MoMo Agents And Agent Banking In Ghana: How Float Works (2026)

Walk into any trotro station, market or junction in Ghana and you will find a table, an umbrella and a laminated sign. The person behind it takes your cash and turns it into mobile money, or takes your mobile money and hands you cash. Roughly the same thing happens at a shop acting for a bank. Most Ghanaians use these agents several times a month without ever asking the two questions that matter: whose money is on that table, and who pays if something goes wrong.

The answers are written down. The Payment Systems and Services Act, 2019 (Act 987) devotes fourteen sections to agents, and the Bank of Ghana and Financial Intelligence Centre issued AML/CFT/CPF Agency Banking Guidelines in September 2025 that tighten how principals must supervise them. Between the two, an agent has far less freedom than the sign outside suggests — and you have far more protection than most people realise.

An agent is not a bank, and that is the point

Act 987 defines an agent as a person who provides agency services to customers on behalf of a principal under an agency agreement. The principal is the licensed institution — a bank, a specialised deposit-taking institution, a payment service provider or an electronic money issuer — whose services are actually being delivered. MTN MoMo, Telecel Cash and AT Money are principals. The person at the table is not.

That distinction is deliberate, and section 91(4) enforces it: an agent or master-agent of a bank or SDI shall not brand itself as a bank or a specialised deposit-taking institution. Contravening that carries an administrative penalty of one thousand penalty units. So a kiosk may display its principal's colours and name, but it may not present itself as the bank. If a shopfront in your area is styled to look like a licensed bank branch when it is really an agent point, that is not a cosmetic problem — it is a breach.

The definitions section also gives us the phrase you will hear at the counter. An over-the-counter transaction is one conducted without the customer making use of the customer's own account — you hand over cash and the agent sends it from their own wallet. That is legally a different animal from a transfer you initiate on your own phone, and it is treated differently for identification purposes, as we will see.

Float: why the agent sometimes has no cash

Here is the mechanic almost nobody explains. Section 87(d) of Act 987 requires that every agency agreement specify that electronic money agents shall operate against pre-funded accounts only. An agent cannot create value. They can only swap between two buckets they have already paid for:

• E-float — electronic money the agent bought in advance from the principal and holds in their own agent wallet.
• Cash — physical cedi notes in the drawer.

When you cash in (deposit ₵500 to your wallet), the agent's e-float falls by ₵500 and their cash rises by ₵500. When you cash out, the reverse happens. Every transaction the agent does moves them along a see-saw, and one side eventually hits the floor.

That is why the answer is so often "the network is fine, but I don't have cash." It usually is not a lie and rarely a scam. In a neighbourhood where most people are cashing out — around payday, at month end, on market day, or in a rural area where more money arrives than leaves — agents drain their notes and end the day sitting on e-float they cannot convert until they visit a bank or a master-agent to rebalance. In a market district where traders deposit takings all afternoon, the opposite happens and the agent runs out of e-float instead.

Two practical consequences follow. First, a refusal to serve you is frequently a liquidity problem at that one table, so walking two streets over genuinely works. Second — and this is the part that costs people money — an agent who is short of cash has an incentive to offer you a workaround. That workaround is usually illegal, and the next two sections explain why.

Where your money actually sits while it is in a wallet

Your wallet balance is not notes in a vault at the telco. Act 987 requires that a dedicated electronic money issuer keep one hundred per cent of the electronic money float in liquid assets (section 36(1)). Those assets must be unencumbered, and may be cash balances held with a bank in the country and withdrawable on demand, or another liquid asset the Bank of Ghana determines. Section 36(3) requires the issuer to hold those balances separately from anything relating to its other operations.

Section 37 goes further, under the heading Fund isolation requirements. The electronic money account of every issuer must not be commingled at any time with the funds of any person other than the e-money holder on whose behalf the funds are held, and must be held in individual or pooled accounts with one or more banks in Ghana. The Bank of Ghana also caps how much of one issuer's e-money balance may sit with any single bank.

And it is checked daily. Section 36(6) requires a dedicated e-money issuer to reconcile the previous day's liquid assets against the e-money value held by customers, agents and merchants on its platform, every day, at a time set by the Bank of Ghana — and to rectify any shortfall. In plain terms: for every cedi of MoMo in circulation there is supposed to be a cedi sitting in a ring-fenced bank account, counted every morning.

That is a strong protection, but it is a different protection from the one covering a bank account. Whether wallet balances fall inside the Ghana Deposit Protection Corporation's scheme is a separate question from fund isolation, so read our guide to deposit protection in Ghana and confirm your own position with your provider before you decide how much to leave sitting in a wallet rather than in a savings account. If you are choosing where to keep balances you do not need this week, our guide to choosing a bank account and the savings calculator are the better starting point.

What an agent may do — and the list they may never touch

Section 90 sets out what an agent may do for a principal: market credit, savings, investment and insurance products; receive, verify and forward applications for those products to a bank or SDI; receive and forward applications for payment cards, account opening and cheque books; deliver mail to customers; and anything else the Bank of Ghana authorises.

Section 91(1) is the list that matters more, because it is the list of things an agent must never do:

• appraise any credit or insurance application, or approve an application for credit, insurance or investment products;
• cash bank cheques;
• undertake any form of foreign exchange transaction;
• make an advance payment from funds still to be released by the principal;
• give any type of guarantee in a transaction the agent facilitates.

Read that third one again. An agent point is not a forex bureau. If someone at a MoMo table offers to change your dollars, pounds or CFA francs "at a better rate", they are performing an act the statute forbids them, whatever the rate looks like. And the fourth one rules out the common "I'll send it now and you pay me tomorrow" arrangement — an agent advancing funds against money the principal has not released is outside the law, and you have no recourse when it unravels.

Section 91(2)(c) adds a rule worth memorising: an agent shall not conduct an electronic money transaction when there is communication failure or when the issuance of a physical or electronic receipt is not possible. No network, no receipt, no transaction. If an agent says the system is down but offers to "record it in the book and push it later", the correct response is to take your cash and leave. That written note has no legal standing, and the transaction that was supposed to back it was prohibited before it started.

Agents cannot charge you their own fee

This is the most commonly broken rule in Ghana and the easiest one to enforce, because it appears twice.

Section 91(2)(b) says an agent shall not directly charge a customer a fee beyond the standard fee prescribed by the principal. Section 88(b) attacks the same problem from the other end, obliging the principal to prohibit an agent from charging any additional fee to an e-money user or payment service customer beyond the fees prescribed and advertised by the principal. Parliament clearly expected this to happen, because section 86(3)(k) requires an institution applying to run an agent network to file a policy document explaining how it will address the risk of its agents overselling or overcharging — and section 102 defines overselling as promising a customer gains a product may not deliver.

So the ₵2 "small something" on top of the tariff, the deduction from the cash handed back, the higher charge because it is late or because the agent is short — none of that is a grey area. The tariff belongs to MTN, Telecel or AT. The agent's income is the commission the principal pays them, which is why section 93 makes a principal disclose the whole agent fee and revenue-sharing structure to the Bank of Ghana when appointing a master-agent.

Two things help you here. Know the published tariff before you walk up — our guide to reducing your mobile money charges sets out where the real costs sit, and note that advice written before the E-Levy was repealed is now wrong, so check the date on anything you read. Then check the SMS confirmation against the cash in your hand before you leave the table. An overcharge is a complaint against the principal, not a private disagreement with the agent.

Your ID, your record, and the SIM-swap freeze

The September 2025 AML guidelines are blunt about paperwork. Under §5.4.2, a principal must put in place processes for agents to collect and maintain the ID number, name, phone number, address and signature of third-party customers in relation to cash deposits and withdrawals. Under §5.2.2, agents must have systems to identify and verify all customers, screen them, and comply with the Bank of Ghana's Ghana Card Directive — the Ghana Card being the ECOWAS identity card issued by the National Identification Authority.

Act 987 lists the identification types acceptable for customer due diligence in section 35(1): the National Identification Card, Voter ID, Driver's Licence, NHIS card, Passport, biometrics, or another type the Bank of Ghana determines. For over-the-counter transactions specifically, the Second Schedule adds an unusual rule — a customer who cannot present acceptable identification must be introduced by a customer who has acceptable identification.

So being asked for ID at an agent point is not the agent being difficult, and an agent who never asks is the one to worry about. It is also worth knowing that section 34(4) requires issuers to keep records of every transaction for a minimum of six years, and section 87(i) requires agents' records to be moved to the principal and kept for at least six years there too. If you need to prove something happened at a table in 2026, the record exists.

One protection is almost unknown and genuinely valuable. Section 34(3) requires a payment service provider or e-money issuer to deactivate your e-money account for two days when you swap or replace your SIM card, and to re-activate it only after you present valid identification. That two-day freeze is the statutory answer to SIM-swap fraud. If your line suddenly goes dead and you did not request a swap, treat it as an attack on your wallet and contact your provider immediately — the clock has already started.

How to check the agent in front of you is real

Five checks, all grounded in enforceable rules:

1. Look for the agent's unique identification, displayed at the location. Section 92(1) requires a principal to give the Bank of Ghana the agent's name, business registration number, physical location, GPS co-ordinates, telephone numbers, the services offered and the transaction limits — within thirty days of appointment, with changes notified within ten days. A genuine agent is a registered entity, not an anonymous table.
2. Check the principal's website. The 2025 AML guidelines, §5.4.6, require a principal to have on its website the list of approved agents. This is the single most useful consumer check in Ghanaian agency banking and almost nobody uses it.
3. Watch for bank branding. Section 91(4) forbids an agent from branding itself as a bank or SDI.
4. Insist on the receipt. Section 91(2)(c) makes the transaction improper without one.
5. Notice if a familiar agent disappears. When an agency agreement is terminated, section 96(2) requires the principal to publish a notice of the termination in the locality where the agent operated and inform the Bank of Ghana within ten days. Section 96(1) makes termination mandatory where an agent is convicted of an offence involving fraud, dishonesty or other financial impropriety, is wound up or declared insolvent, or relocates or ceases to operate at the place of business without the principal's prior written consent. An agent who has quietly moved to a new spot may no longer be an agent at all.

The vetting happens before that. Section 89 requires a principal to consider a prospective agent's criminal record in matters relating to finance, fraud, honesty or integrity, and negative information at credit reference bureaus, before signing. A master-agent must not have been classified as a non-performing borrower in the twelve months before application, and must keep that clean status for the whole contract. If you have ever wondered why your own record matters, the same infrastructure sits behind checking your credit score, and behind spotting an unlicensed lender operating out of a similar-looking kiosk.

When it goes wrong, the principal is liable — not the agent

This is the most important paragraph in the article, and it is the one people get wrong most often.

Section 87(b) of Act 987 requires every agency agreement to specify that the principal is responsible and liable for the actions or omissions of an agent providing services on its behalf — and, in the Act's own words, this holds even if the action has not been authorised in the agreement, as long as it relates to the agency business. Section 95(2) repeats the principle for customer due diligence: liability for an agent's non-compliance rests with the principal. The September 2025 guidelines put the same duty on the institution's Board and Management, which are made responsible for AML/CFT/CPF enforcement and compliance of their agents (§5.1.1).

So when an agent takes your ₵1,000 and it never lands, "the agent has run away" is not a defence available to MTN, Telecel, AT or a bank. The claim is against the principal. Complain to the principal's customer service first, in writing, quoting the transaction reference and the agent's location — the principal is required to have visited that outlet within the last six months (§5.4.5) and to have processes requiring the agent to report fraud and suspicious activity to it within twenty-four hours of occurrence (§5.3.2). If the principal does not resolve it, escalate to the Bank of Ghana, which under section 97 may inspect an agent's books and premises, direct an agent to act or desist, and direct a principal to terminate the agency agreement outright.

The Bank of Ghana has also consulted on a draft disclosure and transparency framework for payment service providers that would, among other things, require fees to be displayed at agents' locations and make undisclosed fees refundable. That document is published as an exposure draft and is not in force, so do not rely on it — but it signals the direction of travel.

One agent, three networks: why that is legal

Newcomers often assume an agent serving MTN MoMo, Telecel Cash and AT Money from the same table must be doing something irregular. The opposite is true. Section 94 of Act 987 is headed Agent exclusivity and says plainly that a principal shall not sign an exclusive agreement with an agent or master-agent, and that an agent may enter into an agreement with more than one principal. Section 91(3) confirms an agent may serve multiple principals provided there is a separate agency agreement with each.

Ghana chose this deliberately, as part of the shift away from the old branchless banking regime — the 2015 e-money and agent guidelines that preceded Act 987 expressly revoked the many-to-many model requirement of the 2008 branchless banking notice. Non-exclusivity is what lets one kiosk in a small town serve every network, and it is why competition between networks reaches places a branch never would. It also means that if one network's agent is out of float, the same person may be able to serve you on another.

For businesses, this same agency framework is what allows a shop to earn commission as a service point alongside its main trade — worth understanding if you are registering a business in Ghana and thinking about revenue lines, or comparing formal options on our money transfer comparison and in the guide to sending money to Ghana.

Frequently asked questions

Is an agent allowed to charge me extra for a withdrawal? No. Section 91(2)(b) of Act 987 forbids an agent from directly charging a customer a fee beyond the standard fee prescribed by the principal, and section 88(b) requires the principal to prohibit it. The agent is paid a commission by the principal. Any extra charge is a complaint against MTN, Telecel, AT or the bank concerned — not a negotiation with the agent.

The agent says there is no network but offers to record my transaction and send it later. Should I agree? No. Section 91(2)(c) specifically prohibits an agent from conducting an electronic money transaction when there is a communication failure or when a physical or electronic receipt cannot be issued. Take your cash and use another agent.

Why does the agent keep asking for my Ghana Card for a simple deposit? Because the rules require it. The September 2025 BoG/FIC Agency Banking Guidelines (§5.4.2) require principals to have processes for agents to collect and maintain your ID number, name, phone number, address and signature for cash deposits and withdrawals, and §5.2.2 requires agents to comply with the Ghana Card Directive. For over-the-counter transactions, Act 987's Second Schedule requires a customer without acceptable identification to be introduced by one who has it.

An agent took my money and it never arrived. Who do I claim from? The principal. Section 87(b) of Act 987 requires the agency agreement to make the principal responsible and liable for the actions or omissions of its agent, even where the action was not authorised in the agreement, provided it relates to the agency business. Complain in writing to the principal with the transaction reference and the agent's location, and escalate to the Bank of Ghana if it is not resolved.

Can an agent change my dollars or euros while I am there? No. Section 91(1)(d) lists undertaking any form of foreign exchange transaction among the activities an agent shall not perform. Use a licensed forex bureau or a bank.

How much can I send or hold in a wallet? Act 987's First Schedule creates four account types — Minimum, Medium and Enhanced Know Your Customer accounts, plus a Merchant account — but it does not fix any cedi amount. Every balance, daily and monthly limit is expressly "determined by the Bank of Ghana", and the same is true of over-the-counter limits under the Second Schedule. Confirm the current limits with your provider or the Bank of Ghana rather than relying on a figure quoted online.

For more on managing money day to day in Ghana, start with our complete guide to managing money, or browse the latest guides on the blog.

Reviewed 28 August 2026. Sources: Payment Systems and Services Act, 2019 (Act 987); Bank of Ghana and Financial Intelligence Centre AML/CFT/CPF Agency Banking Guidelines, September 2025; Bank of Ghana Notice No. BG/GOV/SEC/2015/09.

This article is general information about how agency banking and mobile money agents are regulated in Ghana. It is not financial advice, and it does not take account of your personal circumstances. Rules and limits change — confirm current transaction limits and tariffs with your provider or the Bank of Ghana before acting.