a Case in MoMo’s Defence

First of all, MTN has successfully made a MoMo out of all of us, or should I say ”made a fool out of all of us” in lack of a data protection law, MTN flys over our borders adopting what it deems fit to its products, and the recent MoMo’s Terms and Conditions is but one clear example.

We have observed many posts and comments Highlighting MoMo’s (easy, and risky) registration steps, Netizens are concerned about how easy it is to register to MTN’s mobile money (MoMo), and the lack of users’ Identification requirements in MoMo’s registration process may form a risk to MoMo’s subscribers, encourage fraud, and other criminalities and financial malpractices.

First Some Facts

MTN (the Mobile Network Operator) and MoMo (The mobile Money product) are both MTN services, and referred to as ”MTN Systems” this includes the MoMo and the MTN as we know it, ”which are services marketed, managed, and operated exclusively by MTN in South Sudan” this means the two are vertically integrated;

both services are licensed by their respective regulators, namely the National Communication Authority, and The Bank Central Bank of South Sudan (NCA, BOSS) respectively;

MTN has a registration requirement for all its users, this means everyone who wants to use an MTN line must first register, hence everyone who is using an MTN line has already provided a copy of their identification ID and given Facial photo while registering, Therefore MTN has a copy of your ID, and your photo (the photo they take on registration).

Possible policy arrangements;

the MoMo terms and conditions are clear and it’s available online at the MTN South Suan website

MoMo has a flexible registration method, for old-school aunties and uncles; you could visit MTN Customer Service Point, or a nearby authorized Agent, however for the Dot.Coms you can register by yourself by dailing star 200 Hash, and open your ”MTN Account or Account” which means an account activated in your name on the MTN System upon completion of the registration;

Now based on MoMo’s T&C’s there are several requirements including ”verifications IDs”. (you can read these requirements on MTN’s website).

Using MTN’s system

Since MTN and MoMo, are integrated it is most likely that they share the MTN services which includes all the products and services provided by MTN to its customers including ,….. ”updating Customer Account records”.

This grants MoMo access to MTN’s user’s identifications Data, through this policy, MTN systems enable’s MoMo to verify users who are registered, and by default, MoMo should have the ability to suspend services from users whose identification documents are questioned,

The Fraud, and financial irregularities concerns;

with the above data sharing policy (which We think so) the claim of lack of identification requirements is not true, and the concerns of verifying users, and combating frauds and fraudsters shall be achieved!

Data sharing Concerns;

It appears that MTN systems have automatically extended consumers data which was collected for registration purposes to enable MoMo services almost instantly, Hence a user could just register and MoMo gets the data automatically from MTN, and MoMo does not need to request such data, neither does it have to acquire identification data from the subscriber because MoMo’s Mother MTN has generously provided such identification data to its baby in advance.

Is this il/legal? Should we allow this? Is it alarming? Should we be worried? Do we have a law, legislation, or policy that protects, governs, or regulates the collections and use of personal data! We provide legal opinions on demand.


The claim that MoMo does not require Users Identification data, as such may be alarming is not true, as MoMo’s T&C provides for such requirements, and the MTN system, and services further grants and enables MoMo to retrieve data within MTN systems for such purposes,

it is also good to highlight that MoMo’s T&C’s has provisions that grant it the right to suspend accounts for lack of fulfillment of registration requirements, security enforcement or violations of South Sudanese laws, or for reasons beyond its control, ”we are wondering what these reasons ”out of MoMo’s control might be”

But why MoMo? MTN couldn’t come up with a Better name

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