Alternative Remittance Systems And Terrorism Financing

Governments, through their regulatory bodies, typically regulate formal financial sector players such as banks, which can leave providers working in informal remittance systems outside regulatory channels. Value transfer services financial transfers performed domestically or across borders on behalf of clients are essential to the financial system, and as such, are often offered by both formal and informal actors. Law enforcement and counter-terrorism authorities are evaluating money and value transmission channels for vulnerabilities that may make these channels attractive for illicit use, including the financing of terrorism. 'Alternative Remittance Systems and Terrorism Financing: Issues in Risk Management' aims to help countries bring these informal alternative remittance systems into their counter-terrorism programs, without hindering the ability of those who depend on these systems to send and receive money at low cost.

This paper is designed to cover a subset of such category, i.e. the realm of unregulated/informal Alternative Remittance Systems, also known as informal value transfer systems (IVTS). In these cases, operators form a parallel, underground financial system aimed at rapidly and effectively moving value within or between jurisdictions, often without being detected by regulators and law enforcement, and usually without available transaction records. Where prevalent (as it is often the case in low-income economies), ARS are frequently the only mechanism by which the poor or isolated can send and receive funds and therefore provide an essential service to facilitate economic activity. On the other hand, money and value transmission channels are being evaluated for vulnerabilities that may make them attractive for illicit use, including the financing of terrorism. The paper aims to help countries trying to bring these informal alternative remittance systems into their counter-terrorist financing regime without hindering the poor??s ability to effectively send and receive funds at low cost.

Hawala and other remittance systems have gained attention in recent years with the substantial growth of remittance flows from countries with large migrant labor forces and with increased focus on combating money laundering and the financing of terrorism. The IMF and the World Bank have been researching these systems since 2002 to better understand the interplay of historical, cultural, and economic factors that promote such systems. This book is a survey of regulatory practices and an overview of experiences in different countries, and includes articles on regulatory frameworks in remitting and receiving countries and on the problems that can arise when regulating remittance systems.

Following the events of 9\11 individual countries and the international community became increasingly concerned about how best to prevent the funding of terrorist groups. Alternative remittance systems such as Hawala, where money is moved informally between a network of brokers in the Middle East, north Africa and south Asia have been identified as a potential source of terrorist financing leading to calls for greater regulation of such alternative remittance systems. This book analyses the risk such alternative remittance systems pose in terms of terrorist financing, offering a detailed overview of the historical origins and methods of operation of alternative remittance systems or informal value transfer systems. The factors that have come to ensure that these systems have remained operationally viable in modern times are identified along with the risks they present balanced against an overview of their actual misuse for illicit purposes to date. The book presents a detailed critique of the UK framework for the regulation of these systems drawing where possible on existing data to assess the use and effectiveness of these measures in practice. A range of options for mitigating risks associated with specific remittance corridors is considered ranging from initiatives that promote remittances through the banking sector, to efforts to mitigate risk and the impact on the delivery of UK overseas development aid. The book concludes with key recommendations as to the effectiveness of the current regulatory framework within the UK viewed from the perspective of international efforts to secure the regulation of these systems, and in stemming terrorist finance as part of national and international counter-terrorism policy.

The publication is divided into three main parts : the first deals with global issues, the second with national issues and in particular, national strategy formulation; and the third with financial and professional sector procedures. This second edition now includes additional information on understanding how terrorism is financed. It incorporates both the international standard arising from the revised Financial Action Task Force on Money Laundering 40 Recommendations and the Special Nine Recommendations.

The first edition to this book was titled A Comparative Study of the Money Laundering Laws/Regulations in Nigeria, the United States and the United Kingdom; this edition is titled Deterring and Detecting Money Laundering and Terrorist Financing: A Comparative Analysis of Anti-Money Laundering and Counterterrorism Financing Strategies. The title was changed to reflect the new approach/direction of the second edition and the fact that eight new topics were added to the already-existing chapters. They are "Assessing Risks and Applying a Risk-Based Approach" (chapter 2), "Terrorist Financing Offence" (chapter 5), "Private Banking" (chapter 7), "Prepaid Cards" (chapter 8), "Modern Slavery" (chapter 11), "Fraud" (chapter 13), "Tax Evasion" (chapter 14), and "Confiscation and Provisional Measures" (chapter 15). The second edition uses a mix of different methodologies as opposed to focusing on just one methodology. In addition to the comparative methodology, this edition adopts the case-study methodology. This methodology was not used in the First Edition. The case-study methodology ensures that readers: i. remain familiar with the concepts of money laundering and terrorist financing; ii. are aware of the threat money laundering and terrorist financing poses to you as a banker or practitioner; iii. maintain a proportionate and risk-level based approach to those threats; iv. adopt the anti-money laundering/counter-terrorist financing procedures appropriate to that level of risk; and v. review and maintain those procedures regularly. This book provides guidance on the following: - money laundering process, regulation of diamond dealers and other designated nonfinancial businesses and professions, as well as regulation of hawala and other alternative remittance systems, international bodies and national government agencies charged with fighting money laundering and terrorist financing (Chapter 1); - country-level and reporting entity-level risk assessments, and the measures to prevent the misuse of non-profit organisations and third-party payment processors (Chapter 2); - suspicious activity reports, currency transaction reports, further information orders, disclosure orders and information sharing within the financial sector (Chapter 3); - money laundering offence, penalties and lifetime management of ancillary orders (Chapter 4); - terrorist financing, jurisdiction, penalties and policies and procedures involved in the seizure/forfeiture of terrorist property (Chapter 5); - current measures to reduce the money laundering risks associated with politically exposed persons (Chapter 6); - innovative methods to reduce the money laundering risks associated with private banking accounts (Chapter 7); - strategic measures that meet the goal of financial inclusion (that is, preserving innovation and the many legitimate uses and societal benefits offered by prepaid cards) without compromising the measures that exist for combating money laundering, terrorist financing and other illicit transactions through the financial system (Chapter 8); - calculated processes to prevent the smuggling of the proceeds of crime overseas for the purpose of avoiding the reach of law enforcement agencies (Chapter 9); - complete understanding of the role and responsibilities of the compliance officer (Chapter 10); - timely procedures for combating predicate offences for money laundering-e.g. modern slavery (Chapter 11), the offence of bribery (Chapter 12), fraud (Chapter 13) and tax evasion (Chapter 14); - authorized measures for freezing or seizing property laundered or proceeds from instrumentalities used in, or intended for use in, money laundering or predicate offences (Chapter 15 and Chapter 16); - conscientious assistance that helps firms gain confidence that their customer due diligence obligations have been properly carried out (Chapter 17); - institutional record keeping maintenance (Chapter 18).

The first part presents the findings concerning overall compliance with the revised standard and methodology and the second part compares these findings to those of assessments under the old methodology. The third part discusses interpretative and application issues and the fourth describes logistical issues based on the experience of the assessments carried out to date.