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.
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.
Approximately $3.3 trillion of the $10.7 trillion in U.S. Government programs have already been utilized.Most of these initiatives have been part of an effort to deploy unorthodox policy tools to keep credit flowing in the economy. However, the fundamental issue of “toxic bank assets” remains largely unaddressed by most of the U.S. Government programs to date.
Clearing Member Eligibility
•Swap Portfolio minimum size of USD1 trillion
•Minimum capital USD5 billion in Clearing Entity or in Parent providing Guarantee
•Credit Rating single A or better
•Margin multipliers applied if existing member downgraded below A
•Compulsory participation in Default Management Process