Experience / Case study
Licensing Visa in Somalia.
CAPABILITY
Financial Services
CLIENT
Visa — two related entities
SETTING
The first year of Somalia's rebuilt payments regime
STATUS
Engagement concluded
THE SITUATION
Somalia pays by phone — roughly three in four adults use mobile money. In 2025, the law finally caught up with the market.
A revised Financial Institutions Law and a new AML/CFT Law arrived in May 2025. The Central Bank was running licensing rounds across banking, money transfer, microfinance and takaful. A national instant-payment system — built on ISO 20022, designed to connect fourteen banks and eight mobile-money providers — had launched in January. Into that window, one of the world's largest payment networks moved to establish its Somali position through issuing partnerships with local banks. Two related entities. One regulatory strategy. A statute book that was weeks old.
WHAT WE DID
First, the perimeter.
The threshold question for a scheme operator that never touches a Somali consumer directly: which activities require licensing or registration with the Central Bank, in which category, for which entity? We answered it for both entities separately — what they needed, as distinct from what their Somali partner banks already held. Category errors in a new regime are expensive in both directions.
Then, the compliance spine.
The 2025 AML/CFT law is the framework international compliance teams are assessed against — and the area where the regulator most wants to demonstrate progress. We mapped what Somali law actually demanded of the network's own arrangements, as distinct from its partners', so the global programme could grow its Somalia annex before the applications, not after.
Then, the regime as applied.
The work ran on as the regime itself developed — payment-system requirements under the Central Bank's rules, read with the firm's working knowledge of how this regulator reads its own statutes. The client got the difference between the law as written and the regime as applied, in time to act on it.
THE OUTCOME
A market entry that would have been routine in Nairobi or Dubai had no precedent in Mogadishu — and it was executed in the regime's first year, across two entities, without a category error. The firm that advised it now carries that regime in working memory for every bank, network and fintech that follows.
The team — Abdirizak Mustaf Ahmed (lead) · Mohamed Abdulkadir Ali
The rules were weeks old. Somebody had to read them first — properly, for a client who could not afford a guess.
WHY THIS MATTERS TO YOU
If you are a bank, a payment company, a fintech or the counsel behind one, your Somalia questions land on the desk that handled one of the defining entries of the new regime's first year. The perimeter analysis, the AML/CFT mapping, the regulator's habits — already in the building.
Discuss a payments or licensing matter