Tag Archive for Money Laundering

Confidential Vodafone Comments to Afghanistan Central Bank on E-Money Institutions

1 – Do you agree with the proposed limitations on individual, daily and monthly transactions? If not, what limitations would you propose, and what are your justifications for these limitations from an AML/CFT perspective?

Generally, Vodafone supports a risk based approach to transaction limits, with higher limits granted where KYC levels are increased. This has been applied for M-PESA in Kenya.

Confidential Roshan Comments to Afghanistan Central Bank on E-Money Institutions

Article 2.5.12.2 – anti-money laundering/combating the financing of terrorism
The restriction against corporations should be removed. There does not appear to be a valid policy objective behind the restriction and no other jurisdiction of which we are aware has imposed such a restriction. One of DAB’s policy objectives is to increase access to financial services. Banks and micro-finance institutions may use EMI services to provide their services and products to large sections of the Afghan population, thereby increasing access to financial services. Given that banks and financial institutions are corporations, the proposed ban will prevent them from using such EMI services. This totally undermines DAB’s stated objective of increasing financial access. The proposed rule is manifestly disproportionate to the risks arising from EMI practices and is inconsistent with the practices of regulators in other jurisdictions.

Typologies of Money Laundering through the Real Estate Sector in West Africa

Various studies, including those carried out by the Financial Action Task Force (FATF) over the past few years, suggest that advances in technology and the progressive tightening of anti-money laundering (AML) regulations are leading money launderers to make more complex arrangements outside the formal financial services industry, such as the use of various professional services, and in particular the real estate business.

African Development Bank Group Strategy for the Prevention of Money Laundering and Terrorist Financing in Africa

The international community is concerned with the growing incidence of organized crime, corruption, and terrorism and the debilitating effect these problems have on peace, security and development. A successful strategy to address these international threats necessarily involves measures to address money laundering and the financing of terrorism (ML/FT).