I didn't know that the US Department of State pay good money for people with complex names like the Bureau of International Narcotics and Law Enforcement Affairs to produce reports like the International Narcotics Control Strategy Report (the INCSR). I cannot comment on the rest of the report, but the section that talks about "mobile payments - a growing threat" triggered my interest and I read it with attention.
I must say that the sentiments expressed and the conclusions reached is so far removed from the practices or the intention of the mobile payment and remittance industry. Very few of the statements regarding risks and lack of controls have been verified or tested against the existing practices employed by mobile payment vendors. Compliments to the authors for publishing the report on the Internet. (Read it here). Unfortunately, I could not find any feedback mechanism that would have enabled me to communicate with the authors in order to rectify many of the inaccuracies.
In practice, great care is taken to ensure that subscribers are enrolled with proper KYC compliance. The implications of the Patriot act and FinCEN are carefully researched and deployed to ensure compliance. Most of the vendors in the industry (and I know most) have a genuine intent to build an accessible electronic financial infrastructure for the poor, but that will also eliminate (and block) the actions of criminals and terrorists. These vendors work with the Worldbank and associated agencies (like CGAP) and reputable banks and other financial organisations to try and build well-governed solutions to the massive problem of the poor that is effectively eliminated from modern financial services.
The statements in the report not only harm the delivery of financial services worldwide, but also delay the deployment of electronic tools that would enable legit agencies to monitor transactions and to identify fraudulent and illegal activities. I would like to urge the author of the above report to contact representatives from the mobile payment industry so as to clarify mis-understandings, but also to assist the industry to build better (for all) financial instruments.