How to Efficiently and Effectively Implement Anti Money Laundering, Counter Terrorism Financing and Anti-Corruption Strategies in the Eastern and Southern Africa Anti Money Laundering Group (ESAAMLG) Member Countries
At a time when the use of information technology has become important in e-commerce, major negative implications have soared due to its use by terrorist and money laundering groups. There has been unending reports of money laundering, terrorism acts, terrorist financing and corruption cases around the world, one may stop to pose this question: when will sanity ever prevail and will such cases ever be no more?
With the emergence of advanced technology, international financial crimes seem to be getting more and more complex, thus calling for equally advanced technological and global approach to address them. An effective application of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) approach forms the best method of addressing the problem. This has been cited by scholars to be very critical through preventing losses and further contributing towards improving the country’s security. According to International Monetary Fund AML/CTF creates a platform for extended fight against terrorism by encouraging alertness and cooperation as technology continues to evolve in the world.
The first chapter highlights the current laws and regulations guiding the Eastern and Southern Africa Anti Money Laundering Group (ESAAMLG). Then it goes further to discuss international policies and legislation guarding the same. The second chapter generates further understanding of the different security threats that results from money laundering activities. It comes out clearly that as technological development is achieved; more threats continue being developed by money launders, a notion that has been predicted to intensify with time. An in depth understanding of money laundering as presented in chapter two aids preparing the reader for the results expected in chapters five and six. Chapter three explores the various international policies and regulations on AML and CTF compared to other states. As it comes out in chapter four, the study employs primary data collection method to generate the results for analysis and discussion in chapter four and five.
The analysis of data in chapter four reveals the magnitude of money laundering threats. Finally, the conclusions and recommendations call for more research and intrinsic focus by institutions of higher learning in conjunction with their administrations to design more effective systems for countering the threats. Besides, the conclusion requires further enforcements through policies and legislations in addressing the problem both at the local and international level.
Since 2005, a number of strategic plans have been put in place by this group with the aim of reducing both the inflow and outflow of ‘dirty’ or illegal money. A case in point are the strategic measures that have been adopted and implemented in Uganda for a couple of years now.
Owing to the growing number of money laundering groups across the globe, several nations have put up anti-money laundering measures and regulations. For example, Kenya has passed several legislations to curb this menace. In the wake of terror activities in this country, scores of Non-Governmental Organizations (NGO) were deregistered in 2015 after being suspected of engaging in or financing terror groups through money laundering. As it stands now, a number of NGOs are still on the watch list.
In addition, the Kenyan government has placed a ceiling on the amount of money that can be withdrawn over the counter from banks. Any withdrawal from one million Kenya shillings and above is vetted thoroughly by banks before it can be advanced to a customer. A case in point is whereby the withdrawer should clearly state the source of funds. Besides, the purpose of the funds ought to be indicated by the customer.
While the definition of the term money laundering as Bartlett explains has remained the center of a major debate due to the problem’s extended implications and outlook, it is no doubt that effective and holistic measures should be incorporated to address it.[1] Since the onset of information technology, financial institutions have remained a major target by money launders to facilitate easier transfer of money. It is worth noting that money laundering rates have in the last few years shifted downwards mainly due to the currently intensified fight against the problem.[2]
The effects of money laundering have negative far reaching staggering effects on economic, security and social factors. The first consideration is that it is a practical proof that criminal acts surely pay off; this is a socio-cultural problem. In the long run, it encourages criminal activities thus posing insecurity to the innocent citizens and other people may also get encouraged to indulge into the illicit schemes. In the long run, it may also encourage more corruption and more embezzlement and increase of drug related crimes among other numerous social ills.
As noted earlier, corruption facilitates and creates ease of operations of money laundering and terrorist activities. Developing countries including countries within the Eastern and Southern Africa region, in most cases, are the ones that bear the brunt of the modern money laundering schemes; they are often the prime target due to the fact that governments in such developing countries struggle with the problem of corruption and have not put in place apt regulatory measures and effective strategies to guide them on anti-money laundering, anti-terrorist financing and anti-corruption not to mention implementing them.
Block and Sean explained that high scale financial crimes may lead to artificially inflated financial sectors that can render a country unable to feed its own people, lead to the collapse of banks and the creation of false demands.[3] Prevalence of money-laundering, terrorist and corruption schemes may, therefore, completely impair a country’s financial platform hence ground any development strategy that the country may conceive to implement.
Money laundering is not only a challenge in the USA or Europe. Just like in other parts of the world, money laundering, corruption and terrorism are rife in Eastern and Southern Africa, the only difference is that their effects are adverse because the Eastern and Southern Africa region lacks a proper platform to address them, thanks to the disunity and the poverty status of the region. In light of the above, therefore, the situation of financial crimes becomes more awry when it comes to the region in question. This research proposal seeks to address the strategic attempts of the Eastern and Southern African member states in combating money laundering, terrorism and corruption under the umbrella body known as the Eastern and Southern Africa Anti Money Laundering Group (ESAAMLG) and how to enhance the efficiency and effectiveness in this context. Research
In his view, Aldridge indicates that most criminal activities are aimed at making large amounts of profits.[4] The laundering, therefore, takes three key stages within which the anti-laundering efforts are focused. Alowain explains that the first and perhaps the riskiest stage involves placement of the illegitimately acquired money into a non-suspecting financial institution.[5] However, due to the difficulties presented in depositing large sums of money, the launders then layer their money into several concealments which they transfer to various institutions as a strategy to avoid suspicion and reduce easier tracking.[6] Once the money has passed through this the second layering stage, it becomes even harder to trace in that launders may even use different individuals such as friends and relatives to deposit it in various bank accounts. In addition to that, the launders may further purchase high value items as opposed to taking the money to banks where they are subject to greater scrutiny. Finally, the money reenters economic circulation as legitimate money; a stage at which detecting it becomes even more difficult. [7]
It is imperative to highlight at this point that due to the complexity presented in the laundering process, the Palermo and Vienna Conventions expounded the definition of ‘money laundering’ to include people and entities that support such transactions. According to Berti, under the Palermo and Vienna Conventions any deliberate transfer of money from proceeds of crime, ownership, concealment or even disguise of any nature is considered to be part of the extended money laundering chain.[8] Broome also indicates that these conventions consider buying and or being in possession of money with knowledge of it to have been from proceeds to be part of laundering.[9] It is from this complexity that AML and CTF measures have greatly been intensified at all levels of laundering both locally and internationally.
Cases of business being defrauded by launders, massive loss of funds due to corruption and financing of terrorist organizations as well as the leak of information that is critical to the fight against terrorism to terrorist organizations have been treated with utmost concern. This is due to the level of awareness that is displayed on security. The level of security presence that is witnessed in banks, borders and other financial institutions has mainly been driven by awareness on the risks that the operations of such organizations place them with respect to money laundering.
There are a number of laws and guides that have been required for action by states under ESAAMLG for a successful implementation of anti-money laundering actions. First is the need for the member countries to declare that any act related to money laundering is a criminal offence based on the UN Vienna Convention of 1988.[10] It is not just a requirement but a demand that countries employ severe punishments to money laundering related crimes. This should be made to encompass predicate offences with no chance of parole of appeal. It is up to the member state to ensure that as it tries to implement the ESAAMLG policies, it sets standards necessary to prove without a doubt that a financial crime has been committed. This will seal any possible loophole for a lackluster justice system. Individual states should also be in a position to forward senior members of their government for investigation should they be suspected of any financial crime of whatever nature.
With awareness on the role played by established policies in ensuring ESAAMLG effective operations, ESAAMLG has taken to the adoption of FATF recommendations. The latter has in a great way generally aided the active oriented approach to security. There have since been a number of developments that have generally been aimed at ensuring that information security is well understood including the structuring of security threats into levels and development of a number of technological interventions that have been central to success that has so far been attained in curbing financial crimes.
However, the technological developments that have been attained in ensuring security have been overshadowed by technological threats to security that display the same level of robustness. ESAAMLG has a role of also effectively providing aid to respective governments to enable them implement AML strategies while at the same time taking into consideration the degree of vulnerability following the increased reports of money laundering, terrorism and corruption. A scan of a system to determine weakness in a security system may for instance be used by hackers and network administrators with completely different agenda. This has led to what many consider a vicious cycle in information security development where adjustments are made to address security issues, the adjustments are then outdone by technology which develops a need for better approaches. This cycle has been cited by researchers as being central to the high level of development that is being recorded in information technology as a field. IT and computer science are tipped as being some of the most dynamic fields an observation that most researchers have claimed as being a result of the changing expectation and needs of the consumer that are largely driven by the developments that are being recorded in security.
Economies and business operations have largely been affected by developments that are being recorded in money laundering activities. The loss of funds or access by unauthorized parties may lead to financial losses. The effect that it has on the reputation of an organization and consumer confidence makes it a key operational threat. The current business environment is characterized by high level of losses and corruption which makes development of effective policies one of the key operational goals that ESAAMLG seek. The role of security in the current business environment makes it one of the most important factors in ensuring generation of sustainable value. Various business segments are associated with high level of corruption that makes it hard for businesses to effectively generate value in their operations.
It is important to note that business operations in the areas affected by money laundering, terrorism and corruption is highly unproductive and the role played by ESAAMLG in ensuring that businesses generate sustainable value makes it an important factor that most member countries within ESAAMLG seek in developing their operational strategies. Businesses that have suffered security breaches generally find it hard to regain the confidence of their security. With this loss in funds and overall security the economy of an affected environment or market dwindles and the result may be failure in business operations or far more worse development that may affect the potential that the nations have in ensuring operational success.[11]
Problem definition
There is no doubt on the importance of the role played by the ESAAMLG in curbing high-level financial crimes and terrorism and mitigating the risks that are associated with money laundering. It is apparent that ESAAMLG plays an important role in developing the confidence of the fight against money laundering and terrorism by creating a body which is charged with the duty of protecting the interests of the individual nations as well as look over the back of their neighbors for any undesirable occurrence.[12] The role played by ESAAMLG in curbing the vices of money laundering and terrorism makes it an important operational variable: thus threats to security of nations due to terrorism and which affects economies and lead to loss of lives must, therefore, be addressed effectively.
Money laundering as a general term refers to obtaining money illegally and attempting to conceal the source. Kinds of money laundering techniques vary in sophistication; it, however, falls under a three-stage process. The process of money laundering includes: placement, layering and integration. Placement is the act of introducing money into the financial system through a dubious means while layering is the transferring of funds into different accounts or financial institutions in order to cover the illegal source.[13] Integration is the act of generating wealth with the illegal funds or faking the source of money as if it has come from legitimate financial institutions.[14] It is imperative to highlight at this point that some money laundering schemes must not necessarily involve transactions, but may include impersonations, fraudulent false claims, underground money transaction for illegal drugs and double payments, to mention but a few.[15]
The effects of money laundering are negative far reaching and staggering implications on economic, security and social factors. The first consideration is that it is a practical proof that criminal acts surely pay off; this is a socio-cultural problem. In the long run it encourages criminal activities thus posing insecurity to the innocent citizens and other people may also get encouraged to indulge into the illicit schemes. In the long run it may encourage more corruption and more embezzlement and increase of drug related crimes among other numerous social ills. Developing countries including those in the ESAAMLG region in most cases are the ones that bear the brunt of the modern money laundering schemes; they are often the prime target due to the fact that such governments have not put in place apt regulatory strategies and measures to guide them on addressing modern money laundering schemes. Block and Sean explained that high scale financial crimes may lead to artificially inflated financial sectors that may render a country unable to feed its own people, lead to the collapse of banks and the creation of false demands.[16] Prevalence of terrorist and money-laundering schemes may, therefore, completely impair a country’s financial platform hence ground any development strategy.
Even though the member states of ESAAMLG are committed to addressing the money laundering, terrorism and corruption prevention strategies across ESAAMLG, they are faced with numerous challenges in a bid to fulfill this drive. Owing to the increased use of the technology and the limited control the ESAAMLG has on technology, the vice presents a lot of huddles to contain.[17] Further to this, due to the fact that most countries have cash based economy, it makes it easy for the terrorists and money launders to operate and go unscathed. In spite of the fact that the challenges faced in the global financial market are multifaceted, a resolute commitment from member states will definitely result into substantial score. A due diligence customer program has been identified as one sure way of reducing financial crimes but the process has proven to be challenging to implement in rural and peri-urban regions where no physical addresses are present.
Numerous threats exist from laundering activities and their understanding is important in developing a clear picture of what is required in ensuring the challenges presented by laundering are properly and effectively curbed. This understanding is central to numerous developments by the ESAAMLG as well as relevant financial institutions to determine the best strategies and approaches to ensuring information technology security. However, the existence of many nations in the ESAAMLG region suffering from security breaches, terrorism and corruption with regard to the challenge of money laundering points to the fact that African nations have not established effective strategies and methods of limiting the menace or even appreciating the mitigation process in practice.
In his article, Bargosky indicates that the situation of financial crimes becomes more awry when it comes to the Eastern and Southern African regions.[18] Nations in these areas have experienced massive corruption, lost funds, were defrauded or attacked by terrorists with considerable damage on a nation’s reputation which takes years to develop. It is, therefore, apparent that there is need to develop a clear picture on the threats that nations in Africa face from money laundering, terrorism and corruption and determine what measures may be put in place to these threats. Special emphasis on the role played by ESAAMLG in mitigating threats is important in ensuring that interventions measures are taken to address the challenges affected nations face.
In his view, Fanta explains that the fight against money laundering in the society can only be won by employing technology that is indeed more advanced compared to that being employed by the launders.[19] Anti-money laundering software is a term that is increasingly being used to describe the acceptable and legal controls mostly in the financial institutions to identify and report cases of laundering suspicion to the relevant agency of government dealing with criminal investigations and enforcement. While this method is increasingly gaining popularity and indeed effectively achieving the anticipated goal, its application in other countries as Jeanne and Giraldo confirm, has not been very smooth.[20]
Anti-money laundering software employs three basic components that lead to easier identification of launders in financial institutions. To begin with, the currency transaction reporting systems seeks to trace the movement of large sums of money in the financial institutions. Notably, Henry explains that cash transactions that involve amount of money exceeding US$10,000 require effective reporting to establish the authenticity of the source.[21] Though many people at first were complaining of secrecy invasion in their financial operations, they later came to understand that indeed if your transactions are clean there is no need for worry.
Secondly, anti-money laundering software requires financial institutions to establish closer relationship with their clients and, therefore, know them much better through the customer identity management system.[22] Under this consideration, Reddington indicates that the banking institutions are required to gather enough financial knowledge of their clients; a consideration that makes it easy to link possible fraudulent sources of finances or transactions.[23] However, it is the provision of the locally and internationally suspected list of launders that makes it even easier for the banks to countercheck related transactions and, therefore, report them at the initial most instances.
From his study, Moeller’s conclusion concurs with those of many scholars on the efficacy of analyzing an individual’s financial activities to identify possible deviations which may be used as possible indicators of laundering transaction.[24] Anti-money laundering software third component is Suspicious Activities Reports where transactions suspected to have possible links with laundering are recorded for further investigations by the bank and criminal agencies. As Nance also explains, the anti-money laundering software is a highly integrative tool and created a highly viable model of detecting cases of laundering.[25]
Owing to its inherent vast repercussions in the society, money laundering attracts some of the toughest penalties in the United States.[26] This policy has been very critical in the nation’s fight against laundering and related criminal activities such as drug trafficking and terrorism. As a result, this legislation established the Office of the Comptroller of the Currency (OCC) which would monitor the national banks compliance with its demands.[27]
Ugale explains that OCC operates in conjunction with the Financial Crimes Enforcement Network (FinCEN) to establish the different areas of high intensity money laundering.[28] From this consideration, he indicates that financial institutions in such areas are put on higher alert in dealing with their clients. Particularly, OCC cooperation with other financial institutions is helpful in gathering the necessary information about the possible suspects and also in establishing the epicenter of the money laundering problem. Taking into consideration that OCC is further empowered to forcefully conduct investigations when some financial institutions fail to cooperate, it becomes easier to trace possible layering of the laundered finances in the whole nation. In his view, Zhixiang supports the work of OCC in anti-money laundering operations; he however indicates that there should be established stronger checks and balances for the same actions.[29]
One of the mostly made observation incase of money laundering event is the rise of currency flows in a country or a region. As a result, this consideration could easily be assessed to determine the possible sources of the finances. OCC operates in liaison with banks to regularly assess their overall transactions in relation to the currency flows in a region. Hinde explains that excessive cash flows destabilize the forces of the market and, therefore, risking it with possible crash.[30] The currency and foreign transaction reporting regulations are considered to be effective in that they empower the OCC in conjunction with respective criminal agencies to seize property and or freeze laundering related accounts as involved parties are subjected to further scrutiny for possible prosecution.
In his view, Farah commends the OCC operations for incorporating a highly expansive analysis to detect and counter money laundering.[31] In banking transactions, tracking all the involved parties and related activities is indeed easy because the finances are held in a particular individual’s account. Under this consideration banking institutions form an immediate details hub to OCC which further traces laundering activities even to the external countries. As indicated earlier, AML and CTF establishments are based on the highest possible ethical considerations which make laundering to be unlawful and, therefore, unacceptable irrespective of the country of occurrence. Gunestas further indicates that external operations may at times be obstructed especially when the launders originate from countries that have poor relations with the United States.[32] However, any transaction with people from such high intensity money laundering regions is further evaluated by the local banks in the US.
While emphasizing on the efficacy of the position that banks and other financial institutions hold in the fight against laundering, Farah explains that their operations are specially focused to not only deter but eliminate the same problem from the society. As a result, OCC emphasizes on internal controls that must be adhered to in order for the laundering operations to be effected at all levels. Particularly, they are required to set up programs with clear reporting mechanisms in their currency procedures and monitoring. There is particular emphasis on the mode of book keeping that facilitates use of anti-money laundering software. To articulate the above consideration, OCC requires banks to subject their staff to special anti-laundering related training which facilitate clear analysis at all levels of the banks management.[33]
International Obligation towards Money Laundering
The chief reason that led to the creation of the ESAAMLG was the increasing concern of the African state of always falling victims to money launderers and terrorist attacks. The ESAAMLG countries’ leadership saw it wise to create a body which would be charged with the duty of protecting the interest of the individual nations as well as look over the back of their neighbors for any undesirable occurrence. To implement this drive the African countries in the Eastern and Southern block formed what they baptized by the initials ESAAMLG to operate under the FATF Recommendations. The Group was obligated to work in conjunction with other international organizations with which they share the same agenda; that is combating money laundering by establishing institutions and human resources to tackle the issue, studying and giving recommendations on the emerging topologies in the two blocks and lastly co-coordinating technical assistance whenever necessary. The association prioritizes the regional matters by putting into action anti-money laundering measurers.
International Policies and Legislation
The ESAAMLG brings together a total of fourteen countries drawn from the Eastern and Southern block: these countries which are Kenya, Tanzania, Uganda, South Africa, Lesotho, Seychelles, Zambia, Switzerland, Namibia, Mauritius, Malawi, Botswana, Mozambique and Zimbabwe.[34] As earlier mentioned, these member states agreed to have a mutual program to represent a common interest in curbing money laundering and terrorism in the region. To make this decision operational, the states formulated a number of international policies into seeing that their primary and secondary objectives are met. The report further outlines these policies as follows: –(a) Adoption and the implementation of the then FATF 40+9 Recommendations;
(b) Employing anti-money laundering measurers to related crimes committed against member states; and
(c) Executing measures outlined in the policy document that subscribes to the prevention and reduction of money laundering and terrorism crimes.
Creation of ESAAMLG
ESAAMLG was established by Ministers and other state officials in 1999 in Tanzania. The present members came up with a Memorandum of Understanding (MoU) drafted regarding the previous experiences of nations with money-launderers and terrorists. Most of the ideas that formed the basis/ground on which ESAAMLG was formulated were drawn from the policies of FATF and other related bodies already in operation.
During the Dar es Salaam conference, ESAAMLG expanded its role to cover financing anti-terrorism measures in the region block.
Recommendations
Over the years, the fight against money laundering, terrorism, corruption and other financial crimes, and even the role played by ESAAMLG and other stakeholders have transformed and presented security as one of the key threats that the vice presents in a nation’s economy. Awareness on the role played by ESAAMLG in security is not a recent development in the world and Africa rather it is one of the key areas that the group has guarded jealously over the years. ESAAMLG has traditionally guarded their strategies against possible failure and kept their policies focused and supported by FATF Recommendations.
Many are aware of the FATF recommendations and the need for their application. However, critics indicate that ESAAMLG has not mastered the art of efficiency in implementation of the recommendations.[35] The role of the leadership of ESAAMLG in seeking to generate value by implementing the recommendations in fight against financial crimes is an effective strategy. Others, however, consider the current policies that ESAAMLG uses equally effective in fighting financial crimes within organizations just like the FATF Recommendations that are essential in ensuring ESAAMLG missions and goals are met. There is no doubt that the role played by ESAAMLG in generating value by implementing policies is important and cannot be ignored. Its strategies and even security strategies can effectively be carried out with the aid of FATF Recommendations.
The nature of the recommendations by FATF plays a role in defining what will be required of the systems put in place by ESAALMG that will be developed and is a factor upon which other issues for instance security is developed. However, awareness on the role played by the recommendations in the fight against financial crimes makes it one of the key needs that ESAAMLG must put in mind in implementing their policies. The goals that ESAALMG seeks in mitigating money laundering irrespective of their nature cannot be met if security is sidelined which makes it an important factor that must be considered in formulation of its policies.[36] Therefore, the policies of ESAAMLG and member countries systems as component of their security systems must be developed in a manner that ensures they are in line with the confidentiality, integrity and accuracy, and which seeks to ensure the security of the nations against possible terrorist attacks. It is, therefore, evident that there is need to ensure that security as a factor is considered in formulating the foundations of the policy.
Studies reveal that security is one of the key areas that ESAALMG has in the recent years focused on owing to the awareness or understanding of the potential threat that money laundering and corruption have in affecting other areas of operations. The FATF Recommendations come with a number of security guarantees that may be effective in addressing problems that nations in the Eastern and Southern Africa are faced.
A subordinate corruption in Africa report, the result of a joint investigation of civil society organizations Transparency International (TI) and the Afro-barometer, was released on in 2015 in Johannesburg.
According to Transparency International, 58% of respondents say that African corruption has increased in the last 12 months, and in 18 of the 28 countries where a large surveys were made most people say that governments are failing to fight corruption.
This document was released in the light of the seventh Summit of African Cities, which ran from November 29 to December 3 in the satellite city of Johannesburg in Sandton.
The study conducted in about 28 African countries, highlighted the police and courts as the most corrupt sectors in Africa while Nigeria and South Africa countries with more indexes bribes.
The report stated that 22% of people who had contact with a public service for the last 12 months paid a bribe, particularly in the areas of police and the courts,
Regarding the fight against corruption in Africa, the report suggested that about 53% of the population claims to be able to report bribes, while 38% believe it can do nothing for fear of retaliation.
Luis Lopes, the focal point for urban resilience of UN Habitat, speaks of what must be done to combat corruption. He says it is very much related to the involvement of communities in key sectors such as young people who have a really important role in taking part in local development, to questioning leaders, presidents and other officials.
More legislation on business
Among the main recommendations of the study is strengthening of governments and law enforcement on corrupt businessmen and money laundering in order to decrease the volume of financial flows of the continent.
The establishment of laws that protect whistleblowers and help people to demand more transparency and accountability in public institutions and to launch reforms that combine punitive measures with structural changes in the short and medium term, particularly petty corruption, which has a direct impact on the most vulnerable citizens.
On the other hand, TI also recommends that the African Union members should advance political will and necessary funding to implement the mechanisms defined in the anti-corruption convention.
If it is not checked, corruption slows development d economic growth and undermines people’s trust in government and the accountability of public institutions.
The findings of this survey result of interviews in 36 countries in eastern and southern Africa states. In addition to launching the subordinate report on corruption in Africa, other summits have lamented the rising rate of corruption in eastern and southern African states.
Economic development of the region is not reflected in improvements to the population, says Transparency International according to the 2013 published edition of the Corruption Perception Index.
The Sub-Saharan Africa is the world’s region with the worst average score on the Corruption Perceptions Index according toTransparency International. The ranking evaluated 177 countries on a scale from 0 to 100. The lower the score, the more corrupt it is in the public sector of the country.
The Sub-Saharan Africa has an average score of 32.5, followed by Middle East and North Africa, 37; Asia and the Pacific, 43; America, with 44.8; Eastern Europe and Central Asia, 52.8; and Western Europe, with 65.8.
The world average is quite low (only 43 points). According to the coordinator of Transparency International for Central Africa, Lucas Fernandes Olo, the Sub-Saharan Africa (which includes eastern and southern Africa) has not improved since 2012.
We may think that there is certain development in economic terms, but this has not translated into a greater well-being for the population. We will continue to see this disparity between rich and poor for a long time while corruption is the main cause.
Among the Portuguese-speaking countries in Africa, Cape Verde is cited as an example of the fight against corruption, in 41st place by ranking. According to Fernandes, a possible slight decline of the country in the coming years is still possible.
Since Guinea-Bissau ranks among the most corrupt in the world, at position 163, political instability is hurting the country’s performance in the evaluation of Transparency International.
According to Fernandes, conflicts are often used as pretexts for postponing measures to combat corruption. However, if this is not considered from the beginning, stability will not be sustainable.
Purpose of the study
An understanding of the operational environment in fighting financial crimes is very significant as a requirement in developing strategies, policies and regulations and for setting up of systems that are relevant to the goals that are being sought. The role played by ESAAMLG in the effort to combat corruption in Africa makes it an important operational variable that as a group is left with little option but to ensure that financial crimes are effectively addressed. By developing a clear understanding of the nature of economic threats that Eastern and Southern African nations are faced with and an understanding of the areas of weakness and lack of effectiveness with respect to formulation of strategies, policies and regulations in addressing the threats, it will be easy for ESAAMLG to deal with the threats that the nations face. This is critical in ensuring that they retain investor confidence and the region’s image. An understanding of financial security and dynamics that affect its implementation in the practical environment is thus important in ensuring that the goals of the research and its mechanics in seeking to address the problem are well developed.
Besides, the study will seek to analyze the measurers employed by the Eastern and Southern African nations in curbing high-level financial crimes and terrorism following the establishment of the ESAAMLG block. It will further seek to determine the operational principles of the ESAAMLG, the efficiency, effectiveness and success of the body against its primary objective considering its association with the FATF and implementation of the FATF Recommendations by the ESAAMLG member states.
Theoretical Framework
ESAAMLG is one of the key bodies in Africa that set the nature of strategies and policies that member nations employ in their fight against corruption and money laundering. As a result, the implementations of CTF and AML measures and the application of FATF Recommendations points to the role played by formulation in ensuring effective implementation and evaluation. An understanding of the theoretical aspect and the nature of the financial crimes are just as important as determining the internal organisational systems in developing effective operational strategies.
An understanding of any problem related to financial crime is, therefore, incomplete if an understanding of the operational environment and the factors that may affect it is not developed. The understanding of theory is largely used by the study in seeking to discern the areas that ESAAMLG is not being effective in implementing their laws and regulations.
The role played by ESAAMLG in Eastern and Southern Africa to curb corruption and other financial crimes makes it a most important operational variable in shaping the nature of strategies to implement. The role of ESAAMLG in helping member states fight money laundering in a bid to secure their business environment and nations is appreciated by strategists.[37] Due to the high level of money laundering activities and corruption currently being witnessed in various business segments, public spaces and the government, ESAAMLG has come up as one of the avenues through which the vices may be curbed by expanding the breadth of their assistance to member nations and strengthening the various strategies, policies and regulations it has established.
The question that is asked at this point is: Is ESAAMLG doing enough to fight financial crimes. Is it effectively implementing its strategies, policies and regulations? This effectiveness of the implementation of strategies, policies and regulations by ESAAMLG has, however, been hindered by poor implementation strategies that are considered a critical success factor in ensuring that the integrity of the policies they formulate are maintained and effectively used.[38] Reputation in the current African business environment is tipped as being an important factor in ensuring gain of competitive advantage thus the terrorism threats should be addressed effectively.
It is noted that there have been tremendous developments by ESAAMLG in formulating policies that are aimed at ensuring security by curbing financial crimes. However, these developments have been recorded notwithstanding the threats that African nations face in developing a strategy to control terror funding. An understanding of the magnitude of threats that corruption and terrorism pose appears to be lacking with many nations seemingly understating the threat posed by the money laundering.[39] A research to determine the validity of the existing findings is necessary and plays an important role in highlighting the areas that may be lacking
Recent studies show that with the application of the FATF Recommendations, the fight for security and mitigation money laundering has been made easy as compared to before when the operations were filled with technical issues. This may be out of the realization that the implementation of the potential penalties on offenders have in affecting their perceptions and how it may effectively be used to aid in generating value. Incorporation of the strategic vision in formulating security regulations is important in ensuring that the architecture developed is relevant to all areas of ESAAMLG operations. By considering the vision the architecture is formulated in a manner that is appreciative of developments and groups’ mission.
An effective architecture should be developed in a manner that ensures traceability to the organizational goals by providing a clear direction on how the primary architecture should be developed. The primary business goals that are often relayed in architecture that is appreciative of the goals that the group seeks in operations often display confidentiality, ensuring authorized entry, validation of access, ensuring availability of data to authorized users, verification of identity and validation of users and transactions that they can manage in systems through account based systems. Development of any regulations must be intentionally planned to reduce the risk of accretion growth where growth occurs in a manner that reduces the potential that the group has for generating value.[40] Accretion growth is often characterized by the development of parallel account solutions that leads to avoidable complexity which goes against the development of aggregate and required functionality goal in policy development.
Best practices in policy development require that the design of any regulation provide a number of templates or a menu of options that address each category which goes a long way in saving time and money in developing supporting standards.[41] The banks, financial institutions and economies are presented as key points of attacks with a descending magnitude. This understanding is important in ensuring that both the technical and business aspects in developing security architecture are well captured in developing policies. It is evident that there is need for the inclusion of an operational process that ensures the integration of security in any ESAAMLG undertaking from the very first step. This plays a role in reducing last minute rush to add on security protocols after systems have been completed which often lead to inefficiency mainly because security is dependent on the entire systems which unlike the approach used depends on overall system is avoided.
However, theories underpinning security have widely been discussed. An understanding of the assets, key threats and key activities that are being protected against and rankings of security goals is important in ensuring that each issue is given the weights that it is worth and no aspect of security is left unaddressed. Breakdown of these key areas into security infrastructure, access control, encryption, auditing and monitoring, backup and retrieval, systems redundancy, user awareness, user administration, training, physical access control, availably, systems recovery, disaster recovery and real time monitoring is important. Coming up with a security system is an elaborate task that requires the participation of all members of ESAALGM failure to which the implementation of the system may be erroneous and even detrimental to an organization. This complexity is often blamed for the misconception that have been developed on what constitutes a truly secure system and may be one of the factors that is central to the gap that appears to be between the near perfect theoretical security systems and practical implementation of security systems.
Research Question
A critical evaluation of the compliance systems of Kenya, an ESAAMLG member state.?
Hypothesis
The following hypothesis has been developed to aid in addressing the research questions:
- H0: To a large extent, ESAAMLG is not doing enough to curb financial crimes in Africa.
- H1: ESAAMLG is effectively applying strategies, policies and regulations to curb financial crimes in Africa.
Compliance and Significance
The legislations that regulate financial services industry in Kenya have grown significantly in volume, complexity and intensity.
With a combination of unparalleled data assets, analytical technology and tested linking, the prevention and subsequent solution toward Money Laundering has increased Kenya’s ability to:
Search risk and reduce exceptions efficiently
Create and monitor risk profiles across customer base in financial institutions
Keep an audit trail built to perform better due diligence.
Optimize the entire operation for better due diligence.
The study has largely been motivated by the role played by ESAAMLG in Africa. No one can deny the role played by this group in effecting security dynamics in the Eastern and Southern Africa region through strategies, policies and regulations and by defining requirements in operations.
The variable shown below has been used by Kenya in the past to regulate money laundering and corruption:
Solutions for the prevention of money laundering
Thorough Scan and Consumer Full Life Cycle Monitoring
Identity Verification
sanctions
Politically Exposed Persons (PEPs)
Companies and persons convicted
Negative media
Enhanced Due Diligence
The most recent data sets for a complete advice
Guest getting
Background check
Payment Verification
Guest Continuous Monitoring
Incident Management and Reports
Taking efficiency to Risk Management in Relationships Management Process
ESAAMLG through its strategies, policies and regulations provides a platform upon which financial operations may be done in line with the effects of globalisation and gain from advances that are being made in technology. The role played by an effective regulatory body in ensuring effective adherence to policies and rules is an important tool that be used to develop robust strategies that sustain financial operations irrespective of the nature of the operational environment. This implies that the study has the potential of affecting the quality of life that may be attained by people in the world irrespective of nationality; this is an important factor in ensuring sustainable development which is one of the key challenges that nations under money laundering, terrorism and corruption threats are currently faced with.
As it comes out in the discussion in this chapter, at a time when information technology has increasingly grown, it is expected to continue to create major negative implications due to its use by terrorist and money laundering groups and corruption networks. An effective application of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) policies and regulations form the best method of addressing the problem. The problem of money laundering came out as a well rooted issue at the local and international level. However, though Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) groups appear to have leaped greatly in the fight, it is far from over especially from poor cooperation with international organizations and the more developed countries.
Therefore, the ESAAMLG should seek to create more intensive technologies to identify and apprehend the launders in the society. Besides, it should also increase the penalties of the launders and assimilate better corrective methods to reduce resilience of similar habits. Finally, the international cooperation should be propagated further to trace launders even outside Africa with ease.
Actions taken by other regions
Identity verification
Preparation of data sets and search technology to identify individuals instantly, providing a quick getting customers, risk reduction, improved customer experience and important process efficiency.
Sanctions
Sanctioning individual financial accounts especially of individuals who have been suspected of malicious and corrupt activities is now common among many governments.
Accounts and Payments
Currently, all cash inflows and outflows are checked by financial institutions in order to make sure that money laundering does not find access into the financial system.
Negative media
Risk-based efforts have been used by several governments in order to reduce security threats posed by money laundering and corruption.
.
The identification of risks for individuals and businesses is efficient and of high quality due to unparalleled access to terror-related News, the largest source of information and business currently available. The latter provide a structured approach to identifying prevailing risks.
FATF and ESAAMLG and groups related to them are numerous in the world; owing to the global nature of financial crimes. Firms charged with the duty of addressing money laundering acts face a lot of challenges in the course of their duty due to the fact that the vice is determined by a lot of numerous complex factors, this is coupled by the fact that money-launderers and terrorists do not have definite manner of operation. It came out that successful approach therefore calls for complex monitoring strategies, particularly targeting political leaders.
Besides, a latest growing money laundering and terrorist financing method has been noted to be the internet, thanks to the complexity of curbing cyber crimes which has got multiple faces. But thanks to the implementation of the moves like the Suspicion Transaction Reporting (STR) schemes meant to expose underground criminal activities. This is in addition to Anti-Money Laundering/Anti-Corruption/Countering Financing of Terrorism (AML/AC/CTF) compliance. The jurisdictions on AML/AC/CTF should exploit newly emerging technologies to always stay steps ahead of the criminals. But until the vice is fought with a united front, gullible victims of financial crimes will continue to suffer and underground activities will still strive.
International cooperation and responsible approach by local law enforcement officials is imperative to stem out the rising tide of international financial crimes. International organizations like the Asian Pacific Group, the FATF, Committee of Experts on the Evaluation of Anti-Money Laundering and the Financing of Terrorism (MONEYVAL), the United Nations Office on Drugs and Crime (UNODC), the Organization of American States (OAS) and the International Monetary Fund (IMF) have all been established for that main purpose, namely to combat money laundering and terrorist financing. MONEYVAL similar to ESAAMLG in terms of the fact that it is a regional body established for Europe as a subcommittee of the European Committee of the Council of Europe on Crime Problems (CDPC) in 1997. Like ESSAAMLG, MONEYVAL is a FATF-style regional body and it operates under the mandate of the Council of Europe. MONEYVAL reports to the FATF. Asian Pacific Group, the FATF, MONEYVAL, UNODC, the OAS and IMF have continuously pressed for mandatory AML/AC/CTF compliance by promoting a positive political will.
From the analysis of the information contained in this chapter, it can be said that FATF and ESAAMLG have tried in their attempt to contain financial crimes in their areas of jurisdiction, but a lot of improvements still need to be made. As it is reflected, the rules and regulations on Anti-laundering policies should be made very stringent and accompanying penalties upon proof of the crime should be big and mandatory, running from compensation of the laundered amount to serving jail terms ranging from ten years to life imprisonment. Having weal legislative Anti-Money Laundering laws are an impediment to eradicating the vice, calls for a comprehensive legal framework to address the underlying corruption, terrorism and money laundering cases; no criminal offense should be left unpunished.
Moreover, an international cooperation link between the crimes relating to anti-corruption and those relating to anti-money laundering and counter-terrorism financing based on the argument of the paper shows that corruption is directly proportional to money laundering and terrorist activities. There is need that due to the fact that the corruption, money laundering and terrorism cases have gone global, addressing them should be given a global approach. It means that more institutions to address the problems need to be created and at the same time they should work in collaboration with each other having a unified goal of curbing financial crime. A cooperative approach will ensure that no country becomes habitable to corrupt individuals, active terrorists or money launderers. In the end, they will all be exposed and be compelled to face full force of the law—every country should have its own version of anti-corruption, anti-money laundering and counter-terrorism financing policies designed to address local crimes but with a global perspective.
It is evident that corruption, terrorism and money-laundering have the capacity to completely bring to the ground even the most promising economies, the devastating effects of financial fraudsters cannot be over-emphasized. They make the poor to sink deeper in poverty; the genuinely rich people are tricked into losing their money, while the terrorists and money-launderers make a kill. There is a dire need to institutionalize groups like the FATF and ESAAMLG as they will help cushion the underlying destructive effect of financial crimes. Terrorists are active all around the world looking for potential targets to strike not only to create economic loss, but also to create unnecessary tension, security threat and political instability. Their actions lead to nothing good, other than ill intent. Countries should be committed to not only protect their local borders, but also their international interests that terrorists may view as prime targets and that includes citizens in Diaspora, embassies and allies.
Besides, it clearly came out from the study that a collaborative approach and commitment from individual governments will protect borders and filter cross-border transactions, hence making it difficult for terrorist and money-laundering operations. Almost all countries in the world have clear jurisdictions addressing cash and goods transfer into and from its borders, such items that are suspected to be tied to any illegal intention are, therefore, seized and investigated.
The organized nature of money-launderers and terrorists calls for the implementation of up-to-date and modern approaches of anti-money laundering strategies with global effect. Any slackness, laxity, hesitation in executing the policies will mean that the terrorists will be way ahead of the groups created to address the vice, hence the ill activities will continue to thrive undeterred. A collaborative approach, a committed government and stringent anti-corruption, anti-money laundering and anti-terrorist rules will without a doubt bring desirable results in addressing the problem at hand. In conclusion, in absence of a relentless effort, personal accountability and adherence to the rule of law, the ills associated with corruption, money laundering and terrorist financing will never be eradicated, so the world should never give up the fight.
Chapter Two: Historical Background
Developing a clear understanding of issues involved in any research is significant in developing a vivid picture of what entails the roles of a study. It ensures that the approach a research adopts is placed in the right context. As it shall be examined, money laundering has become a distressing problem as launders continue to intensify their technology to implement their unethical objectives including, financing of terrorist activities and enhancing corruption. The latter is regarded as a link to financiers of terrorist activities and the actual terrorist acts.
This chapter highlights current laws and regulations that guide the Eastern and Southern Africa Anti Money Laundering Group (ESAAMLG). The chapter also points out the international policies and legislations that have been put in place in the recent past to curb money laundering in the two regions. For instance it is crucial to mention that other nations across the globe have put strict legislative measures that can be used to curb acts of terror fueled by money laundering.
However, the fight is considered to be far from over in that the same problem is highly recurrent in states that lack effective human, financial capital or the necessary goodwill to address it. It is from this consideration that analysts are asking whether it is indeed possible to fully eliminate the problem of money laundering or governments including governments within the Eastern and Southern Africa Anti Money Laundering (ESAAMLG) region should only focus in reducing its negative implications. The analysis of the mechanisms used by money launders globally brings out the magnitude of the problem.
On the other hand, the systems employed indicate the goodwill of the government to address the problem. Besides, the established legislations and comparison of the employed tactics with those of other countries indicates the position of the United States in fighting the problem globally.
One of the key considerations of ESAAMLG in its strategic plan is the enforcement of the various laws and policies it has established. It has been able to implement effectively FAFT standards while promoting financial inclusion through a joint effort with the Alliance for Financial Inclusion (AFI). Its regulations, laws and policies have been established through survey of member countries. The latter have ensured the AML/CTF laws are reviewed and amended to support financial inclusion. The laws spell penalties for money laundering acts which include transfer or conversion of funds which are proceeds of crime. This also includes disguising and concealing of such funds.
Terrorism is one of the key vices that the laws are seeking to impede. Money laundering provides an avenue for availability of money to fund terrorist activities. The fight against terrorism has been made cumbersome by the problem of more money from laundering activities and rampant corruption. Corruption opens borders for smuggling of funds and entry of terrorism thereby being a major contributing factor to the security of African nations. The Prevention of Terrorism Act of Kenya, an ESAAMLG member state, for example, defines terrorism an act intended to cause harm, bodily injury or death of civilians as well as taking of hostages. It provides penalties for the act of committing a terror activity. This also includes organizing terrorist acts and participating in terrorist activities. Financiers of terrorism directly or indirectly provide funds while corrupt officials collect funds in an attempt to allow terrorists to carry out their schemes. ESAAMLG strategies to curb this include freezing of suspected accounts, seizing of funds to await investigations and confiscation as well as shutting down of financial institutions funding criminal activities.
Some universal approaches which ESAAMLG has also embraced include heavy fines for non-compliance to the laid down regulations, increased sanction, screening of bank accounts and bank account holders and elimination of mystery account holders. Such strategies ensure that declaration and disclosure systems are utilized to detect monetary cross-border dealings.
The role of ESAAMLG in implementing policies in the fight against money laundering and corruption is regarded as one of the most important developments in the African region. It employs the mandate it has by setting up measures and strategies to ensure that the vice is mitigated locally and in a global scale. With adoption of the FATF recommendations in formulating policies and setting up a path for their effective implementation, one would easily agree that the development and implementation of procedures and protocols that aid its use in fighting financial crimes has developed into one of the most important milestones. Though the initial phase of where ESAAMLG gained considerable leverage in the fight against financial crimes over others by application of its policies may be long gone, the addition of the FATF recommendations plays a crucial role in shaping up ESAAMLG strategies and makes it one of the key operational factors.
Developments in both ESAAMLG policies and the introduction of the FATF recommendations have mainly been aimed at ensuring greater operational stability, improving the speed of the fight against corruption and money laundering and ensuring security against terrorism. Most of the recommendations apart from adding to functionalities are generally aimed at ensuring greater speeds and dealing with security threats that are faced by the nations in Africa. Procedures, policies and even standards have been developed with the sole aim of developing a clear approach employed by ESAAMLG in developing their strategies. This is significant in that it plays an important role in ensuring the development of more robust strategies.
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[37] Ibid 397
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