REPORT OF NIGERIA NATIONAL RISK ASSESSMENT ON MONEY LAUNDERING AND TERRORIST FINANCING

The prospect of Nigeria and its huge economic potentials is not without challenges, as proceeds from Advance Fee Fraud, armed robbery, arms trafficking, banking fraud, bribery and corruption, capital market fraud, counterfeiting of currency, currency trafficking, drug trafficking, fraud and forgery, human trafficking and sexual exploitation, kidnapping and hostage taking, pipeline vandalism and illegal oil bunkering, piracy and copy rights infringement and
smuggling all constitute major sources of illicit proceeds and source of financing terrorism in Nigeria. Money laundering in Nigeria takes many forms. Perpetrators launder money through real estate investment, wire transfer to offshore banks, deposits into foreign banks, round tripping, reselling imported goods, such as luxury or used cars, textiles, and consumer electronics purchased with illicit funds, jewelries as well as bulk cash smuggling. Consequently, Nigeria in her effort to rise above the foregoing menace, successfully conducted its first National Money Laundering and Terrorist Financing (ML/TF) Risk Assessment (NRA) in 2016. The assessment was also in response to recommendation 1 of the Financial Action Task Force (FATF)’s 40 recommendations which, requires all countries to identify, assess and understand the money laundering and terrorist financing (ML/TF) risks elements prevalent in their jurisdictions for the development of efficient measures to combat the crime and efficient allocation of scarce resources to do the same. The Nigeria Financial Intelligence Unit (NFIU) in consideration of its strategic role as the national agency responsible for the coordination of Anti- Money Laundering and Combating the Financing of Terrorism (AML/CFT) matters in the country, coordinated and led the process under the auspices of Nigeria’s AML/CFT Inter-Agency Ministerial Committee (IMC). 

2016

TYPOLOGIES STUDIES ON MONEY LAUNDERING ARISING FROM ELECTRONIC COUNTERFEITING AND INTELLECTUAL PROPERTY THIEF IN WEST AFRICA

The literature on counterfeiting and IP theft is fraught with a series of issues. First, there is no consensus on basic concepts and the definitions of the phenomenon. Thus, although counterfeiting is a widely used word, its usage in particular contexts has not been defined. National definitions, especially in relation to counterfeit drugs and medicines, vary considerably. Nonetheless, counterfeiting has been defined generally in relation to infringement on IP rights,
especially trademarks. The WTO defines it as “unauthorized representation of a registered trademark carried on goods identical or similar to goods for which trademark is registered, with a view to deceiving the purchaser into believing that he/she is buying the original goods.”39 This is similar to the definition provided in the WTO TRIPS Agreement, which defines “counterfeit trademark goods” as “any goods, including packaging, bearing without authorization a trademark which is identical to the trademark validly registered in respect of such goods, or which cannot be distinguished in its essential aspects from such a trademark, and which thereby infringes on the rights of the owner of the trademark in question under the law of the country of importation.” The OECD also a definition that highlight violation of trademarks.41 However, there are often terminological differences in the description of counterfeiting. For instance, counterfeiting is often used interchangeably with piracy – the unauthorized use of copyright-protected materials such as music, movies, books, and computer software.

February 2017

MONEY LAUNDERING RELATED TO FRAUD IN PUBLIC PROCUREMENT IN WEST AFRICA: A CASE STUDY OF NIGERIA

Money Laundering Related to Fraud in Public Procurement in West Africa: A case Study of Nigeria.

February 2014

TYPOLOGIES OF MONEY LAUNDERING THROUGH THE REAL ESTATE SECTOR IN WEST AFRICA

Various studies, including those carried out by the Financial Action Task Force (FATF) over the past few years, suggest that advances in technology and the progressive tightening of anti-money laundering (AML) regulations are leading money launderers to make more complex arrangements outside the formal financial services industry, such as the use of various professional services, and in particular the real estate business.

The primary objective of this typologies exercise is to carefully examine the vulnerability of the real estate sector in West Africa, given the large volume of monetary transactions involved and its significant impact on geo-political and socio-economic conditions in the West African region. The exercise also attempts to shed light on how the real estate sector in West Africa could be especially attractive to launderers.

The study aims essentially at (i) exploring the means by which illicit funds are channelled through the real estate sector to be integrated into the formal economy, and (ii) identifying the control measures in place to combat this form of abuse in member states. It is essential to note that one of the most effective ways of gathering information on how the sector is manipulated is to examine concrete case studies. The report is therefore based on information provided by GIABA members who took part in the 2008 typologies exercise.

TERRORIST FINANCING IN WEST AND CENTRAL AFRICA

Terrorism is of growing concern for the international community which, in the recent past, has witnessed an increasing number of attacks at the hands of terrorist groups. West and Central Africa are particularly vulnerable to terrorism. The continuing violence and conflict in this area since 2010 has sparked concerns that the threats from terrorism could derail hard-won economic gains, contribute to political instability and undermine future development. Communities in these areas have experienced the devastating impact of extremist violence from a multiplicity of terrorist groups.

However, as we have experienced with ISIL, in a more globalised world, the threats from a regional conflict can spread to impact the global community. The regional and potentially global impacts of terrorism, highlights the importance of the international community taking all necessary steps to find ways to deprive terrorist organisations of their funding. Terrorist organisations are all different in their nature and purpose but they all require resources for self-maintenance, facilitation and funding of various types of attacks. Terrorist financing (TF) may encompass complex financing structures used to conduct large scale attacks or simplistic models used to support small cells and fund smaller attacks.

This report is intended to update the FATF/GIABA report on Terrorist Financing in West Africa (October 2013) and to extend the study to the Central African region. It finds that while the 2013 study is still relevant, the scale and nature of terrorist groups within the region have changed and this has had an impact on financing strategies as well. The report considers the possible funding sources (the threats), particularly in relation to Boko Haram and groups linked to Al-Qaeda, including Al-Qaeda in the Lands of the Islamic Maghreb (AQIM) and its affiliates, and also considers potential means to finance terrorism and other contextual factors (the vulnerabilities). It reveals a number of threats and vulnerabilities that are specific to the region including the prevalence and profitability of cattle rustling as a key feature of rural and cross-border criminality in the Chad Basin. It also highlights the role of cash, including foreign currency, in TF in the region.

The report breaks down the threats into confirmed and suspected sources of funding. It appears that Boko Haram is mostly funded locally, while Al-Qaeda affiliates may also be benefiting from foreign donations. While there are indications that terrorist organisations are associated with criminal organisations and with organised crime in the region, there is limited evidence to support these alleged links.

THE NEXUS BETWEEN SMALL ARMS AND LIGHT WEAPONS AND MONEY LAUNDERING AND TERRORIST FINANCING IN WEST AFRICA

This presents the findings of field research on the nexus between illicit trafficking in Small Arms and Light Weapons (SALW) and Money Laundering (ML) in West Africa on the one hand; and illicit trafficking in SALW and Terrorist Financing (TF) in West Africa on the other in all 15 member States of the Economic Community of West African States (ECOWAS).  

Following a comprehensive desk research and analysis of relevant laws and egulations related to SALW and money laundering and terrorism financing, fieldwork was conducted in the form of interviews on the basis of confidentiality with relevant stakeholders in public, private, and civil society sectors. Further analysis of research data was conducted by consultants.

TERRORIST FINANCING IN WEST AFRICA

In West Africa, there is significant concern about the rise of terrorism. This is manifested by the number of terrorist attacks in some West African countries that have resulted in large human casualties and the destruction of property. The source of funding for terrorist activities has equally been of concern in the sub-region. The phenomenon is underpinned by several factors, including the presence of large, informal, cash-based economies, political instability, ethnic and communal violence, pervasive corruption, widespread poverty, gross unemployment, and underemployment. Significantly, terrorist groups and their financiers drive funds from both licit and illicit activities, and move them through formal and informal channels to support their activities. All of these factors
have adverse effects on peace, security, and development in the sub-region.

The devastating effects of terrorism and terrorist financing have provoked strong interest among the authorities and national governments of the Economic Community of West African States (ECOWAS) on countering the threat, based on a clear understanding of the modus operandi of terrorist groups and their financiers. Accordingly, this typologies study aims to discover the methods used by terrorists, terrorist groups, and their supporters to collect, transfer, and utilise funds for their activities. It aims to provide a deeper understanding of the methods used by financiers to assist terrorists in carrying out acts of terrorism. The study also aims to provide information on terrorist financing methods to assist competent authorities and reporting entities in their responsibilities to combat terrorist financing. In this regard, the study provides case studies, from which key indicators and red flags have been generated to help policymakers and regulatory and enforcement authorities as well as reporting entities to understand better the nature and dynamics of terrorist financing in the sub-region.

As a prelude to this typology study, and recognizing the challenges of getting information on the subject matter in the sub-region, the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) commissioned five experts, one each in Burkina Faso, Mali, Niger, Nigeria and Senegal, to carry out a background study on terrorism and terrorist financing in their countries. These countries were selected based on the prevailing incidences of terrorism or its effects on them compared to other GIABA member States.

October 2013

NATIONAL RISK ASSESSMENT OF MONEY LAUNDERING AND TERRORIST FINANCING: REPUBLIC OF GHANA

A key feature of the NRA is to understand ML/TF risks and in so doing, identify and evaluate threats, vulnerabilities and their impact on the country and that on the economy of Ghana. The NRA process tested the robustness of the current AML/CFT regime in Ghana. The objective is to identify, assess and mitigate ML/TF risks, through adjustments and amendments in the legal and regulatory frameworks. These measures may require direct policy changes. The desired outcomes of the NRA process are to develop a National Strategic AML/CFT Action Plan that will assist in the allocation of AML/CFT resources, as well as, assist in revising or developing guidance for “Accountable Institutions” so as to ensure compliance with the AML/CFT regime.

The NRA process should support the Government of Ghana’s declared fight against money laundering, illicit financial flows and transnational organised crimes. As far as the process is concerned, the World Bank provided the conceptual framework in the form of a national risk assessment tool (including excel templates), gave technical assistance and guided the working groups in the effective use of the tool. All the findings, interpretations, and judgments of the exercise, are solely the work of the working groups in Ghana, and they do not reflect the views of the World Bank. This report was produced entirely by the working groups.

The NRA process in Ghana involved three phases, undertaken between September 2014 and April 2016. This report discusses the last phase, which is the finalisation and recommendations of the Report and the Action Plan. The Mutual Evaluation done on Ghana in the year 2009, revealed several shortcomings in the country’s compliance with the AML/CFT measures. For instance, Financial Institutions did not conduct any CDD on their customers as required by recommendation 5 of the FATF Recommendations. There were no guidelines. There were no guidelines to enable Accountable Institutions fashion out internal rules in compliance with the afore mentioned recommendations. Besides, the Financial Intelligence Centre was not in existence. The situation has however changed as several legislations have been passed to address the shortcomings revealed during the last Mutual Evaluation of Ghana in the year 2009. All the sectors captured in this NRA have acknowledged the fact of the tremendous growth of Ghana’s cash-based economy. As a result many microfinance institutions have emerged, and are operating, thus boosting the internal transfer of money. This has made the financial system vulnerable to ML/TF risks.

FINANCIAL INCLUSION PRODUCTS RISK ASSESSMENT: NIGERIA NATIONAL MONEY LAUNDERING AND TERRORIST FINANCING RISK ASSESSMENT

As part of her National (ML/TF) Risk Assessment (NRA), Nigeria assessed the money laundering/terrorist financing risk in financial inclusion products in Nigeria. This is in compliance with Recommendation 1 of the Financial Action Task Force (FATF) Standards. The objectives of the Assessment is to determine and assess the level of money laundering and terrorism financing threats inherent in existing or proposed products and services targeted at financial inclusion, as well as determine and assess the vulnerabilities of institutions, financial or non-financial actors or professionals.

The assessment covered the formal and semi-formal sectors of the country’s financial system including Banking, Capital Market, Insurance, Pension and Non-Bank Micro Finance Institutions. In Nigeria, financial inclusion is defined as adult Nigerians having easy access to a broad range of formal financial services that meet their needs at an affordable cost. The services include payments, savings, loans, insurance, and pension products. Based on a national survey conducted in 2010 by Enhancing Financial Innovation and Access (EFInA)1, it was revealed that 39.2million Nigerians representing 46.3% of the adult population were financially excluded and had no access to either formal or informal financial services. Also, according to the EFInA 2010 Survey, only 25.4million were banked (representing 30.0% of the adult population) and the main barriers to having a bank account are lack of money, irregular income and distance to the bank.

2016

IMPROVING COMPLIANCE WITH INTERNATIONAL AML/CFT STANDARDS: REPORT ON THE STRATEGIC REVIEW OF THE FIRST ROUND OF MUTUAL EVALUATIONS OF GIABA MEMBER STATES (2007-2012)

As a Financial Action Task Force Style Regional Body (FSRB), the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) is mandated to undertake mutual evaluation (ME) of its member States. The ME exercise commenced in 2007 with the evaluation of Sierra Leone, and was completed in 2012, with the evaluation of Sao Tome and Principe, which became a full member of GIABA in 2012. In total, sixteen (16) member States, namely, - Benin, Burkina Faso, Cape Verde, Cote d'Ivoire, Gambia, Ghana, Guinea, Guinea Bissau, Liberia, Mali, Niger, Nigeria, Sao Tome and Principe, Senegal, Sierra Leone and Togo, were evaluated. Sao Tome and Principe has not been included in this review for two strategic reasons. Firstly, the country became a member of GIABA at the time when the first round of MEs was about to be concluded. This means that there was limited engagement with the country throughout the first round of the evaluation. Secondly, because the country is not a member of ECOWAS, it has not benefitted from the technical assistance given to ECOWAS members States. The data for the ME, therefore, may be skewed and incomparable with those of ECOWAS member States.

The evaluations were aimed at determining the level of compliance of the member States with the FATF Recommendations, based on a set of objectives and guiding principles as laid out in the 2004 FATF Methodology for Assessing Compliance, the FATF Handbook for Countries and Assessors and the GIABA Mutual Evaluation Process and Procedures (P&P).

Following the conclusion of the first round of MEs of GIABA member States, and in order to improve on subsequent evaluation outcomes, GIABA conducted a strategic review of the first round of the evaluations. The objectives of the review were to: i) review and analyze the framework for the evaluation in relation to the peculiarities of GIABA member States; ii) review and analyze the process and procedures adopted during the evaluation and determine the challenges encountered; iii) assess the outcome of the MEs and determine the consistency of the outcome; and iv) provide key observations, conclusions and recommendations drawing from the analyses and assessment of i-iii above in order to learn lessons that will help to improve the second round of MEs.

January 2014

ASSESSMENT OF COUNTER TERRORIST FINANCING CAPACITIES IN WEST AFRICA

The scourge of terrorism in West Africa which is sustained by numerous channels of terrorist financing have persisted despite numerous levels of engagements adopted at national and regional levels by the member states of the Economic Community of West African States (ECOWAS) to address it. The sources and methodologies for the financing of terrorism in the region have also continued to evolve and include the use of funds derived from licit and illicit activities. These funds are sometimes moved through the relatively under-regulated formal and largely unregulated informal channels to support the perpetration of various forms of terrorist activities. The incidences of terrorist financing have therefore persisted in West Africa irrespective of the measures adopted and targeted at combating them.

This background formed the motive force for this study initiated by the Inter-Governmental Action Group against Money Laundering in West Africa, otherwise known as GIABA. The study focuses on the assessment of the capacities of five (5) of GIABA’s terrorism most affected member States, notably Burkina Faso, Cote d’Ivoire, Mali, Niger and Nigeria in countering the financing of terrorism. The main objective of the study is to examine the capacities of the selected GIABA member states in countering financing of terrorism (CFT) through the application of international CFT standards and requisite domestic measures with a view to strengthening the capacities of these states in meeting the respective national CFT needs.

August 2020

ILLEGAL WILDLIFE TRADE AND FINANCIAL INVESTIGATIONS IN WEST AFRICA

In the last five years, West Africa has emerged as a major source and transit hub in the global illegal wildlife trade (IWT).1 The industrial scale of the multi-tonne, multi-product seizures originating from West Africa clearly demonstrates that profit-driven organised crime groups are running the trade. Yet, while the significance of the region in global IWT flows is increasingly recognised, very little is known about the financial aspects of these criminal operations. Based on 89 interviews with key stakeholders in West and Central Africa, as well as a survey of 12 out of 17 financial intelligence units (FIUs) based in the member states of the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA), this paper assesses the extent to which the financial dimensions of IWT are investigated in the region. It finds that no country in West Africa currently conducts routine parallel financial investigations in IWT cases.

April 2021

MONEY LAUNDERING AND TERRORIST FINANCING LINKED TO THE EXTRACTIVE INDUSTRY/MINING SECTOR IN WEST AFRICA

The extractive industry of Africa is one of the largest in the world. For many African countries, the extraction and production of minerals constitutes significant parts of their economies, accounting for a high share of gross domestic product (GDP) or total exports. The sector remains the key to future economic growth in the region despite all challenges. It is a fact that the sector is marred with irregularities such as illicit artisanal mining, tax evasion, fraudulent contracts, high-level corruption and organised crime - all of these contributing to a considerable amount of proceeds being laundered or siphoned each year. Enforcement
agencies are not well equipped to deal with the very high degree of sophistication of the criminal elements operating in the extractive industry.

October 2019

MONEY LAUNDERING AND TERRORIST FINANCING THROUGH THE INFORMAL AND ILLEGAL CURRENCY EXCHANGE SERVICE PROVIDERS IN WEST AFRICA

Money laundering through foreign currency ex-change operations is a very efficient way of dis-guising the true origin of illegal proceeds and their integration into the legal financial system. Cur-rency exchange services (CES), including bureau de change services, that involve foreign currency exchange operations are the fastest growing sector in the West African financial services industry in terms of the number of institutions that have sprouted over the last 10 years. The emergence of CES in West Africa has been associated with the advent of economic liberalization of the mid 1980s and early 1990s. Exchange controls were abolished subsequently after the introduction of the Foreign Currency Regulations, by the Central Banks/CES regulators, which were to govern the operations of the CES in liberalized economies.

August 2020

MONEY LAUNDERING/TERRORIST FINANCING AND THE SMUGGLING OF GOODS IN WEST AFRICA

This study was conducted by GIABA in order to explore the linkages of money laundering and terrorist financing (ML/TF) to the smuggling of good in West Africa. Goods smuggling is known to be a lucratively rampant criminal activity across the region that has defied law enforcement efforts over the past decades. However, while it is generally accepted that goods smuggling has become a serious transnational organised crime in the region, there has been no concern about the illic financial proceeds that flow from the activity. This study was embarked upon to focus on such illicit proceeds and to explore the risks of ML/TF associated with the criminal activity. Hence, the study is not a regular typologies exercise, which typically builds on existing cases of ML/TF to establish trends and methods. In undertaking this study, data was collected from all 15 member States of GIABA. Questionnaires were administered and interviews held during visits to the countries by the GIABA research team.

August 2020

MONEY LAUNDERING RISKS OF CASINOS AND THE GAMBLING SECTOR IN WEST AFRICA

This vulnerabilities report covers the risks of the casinos sector in West Africa, including risks of money laundering and other forms of illicit finance in the sector. In particular, the report focuses on the casino and gaming sectors in six GIABA Member states (Ghana, Nigeria, Senegal, Cabo Verde, Côte d’Ivoire, and Benin). This study has been ordered by GIABA, implemented with technical assistance provided in the context of the OCWAR-M project (Organized Crime: West African Response to Money Laundering and the Financing of Terrorism) by Expertise France, and funded by the European Union. These countries were chosen due to their systemic importance to regional stability, and relative risks present in their casinos and gaming sectors

THREAT ASSESSMENT OF MONEY LAUNDERING AND TERRORIST FINANCING IN WEST AFRICA

This report conducts a threat assessment of money laundering and terrorist financing in the West Africa region, specifically in Benin, Cape Verde, Côte d’Ivoire, the Gambia, Ghana, Nigeria and Senegal. The introduction outlines the objectives of the study and includes a
description of the methodology and operational approach, which included data collection from open source material, as well as a range of interviews with relevant observers, local officials, and key practitioners and decision makers. This was followed by detailed analysis seeking to examine the source of illicit funds, how they are laundered, and where they are being moved to, and in doing so, throw light on a range of issues, including the weaknesses in regional efforts to tackle laundering and the consequences of money laundering for the rule of law.

The first chapter addresses West Africa’s informal economy, which is a major vulnerability with regard to money laundering. It comprises perhaps 60-70% of formal regional GDP. In very general terms, the informal economy is the unregulated non-formal portion of the market economy that produces goods and services for sale. The large size of the informal economy in the region goes hand-in-hand with the cash- and commodity-based nature of the region’s economy. A distinction is drawn, though, between the merely informal on one hand and the outright criminal on the other; the major categories of predicate criminality for the purposes of money laundering being tax evasion and smuggling.

May 2010

KNOW YOUR CUSTOMER/CUSTOMER DUE DILIGENCE MEASURES AND FINANCIAL INCLUSION IN WEST AFRICA: AN ASSESSMENT REPORT

This report is the outcome of a study conducted directly by the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA), which commenced in September 2016. The study is a follow up to an earlier study on financial inclusion carried out in 2013. It was undertaken to understand and address the challenges of implementing the money laundering and terrorist financing (ML/TF) preventive measures of Know–Your-Customer (KYC)/Customer Due Diligence (CDD) with due regard to financial inclusion. On the basis of the findings of the study, recommendations have been made to assist the relevant authorities in GIABA member States to design effective KYC/CDD frameworks that promote financial inclusion, in compliance with the letter and spirit of the Financial Action Task Force (FATF) Recommendations and Assessment Methodology (as revised).

The report will considerably help countries in the region as they struggle to expand access to financial services for the people, while ensuring effective protection of their financial systems against ML/TF. In so doing, countries in the region will be able to adapt the flexibility offered by the risk-based approach (RBA) to the implementation of ML/TF preventive measures, as contained in the international anti-money laundering and countering the financing of terrorism (AML/CFT) standards.

June 2018

ILLICIT FINANCIAL FLOWS: THE ECONOMY OF ILLICIT TRADE IN WEST AFRICA

Africa is the world’s second fastest-growing economy after East Asia, and yet the continent is also home to the largest share of people living in extreme poverty, in countries with poor foundations for human development. Income inequality is rising, while underemployment and the lack of economic opportunities push some individuals to join criminal groups, gangs or rebel movements, reinforcing the links between inequality, criminal activity and violence.

The United Nations Economic Commission for Africa’s High Level Panel on Illicit Financial Flows has estimated that illicit financial flows (IFFs) from Africa could amount to as much as USD 50 billion (US dollars) per year. Although the figures on IFFs are heavily disputed, current analyses agree that IFFs exceed the amount of ODA provided to Africa.

Previous research has largely focused on capturing the volumes and sources of IFFs, and on identifying the commercial practices that contribute to them such as trade misinvoicing, tax evasion and avoidance, and transfer pricing. This publication takes a different approach by seeking to build the evidence basis on
criminal and illicit economies, the IFFs these economies generate, and their impact on development. The report reviews diverse forms of economies prevalent in West Africa that are usually seen as criminal or illicit, organising them through a typology according to a range of illegal activities, from natural resource crimes to illicit trade in normally legal goods.

This analysis leads to the following conclusions: criminal and illicit economies produce IFFs that undermine country capacities to finance their development; and criminal economies and IFFs are a potent negative force that contribute to the degradation of livelihoods and ecosystems, undermine institutions, reinforce clientelist politics and enable impunity, in different ways across the region’s countries.

OECD,2018

A REVIEW OF THE STATE OF IMPLEMENTATION OF ANTI-MONEY LAUNDERING MEASURES IN RELATIONS TO FINANCIAL INCLUSIONS IN GIABA MEMBER STATESAL INCLUSION

The FATF counter measures on money laundering and terrorist financing have been under scrutiny in the recent past as posing challenges to the financial inclusion drive. Mindful of the fact that majority of jurisdictions within its membership being emerging markets, developing countries, or low capacity countries, the FATF is making sure that these services are provided within the realm of some formal mechanism. 2. Financial service delivery through new payment methods provide the possibility of
dramatically reducing cost and distance barriers to sustainably provide appropriate financial services to the poor and isolated communities.

The transformation from cash to electronic value, stored and conveyed by mobile phones, is hitting developing countries. Apart from mobile phones, other branchless banking approaches are attracting attention as well. 3. Financial inclusion is the process by which the financially excluded, i.e., the unbanked, underserved and economically active rural dwellers in remote and isolated communities can access formal financial services at affordable cost to a range of services, including savings, credit, insurance, payments and transfers. These financial services are made available by regulated institutions subject to AML/CFT standards. Access to financial services insulates against poverty and is a master key to sustainable development.

2017