing registration/log books on behalf of customers and Logbooks not filled in |
Offence 3 |
Suspension of all Agent’s outlets for 1 months
Suspend offending outlet for 3 months |
Procedural Irregularities | ||||
8 |
3 |
Facilitating customers’ direct deposits to avoid charges/ or because customer is not registered |
Offence 1
|
Warning letter and suspension of offending assistant for 3 months |
|
|
|
Offence 2 |
Suspension of offending outlet for 1 months |
|
|
|
Offence 3 |
Complete withdrawal of tills |
9 |
3 |
Assists sharing pins |
Offence 1 |
Warning letter and suspension of offending assistant for 3 months |
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|
|
Offence 2 |
Suspension of offending outlet for 1 months |
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|
|
Offence 3 |
Complete withdrawal of tills |
10 |
3 |
Non-compliance to 1.5X float rule (both float and cash) |
Offence 1 |
Warning Letter |
|
|
Not maintaining minimum 30,000 float |
Offence 2 |
Suspension of offending outlet until criteria met |
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|
|
Offence 3 |
Suspension of all agent outlets until criteria met |
11 |
3 |
Irregular relocation of tills without prior consent and audit from Safaricom |
Offence 1
|
Warning letter and Suspension of offending outlet until regularized |
|
|
|
Offence 2 |
Withdrawal of offending till |
|
|
|
Offence 3 |
Suspension of all agent outlets for 1 month |
12 |
3 |
Till applications for non existent outlets
Falsifying information to secure agent tills |
Offence 1 |
Blacklisting from till application for 3 months |
Safaricom reserves the right to change the Agent Penalties and Irregularities from time to time