Risk Assesment of Products of Bkash
Risk Assesment of Products of Bkash
Risk Assesment of Products of Bkash
By
Iffat Rubaiyat
ID: 15104189
An internship report submitted to the BRAC Business School in partial fulfillment of the
requirements for the degree of
Honors
1. The internship report submitted is my own original work while completing degree at
BRAC University.
2. The report does not contain material previously published or written by a third party,
except where this is appropriately cited through full and accurate referencing.
3. The report does not contain material which has been accepted, or submitted, for any
___________________________________________
Ms. Fabiha Enam
Senior Lecturer, BRAC Business School
BRAC University
___________________________________________
Iffat Rubaiyat
Student ID: 15104189
ii
Letter of Transmittal
Senior Lecturer
BRAC University
66 Mohakhali, Dhaka-1212
Respected Madam,
I express my gratitude to you for providing me with the supervision and support to
devoted to find out the core information from different aspects. I hereby, thank you
Sincerely yours,
_______________________
Iffat Rubaiyat
BRAC University
iii
Non-Disclosure Agreement
This page is for Non-Disclosure Agreement between the Company; bKash Limited
This agreement is made and entered into by and between bKash Limited and the
iv
Acknowledgement
without the guidance and proper instructions of the people of my academic area as
University, Ms. Fabiha Enam for providing me the guideline to write my internship
her for being available and supportive to me all the time during my internship period.
I would also like to thank Mr. Saber Sharif, head of AML and CFT department, for
selecting me as an intern of his department and I would also like to show my cordial
Hereafter, I would like to thank my onsite supervisor Mr. Shahrear Ahamed, Assistant
Manager, for helping me in every possible way. Without his guidance in every step, it
would be impossible for me to write the report. Last but not least, I would like to
thank, all the employees of the department for their help towards me.
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Executive Summary
Internship is the opportunity to experience the practical work environment. The main
First of all, the report gives an overview of bKash Limited. Hereafter, it draws
attention towards the practices of AML and CFT in Bangladesh and also helps to
identify the importance of the process for any organization. In the third part, the risk
assessment of the products in bkash has been described in detail. Before that, a
comparative study has been shown about the products of bKash. Last but not least, a
KYC checking is given so that the first step of risk mitigation can be shown. At the
very end, recommendations have been stated as per practical knowledge and
Here, the comparative researches are shown so the mobile financial services can be
compared.
The report is prepared to evaluate the effectiveness and areas of further development
Furthermore, here is a small description of the latest product eKYC is given which is
Keywords: AML and CFT; Mobile Financial Service; CPMCT; Risk assessment.
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Table of Contents
Declaration................................................................................................................................ii
Acknowledgement .................................................................................................................... v
List of Figures..........................................................................................................................ix
Glossary ..................................................................................................................................xii
Chapter 1 Introduction.......................................................................................................... 13
1.3 Mission.............................................................................................................. 16
vii
3.2 Competetive Analysis ........................................................................................ 21
References ............................................................................................................................... 49
viii
List of Figures
ix
List of Tables
x
List of Acronyms
EC Election Commission
eKYC Electronic-know-your-customer
xi
Glossary
account.
themselves.
xii
Chapter 1: Introduction
In 2011, bKash started its journey along with 12 employees. Moreover, in a very short period
of time bKash has become the leading MFS (Mobile Financial service) of Bangladesh. The
impact bKash has created to rural and urban people are life changing. Its mission is to reach
to all the unbanked people by offering the financial services at the lowest possible cost and
through mobile network. It already has a huge customer base and is the market leader. But,
like all financial service provider bKash has been facing fraudulent activities and to mitigate
these risks the Division of External & Corporate Affairs is working day and night. As per
Bangladesh Bank rule and regulation MFS providers must follow guidelines and policies
which include the CDD which is the Customer Due Diligence. bKash application is basically
act as depository of electronic money while the transaction is being done through customer’s
cell phone. But this platform is being misused by some criminal minded people who are
basically corrupted and has no moral values. Every minute a lot of customers are using this
application and becoming victims of serious criminal offence like money laundering and
terrorist financing. For some reasons day by day ML&TF activities are increasing at an
alarming rate which can be potential threat for bKash application. I got the opportunity to
work under the team where I got to do the CDD of personal bKash account holders. There are
certain guidelines by BFIU by which we accept or reject registered KYCs which was my
main job responsibility. KYC is fulfilled to complete a registration and according to BFIU
guidelines there are some mandatory fields which must be filled properly to maintain a
Mobile Financial Services (MFS) is an approach to offering financial services that combines
banking with mobile wireless networks which enables users to execute banking transactions.
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This means the ability to make deposits, withdraw, and to send or receive funds from a
mobile account. Often these services are enabled by using bank agents that allow mobile
In 2011 BRAC Bank launched a 51% owned subsidiary called bKash combined with an
Bangladesh bank to jointly operate MFS in Bangladesh. In April 2013, International Finance
Corporation (IFC), member of the World Bank Group, became an equity partner and in April
2014, Bill & Melinda Gates Foundation became the investor of the company. In 2017, bKash
Limited, the largest mobile financial service provider in Bangladesh was ranked 23rd on
Fortune’s third annual ‘Change the World’ list which recognizes top fifty companies that are
bKash provides one service menu for MNOs which includes Robi, Banglalink,
Grameenphone and Airtel. bKash is the largest MFS in Bangladesh with a network of over
200000 agents scattered through the urban and rural areas of Bangladesh touching the
unbanked communities with over 35 million registered accounts. bKash has also collaborated
with big organizations as business partners such as Aarong, Bata, Lotto etc. which are known
as merchants.
Bangladesh Bank plays a huge role in shaping the regulations of bKash’s operations. bKash
follows compliances and amendments so that no fraudulent activities can take place using the
services provided by bKash. bKash maintains the requirements of Bangladesh Bank and most
importantly bKash does Customer Due Diligence (CDD) or Know Your Customer (KYC) for
background check to ensure the customers are properly risk assessed before being on boarded
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By providing various banking services such as cash in/out, buying airtime, making
payments, sending money and remittances through mobile networks bKash has
every district of Bangladesh and has provided affordable banking services to people
who could not afford banking services and is contributing a large portion to the
1.2 Objectives
In Recent days mobile financing industry become very much comprehensive. It deals
with different areas to capture the market & it requires huge promotional activities to
survive. Beside this it takes huge effort to known this system with general people.
Moreover, they have to come up with different innovative ideas to have a position in
the market. Thus, the study covers a broad spectrum such as Service, price,
promotion, government, regulation etc. Based on the above facts the specific
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1.3 Mission:
Being the largest MFS in Bangladesh, the objective of bKash is to provide convenient,
affordable and reliable financial services. The company aims to widen the net of financial
inclusion and provide a solution for Mobile Financial Service built on a highly scalable
mobile money platform, allowing the people to do safe money transactions through mobile
1.4 Methodology
For making a report, correct information and data are needed. Moreover, this report mostly
Primary Data:
This data is directly collected from the source that is from the company directly. Here,
the interns can gather information by asking the employees and also can add their
Secondary Data:
For further information and data collection secondary data collection is done by
collecting data from internet, previous research’s and going through company
documents.
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Chapter 2 The organization
bKash has several divisions which are divided into into different departments to carry out
functions. The departments are then divided into several teams working together as a whole
Commercial
Marketing
Finance
AML & CFT
Technology
Regulatory &
bKash
Corporate Affairs
ECAD
External Affairs
Human Resource
Admin
Corporate
Government & Legal
Internal Audit
Customer Service
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An an intern in the External & Corporate Affairs Division (ECAD) which is one of the largest
divisions of bKash with four departments divided into several teams is a great opportunity.
ECAD mostly works with compliance, fraudulent activities and works to mitigate risks
associated with bKash and it’s operations. ECAD division of bKash harmonizes the interests
of bKash with the regulations of Bangladesh Bank required for MFS provider related to
Intelligence Unit (BFIU) provides the compliance and amendments related to risk mitigation
for bKash. ECAD deals with the external affairs related to bKash. As an intern in the Anti
Money Laundering & Combating Financing of Terrorism (AML & CFT) department and got
to work with the CPMCT. CPMCT is Compliance process monitoring and control team.
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2.2 The Teams &Their Functions:
CPMCT
External & Corporate Affairs
RMCT
Regulatory Affairs
Division (ECAD)
SCT
STR/SAR
Anti Money Laundering &
Combating Financing of Terrorism
Training team
FCAT
Regulatory &
Corporate Affairs
RAMLCO
Figure 2: Teams
This team works with customer services, rechecks their works, gives feedbacks and develops
This team monitors situations, identify risks that can arise using bKash services and provide
This team analyses the provisional risks that might arise after implementing new strategies and finds
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Suspicious Transaction Report/ Suspicious Activity Report Team (STR/SAR):
This team reports unusual activities and transactions using bKash services then raises complaints and
Training team:
This team trains agents, distributors and merchants according to the requirements of Bangladesh
This team keeps all the documents and records of the entire department and directly works with
Bangladesh Bank.
This team works directly in the field, assess problems of unusual transactions directly through the
primary sources.
They are the heads of individual division in different regions who follows up regional problems
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Chapter 3 Industry Analysis:
bKash Limited is a joint venture between BRAC BANK Limited, Bangladesh, and Money in
Motion LLC, USA. The ultimate objective of bKash is to ensure access to a broader range of
financial services for the people of Bangladesh. It has a special focus to serve the low-income
masses of the country to achieve broader financial inclusion by providing services that are
The report is containing a comparison between bkash and DBBL Mobile Banking in terms of
their branding. There the comparison based on visibility level, area covered by the company
The report also portrays the industry through Porters’ Five forces model. The state of the
industry is best portrayed through the model. The threat of new entrants is low due to the
If one studies the comparative analysis of the market, it can be seen that bkash has already
built brand equity among its customer. Thus far, it has been able to hold on to its leadership
SWOT Analysis: SWOT analysis is a framework used to evaluate a company's competitive position
and to develop strategic planning. SWOT stands for strengths, weaknesses, opportunities and threats.
SWOT analysis assesses internal and external factors, as well as current and future potential. (SWOT
21
3.2.1 Strength
1. Market leader
UCash
2. Receives full cooperation from parent bank
3. Made a contract with BRTA for receiving all sort of road tax
22
3.2.2 Weakness
1. No interest on savings
UCash
2. Very low market share
23
3.2.3 Opportunities
business globally
2. Helping parent bank in converting 90% mobile users to core banking customer
3. Potential growth of the industry and more focused operation from the authority
3. Have the ability to utilize trust banks conventional customers to increase market
share
2. Ability to make deals to receive different types of government fees and taxes
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3.2.4 Threats
bKash
2. The gap with the nearest competitors is decreasing
Rocket 2. The possibility of losing existing market share if bKash offers even better
market shares.
UCash
2. Lack of creative ideas is making its customers exhausted
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3.3 MFS Industry Analysis:
The mobile wallet market in Bangladesh is likely to gain momentum in 2019 as a global
report forecasts its growth to USD 250 billion by 2024 from over USD 100 billion in 2017,
according to experts. Mobile Financial Service (MFS) experts said the size of the mobile
wallet market was expected to increase at a 30 per cent compound annual growth rate
(CAGR), while it is 15 per cent around the globe. The mobile wallet market in Bangladesh is
growing with increasing digital shopping, introduction of the QR code and cash back offers
US-based Global Market Insights, in its report released on Tuesday, says the mobile wallet
market is expected to grow from over USD 100 billion in 2017 to USD 250 billion by 2024.
It suggests that the growth is influenced by attractive discounts and cashback offers by
mobile wallet providers. The report says significant capital investments by major industry
players towards redevelopment programs as well as collaboration among fintech firms and
commercial banks will further stimulate the industry growth. (Bhutani & Wadhwani, 2019)
“Cashback offers also reduce the customer acquisition cost by preventing companies from
spending large amounts on marketing their products,” the report says, noting that countries
like Bangladesh and India will also see further growth in the mobile wallet market in 2019.
Countries like India, Bangladesh and Kenya will also see impressive growth in the mobile
wallet market in the days ahead, the report says. (Azad, 2019)
Commenting on the report, a Bangladesh Bank (BB) official said the Bangladesh MFS
market would gain momentum in 2019 as most players are offering lucrative discounts and
26
cashback offers and likely to introduce lucrative services in cooperation with global players.
(Azad, 2019)
27
More than 50 million people are using mobile financial services offered by 18 banks to meet
their needs under a regulatory environment. The industry has experienced 120 per cent
growth since 2011 thanks to rapid customer’s adoption and innovations in services offered.
"bKash, a multinational company is a leading MFS player in Bangladesh with a lion’s share
of the market, followed by Rocket and Sure Cash”, said the central bank official. It is
expanding its customer base with lucrative cash back offers. bKash has already adopted QR
code in its payment apps to facilitate customer’s cashless shopping experiences, the BB
official said, adding that government offices are increasingly accepting this new mode of
payment, while different private sector companies have been using this platform for salary
disbursement.
According to BB’s report on MFS, the total volume of transactions conducted through MFS
platform was Tk. 378,885 in 2018, which is 20 per cent higher than 2017. Moreover, the
number of active customers has also increased to 3.73 in 2018 from 2.1 crore in 2017.
Shamsuddin Haider Dalim, head of corporate communications of bKash, said the wallet-to-
wallet fund transfer is still the most popular segment in MFS transactions. He also said there
is tremendous growth potential in some other segments too, including bill payment, merchant
payment, salary disbursement and international remittances. “We have seen a strong impact
on our remittance solutions where our partner banks like MTBL, Bank Asia, City Bank and
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3.4 Comparison of Product & Services Offered and Fees charged
Offered
Availabili Fees Availabili Fees Availabili Fees Availabili Fees
ty ty ty ty
Opening
Agent for
salary
or
stipend
produc
ts
Bank for n
Branch salary
or
stipend
produc
ts
from Bank
A/C
29
Cash Out Yes 1.85 Yes 0.9 to Yes 1.85% Yes 1.85%
from an % 1.8%
agent
m 2000
taka)
Cash Out N/A N/A Yes 1.80% N/A N/A N/A N/A
from Bank
Branches
Transfer
Savings to
4%
Bill & Yes Free Yes Free Yes Unknow N/A N/A
Merchant n
Payment
% n
Payment to
(cost to 1.8%
merchant)
30
Disburseme % n
nt
Settlement % n
Fee
Balance n n
Requiremen
Recharge
After analyzing all the products and services offered by the different MFS operators,
it is very clear that bKash and Rocket provides the most premium services among
all other MFS operators. Their services are almost similar to each other, in terms of
cash in from bank branches Rocket has got an edge over bKash, on the other hand
cash in from bank account is only provided by bKash, which gives bKash an edge
provided by bKash to its customers & there is no minimum balance requirement for
bkash account holders. All these extra advantages given by bKash make it more
Services Offered
M-Pesa bKash MTN
Momo
P2P Transfer
Yes Yes Yes
P2P Transfer to
Yes N/A N/A
Unregistered Users
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Interest on Savings
Yes Yes Yes
Specialized Savings
Yes No Yes
Account
Providing Loan
Yes N/A Yes
B2P
Yes Yes Yes
Disbursement
Minimum Balance
No No No
Requirement
Mobile Recharge
Yes Yes Yes
Leasing Services
Yes No Yes
Remittance Services
Yes Yes Yes
Payment Gateway
Yes Yes Yes
It can be seen there are some major differences between products & services offered by bKash and
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The first major difference between bKash and other two MFS is, bKash is a
subsidiary of a bank, whereas M-Pesa & MTN MoMo both are a specialized service
provided by two of the world’s largest mobile operator company. M-Pesa is owned
Though M-Pesa and MTN MoMo are owned by two mobile network operators but
they are providing complete banking services to their customers compared to bKash.
M-Pesa and MTN MoMo customers can take loan, deposit their money through a
specialized saving scheme, even they can receive or disburse lease payments using
mobile money account. bKash customer does not receive such services. M-Pesa is
providing life insurance services to their customers. bKash need to adopt those
M-Pesa and MTN MoMo provide some services which should be provided by every
MFS operator in our country to increase financial inclusion. They are P2P transfer
to different operators and P2P transfer to unregistered users. This advantage will
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Chapter 4 Products and Their Risk Assessment:
Cash In
Request
Cash Out
Money
Movie Send
Tickets Money
bKash
Products
Card to
Payment
bKash
Bank to
Remittance
bKash
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Descriptions:
Cash in: Users can load e-money into their bKash accounts from bKash agents or
ATMs. This does not cost any charge; the user gives money to agent or transfers from
Cash out: Users can withdraw money from their bKash account or ATMs. They can
only withdraw the amount they have in their account and requires certain charge in
every withdrawal.
Buy airtime: bKash account users can directly buy airtime using any Mobile
Payment: bKash account users can also make payments in collaborated stores known
Send Money: One bKash account user can transfer e-money to another bKash
Remittance: bKash has strategic alliance with Western Union and MasterCard to
enable transfer of foreign remittance through bKash accounts which is available 24/7
and people can send money from 200 countries to Bangladesh which makes this
Bank Transfer: bKash account holders can transfer money from their bank accounts.
Request Money: A bKash account holder can request another account holder for
Bills: bKash app can also be used as a bill payer for electricity.
Bank to bKash: By this, customer can transfer money from bank to a bKash app.
Card to bKash: In this cashless tendency society people tempt to carry credit cards
more than cash. So, bKash app allows to transfer money from cards.
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eKYC: A new feature for the app so that customers can open their own accounts by
themselves only by scanning their NID and clicking a photo. For now, only the agents
have the access but from 1st September, 2019 each and every customer will get the
This year bKash launched e-KYC (Electronic-Know-Your-Customer) app for the individual
customers so that one can open their own account by using their own mobile bKash app. As
bKash App is most popular and have maximum user became the first mobile financial service
According to the press release by bKash they announced that, the eKYC app allows customer
to open their accounts by instant activation by scanning NID and taking a photo.
OCR (Optical Character Recognition) is to collect data from NID, face detection technology
and cross matching data with Election Commission (EC) database, the app is making the
whole system more integrated and less operational complexity. Furthermore, it saves more
time.
An automated scanning process OCR helps to extract information from the NID and filled the
eKYC form.
Then a photo is taken directly by the mobile phone and all the information are cross matched
with EC database.
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After proper verification, the system will automatically register the customer account and
send confirmation message to both the eKYC app user and the new customer.
At this moment, agents, bKash care, bKash center and distributors are registering new
But, bKash plans to render this solution directly to the customers so that they can open
accounts by themselves.
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4.3 Risk Assessment of The Products:
Risk Definitions
1. Systemic: A risk that could cause collapse of, or significant damage to, the
3. Reputation: A risk that damages the image of one of the stakeholders, the
6. International: A systemic risk (as defined above) that could have cross-border
contagion effect
bKash is a mobile financial service, so its services are its products. Moreover, there may be
Other products are giving service for about 2-3 years but for now the main concern is eKYC
app. For this reason, there are some thresholds that for avoiding the risks.
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Previously its known that eKYC app is a self-controlled app by which customers can open
their own accounts. But then again, the customers can be a fraud, he/she might want to open
multiple accounts, can use a death customers NID or number and also there are some more
problems. Moreover, as the app is not launched yet for every customer it is not allowed to
To avoid opening multiple accounts bKash has set the rule, one NID one account.
Furthermore, for avoiding risks for death persons' account while taking the picture for eKYC
The main service or products of bKash is to transact money. Moreover, all the
There are some regulatory guidelines that are settled by BFIU which bKash follows
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Chapter 5: CPMCT
As an intern the scope of working and access to work was limited. In the past three months of
internship in bKash has been an amazing experience and a journey of learning. Through the
internship period one could step into the corporate world where they did not just learn about
the work environment and behavior but they could also enhance their skills. Intern had to
work in MS Excel where all developed Excel skills.Interns got the chance to go through
BFIU circulars where everyone got to know about the rule, regulations and policies.
Furthermore, Intern were given the responsibility to monitor, detect and give observations on
the registered forms of personal customer account. They had to check the quality of KYC
forms according to certain guildelines by BFIU for mobile financial service providers and
For opening a personal account, the account holder has to be physically present in an agent
point with their NID/ Driving license/ Passport as a photo proof and needs to fill up the KYC
designed for personal account. The KYC form fro personal account is given below:
41
Figure 5: Personal KYC Form
42
To check if the KYC is compliance effective or not BFIU has provided some
The photo submitted with the KYC must match with the photo ID
Use of Fluid anywhere in the KYC will automatically be the cause of rejection
The applicant must provide a signature in the photo copy of the photo ID given and
the signature given in the KYC must match the sign in the supporting document.
No overwriting or corrections are allowed in the KYC, however, upto four corrections
are allowed but the customer has to provide a counter signature for each correction. If
the number of corrections exceeds four the KYC will be rejected. Any sort of
correction in the customer’s wallet number will lead to direct rejection of the KYC.
In terms of various appearance deviation like age, gender etc will lead to KYC
blind he/she can wear dark glasses but he needs to provide a certified document.
Front faced photos are accepted only. Picture with single colored background or shade
is accepted.
The date field must be filled and absence of date in the KYC will be rejected.
Date of Birth (D.O.B) has to match the photo ID provided and can be written in both
code) must be filled out in both permanent and present address fields.
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Details of occupation must be filled out. Source of funds, Monthly income must be
Signature of agent and distributor with date is a must, thumb print will cause
Any customer account number with less/more than 11 digits including zero should not
Any supporting document used as Photo ID must have validity date wherever
applicable.
Personal accounts can also be opened by armed license, military, para military, SAGs
and NGO beneficiary ID but birth certificate must be given along with it.
Internsare to recheck the KYCs which were accepted by Customer Service and if the
forms were compliance effective they have to accept the sampled KYCs but if any
error foundhave to reject those KYCs and give certain observations with remarks and
give input in MS Excel. Some observations and reasons for those observations are
given below:
Unclear Photo ID clear, readable and visible, if not, we give this (QC) Not
observation possible
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If the photo given with the KYC has different
Incorrect Photo coloured background or the front face of the KYC is Rejected
Father’s/ Mother’s Name Father’s/ mother’s name has to match with photo
KYC is rejected
Missing ID, if not we give this observation
this observation
Signature not found in The applicant must sign the photocopy of the
KYC is Rejected
supporting document photo ID, if not we give this observation
45
observation
Incompleteness of KYC form will be considered incomplete and we give KYC is Rejected
this as an observation
Customer and Agent sign same applicant’s sign because the agent cannot open a KYC is Rejected
Different supporting The photo ID information must match with the KYC is
Address not captured/ filled Four fields of address must be filled or else we KYC is
Validity date Any photo ID provided that has validity date KYC is
46
this observation
Interns either reject the KYCs checked by CS with these observations or if all the
fields are correctly filled we accept those KYCs. In case the information required are
not filled properly bKash gives sixty days time to fix the problems orelse their wallets
are freezed. By this process we work as a control body over the CS to maintain the
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Chapter 6 Conclusion:
6.1 Conclusion:
Risk assessment is one of the most important practices for any mobile financial service. By
this the products can be saved and the risks can be mitigated. Moreover, customers will be
Furthermore, bKash have a huge customer base and to keep track of them a team work on the
fields to train the agents and a team monitor them from head office.
In addition to that, the product team always try to make their products flawless and user
friendly. Most importantly, each and every time they give their heart and soul to innovate
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References:
[1] (2016, March 10). Comparative Analysis of bKash Limited. Retrieved from
https://www.assignmentpoint.com/business/management/comparative-analysis-of-bkash-
limited.html
[2] Mohammadruhulkader. (2018, December 1). The MFS Service Charge Question, bKash and
charge-question-bkash-and-remittance-conundrum/
[3] (2019, August 8). bKash launches eKYC app for AC opening. Retrieved from
https://www.dhakatribune.com/business/2019/08/09/bkash-launches-ekyc-app-for-ac-opening
[5] Kaler Kantho. (n.d.). bKash launches eKYC for digitally opening account. Retrieved from
https://english.kalerkantho.com/online/tech/2019/08/08/25883
[6] (2019, July 7). Digital Financial Services – The Next Step. Retrieved from
https://www.lightcastlebd.com/insights/2019/01/15/digital-financial-services-the-next-step
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