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.