Africa Finance Forum Blog

Interoperability of Digital Financial Services in Tanzania

10.04.2017Kennedy Komba, Head of Strategy and Member Relations, AFI

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.

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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.

What do we know about remittances and forced displacement?

10.04.2017Kirsten Schuettler, Senior Program Officer, World Bank

This post was originally posted on the World Bank - People Move website.

Over 65 million persons were forcibly displaced worldwide due to conflict and persecution at the end of 2015. Many of them remain displaced for a long period of time. Personal transfers sent to refugees and Internally Displaced Persons (IDPs) can contribute to livelihoods in protracted situations and increase self-reliance. Existing evidence suggests that they can be an important source of income, sent from the diaspora in third countries or from families and friends left behind. They can also play an important role in helping set up economic activities in protracted situations. At the same time, refugees and IDPs also send remittances, to refugees and IDPs in other places or to family and friends back home during times of conflict and peace. As their main reason for moving was not economic, their remittance behavior and the challenges they face might differ from economic migrants and might change over time. Policy frameworks and regulations can limit or promote refugee and IDP access to remittances.

However, there is a lack of knowledge on remittances send to and from refugees and IDPs. Research has mainly explored remittances in the context of economic migration. A literature review conducted for the Global Knowledge Partnership on Migration and Development (KNOMAD) showed that there is almost no research on transfers sent and received by those internally displaced and the evidence on refugees is concentrated around a few country case studies. There is also a scarcity of quantitative research. A better understanding of remittances in forced displacement situations can help policy makers design policies and regulations to maximize their positive impacts and minimize the risks.

A KNOMAD workshop brought together leading researchers and practitioners in this field to define key research gaps from a policy perspective, identify solutions for methodological challenges and develop ideas how to improve the evidence base.

Among the key issues identified was understanding the regulatory environment and its impacts on the number of formal remittance service providers available to refugees and the costs of using them. The regulations are, on the one hand, linked to the legal status of refugees (and might in some cases serve to deter them from coming and/or integrating into the host country). These regulations might or might not allow them to officially send remittances, open bank accounts, provide the required identification documents and travel to use the services of different remittance service providers. On the other hand, there are financial regulations that are linked to security concerns, notably the AML/CFT and KYC regulations, and how the private sector implements these regulations. The second priority identified was understanding the role of remittances in the livelihoods of the displaced and how this is influenced by policies in the host country (like the right to work or set up businesses).

Regarding the data sources, participants agreed that further research should focus on quantitative approaches but triangulate the results, and include research over time (longitudinal data). Besides conducting new surveys, existing data sources should be exploited. The literature review prepared for the workshop listed a number of further data sets that have information on transfers and allow to identify refugees or IDPs but have not been exploited by researchers yet (see annex 2 of the literature review). Participants also recommended including more questions on refugees and IDPs and their remittances in ongoing household surveys, to see if it is possible to oversample refugees and IDPs, and to exploit UNHCR registration data. Furthermore, data collected by Central Banks and remittance service providers should be accessed and used. Remittance price comparison websites also generate data that have not been analyzed yet, and could potentially generate even further data. The workshop also triggered further ideas on exploiting synergies with humanitarians working on the establishment of cross-border cash transfers.

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About the Author

Kirsten Schuettler is a Senior Program Officer at the World Bank's Development Economics - Global Indicators Group. In the Migration & Remittances team her responsibilities include monitoring remittances flows to the MENA region and contributing to the implementation of the Global Knowledge Partnership on Migration and Development (KNOMAD).

Can West African households dream of purchasing a home?

27.03.2017Caroline Cerruti, The World Bank & Olivia Caldwell, Affordable Housing Institute

110 million people currently live in the WAEMU region; over the next twenty years, an additional 100 million more will be born. Most of them will be urban dwellers, as the area is experiencing rapid urbanizing. This trend is aggravating an already large housing deficit, which mostly affects lower income groups in a context of widespread poverty (about 43 million live below the extreme poverty line). In Abidjan alone, 40,000 additional new households come to the city every year. Municipalities are struggling to keep up with population growth and rapid urbanization and as a result informal settlements and slums are growing.

So how can the growing housing deficit be addressed?

Making housing finance more affordable will enable a greater number of households to purchase a home. The latest data (2013) indicates low mortgage penetration with region-wide residential mortgage lending at just 15,000 new loans, despite a documented need for nearly 800,000 homes a year. WAEMU governments are acutely aware of the demand-supply challenges, and most have developed ambitious programs to build affordable housing; however, these are not enough to meet the existing demand and the quantum of public spending required is not sustainable. Instead, country and regional policies should leverage the resources of the financial sector to grow effective demand by increasing affordability via reductions in monthly required payments.

Fortunately, the WAEMU region presents some of the best conditions in sub-Saharan Africa to develop housing finance. The peg of the FCFA to the Euro has imported low inflation and favored macroeconomic stability creating an ideal environment for lengthening loan tenors. By contrast, rates in Nigeria, Kenya, Uganda and Ghana are double digits, reaching above 30% in Ghana.

Short loan tenors present one of the greatest constraints.

Currently, average mortgage interest rates are 7.5% with loan tenors of 7 to 8 years. If we consider the cheapest formal house priced of FCFA 7 to 11 Million (USD 11,300 to 17,800), a household needs a minimum annual income of USD 6500 to 10000 in order to afford it. When the loan tenor is lengthened to 15 years, the income required is lowered by 40%. Extending tenors with fixed rate loans has a much greater impact than lowering the rates themselves. We have estimated that by increasing tenors to 20 years, up to 1.5 million additional households will be able to afford the cheapest currently available houses on their local market.

So what can be done to lengthen tenors and increase affordability?

Five years ago, the WAEMU governments and the private sector acted by establishing the Caisse Regionale de Refinancement Hypothecaire (CRRH), a public-private regional liquidity facility that refinances banks' mortgages by borrowing in the domestic markets. Since 2012, it has issued six bonds, which helped provide ten year loans to banks to refinance their mortgage portfolio, thus allowing them to make customers' mortgages affordable by extending the tenor.

These efforts should be encouraged. The CRRH has so far only refinanced over 4000 loans, which is little compared to the needs. Longer term financing into the CRRH would allow it to refinance banks at longer maturities. At the same time, the CRRH should look at ways to refinance the large microfinance and cooperative networks which are in good standing and are interested in extending housing loans. Over 70% of WAEMU households work in the informal economy, are excluded from the banking sector and rely on microfinance networks for their financing needs. Supporting the CRRH with long term financing will enable banks and microfinance institutions to gain access to long term liquidity. The results will be directly captured by households who will have access to longer term loans and thus increase their home purchasing power.

Will this be enough?

The housing value chain in the WAEMU region presents many weak links that need to be addressed in order to promote a healthy housing market. Access to clean property titles remains a significant issue which continues to curtail both the supply and the demand side of the value chain. Though some countries have implemented reforms to improve their land systems (new Code Foncier in Benin in 2013, Reform Sheida in Niger in 2006, and digitization of the tilting agency in Cote d'Ivoire), these reforms have yet to pick up speed and be implemented at the regional level. The construction of affordable housing must also be supported as government programs have proved slow and mostly target public sector employees. Finally, rental housing should not be left behind as home ownership is not the only option to promote a better quality of life.

The affordable housing sector is in the process of being catalyzed. There is now a widespread awareness in all WAEMU countries that something must be done to address the urbanization and population growth. Steps are being actively taken to address the housing deficit across the region. We believe that through the supported development of CRRH, the dream of buying a home is at last within grasp.

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About the Authors

Caroline Cerruti is a Senior Financial Sector Specialist in the Africa region of the World Bank. She works primarily on housing and infrastructure finance, financial sector restructuring issues, and financial inclusion. She has been involved in various financial sector assessments jointly with the IMF. Before joining the World Bank, Caroline worked for the French Treasury on trade and financial regulation issues, and for three years as a banker in the European Bank for Reconstruction and Development. Caroline was educated at the Institute of Political Science in Paris (Sciences-Po), the Ecole Nationale d'Administration (ENA) in Paris, and is a CFA Charterholder.

Olivia Caldwell is Project Manager at the Affordable Housing Institute (AHI) where she focuses on housing development and finance in Sub-Saharan Africa and Haiti. Before joining AHI, Olivia worked with CEMEX and Bayer's Inclusive Business Platform, where she helped develop energy efficient affordable housing and infrastructure projects in Latin America and South East Asia. Olivia holds an Executive MBA at the London School of Economics and an MA in Sustainable Development from the United Nations Mandated University as well as a BA in Anthropology from McGill University.

Expanding access to finance for smallholders one lease at a time

27.03.2017Ashley Olson Onyango, Programme Manager, Agricultural Finance

This post was originally posted on the Rural & Agricultural Finance Learning Lab website.

In rural sub-Saharan Africa, working in agriculture tends to be an extremely labor-intensive job with high risk and low payoff. As a result, new generations of farmers and other entrepreneurs are often deterred from pursuing a career in agriculture. This leaves the agricultural industry with ageing farmers and declining agricultural production. One potential solution, however, is the mechanization of farming which can help decrease the need for hard, manual labor, while also improving production, household incomes, and livelihoods. A shift to tractors and other machine-powered equipment is part of a broader strategy to improve rural livelihoods and make agriculture attractive for new generation of farmers.

Although this shift may seem easy, the challenge is that tractors and machine-powered equipment are expensive - and access to finance is frequently cited as a key barrier to increased investment and productivity for smallholder farmers in sub-Saharan Africa. Farmers struggle to mobilize the resources required to effectively invest in their land without additional financial support, but at the same time, lack adequate collateral to access credit from financial institutions.

Financial Sector Deepening Africa (FSDA) and Nathan Associates recently published the Agricultural leasing market scoping study for sub-Saharan Africa, which directly tackles the barrier of adequate collateral. In fact, a key advantage of leasing is that it doesn't require collateral, since the lessor retains ownership of the asset for the duration of the lease contract. That being said, lessors still need to mitigate their risk by taking an initial down payment from lessees. Specifically, "in agricultural leasing, concerns around willingness to pay, crop failure, and asset depreciation all drive up the size of the initial payment required by financial institutions."

The required down payment on agriculture equipment typically varies by region and product. For example, in developed countries the required down payment is generally in the range of 10% to 20%. Compare this to developing countries, where the FSDA study found that in the eight reviewed - Ethiopia, Ghana, Kenya, Mozambique, Nigeria, Tanzania, Uganda and Zambia - downpayments generally range between 20% to 40% of the value of the asset. This is a threshold that is above what most smallholder farmers can pay - creating a significant barrier to accessing leasing products, which ultimately holds back demand.

One recommendation to overcome this challenge is to establish a fund that would increase market access for financial leasing by reducing the credit risk of leasing companies. For instance, a fund could bridge the gap between what potential lessees are able to pay and what lessor's risk policy deems an acceptable down payment. If the lessee (farmer) can make a 10% down payment, but the lessor requires a 30% down payment, the fund could make up the difference by paying the 20% differential. The 20% would be paid directly to the lessor, so the lessor receives their full 30%. The lessee ends up only paying the ten percent that he or she is able to afford at that time. The 20% paid by the fund becomes a separate loan and with every lease payment from the lessee to the lessor, a percentage of that amount is paid back to the fund to cover the 20% loan.

A potential fund to make lease finance more accessible, as FSDA's report recommends, could address customers' needs for an innovative product that tackles the issue of adequate collateral for financial access. Furthermore, it could address the challenges that suppliers of such financing face by buying down some of the risk and making an entry into this sector more attractive. We might call this a "smart subsidy" that could be transformative if well designed and executed by strong partners (see Inflection Point for context on "smart subsidy").

To bridge the gap of finance and improve rural livelihoods, development financial institutions should ask themselves what role they can play in making this new form of finance accessible to the agricultural sector - promoting growth and mechanization for improved livelihoods through the fund. While leasing finance is just one piece of the puzzle, the country scoping sheds light on how to enter this space given the current state and where are the risks and opportunities.

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About the Author

Ashley Olson Onyango is the Programme Manager, Agricultural Finance at FSD Africa. Ashley has been working in the agricultural finance development sector across sub-Saharan Africa. Ashley previously spearheaded the development of a new lending portfolio with Root Capital, focused on domestic value chains and food security crops. After the launch, she managed the start-up of the portfolio and integration of the new portfolio into Root Capital's lending operations. More recently, Ashley has been consulting in the agricultural finance development sector with a number of clients and has joined the FSDA as a long-term consultant to manage its Agricultural Finance Programme. 

Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) in Nigeria - A Call for Rescue

13.03.2017Dr. Abdullahi Y. Shehu

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.

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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).

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