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This post was originally posted on the Alliance for Financial Inclusion (AFI) website.
In Tanzania, access to financial services for the unbanked expanded drastically when convenient and relatively cheaper options became available to receive and send money through simple feature mobile phones.
Four mobile network providers were in stiff competition in a market of 39 million registered mobile wallets (this registered wallet number does not include multiple wallet holders nor some of the dormant wallets from providers that did not exclude them after recycling their mobile numbers), 13 million of which were active ("active wallets" refers to the use of a mobile money account at least once in 90 days. This is the total number of all active accounts in the referenced month). This was in October 2014, when three of the four mobile money providers signed on to interoperability and made Tanzania the first country to successfully develop and implement standard business rules for interoperability (Source IFC: Achieving Interoperability in Mobile Financial Services: Tanzania Case Study).
By February 2016, the fourth provider had signed on and Tanzania was a global leader in the interoperability of digital financial services delivered by mobile network providers. How did this happen? This article highlights the key factors contributing to DFS interoperability in Tanzania.
Establishing an enabling environment
A regulatory environment nurturing competition and cooperation provided a foundation for dialogue and engagement around interoperability. The Bank of Tanzania, the country's central bank, played a monitoring role, ensuring that DFS providers offered services in compliance with risk mitigation frameworks (guidelines were issued that emphasized the use of international standards) that supported the dual objectives of financial stability and financial inclusion. This led to policies advocating for non-exclusivity in the use of mobile money agents and ultimately to agent interoperability. However, as the market continued to grow and mature, some market players demanded interoperability to kickstart client uptake, which had not seen rapid growth. Comprehensive interoperability was a clear need.
The Bank had to assume a leadership role in the push for sustainable interoperability. It opted for a market-based approach to interoperability, which was backed by evidence, and began to coordinate the process. It approved a neutral market facilitator, the International Finance Company (IFC) and the Financial Sector Deepening Trust (FSDT) of Tanzania, to facilitate engagement with DFS providers and reach agreement on an interoperable solution.
A market approach works
The IFC facilitated the industry-led interoperability project, with financial support from The Bill & Melinda Gates Foundation and the FSDT. This involved coordinating industry meetings to develop and reach consensus among mobile money providers on business rules and commercial agreements for interoperability and submit them to the Bank of Tanzania for consideration. This exercise began in September 2013 and, after several meetings in which participants reached a greater understanding of the regulatory framework, market demand, payment systems and rule development, consensus was reached. A year later, in September 2014, two of the four mobile network operators (MNOs) signed off on the wallet-to-wallet operating rules, which led to technical arrangements to initiate interoperability. In December 2014, the third MNO came on board. It took another year for the fourth to sign on, and by February 2016, Tanzania was one of the first markets in the world to have full interoperability of mobile money services (Figure 1).
Figure 1: Key Milestones for Mobile Money Interoperability in Tanzania
Other markets could learn lessons from Tanzania's journey. It is worth noting that although Tanzania was well-suited to a market-based approach to interoperability, with its supportive central bank, conducive regulatory framework, and a sufficient level of market competition and maturity, two other factors played an important role: (i) the value proposition for the private sector was taken into account; and (ii) private and public sector dialogue was enhanced through the public policy lens of financial stability and financial inclusion. This helped the regulator balance its dual mandate and ensure financial inclusion initiatives do not compromise financial stability.
The next frontier
Tanzania's interoperability journey is still underway: the market is currently expanding the use case for interoperable services through merchant payments and extending interoperable services beyond MNOs to banks and other players. This will also involve improving the clearing and settlement process, shifting from bilateral arrangements to a multilateral process that includes a switching process. The Bank of Tanzania is continuing to play a monitoring role and provides guidance and direction on a process that is efficient and creates value not only for market players, but also for users and other stakeholders. In the end, this will ensure the best solutions are implemented and satisfy both private sector and public policy objectives-a task guided by the same principles that led to interoperability in the first place.
About the Author
Kennedy Komba is currently Head of Strategy and Member Relations of Alliance for Financial Inclusion. Prior to this new role which he assumed in April 2016, he was the Senior Advisor of the National Payment System in the Bank of Tanzania. He is an Accredited Fellow of Macro-economic and Financial Management Institute of Eastern and Southern Africa (MEFMI) and a Fellow of Fletcher Leadership School for Financial Inclusion of Turf University, USA. He has experiences in financial inclusion policy, strategies and regulatory frameworks. He was instrumental in leading the development of the Tanzania regulatory framework for the National Payment Systems including electronic money regulations. He also was involved in the development of the Tanzania National Financial Inclusion Framework.
This post was originally posted on This Day Live.
The aim of any AML/CFT regime is to prevent, detect, interdict and control money laundering and the financing of terrorism. The global framework for this is adumbrated and elaborated in the Financial Action Task Force (FATF) 40 Recommendations on Money Laundering, and the Financing Terrorism and Proliferation (2012). In brief, the Recommendations set out measures, including AML/CFT policies and coordination; criminalization; prevention; transparency; as well as powers of competent authorities and international cooperation, for the prevention and control of these phenomena. The forty recommendations, the acceptable international standards against money laundering, terrorist and proliferation financing and are enforced globally. The enforcement of these measures is monitored through the FATF network process of peer review known as 'mutual evaluation'. Countries that are not members of the FATF or its Regional Style Body are targeted based on perceived deficiencies and risks from their jurisdictions and engaged by the FATF for the purpose of enforcing compliance with the standards.
The FATF Standards, even though referred to as recommendations have become powerful tools for combating transnational organized crime and their enforcement has become a major policy issue in all jurisdictions. Indeed, the spirit and letter of the standards have proven over the years to promote sanity and best practices and protect the international financial system. Thus, any country enforcing the standards does so in its own interests and not necessarily satisfying foreign obligations.
The Nigerian AML/CFT Regime
Although Nigeria is not a member of the FATF, it is a founding and active member of the ECOWAS Inter-Governmental Action Group against Money Laundering (GIABA), which is a FATF Style Regional Body responsible for the promotion and enforcement of the FATF standards in West Africa. Accordingly, Nigeria has committed to the full implementation of the international standards against money laundering, terrorist and proliferation financing. Nigeria's AML/CFT was the first to evolve in the west Africa, and indeed the whole Africa, because the Nigerian Money Laundering Decree No. 3 of 1995, even though it criminalized only drug money laundering, was the first piece of legislation against money laundering in Africa. Nigeria was the first country in West Africa to establish a specialized agency (the EFCC) for money laundering enforcement; the first to establish a Financial Intelligence Unit (FIU); and most importantly, it was Nigeria's leadership, in collaboration with the UNODC and the ECOWAS that led to the establishment of the regional body (GIABA). Unfortunately, however, and despite being the first to put in place the initial structures for AML, Nigeria missed the opportunity to become the first African country to attain a FATF membership, mainly because Nigeria's efforts were not properly coordinated and sustained.
By the FATF fundamental and technical criteria, Nigeria is no doubt a strategic country obviously because of the prevalence of corruption and money laundering, but mainly because of its GDP, the size of its banking and financial system, its integration with the international financial system, as well as its geographical and political influence in Africa. As a result of none response (in fact nonchalant attitude) of Nigeria to engage, the FATF was left with no alternative than to blacklist Nigeria among countries considered to be non-cooperative countries and territories (NCCTs) in 2001. Subjecting Nigeria to this process meant that Nigeria was perceived as a risky jurisdiction for business and all financial transactions with Nigerian banks were subjected to extra ordinary scrutiny - and embarrassment. But this did not stop the laundering of proceeds of corrupt enrichment from Nigeria in other jurisdictions anyway. I am not going into the details of the responsibilities of other jurisdictions here as it is not the aim of this article.
It took Nigeria six years of engagement to be removed from the NCCTs process in June 2006. One of the conditions for Nigeria's removal from the black list was for Nigeria's AML/CFT system to be evaluated by GIABA to ascertain its level of compliance with acceptable international standards. The first comprehensive mutual evaluation of the AML/CFT regime was carried out in 2008 and the report showed significant deficiencies, particularly in strategic areas like insufficient criminalization of the offences of money laundering and terrorist financing, lack of effective regulation and supervision of the financial system, inadequate records keeping of financial transactions, insufficient measures for the enforcement of United Nations Resolutions 1267 and 1373 with respect to financing of terrorism, and lack of mutual legal assistance law to facilitate effective international cooperation, among others.
These deficiencies again, made Nigeria to be subjected to the FATF review under its International Cooperation Review Group (ICRG) process in 2010. By subjecting Nigeria to the two FATF processes of global enforcement is not suggestive of Nigeria's strategic importance; but rather notoriety for non compliance, which is not good for the image and integrity of the country. Nigeria suffered the consequences and also had to invest both in human and material resources to get out of this process in 2013. As an active participant in all these processes, I feel very bad for my country and all this is blamed on lack of synergy and coordination of Nigeria's efforts. There are too many stakeholders in the AML/CFT arena, and yet leadership remains a huge challenge.
Within the framework of the GIABA processes, the ministers of Finance, Justice and interior in each country are responsible for AML/CFT, but the obvious responsibility going by the FATF standards lies with the minister of finance. I was told the Minister of Justice has this responsibility in Nigeria, and yet sixty percent of AML/CFT obligations lay within the financial sector. Furthermore, the key strategic technical deficiencies, notably, the lack of a mutual legal assistance, asset recovery and management laws, as well as harmonization of the money laundering and terrorism prevention laws are the responsibilities of the minister of Justice.
Vulnerabilities and Risks in the AML/CFT Regime
The main thrust of AML/CFT is the identification and mitigation of risks. That is why the international standards place emphasis on risk assessment, which Nigeria has recently done but the report is yet to be released. Without pre-empting the outcome of the risk assessment, I know for certain that since 2013 after Nigeria was removed from the FATF ICRG Process, the following fundamental weaknesses remain in its AML/CFT regime:
- Absence of compressive mutual legal assistance legislation;
- Lack of Proceeds of Crime Law;
- Lack of harmonization of the various amendments made to the Money Laundering (Prohibition) and the Prevention of Terrorism Acts 2013 to make them consistent with acceptable international standards;
- Ineffective coordination of the overall AML/CFT regime;
- Controversy surrounding the status and location of the Nigeria Financial intelligence Unit (NFIU);
- Lack of credible records of statistics on the achievements in AML/CFT;
- Obvious or visible patterns of money laundering through various methods, including massive outflow of cash, real estate and the prevalence of corruption;
- Poor records of dealing with 'high profile' corruption cases, most of which remain inclusive; and
- Weak beneficial ownership and legal arrangements, among others.
It should be noted that these weaknesses are within the technical compliance requirements; meaning that there is more to be done to achieve effectiveness as a pre-requisite for the next round of evaluation under the revised FATF Standards.
Rather than for Nigeria to focus on addressing the strategic deficiencies in its AML/CFT, which would automatically give it credit and recognition to become a member of the FATF if that is Nigeria's ultimate objective; there is a misplaced priority on Nigerian officials' participation in FATF Plenary meetings to "observe and learn" nothing that is not already known on AML/CFT. How can that change the system back home other than draining resources? It is disappointing, to say the least, that many countries, most of which are less endowed than started the process after Nigeria, but due to their commitment and prioritization of actions, they have surpassed Nigeria in many aspects. This is why my own contribution is not a critique per se, but a call for rescue to address the weaknesses in the Nigerian system.
Nigeria's Membership of the FATF
Becoming a member of the FATF is desirable for Nigeria, but it is not a priority. What is a priority and important for Nigeria is to review its AML/CFT architecture and address the specific technical deficiencies that would provide the building blocks for a solid regime. Without those building blocks being in place, little can be achieved in terms of effectiveness, talk more of aspiring to become a member of the FATF. In any case, Nigeria can play a leading role within the regional AML/CFT framework that can earn it the respect of the international community and by so doing, becoming a member of the FATF will be much easier. In fact, the FATF will be the one courting Nigeria rather than Nigeria struggling to become a part of it.
At any rate the criteria for attaining FATF membership are clear and these include the technical requirements that a country must achieve nothing below the rating of largely compliant on the core recommendation 3, which has do with criminalization of money laundering; recommendation 5, which has do with criminalization of terrorist financing; recommendation 10, which deals with customer due diligence; recommendation 11, on records keeping; and recommendation 20, on reporting of suspicious transactions. Can the current status of the NFIU achieve this requirement?
The Status and Location of the NFIU
Practitioners in the AML/CFT cycle have always asked and would be eager to know my view with respect to the seemingly controversial status and location of the NFIU. I have come to realize that the problem with the NFIU is not with its operational independence as most people would claim, but with a misplaced notion of who is in charge of what and a misperception of public office as a personal and life time vocation. Perhaps the most credible arguments in the controversy for a review of status and location of the NFIU are that: (1) the EFCC being a law enforcement agency cannot at the same time be the FIU of Nigeria as contained in section 1 (2) of the EFCC Establishment Act; and (2) the NFIU has not been administered professionally to make it truly a centralized authority for all law enforcement agencies to derive financial intelligence from it, rather, it is perceived as the property of the EFCC. Indeed, we must acknowledge the foresight and good leadership of the EFCC in establishing and strengthening the NFIU, but since we must conform to acceptable standards, what is required is either to enact a standalone law establishing the FIU according to the Egmont standard, or amend the EFCC Act to say the FIU is located within the EFCC as it has to be located somewhere anyway.
There is no proof that the FIU can be better in any other location other than where it is at the moment. After, all what is in a location? It is instructive to note that what is required is the operational autonomy and financial independence of the FIU and its ability to serve all law enforcement agencies. That can be achieved through either of the two alternatives contemplated here. This seems to be a hard nut to crack, but it must be done somehow if the system must work very well.
Conclusion and the Way Forward
Anti-money laundering and counter financing of terrorism is an important element of the fight against corruption, which is one of the main thrusts of the government of Nigeria. Yet, since 2013, no significant input has been added to the AML/CFT framework. As Nigeria seeks to strengthen democracy by reinforcing rule of law, there is no alternative to strengthening the mechanisms for accountability, including a robust ML/CFT regime. These issues are neither academic, nor are they political, inspite of the legislative processes; they are purely technical issues, which require technical expertise to address. With South Africa as a member of the FATF and with Egypt nearer to attaining membership, the regional balance that FATF sought for may have been achieved to some extent. However, it would still be a fact that sub-saharan African is not represented and it would be a disappointment if any other country will overtake Nigeria and become a member of the FATF. The second round of the evaluations have already commenced and if the Nigerian system remains as it is with the strategic deficiencies mentioned earlier on, Nigeria's leadership and influence in AML/CFT will diminish regrettably. Time is of the essence and a word is enough for the wise.
About the Author
Abdullahi Shehu is a Professor of Criminology and former Director General of the ECOWAS Inter-Governmental Action Group against Money Laundering (GIABA).
First published on the Milken Institute Blog website.
A key step in developing a local capital market is to develop the "buy side"-to encourage greater participation of local institutional investors such as pension funds and insurance firms. If managed well, these pools of savings can become important sources of long-term financing, including for infrastructure, which can drive socioeconomic growth.
The share of residents in East African Community (EAC) countries Kenya, Rwanda, Tanzania, and Uganda who access pension and insurance products is still small, although growing. Savings managed by local institutional investors in these countries nearly doubled in just four years, to about $19 billion by early 2016. We recently surveyed buy-side institutions in these four countries to ask how they are managing savings across asset classes and EAC countries. See the findings here.
We found that most of these investors want to further diversify their portfolios, but they are impeded largely by a lack of investable securities and risk-management products that allow them to invest in a way that meets their aims. This points to a need in these markets for more long-term investment vehicles, in particular-as well as market participants. For example, a large majority of surveyed investors showed strong interest in new vehicles such as a regional "fund of funds" that could pool their resources and manage risk by investing across diverse infrastructure projects by sector and country.
There already are clear signs that pension funds, in particular, have been diversifying their portfolios over the past decade-shifting further away from the most liquid asset classes. Surveyed pension funds hold an average of just 1 percent in cash and demand deposits across the EAC focus countries. And pension fund and insurer investments in short-term government securities typically fall well below national and even internal ceilings. Survey findings show pension funds generally hold much more in longer-term than short-term government securities. But very limited corporate bond holdings, even for pension funds, is at least partly the result of small market size and lack of product.
Our findings also show that tiny allocations so far to private equity and venture capital (PE/VC) reflect limited experience and capacity evaluating these new asset classes-more so than lack of demand or investment limits. In fact, national regulatory approaches are still evolving. Greater clarity on how regulators will treat these new asset classes may encourage more investment. While certainly not risk-free, some investment in PE/VC as part of a well-managed portfolio could help generate returns. At the same time, it will be important to boost risk-evaluation capacity among regulators, investors, and financial intermediaries.
How do national regulations affect how these investors manage their portfolios? We found that in most cases, national regulatory investment limits are not the binding constraint preventing local institutional investors in the EAC from further diversifying their portfolios. Their actual allocations to public equities and corporate bonds generally fall well below national regulatory caps. And internally set targets tend to fall well below national ceilings-as does actual investment in these securities.
Around half of investors said they invest some of their portfolio assets outside their home countries-typically in other EAC countries. How can these EAC markets draw on regional ties to attract institutional investors? Roughly half of survey participants said access to better strategies and instruments for managing foreign exchange risk would make them more likely to invest in assets across EAC borders.
We found that some investors may not be clear on the intraregional restrictions by asset class they actually face. Regulators should step up communications with investors to ensure they clearly understand both the limits and opportunities in how they invest within the EAC and across asset classes. A well-functioning buy side can reduce an economy's reliance on foreign portfolio investors, increasing its resilience to sudden capital inflows and outflows. Further progress on intraregional integration within the EAC may help mitigate some of the risks associated with cross-border investment. Limited investable securities in local capital markets strengthens the case for easing or harmonizing restrictions intraregionally. This, in turn, could improve market liquidity, deepen the EAC's capital markets, and make it easier for local institutional investors to diversify their portfolios.
Our complete survey findings are available here.
About the Author
Jim Woodsome is a Senior Research Analyst at the Milken Institute's Center for Financial Markets. In this role, he conducts research, organizes events and helps manage initiatives related to the Center's Capital Markets for Development (CM4D) program.
First published by FSD Africa on 9 February 2017.
Nearly a year ago, we joined the A2ii in Abidjan to sit down with a roomful of regulators to discuss the challenges and imperatives CIMA faces in regulating mobile insurance at the CIMA-A2ii Workshop on Mobile Insurance Regulation. In the CIMA context, as with most countries in Africa, mobile network operators (MNOs) and the technical service providers (TSPs) that support them are emerging as key players in extending the reach of insurance. The discussions at the workshop focused on how insurance regulators can broaden their focus to include these MNOs and TSPs, as well as how to cooperate across different regulatory authorities.
A year on, these considerations remain as valid as ever, but we have come to realise that there is more at stake than m-insurance. Digital technology is changing the insurance landscape as we know it by paving the way for new players and business models with the potential to rapidly expand coverage. This is causing a re-think of how insurance is traditionally delivered. In addition, while m-insurance remains important, looking beyond m-insurance to the broader insurtech field is important to truly understand the opportunities technology provides to change the game in inclusive insurance and the associated risks.
Thus far, the insurtech debate has largely focused on developed country opportunities. But the tide is turning. My colleagues and I recently scanned the use of insurtech in the developing world to see what the potential is for addressing challenges in inclusive insurance. We found more than 90 initiatives in Asia, Latin America and sub-Saharan Africa that fit the bill. What we saw is that the "insurtech effect" is happening in two ways.
Firstly, digital technology is a tool to make insurance as we know it better: it is being used as a backbone to various elements of the insurance life cycle, in an effort to streamline processes, bring down costs and enable scale. Examples include new ways of data collection, communication and analytics (think big data, smart analytics, telematics, sensor-technology, artificial intelligence - the list goes on), as well as leveraging mobile and online platforms for front and back-end digital functionality (such as roboadvisors, online broker platforms, mobile phone or online claims lodging and processing, to name a few!). It also allows for more tailored offerings: on-demand insurance initiatives are covering consumers for specific periods where they need that cover, for example for a bus ride, on vacation or when borrowing a friend's car for one evening, while advances in sensor technology mean that insurers can adapt cover and pricing based on usage, for example allowing customers to only pay car insurance for the kilometres they actually drive every month.
In all of the above, digital technology, including the application of blockchain for smart contracting and claims, makes the process seamless.
Secondly, digital technology is a game changer. In many ways, it is changing the way insurers do business, design and roll out their products, and, importantly, who is involved in the value chain. Peer to peer platforms (P2P) are a much-discussed example of these next generation models. They are designed to match parties seeking insurance with those willing to cover these risks. The revolutionary element lies in the ability to cover risks that insurers usually shy away from due to the lack of data to adequately price the risks - all now enabled by digital technology. But these platforms are often positioned in regulatory grey areas: if all the platform does is match people to pool their own risks, does it then need a licensed insurer involved? And if advice is provided by a robot powered by an algorithm, who is ultimately accountable? No wonder insurance supervisors are sitting up straight when you mention the word "tech". As Luc Noubussi, microinsurance specialist at the CIMA secretariat, said at the 12th International Microinsurance Conference in Sri Lanka late last year: "Technology can have a major impact on microinsurance, but change is happening fast and regulators need to understand it".
So, how do they remain on the front foot in light of all of this, what different functions, systems and players do they need to take into account and what are the risks arising? In short: how can they best facilitate innovation while protecting policyholders? Front of mind is how current regulatory and supervisory frameworks should accommodate new modalities, functions and roles - many of them outside the ambit of "traditional" insurance regulatory frameworks - and what cooperation is required between regulatory authorities to achieve that.
Two weeks from now we'll again be sitting down with regulators from sub-Saharan Africa for the Mobile Insurance Regulation conference hosted in Douala, Cameroon, from 23 - 24 February 2017 by the A2ii, the IAIS and the 14 state West-African insurance regulator, CIMA, supported by UK aid, FSD Africa and the Munich Re Foundation. This conference will delve into the opportunities that mobile insurance present and the considerations for regulators and supervisors in designing and implementing regulations to accommodate it. The imperative to find an m-insurance regulatory solution remains, but it is clear that the horizon has broadened: at play is the way that insurance is done across the product life cycle, who the players are in the value chain and, at times, the very definition of insurance.
As we suggested in an earlier blog, this could be microinsurance's Uber moment, but then regulators need to be on-board. We look forward to taking part in the discussions to see how supervisors plan to do just that.
About the Author
Catherine Denoon-Stevens is a Senior Research Associate at Cenfri and has been part of the team since 2012. At Cenfri, her research has focused on building access to inclusive insurance markets, specifically the harmonisation of insurance regulation within the Southern African Development Community (SADC) region; innovative financial services distribution models; and Making Access to Financial Services Possible (MAP) studies in Southern Africa and South Asia. In addition, she is part of the team that runs Cenfri's capacity building portfolio, coordinating open-enrolment and in-house executive education trainings in microinsurance and national payment systems.
Let me begin by wishing you all a very happy and prosperous 2017, on behalf of all of us at the MFW4A Secretariat.
2016 was a rewarding year for MFW4A. We were proud to host the first Regional Conference on Financial Sector Development in African States Facing Fragile Situations (FCAS) in Abidjan, Cote d'Ivoire, jointly with the African Development Bank, FSD Africa, and FIRST Initiative. The conference attracted some 140 policy makers, business leaders, academics and development partners from over 30 countries, to discuss the role of the financial sector in addressing fragility. The conference has already led to several initiatives by MFW4A and our partners in the Democratic Republic of Congo, Liberia, Sierra Leone and Somalia. We expect to build on this work in 2017.
Our support to the Conférence Interafricaine des Marchés d'Assurances (CIMA), the insurance regulator for francophone Africa, helped them to secure financing of EUR 2.5 million from the Agence Française de Développement. The funding will help to expand access to insurance in a region where penetration rates are less than 2% - well below the average for the continent. We worked closely with a number of our funding partners to help define their strategies in Digital Finance and Long Term Finance. These results are a clear demonstration of how the Partnership can directly support the operations of its membership.
With the support of our Supervisory Committee, we took steps to ensure the long term sustainability of the Partnership. The approval of a revised governance structure which fully integrates African financial sector stakeholders, public and private, was a first critical step. The ultimate objective is to expand membership and build a true partnership of all stakeholders in Africa's financial sector.
2017 will be a year of transition for the Partnership. It marks the end of MFW4A's third phase, and the beginning of its transformation into a new, more inclusive partnership, with an expanded membership. We will focus on revamping our value proposition to provide more focused, needs based services with the potential to directly impact our current and potential membership. In so doing, we hope to consolidate MFW4A's position as the leading platform for knowledge, advocacy and networking on financial sector development in Africa.
In closing, I must, on behalf of all of us at the MFW4A Secretariat, thank all our funding partners, stakeholders and supporters, for your constant support and encouragement over the years. We look forward to working together to strengthen our Partnership.
With our best wishes for a happy and prosperous 2017,
MFW4A Partnership Coordinator