Chea Serey, assistant governor and director general of the National Bank of Cambodia discusses the development of the newly launched Bakong payment system, the first in the world to be
The official launch of Bakong payment system on 28 October 2020 provides a common platform for commercial banks, microfinance institutions (MFIs) and payment service providers (PSPs) in Cambodia to deliver e-wallet and money transfer services to consumers to transact with businesses and each other without the need for a bank account. Built on the Hyperledger Iroha closed-loop permissioned based distributed ledger technology (DLT), it is a mobile app-enabled payment system that facilitates peer-to-peer and quick response (QR) code transactions in real-time and round the clock, through open APIs (application programming interfaces).
Chea Serey, assistant governor and director general of the National Bank of Cambodia (NBC) was adamant to clarify that although the system is built on DLT, it is not a central bank digital currency (CBDC) that some may be quick to assume. Instead, the platform augments the existing Fast and Secure Transfer (FAST), real-time retail payment system and Cambodian Shared Switch (CSS) that facilitate mainly interbank transactions among commercial banks and MFIs. They were launched respectively in 2016 and 2017 and are Cambodian riel (KHR) and US dollar account-based systems that do not interoperate with the twenty or so PSPs that serve mainly the unbanked.
FAST and CSS member institutions have also been slow to introduce mobile and internet interfaces for customers to access their services hence limiting usage. With the launch of Bakong, banks, MFIs and PSPs have a ready-made universal mobile app interface to connect users with FAST, CSS and each other. The KHR-based system will also promote financial inclusion and use of the national currency in the hitherto highly dollarised economy.
In this interview recorded on 10 Novemer 2020, assistant governor Serey discussed with Emmanuel Daniel, NBC’s role in providing a common infrastructure in an otherwise noisy and fragmented payment marketplace, its key objective to drive interoperability, foster competition as well as to provide affordable and inclusive financial services to the country’s large unbanked population.
The key points covered in the discussion were:
Here is the edited full transcript of the session:
Emmanuel Daniel (ED): The payments industry worldwide is undergoing tremendous activity, although we should not be in a hurry to call any of them specific trends that are going to define the future of payments. We have at the wholesale level central bank digital currencies, which are still work in progress in a number of parts of the world, by the way and some of which have already undergone pilot schemes from which we do need to make some preliminary conclusions. And then at the retail and at the financial inclusion layer, you have M-pesa, you've got a number of different peer-to-peer platforms. And today's interview is focused specifically with the assistant governor of the National Bank of Cambodia, Chea Serey, on her pet project, which is Bakong, which she describes as being a peer to peer platform In order to appreciate this interview, you need to understand a couple of things about Cambodia. Firstly, it is a crowded market, despite being a small and developing market. It's a market with 50 banks. almost anyone who wants a banking licence and who can afford the capitalisation required, can get a banking licence. And then you have microfinance institutions, a couple of them actually being global best practice as microfinance players. And then you have about 20 payment systems providers who already dominate the payments infrastructure in Cambodia. And it's also a market where two currencies sort of vie for legitimacy, the US dollar, and the domestic riel. You need to have all of these at the back of your mind, as you listen to how Chea Serey describes the development of the payment infrastructure in Cambodia.
Solving the problems of a fragmented and disconnected payments market
This is probably one of the first times I think we're going to have you describe the project for people outside of Cambodia. Give us a landscape of the payments landscape and then put in context the Bakong story.
Chea Serey (CS): If you already have something that is stable and efficient, you wouldn't want to disturb with something new and untested. And that's really what a lot of country asked why is it that Cambodia like small country is launching this ahead of some of the developing countries who already have been doing a lot of studies on this. And my answer is that's because we have something that is going on well, and so bringing in, a project like Bakong, in the best case scenario would help. And if not, then we can easily put it off without disturbing anything that is going on in the market. Also, in terms of our whole financial sector landscape, it's quite fragmented. And we have the banking sector where they're doing pretty much anything or everything. And then we've got 70-80 microfinance institutions, and the small microfinance can lend but they can't take deposit. And then we've got the payment service providers, they are about 20. They can only provide payment instrument to the users. They can't take deposit, all the wallet float that they collected, and need to be deposited in financial institutions are 100% guaranteed. So they can't use that wallet, float to do lending or anything else. In 2019, we had the first payment service provider in the country, and it was Wing and what was well known back then was M-Pesa in Kenya. And when Wing was introduced in the country, it was in sort of like an experimental project was launched by the Australian ANZ Group and the idea is to promote financial inclusion through this kind of services. I am trying to emulate M-Pesa, in a way, and I think the first reaction from the regulators at the time, I worked with the Banking Supervision. And my reaction was that, well, if you're taking money from the public, you are a bank and you need to be regulated as such. So we come up with a tiered regulation. Initially, we allowed this company to operate with 100% guaranteed by licensed bank. Because the idea is that we don't understand this animal. But we know it's going to do good for the industry. And we asked banks to regulate or, on our behalf, to sort of manage the risk of these payments service provider. And eventually we come up with a licensing criteria and licensed these payment service providers independently from the banks. And these payments service provider then bloom in the country. Many more came and got their licences, and it actually was quite widespread and people were very interested in that. It usually operates through mobile phone. And mobile phone penetration in Cambodia is already very high compared to the population. We have about 21 million mobile phone subscription for a population of about 16.5. It was actually a very good medium for people to access for more financial services. They go through this payment service provider to send money from their urban area to the rural area. Where any small shop can act as a cash disbursement centre for these payments service providers.
Different sort of institutions operate independently from each other. For banks that have mobile banking app, it would usually be for their own customer base. And if you want to do a cross institution money transfer, you have to have a bilateral agreement with the other institution. So privately, they will go and negotiate the terms and conditions, then only their customer can send money across.
And what the National Bank of Cambodia first introduced was a FAST system, which allowed an account to account money transfer. This was in a basic infrastructure, meant for banks, trying to connect account to account cross institution, so every bank will just have to connect to the central bank FAST system. It's a centralised system, and then they don't have to do bilateral negotiations. And then their customers can do account to account transfer, regardless of the institution of the beneficiaries, the beneficiary bank with. Then what we realised is that we made it happen for banks, but we were actually excluding the payment service provider because they didn't have bank account, per se, they were holding wallet, but those are not bank account. So there's a disconnect between the bank and the payment service provider, but also a disconnect between urban and rural. And the idea behind our project is how can we connect them together, And we were exploring different infrastructures, and then bearing in mind that we don't have at the moment in Cambodia an RTGS (real time gross settlement) system yet. We were also taking into account the fact that when we first launched Fast System, which is the basic infrastructure for bank to connect with each other, was real time for customers, although the banks will have to wait for the settlement agreement two times a day. And what we realised was that the banks will have to provide a convenient user interface by creating a mobile app for their users to do those kinds of transactions. And what happened is that the banks didn't do that. So as a customer, if I wanted to do to transfer money to somebody else, I will still have to walk to the bank counter and perform that transaction. And even though it's real-time, it was inconvenient. We realise that we needed a universal app that everyone can adopt. Because we can't wait on banks to do that, because I can provide many infrastructures, but then if the user interface is not there, then it's not going to work.
ED: For interbank transfer, you have Fast, which, incidentally is in local currency? But a lot of the economy is also dollar based. Do you have an interbank clearing system, for dollar?
CS: We have US dollars interbank clearing system sitting at the central bank. The Fast system allow only for local currency. And what we were trying to do is to differentiate convenience, it's all about convenience. If people find that transacting in local currencies more convenient to US dollars, then perhaps they would switch to use more local currency. And it didn't happen,
ED: As you build the back end for the interbank you also trying to solve the problem of the back end for the interbank and the payment system players? Why is that the central bank's job? Shouldn't it be that the connectivity between the different payment system players should be negotiating on their own with their respective banks or something like that.
CS: It's a good thing that you have a women at the helm, I've been looking at it as a parent, taking care of their children. And obviously, you want your children to be independent and do things on their own. And if it's not happening, you need a bit of push. And that's exactly what happened with the system in the industry. We have dialogue with them. We said, look, we have Fast system, why are you not using it? Why are you not facilitating the end users with mobile applications? And of course they will come to you with a lot of excuses. When we announced that we're going to do this project, we call the industry and we explained to them, that we're going to do this, and this is how it's going to work and we need your support. And that's when the banking industry realised that they need to be doing something otherwise the regulator will be doing everything. And in a way, it's kind of help but the intention is not really to compete with the private sector, but to tell them that this is something that you need to be doing, innovation and also stimulate some of innovations in in the industry.
And what we had done was to actually bring connect the payment service provider into the Fast system. And as there are some technical issues and some regulatory barriers as well. One is that we have to identify an account, not wallet. And there's going to be quite a challenge for us to reconcile that together. Second is that when if I were to include the PSPs into the clearinghouse of the fast system, it means that the payment service provider will have to follow the liquidity management rules of a bank. Because we don't have an RTGS system, banks have a settlement account with the central bank, they have to monitor it on a daily basis, they have to have credit line with the central bank, just for the settlement purposes. If I were to do this with a PSP, then I would have to require them to have the same level of liquidity management as I would require from a bank. And that's when the Bakong project came about where it's a peer-to-peer, so I don't have to worry about PSP managing their settlement account. And they, if they want a customer to use, they just have to have enough balance, and the customer can only send if they have balance on their wallet themselves. In a way that takes away all these regulatory challenges.
Clearly differentiated roles of commercial banks, multifinance institutions and payment service providers
ED: The thing that is that needs to be captured in this conversation is that the ambitions of the PSPs. Were they trying to become banks eventually? Which direction were they going into? Were they going into financial services? Or were they going into platforms as a business? What was the evil that you were dealing with? And also what you're saying is that Bakong becomes a wallet in itself. Doesn't that get into competition with all the other wallets? That means it sort of ends the wallet game, once and for all.
CS: And so firstly, your question is what are the ambition of the PSPs, and I don't know what their ambitions are. But the rules were clear. You can become a bank if you provide three services combined, so deposit taking, any form of credit and provision of a payment instrument and the processing of that set payment instrument. We designed a licence in such a way that payment service providers would only keep doing the payment part. And they can't do credit. And that's why when I mentioned about the float of the wallet, the balance that they collect from the customer must be deposited in a bank account. And 100% of it must stay there. They can't use it for lending purposes.
And then banks are the one who are doing intermediaries of this money. We make sure that these wallet balances, don't get any interest and that's to make people understand that their wallet is not savings. But in terms of payment, there are many things which they can do. Of course, they can help microfinance institutions to collect. It's just not money transfer.
ED: So you have restricted their business to only the fee on the transfers that they make. I don't know if that makes it less interesting for them, or even commercially viable. Can all of these payment players onboard Bakong on to their respective apps?
CS: Yes, definitely they all can. And it would actually force them to compete with each other in a much more meaningful way. It's not just customer acquisition, because ultimately any customer can send money to your customer. You can't restrict it anymore, when you have a Bakong account. And I think the competition would then be focused on the quality of the services, the affordability and the options of services that you can offer. And I think from that perspective, it will be much better for the end users. In terms of the central bank or Bakong project competing with the payment service providers, there are many options. And I think a lot of the time the public confused that Bakong is just a wallet. But we mentioned in our white paper, that it's a backbone payment system and the wallet is not the ultimate service. This is more like a bit of it.
Bakong is 24 by 7, real-time infrastructure that offers a universal mobile app interface
ED: You say backbone service, but you have several backbone services, you've got Fast, you've got the national clearing system and then you've got Bakong. And I think recently, you're introducing something called Retail Pay.
You describe Bakong as an infrastructure, you have several infrastructures, so which aspect of the infrastructure does Bakong play?
CS: A lot of the existing infrastructures that we're having, except for Fast, it's not a 24 by 7, Retail Pay is not a 24 by 7 infrastructure. And there's a limited time to it. But Bakong in particular, can complement the 24 by 7 part because it's peer to peer, it doesn't need any clearing and settlement from the central bank path. Second, is that the other infrastructures that we had in place, the payment service provider, were not included. It's was specifically designed for the banking system and Bakong is the one that link everyone together. The Retail Pay that we are going to launch is an enhancement of the existing Fast System. A bank could use Fast system where the amount can go higher. So it's not really a gross settlement, but the cap is higher than if it were to be transacted through the Bakong system. Also because Bakong provides a universal app, banks that don't have existing mobile application for their users, especially smaller banks, can actually free ride on ours, and have their customer use that.
Once the banks are integrating with the Bakong system. For me as the end user, it doesn't matter if the transfer is through Bakong or Fast. What we bring along with Bakong is also a standardised QR code, where every bank’s app in the country can read each other’s.
ED: You think Bakong is being described outside of Cambodia as the central bank digital currency. Is it a central bank digital currency already? Or is it just an account and accounting system at the moment?
Bakong is not a central bank digital currency although it is built on DLT
CS: I never described this project as a central bank, digital currency. I always described in many of my interviews that it is it is a backbone payment system, using the DLT technology. I mean, technology wise, because it's peer to peer, and is issued by the central bank, therefore people think is central bank digital currency. It is quasi and it's not exactly what a central bank digital currency supposed to be. For instance, it is not a token based, it is account based. We don't gain any seigniorage from issuing it. We're not adding anything new to this.
ED: It's a personal peer to peer account, managed at the central bank. Then the question is, how does the distributed ledger come in, unless it validates peer to peer or something, and also distributed ledger is not well developed yet. So is there a need for that?
CS: What we're using is a closed loop technology. So that's mean, unlike many DLT, where it's really, genuinely distributed, where the public can actually come in and validate the transaction, we can't do that in a financial system. You need some confidentiality, privacy and you need to safeguard the integrity of the system.
ED: So you're giving people who do not have a bank account, some form of identity, some form of confirmation, a non-repudiation of transaction, that's actually what you're providing. But then the million-dollar question is, is DLT even necessary for that?
CS: Personally, I'm not even interested with a DLT or blockchain or whatever you've called it, it doesn't really matter. What matters is I've got something that I want to solve. And this technology happened to be there, and I'm just going to use it and whatever you call it, it doesn't really matter. And going back to your question is that it's a closed loop. So the central bank actually is the one validating all the transaction.
ED: There's already competition on the QR part in Cambodia. In fact, the good news is Cambodia is a bigger user of QR code than many developed countries right now. And there are banks like ABA Bank that have, you know, QR codes, the with the dominate that space. So are you saying that all payment players now have to use the Bakong QR code?
CS: And so I just want to specify that Bakong allow interoperability among the different players in our financial system. When it comes to the QR code, at the moment, different banks have a different payment service provider with their own proprietary QR standard. So if I have, let's say, what you mentioned, ABA, mobile applications, I won't be able to read the QR code of a payment service provider. It probably can read it, but it wouldn't know where the destination is, where are the beneficiaries. What we're trying to do is to bring all these together, and at the end of the day, it's about convenience to the end users. If you want to promote people to come into the system and use the system, you have to make it easy, frictionless and affordable. And that's, that's how you promote the unbanked to come into the banking system. So part of it is, of course, interoperability and make it easy for people to use it. And QR code wasn't the thing that come with Bakong, but I think because we already have Bakong and we thought if we were to add something, may be QR code can be add on Bakong.
ED: Something that a lot of people outside of Cambodia may not appreciate, is the highly competitive and highly entrepreneurial nature of financial services in a small country. You've licensed all these different types of players to give access to a population that is largely rural, and and highly migrant. And on top of that the per-payment amount tends to be small. And you need to build infrastructure that is both ubiquitous and cost efficient. You are a central that is actually creating an infrastructure and saying, this is interoperability, all of you can come on my platform, and then you can play with each other. What will probably result from that is that it will change the landscape of the payment service providers in Cambodia. It might actually consolidate them, only fewer will survive, because their income streams are narrowed. So you'll have one or two, which will scale and then the rest will not. Is that something that you might see as being an inevitable consequence of creating Bakong?
It enables interoperability, allows players to innovate and compete
CS: I think a lot of the payment service provider right now they're betting on building their customer base, the more they bring in, the better it is, because then you preserve that customer base and they'll keep using your service, which is good. But with Bakong coming into play, now, it's not just about building your customer base but you also have to think about the quality and the affordability of your services. I mean, competition is going to be tough for the payment service providers. It's going to be a much more meaningful competition. And it is capitalism, The big fish will eat the smaller ones. That's how it is. The competition is going to be tougher.
ED: When you take the commercial payment platforms, like WeChat, or Alipay, these were funded by venture capital billions of dollars, several years of free service, and marketing and so on and then you build the critical mass. Is that what you see that you need to invest in Bakong in order to be become that? You're a central bank, you may not have thought about the amount of investments needed to make something a platform and isn't that in competition with all the others? And you need to mandate free service, perhaps, or absorb costs, and so on. When you do that you are actually destroying the payments industry’s revenue model. They need to recreate the revenue model from there.
CS: Bakong doesn't exist on its own. It exists on the back of the existing players. So as the National Bank of Cambodia, we don't go on and do advertisement and customer acquisition, these lay with the financial institutions, and a financial institution and the payment service providers embed Bakong into their existing application. We exist in a way through that. In terms of us, destroying the payment service providers, I think by creating interoperability, it shouldn't destroy them, it should actually strengthen them. I'm providing them an access for their existing customer base through everyone else. Let's say if I'm a client of a payment service provider, currently, I can only send money to those who have account with that same payment service provider. Exceptionally, if my service provider has a bilateral agreement with the bank, then I can send to that bank as well. Now, what I'm providing them is an access to any others, customer from any other financial institutions and payment service providers. They should take it as an advantage. Next, I said, what else can you add beyond the transfer? What else can you add for the user, so I will keep staying with you. If it's cheaper, it's more convenient, etc,, I will stay with you. But if it's not, I'll move to somebody else. Because at the end of the day if I'm a company, it doesn't matter where my employee having an account with, I can still do the payroll without having to worry, you know, it has to be the same institution, etc. And again, I stress on the fact that interoperability shouldn't kill competition, competition should use that and make it more meaningful.
ED: You know, this, this whole conversation is fascinating. Because what China is trying to do now is to reverse engineer what you're trying to do on a commercial basis. In China, the platforms had become ubiquitous, they created the national infrastructure, and now the banking system is trying to pull it back in. And the so-called central bank digital currency is to bring the relationship back into the banking system. Now, and what you're doing is you're trying to say that all of the players out there can be as they are. But you're going to start with the banking system, and the central bank owning the the platform, the QR code, the app and the money in the account. And I can't imagine how your approach is going to build without a profound change in the way that payments evolve in Cambodia. You're actually appointing the PSPs to become the marketing agent for Bakong now. In other words, the more they onboard Bakong, then you become successful. Now, the reason I'm asking all these questions, is also because many countries are thinking about the huge dynamics between venture capital funded payments, infrastructure built on an open economy basis, free enterprise and so on and the other diametrically different approach, being central bank centric. And yet the winning formula is acceptability and that people use the infrastructure freely. Just give us a sense of, how successful has it been so far? How do you measure your rollout? How many downloads of the apps have you had, what is the average transaction per day and how many customers you think you have?
Too early to measure success
CS: It's a bit too early to measure that. I think the successful criteria is to have users to be able to send money smoothly to anyone in the whole system, without having to worry. In terms of the downloads, as I said, Bakong doesn't exist on itself. So even if I were to count the number of downloads of the Bakong app, it is unfair to assess the success of Bakong based on that. Because for banks who have embedded Bakong into their application, automatically, that will be counted towards the usage of Bakong as well. So it's not just the app downloads, but the usage of the of the system and the platform. And if we were to count all the member banks in Bakong, I will have to add every of their users to the solo downloads of Bakong. I don't have that number, but it very easily exceeds millions.
ED: Do I assume that Bakong is being funded by Japanese aid money?
CS: It's co-developed by the National Bank of Cambodia and the Japanese company. So we co-own the IP (intellectual property) and everything. It's funded by the central bank.
ED: And then your Retail Pay is with Korean technology company. Do you think that there might be issues there that you might be championing two conflicting technologies?
CS : These are complementary systems. There may be some overlaps that we need to resolve, but definitely it is complementing each other
ED: Why didn't you go all the way and just centralise fiat money anyway and make it digital completely? That would have solved all your problem with the different infrastructure that you need to put in place.
CS: I think nobody knows what could be the end consequences of a CBDC. People are still studying it. And I won't claim that we're the smartest and we found a solution, therefore, we're going to do it first. In our circumstances, there's no use of it. A lot of the question I got asked is that why is it a developing country like Cambodia introduced the CBDC?. All I know is that I've got a problem that I want to solve and this technology is there. Were we specifically targeting DLT hyperledger Iroha? I mean, this technology can provide me with the solutions, and therefore we go along with it. That's the only reason we use it. When you're newer, why don't we just go to CBDC? Legally, we can't hold individual account at the central bank and we need to change the law. As right now, we don't need it. Why would we want to complicate our life with something that you know?
ED: What is your relationship with the telcos in Cambodia? Why couldn't they have been a platform themselves? What's your conversation with them?
CS: Many of the telcos here has their own payment service provider.They're already part of this conversation. And it's interesting, because, I mean, there's argument about, you license the service and not the institutions. And we chose somewhere in between where we license the institution. So if the telco want to do that kind of services, they have to set up a separate entity, specifically doing that. It is better that we work with the payment service providers, because they are directly under our oversight, than we work with a telco who would be under the telco regulator. So it will be very conflicting, and the coordination will be more challenging.
ED: Which countries do you look at for modeling your approach, which countries are most interesting to you as a regulator?
Modelled on Philippines payment system with local adaptations
CS: In 2009, when we first tried to come up with a way to regulate the first payment service provider that was going to be operating in the country, the IFC, the World Bank, assisted us in doing some study visit and there were three countries that were chosen. One was Kenya, which is a very freely operating payment service provider, very little regulation from the central bank. And then a South African country, where it was very strictly regulated. And then we visited the Philippines, which was something in between. And I think we sort of model ourselves towards the Philippines model with a tweak to our own local context.
ED: What are the milestones that you're giving yourself, both for Bakong and payments infrastructure as a whole?
CS: I think, at the end of the day is to have these two systems complementing each other. And the banks are good with credits and deposit. There can be someone who can be very good with a payment service as well, some added services, but they're not really making any money. The payment service providers, on the other hand, are actually making money out of these services, they're actually more innovative in creating value added service, for instance, on payment scoring. So I sit on the Cambodian Credit Bureau, as well as the chairperson. At the moment, we have a credit history, and then we create a scoring out of that. But what if we also add alternative data and have a payment history added to the scoring?
Why not let the payment service provider do what they are doing and do it even better, let the bank do what they're doing better, and help bringing them all together and complement each other. As I said, interoperability, complementarity among the different players, that's really important.
ED: Last question. A lot of the innovations taking place in payments, the excuse given is to reach the unbanked to make finance available to the masses and so on. But the truth is, that, in all of these areas, payments is actually expensive. and the more technology you put into it, the more expensive it becomes. So, a lot of these so-called startups, fintechs and the venture capitalist behind them, they're not looking at making it cheaper, they're looking at making money from it. You are in a country where this is exactly what is happening. Everyone sees payments as a revenue generating business to be pursued not to go out and make life easy for the masses and so on. What is your sense of the commercial aspect of payments?
Venture capital focuses too much on supply side to inflate funding and valuation, not enough on demand side to grow users and drive uage
CS: There is the interoperability path that going to push competition stronger, but what really bothers me is that a lot of the fintech companies are doing really good, and I appreciate that, but a lot would, like you said, use the financial inclusion as a selling point of their product. So you've got a lot of venture capitalists putting money into those projects, with the belief that they're helping the unbanked. And actually, not necessarily, because they're helping the tech company, the founders, the investors, but they're not helping the unbanked So this is the supply part of it, what hasn't been done is on the demand side of it, that is the customer. Nobody invests in educating people about the usage of digital devices, nobody educates the customer, or the user, about financial. So financial literacy, digital literacy, very little investment, you keep pushing this on a supply side, you keep pushing all these products, without considering what is the consequences on the demand side. And at the end of the day, if you're pushing the wrong thing to the people, you're creating risk much bigger than just access. I mean, access is one usage is two. If you access and you misuse it, then the consequences are even worse. It actually takes you a step back to your initial objective. So that's what really upset me is that very few venture capitalists or those development funds goes into the demand side, which is the people who are ultimately benefiting. And money keeps flowing billions and billions of dollars into these tech companies and thinking that it's going to help these people but it's not.
This interview with Chea Serey, the assistant governor of the National Bank of Cambodia has given us an insight on several points. She clarified that Bakong is not a central bank digital currency, despite everything that is being said in media around the world. And perhaps more important that the challenge that she has, is more a business challenge, rather than a technology challenge. Cambodia is a marketplace with more than 20 payment system players. Each of them having invested money and wanting to dominate the payments infrastructure from which a project like Bakong, actually de-commercialises the payment infrastructure because it's being delivered almost free, and so on. And on top of that, it's interesting to see in the near future, how Bakong will evolve if the retail payment infrastructure becomes viable and becomes operational, because Retail Pay network is bank centric, and Bakong is meant to be peer to peer. All countries go through an evolution in their payment infrastructure. The more unbanked a country is, the more ready it is for a Bakong or a M-pesa type platform. And as the country becomes increasingly progressively banked, the population becomes more dependent on a bank centric platform and network and backbone. Cambodia has another problem, which is the fact that it has two operating currencies, the dollar and the domestic riel. And the validation of a platform is also a validation of the more dominant, the more acceptable the more popular currency in operation And it's very unique in that, only a few countries have this as an issue. And on top of that are the players who are delivering on the project and how they will evolve. We know for example, that there is a Japanese company that is trying to put its technology on the ground through the Bakong project and then a Korean company that is working out the Retail Pay platform and how these two initiatives will evolve remains to be seen. At the back of the scene is the political process in Cambodia, where, because it's a growing economy, the political process has opened up the financial infrastructure to any number of players from anywhere in the world who want to contribute to building capital and financial access in Cambodia and without losing momentum on that to build an infrastructure that is both ubiquitous and interoperable. These are the challenges that Cambodia has. And I think that's what we've been able to capture in this interview with the assistant governor.