At the request of the Alliance for Financial Inclusion’s Pacific Islands Working Group (PIWG), the
Pacific Financial Inclusion Programme (PFIP)3 contracted Jonathan Greenacre, a consultant, to analyse
the trust arrangements used by e-money issuers in the following Pacific countries: Fiji, Papua New
Guinea, Samoa, Tonga, and Vanuatu (collectively termed ‘Pacific focus countries’ in this document).
This project was designed to focus upon customer protection mechanisms contained in the trust
arrangements in each country and make recommendations on how to strengthen them. It was a remote
project, and involved liaising with e-money providers and regulators in each country through email and
teleconferences. The regulators included the Reserve Bank of Fiji, the Bank of Papua New Guinea,
Central Bank of Samoa, the National Reserve Bank of Tonga, and the Reserve Bank of Vanuatu. The
relevant e-money issuers were Digicel Fiji, Digicel Vanuatu, Digicel Samoa, Digicel Tonga, Digicel
PNG, Vodafone Fiji, and Post PNG.
The project was undertaken in two separate stages: June-September 2012 and January-March 2013. This
Knowledge Product and the Model Trust Deed come from insights obtained from both stages of the