Somalia/money transfer: Barclays Decision Threatens Efforts to Build
Lasting Peace and Security – By Laura Hammond

July 9, 2013

Abdirashid Duale - CEO of Dahabshiil - has called on Barclays to
reconsider withdrawing banking services to money transfer companies.

A recent decision by Barclays Bank to close the accounts of 250 money
transfer organisations working around the world will have a
particularly severe effect on Somalia’s efforts to emerge from two
decades of conflict. The timing of this decision could not have been
worse; just when the country has formed the first government to be
internationally recognized in two decades, when piracy is at a
historic low, and the al Shabaab insurgents seem to be weakening, the
main channels by which remittances, foreign investment and
international aid funds flow to reach those who need them are in
danger of being closed down.

A study recently conducted by FAO’s Food Security and Nutrition
Analysis Unit, based on interviews with over 700 households in
Puntland and Somaliland, estimated that 42% of the population relies
on remittances. These funds are used for basic food, education and
medical expenses, as well as to start up small businesses and settle
debts. One third of recipients said that if remittances were stopped
they would not be able to afford basic food. More than 80% of the
sample relies on a single sender of remittance support, and 93% of
recipients get their money through Somali money transfer
organisations.

If Somali money transfer companies lose their accounts with Barclays,
not only will members of the diaspora living in the UK and many other
European countries be unable to legally send money to Somalia, many
aid agencies will also have difficulty. Money transfer companies need
the services of a bank in order to transfer funds from the UK to a
holding company, usually located in Dubai. From there traders with
letters of credit are able to withdraw funds in hard currency,
repaying the credit inside the Somali territories in local currency.
This makes it possible for money to circulate without having to incur
the risks associated with being physically imported or exported. In
addition, money service businesses must have a bank account with an
accredited bank in order to remain licensed by the Financial Services
Authority to operate; if they lose their accounts they will lose their
licenses and be unable to operate legally not only in the UK, but in
most of the rest of Europe and in Ethiopia.

According to Abdirashid Duale, CEO of Dahabshiil, the largest of the
Somali money transfer organisations, “Over 95% of the international
organisations in Somalia, including the United Nations, World Health
Organisation, World Bank, Oxfam and Save the Children, rely on
[Dahabshiil] to provide payment services for their staff, contractors,
government institutions and partner NGOs.”

Asked what the impact would be if Barclays’ accounts with Somali MSBs
were closed, Abdirashid Duale said, “The suspension of remittances to
Somalia by Barclays will destroy Somalia’s only success story – its
vibrant, resilient economy.  Income from remittances is absolutely
vital to many Somalis.  Preventing them will certainly lead to
enormous economic hardship and deprivation, to aid and development
monies decreasing, and to a significant increase in illegal money
transfers…For 20 years terrorists and warlords have tried, but failed,
to destroy the region, I urge Barclays to understand that their
proposed actions have to ability to do what the warlords couldn’t, and
hope with all my heart that they will reconsider.”

The reasons for Barclays’ statement remain opaque. In its letter to
Dahabshiil, a company with which it has been doing business for more
than fifteen years, a representative of Barclays said:

“Please understand that the decision to exit our business relationship
with you is not a negative reflection of your Anti-Money Laundering
standards, nor a belief that your business has been unwittingly been a
conduit for financial crime. It is, however, a commercial decision
that we have taken due to the risks of the sector in which you
operate.”

This contrasts with a subsequent public statement from Barclays, which
said “It is recognised that some money service businesses don’t have
the proper checks in place to spot criminal activity and could
unwittingly be facilitating money laundering and terrorist financing.”
The money service businesses whose accounts are threatened with
closure say they have not been told which checks are lacking, and that
there is no evidence that they have been engaging in illegal activity.

Given that the decision to close MSB accounts is applied not only to
Somali companies but to those working elsewhere, it does not appear
that it is motivated by dynamics going on inside the Horn of Africa.
Rather, the decision to curtail its business with these companies is
more likely to be motivated by concerns about the legal, financial and
reputational liabilities after HSBC bank was hit with a $1.9 billion
fine in 2012 for being implicated in money laundering schemes.  There
does not appear to be any link between this case and parties
associated with Somalia.

Coming on the heels of a major international conference on Somalia
hosted by the UK and Somali governments in London in May, in which
donors pledged over $300 million in assistance to develop the
country’s armed forces, police, justice sector, and public financial
management systems, it is ironic that the main obstacle to delivering
that aid should come from a UK-based bank.

The reasoning that money service business accounts are to be closed to
prevent money laundering and terrorist financing is counter-intuitive.
Closing legal channels of transferring money will only encourage
people to send money, either for legitimate or ‘nefarious’ reasons,
through illegal channels. This will make tracing the flow of funds
impossible, and will greatly increase the likelihood that funds will
channelled for these illegal uses. A black hole of accountability will
develop. It would seem that a serious attempt to crack down on these
practices would be to increase regulation, transparency and monitoring
rather than to force it underground.

On 23 June a group of 105 academics, researchers and practitioners
sent a letter to Mark Simmonds, MP, Foreign Office Minister for
Africa, asking the UK government to intervene to ensure that trading
practices with regard to money transfer companies are fair and
transparent. The letter asked for government support in facilitating a
dialogue between banks, money services businesses, and government to
try to find a way out of the impasse that would enable funds to
continue to be transferred. It also asked for government support for
the request for complete disclosure of the evidence that Barclays
claims it has that the companies concerned are not in compliance with
existing regulations, or clear delineation of the steps that would
need to be taken to restore Barclays’ confidence in the companies, as
well as a period of six months in which companies could revise their
procedures to ensure that they are in full compliance.

Similar requests have been made by a group of 180 Somali civil society
groups, international NGOs, the President of the Somalia Federal
Government, and many other concerned groups and individuals.  More
than 1100 concerned people throughout the world have signed a
petition.

In response to the pressure, Barclays first granted a one-month
extension to some of the companies, and has left the door open to the
possibility of further extensions. What it has not done is provide
sufficient details about where it thinks that companies are not in
full compliance with the law or with corporate policy. In a response
to the academics and practitioners’ letter, Barclays CEO Antony
Jenkins said , “We appreciate that our decision, and decisions made by
many banks for similar reasons, will have potentially difficult knock
on effects such as those you outline in your letter and we have
already provided double the legal notice period in such cases but are
also looking at requests for reasonable extensions sympathetically.’

This letter seems to suggest that there is a glimmer of hope that a
crisis can be averted, but a one-month extension, coming during
Ramadan – the peak period for sending remittances – is unlikely to be
sufficient.

There is an urgent need to keep up the pressure on Barclays and the UK
government to participate in discussions aimed at solving this
problem. In the medium to long term, there may be a need to reconsider
existing regulations or methods of ensuring compliance, introducing
more stringent rules to prevent these channels from being misused, or
of creating new banking mechanisms that provide government guarantees
to give more protection to private banks working with MSBs. However,
time is running out, and these steps would take time. In the short
term an agreement is needed to help keep the remittance and aid
channels open.

Laura Hammond is Senior Lecturer at SOAS.

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