In March 2019 we took a look at the then recently reintroduced Bureaux de change business and the requirements for setting one up. A full three years plus later we note that BDCs have indeed survived and are thriving as part of the Zimbabwean financial landscape. They say change is a constant and in Zimbabwe’s monetary space this is very easy to see. There have been some changes introduced to the rules and regulations, especially with foreign currency. 3 years later is as good a time as any to update what it takes to start bureaux de change business.

Bureaux de change

A BDC is an authorised limited dealer according to the Exchange control statutory instrument 104 of 2015, section 7. BDCs are tier 3 dealers defined as locally incorporated financial services providers which only buy and sell foreign currency on a spot basis. All BDC licences shall expire on the 31st of December each year and must be renewed by the 31st of January each following year.

Documentation

When submitting an application form for BDC licencing you will also need to submit quite a few things. The details of the company include a certificate of incorporation, memorandum of association, articles of association and the shareholder’s register (CR14). These must also be accompanied by a full business plan with 5-year projections for growth and profitability. This must include a risk management and risk mitigation plan. You will also have to obtain an anti-money laundering certificate or endorsement from the RBZ’s Financial Intelligence Unit. There’s more. You will need to submit the CVs of all board members, management and officers of the BDC as well as Police clearances. A register of all the natural person beneficiaries of the BDC business must also be submitted. Finally, your business plan must include both an organisational structure with roles and members as well as show the ability to implement an adequate IT system to process and record all transactions. Responses are sent out within 30 days of the lodgement of the application.

Capital requirements and fees

Capital requirements for tier 3 authorised dealers are at US$15000. This is the initial capital requirement for the business and does not include branch licencing fees. As of the December 2019 exchange control circular addressing BDCs, licencing fees were as follows.

So when applying for licencing and renewal the application shall include the main licence and each branch as per the fee schedule.

Other requirements

The licencing process also involves an inspection of the premises. In this process, the bank will send inspectors to the branches to examine them. They will need to see the implementation of the aforementioned computer system and measures to detect counterfeit currency as well. This includes looking at the operational procedures and methods used in the business.

Operational modalities

Exchange control circular number 1 of 2022 clipped the wings of BDCs in terms of what business they could process. While BDCs are still allowed to buy foreign currency adhering to KYC principles they were limited in terms of the persons and purposes they could sell foreign currency to and for. At present they are only allowed to sell foreign currency to pensioners, senior citizens, people living with disabilities and those requiring foreign currency for medical purposes. Zimbabweans are now allowed to purchase foreign currency in banks and BDCs can sell to the aforementioned groups. BDCs will be required to issue foreign currency receipts to all customers and keep photocopies of their identity documents and proof of status to show they qualify as one of the aforementioned persons. Transactions will now be done at the willing buyer willing seller interbank rate according to the Monetary Policy statement of February 2022.

Violations

Not much has changed in this section but it is worth restating. 14 violations will lead to the revocation of a BDC licence which includes multiple ownership of BDCs, members sitting on multiple BDC boards, failure to submit returns, accessing foreign currency from sources outside the legal channels, misrepresentation during the application process and members or shareholders being found guilty in a court of law for fraudulent or dishonest practices. Other lesser offences attract fines and possible suspension while the Financial Intelligence Unit carries out investigations.

We posed a question when BDCs were readmitted to the Zimbabwean financial arena which was how many would register under the new rules and framework. According to the last update from the RBZ (April 2021), 74 licensed BDC were operating 709 branches across Zimbabwe.