Category Archives: AML

Mobilizing Domestic Resources for Africa’s Transformation

This is the theme of the third Africa for Results Forum (AfriK4R) forum that’s taking place in Nairobi from July 13 to 15, and organized by the African Capacity Building Foundation (ACBF) and the African Development Bank (AfDB).

The first one was held in  2013 in Harare, and the next  in 2015 in Abidjan. One of the main concerns has been that, with the diminishing official development assistance (ODA)  to Africa, estimated to be 27% in 2014, and down from 38% in 2004., the budget needs of African governments need to be matched by a growth in local resources like taxes, exports and natural resources.

Kenya’s Devolution CS Mwangi Kiunjuri cited some of the resources available to Africa including $520 billion annually from domestic taxes that Africa generates, $168 billion from minerals & fuels,  $400 billion that Africa holds in international reserves, rise in Stock market Capitalization from $200 billion in 1996 to $1.2 trillion in 2007 and $160 billion in sovereign wealth funds (10 African countries have established these)

Challenges of African government face to mobilize domestic resources include: a very narrow tax base and a huge informal sector; high levels of capital flight; tax evasion & avoidance; proliferation of tax exemptions; lack of legitimacy of tax administrations; relatively low penetration of the formal banking sector; and lack of human, technical, legal, regulatory, and financial capacity to deal with illicit financial flows – Thomas Munthali, Director, ACBF.

Munthali, also cited good examples of domestic resource mobilization including the  Central Bank of West African States (BCEAO) reform on e-money; the Uganda border-post anti-smuggling trade measures; the Zambian direct deposit of fees into one government account; Zimbabwe’s tapping on the informal sector by introduction of presumptive tax; and Malawi’s use of Electronic Fiscal Devices in VAT collection.

Kenya Crackdown on Paper Bag Banking

The Central Bank of Kenya (CBK) has sent out new mandatory guidelines to banks to be on the look out for large volumes of cash being transacted over the counter. The notice targets customers who withdraw or deposit cash amounts of Kshs 1 million (~$10,000) or above.

It requires banks to get more information about why their customers are depositing or withdrawing these large sums of cash and query (among other things):

  • Why can’t the cash deposit or withdrawal be made through electronic means? 
  • What is the money going to be used for?
  • Who will be the direct and indirect beneficiaries of the money and provide the identity of the intended beneficiaries of the money.
Illustrative pic from the Star Newspaper to show what a large sum of cash will look like

Illustrative pic from the Star Newspaper to show what a large sum of bank cash may look like

The guidelines are drawn from existing crime and anti-money laundering regulations, and come after other attempts in the past to target money laundering, corruption, terrorism, or crime funds being transferred through mobile phones or remittances / hawala. But it seems, there’s been a realization, probably after investigations into the NYS saga, that cash was moved between banks in paper bags.

Brown envelope

In Kenya, large sums (over Kshs 1 million)  are meant to be transferred through electronic funds transfers (EFT) and real-time gross settlement (RTGS). Indeed cheques over Kshs 1 million are not accepted unless they are in support of amounts being transferred between accounts within the same bank.