The Central Bank of Ghana (BoG) has released a document detailing the treatment of dormant electronic money accounts and unclaimed balances.

The guidelines issued are to ensure that section 33 of the Payment Systems and Services Act 2019 (Act 987) is being operationalized.

According to BoG, the objective of these Guidelines is to establish processes and procedures for reclaim of funds by dormant electronic money account holders or their legal representatives; and ensure that funds of electronic money account holders which are classified as dormant are adequately protected.

BOG further clarified that, these guidelines shall not be applicable to electronic money accounts that are subjects of: litigation, fraud investigations by a regulatory authority or law enforcement agencies as well as any encumbrance including, but not limited to, liens and collaterals.

In addition, the guidelines shall not apply to registered transactions due to errors including system errors and are under investigation for correction or have been so determined by the Bank of Ghana.

BOG defined dormant electronic money account as an account with no registered transaction by the account holder for a period of 12 consecutive months; or account that does not have a registered transaction performed by a 3^rd party for a period of twelve (12) months.

According to BoG, Dedicated Electronic Money Issuers (DEMI) shall provide a register of dormant electronic money accounts for monitoring purposes and shall maintain the account for a period of twelve (12) months after which the account shall be terminated.

“Dedicated Electronic Money Issuers (DEMI) is obliged to be in constant communication with the account holder in question to give him or her notice of the status of account, before the account goes dormant, and after the account goes dormant.
“They shall also provide instructions on the procedure for reactivation of the account”.
Bank Of Ghana

BoG disclosed that, a DEMI that receives a request for dormant account reactivation shall adhere to its internally approved procedures for reactivation, re-activate the account within 3 working days upon receipt of request, and an additional 2 working days for complex issues.

Investing Funds of Dormant Electronic Money Accounts

BoG clarified that, a terminated electronic money account that remains dormant for 12 months without reactivation will have its balance transferred to a separate account with a float holding bank or a bank designated by the BoG within 10 working days after termination.

“A DEMI shall transfer the balance of a dormant electronic money account that is not reactivated to a separate account with a float holding bank, or any other bank designated by the Bank of Ghana.
“DEMI shall invest the funds in the accounts in safe Government security and retain 10% of the interest earned. There will be a remit of 10% of the interest earned to the DEMI, and the remaining 80% of the interest earned on the investments to the principal.”
Bank Of Ghana

In addition, BOG further explained that in a situation where a request for claim of funds invested by the account holder is received, the DEMI shall take steps to validate and make the claim on behalf of the claimant at BoG within 5 working days after validation.

In the event of non-existence of the DEMI, the claimant shall have recourse to the Bank of Ghana or any institution designated by BoG. BoG shall pay the said amount into an account specified by the claimant of the funds, BoG noted.

Internal Policies and Procedures

A DEMI shall establish and implement internal control policies and as well monitor accounts, BoG disclosed.

“A DEMI shall review its dormant electronic money account and unclaimed balance registers to ensure that controls put in place are effective and prevent abuse of such accounts.
“The review shall be part of the DEMI’s internal control function. It shall monitor accounts that show tendencies of dormancy and take actions to protect same from fraudulent activity.”
Bank Of Ghana

BOG has made it an obligation that a DEMI shall submit to the Bank of Ghana returns on dormant electronic money accounts; unclaimed balances; re-activated accounts; and any other returns as may be determined by the Bank of Ghana.

BoG concluded that, DEMI or a float holding bank who fails to comply with the provisions of these Guidelines is liable to pay to the Bank of Ghana an administrative penalty of not less than five thousand units in accordance with Section 33(8) of Act 987.