The Sentry: Cash Grab | Billion-Dollar Letters of Credit Scam in South Sudan

Between 2012 and 2015, the government of South Sudan received a credit line of nearly one billion dollars from Qatar National Bank (QNB) and CfC Stanbic Bank in Kenya to support efforts to import much-needed food, fuel, and medicine to the war-torn and newly independent country. The credit line—issued in US dollars in the form of letters of credit (LCs)—was intended to help local traders pay for these imports, considering the extreme shortage of hard currency and the weakness of the new local pound.

The government was supposed to allocate the LCs to traders, who could exchange South Sudanese pounds (SSP) at the then-official exchange rate of 3.16 SSP per dollar. Traders would then use the LCs—essentially a guarantee from the bank—to pay the exporter upon confirmation of delivery of the needed goods.

From the beginning, things went terribly wrong. The Sentry’s three-year investigation into the LCs program found that multimillion-dollar contracts were awarded to foreign-run companies, companies that only existed on paper, and inexperienced middlemen. Businesses with connections to the ruling class—including President Salva Kiir’s family, the then-governor of the central bank Kornelio Koriom, and multiple military officials—were among those that received contracts collectively worth tens of millions of dollars under the program, according to official documents reviewed in connection with this investigation. It appears that millions of dollars’ worth of essential pharmaceuticals, fuel, and food were not delivered. The government failed to repay the borrowed money and entered arbitration proceedings initiated by QNB at the International Center for Settlement of Investment Disputes. By July 2020, the matter remained unresolved, and the government reached a debt-restructuring agreement with QNB.

The failure of the LCs program and the subsequent corruption scandal resulted in shortages that would affect the country for years to come. Almost $1 billion effectively walked out of the country, and the human cost remains to be calculated. At the peak of the LCs program, when hundreds of millions of dollars in goods should have arrived in markets, more than two million people went without food, hospitals and clinics had to treat patients without medicine, and fuel shortages resulted in black market price gouging. In October 2015, just months after the last LC-backed contracts were awarded, the United Nations (UN) reported that 3.9 million South Sudanese faced severe hunger and tens of thousands were on the brink of famine. The country was saddled with unmanageable debts that continue to constrain the government’s ability to devote funds to crucial services. Food, medicine, and fuel shortages persist to this day.

A 2015 report by Stephen Wondu, the auditor general (AG) of South Sudan, was presented to parliament but was never made public. This report, as well as interviews with South Sudanese close to the LCs program, shows that the disbursement process developed into a confusing, disjointed system of documents and signatures that corrupt actors circumvented or subverted. The report, reviewed by The Sentry, provided a comprehensive overview of the timeline of events surrounding the LCs program, the parties involved, and the wrongdoing committed. The report did not identify which individuals or companies benefited directly from the lucrative scheme or may have violated the law, but it clearly set forth the facts surrounding the failure of the program. In 2015, the AG’s findings were presented to Kiir and to parliament, but no action was taken and no one was brought to justice or held accountable for the program’s failures—legally or politically. In August 2021, a copy of the AG’s summary report was circulated on social media in South Sudan, and Wondu asked parliament to initiate an action leading to the prosecution of those government officials who siphoned money out of South Sudan via the LCs program. To date, there have been no prosecutions for corruption linked to the LCs program.

The mismanagement evident in the LCs program has had dire and long-lasting consequences for the people of South Sudan, and the program’s failure is indicative of government corruption and ineffective rule of law. South Sudan’s public officials and institutions have undermined the nation’s ability to achieve economic progress, and the abuse of the LCs program is just one example. In 2021, for the second year in a row, South Sudan ranked as the most corrupt country in the world on Transparency International’s Perceived Corruption Index. The UN reported in September 2021 that “more than $73 million USD was diverted since 2018, including transactions worth almost $39 million USD in a period of less than two months.” The government’s failure to properly carry out the LCs program and repay the loans led to a succession of damaging government policies, including the wasteful and opaque practice of borrowing hundreds of millions of dollars from oil companies. The full scope of the fraud might never be uncovered, but there are measures that can be taken to promote transparency and accountability in the allocation of public funds and to help ensure that the people of South Sudan are not cheated on this scale again.

The Architects of Taste and Pleasure Come Together for a Holiday Season Collection of Coffees, Confections and More to Celebrate the Joy of Gathering and the Art of the Everyday

Nespresso and world-renowned pastry chef and chocolatier Pierre Hermé are thrilled to join forces and announce a capsule collection to kick off the festive season. The exclusive coffees and confections are a celebration of refined tastes and indulgence, representing the best of the best across gustatory pleasures.

The limited-edition collaboration builds upon Pierre Hermé’s extensive background as an expert of flavour, putting forth a collection that deepens the indulgence of the palate by relishing in the shared joy that we experience with friends and family. Herein lies an invitation to gather, to discover and delight in unexpected surprises: from the visceral pleasures of tasting a new coffee or pastry to the combined laughter between friends, fuller stories are written with the Nespresso | Pierre Hermé coffees and confections that bring the art of the haute pâtisserie into the everyday, enriching both in equal measure.

From the creator of the Haute Pâtisserie, Pierre Hermé’s pastries are at the apex of avant-garde design, skilled technique and refined flavours. Decades of experience beginning with an apprenticeship at age 14 for Gaston Lenôtre, widely considered the father of modern pastry, led to Pierre Hermé being crowned the prestigious title of World’s Best Pastry Chef in 2016. With namesake boutiques and cafés all over the globe, Pierre Hermé’s creativity and sophistication in gastronomy is unparalleled. His unmistakably modern imagination pairs with technique to craft the ultimate coffee for the most discerning of palates – epicures will delight in the complex flavours while rejoicing in the ease of use, all in the comfort of one’s own home.

The collaboration consists of delightful coffees, confections, and gifting with Nespresso rounding out the festive season’s offerings by adding limited-edition coffee machines and accessories to bring Nespresso quality into all areas of one’s day.

Leading with a black single origin coffee from Colombia, the Infiniment Espresso, is sourced from the new supplying region of Tolima, where farmers mostly use natural methods and prioritize low-impact agriculture, benefiting the land and its inhabitants. The Arabica beans available in both Original and Vertuo as the Infiniment Double Espresso bloom with vibrant red fruit and smooth cereal notes, expressing an impressive depth of flavor and an elegant mouthfeel.

The Original espresso offerings also include two flavoured coffees: the Infiniment Gourmand Saveur Noisette, crafted from delicately sweet South American Arabica beans, begins with the unmistakable aroma of roasted hazelnuts flavour followed by sweet top notes of almond biscotti and delicate vanilla. The refreshingly smooth Infiniment Fruité Saveur Framboise articulates a smooth cereal aroma pairing beautifully with the alluring flavour of raspberries. Both of these inspire a premium pastry experience by declaring the same complex flavours one associates with Pierre Hermé’s elevated pastries.

When it comes to the decadent mug sized Vertuo flavoured coffees, the Latin American and African Arabica beans of Infiniment Gourmand Saveur Noisette reveal graceful roasted hazelnut flavours with top notes of praline and vanilla, while Vertuo Infiniment Fruité Saveur Framboise divulges the bracing tartness of raspberry flavour juxtaposed with the smooth cereal notes from its Latin American and African Arabicas.

No Pierre Hermé collection would be complete without sweets: to complement the coffees, the Infiniment Exquis 70% Dark Chocolate Squares, crafted from single origin dark chocolate sourced from the Dominican Republic, are delicately perfumed with the rare essence of Timur berries, which are harvested by a local community in Nepal, offering an aromatic profile of grapefruit, pepper and floral notes.

The Infiniment Savoureux Raspberry Cinnamon Biscuits are also available in the range, designed under Pierre Herme’s artistic direction. Intended to be paired with Nespresso coffees and bring new dimensions to the flavour profiles within each of them, the shortbread features dried raspberries and the warm spice of Ceylon cinnamon harnessed in a crunchiness that is a lovely foil to the inherent creaminess of Nespresso coffees.

The Café Noble Scented Candle was imagined in collaboration with master French perfumer Olivia Giacobetti and Pierre Hermé for a longer lasting immersion into the festive spirit. The soft, cozy scent is inspired by the Colombian tradition of adding panela, a golden-brown raw sugar that is as sweet as honey to coffee for an indulgent confection. With all of the complexities and nuances of coffee, the candle boasts notes of cinnamon, vanilla, spice and a robust Arabica bean, and is housed in a reusable porcelain vessel.

Rounding out the festive collection are this season’s Original and Vertuo Advent Calendars, containing 24 coffees and a surprise gift for the last day. The giftable advent calendars contain the three co-created Nespresso | Pierre Hermé coffees as well as favorites from the Nespresso permanent range, offering a different coffee behind each door for a delightful surprise on the path to the festive season, all presented in an exquisite box designed to be reused afterwards.

Outside of the co-created collection, Nespresso is also offering limited-edition coffee machines, the Vertuo Next machine in a shiny Silver or Titan finish and its iconic CitiZ machine in Magic Blue, both of which can be used to create the Nespresso | Pierre Hermé signature coffee recipes. Crowning the collection is the Nomad Travel Mug in a Raspberry color, giving the ability to take the flavours from the artistry of haute pastry anywhere, anytime.

Nespresso’s sophistication meets its match in Pierre Hermé, the architect of taste, with coffee as the connector – a multisensory gourmand treat to delight everyone’s palate and weave connections amongst generations.

The enchantment of indulgence, the gift of conviviality: the Nespresso | Pierre Hermé collection arrives in Nespresso boutiques worldwide and online on [November 1st TBC, per market and offering]. As with all shared moments, the collection is available for a limited amount of time and in limited quantities, while supplies last.

The Global Financial Centres Index 32

The thirty-second edition of the Global Financial Centres Index (GFCI 32) was published on 22 September 2022. GFCI 32 provides evaluations of future competitiveness and rankings for 119 financial centres around the world. The GFCI serves as a valuable reference for policy and investment decision-makers.

China Development Institute (CDI) in Shenzhen and Z/Yen Partners in London collaborate in producing the GFCI. The GFCI is updated and published every March and September, and receives considerable attention from the global financial community.

128 financial centres were researched for GFCI 31 of which 119 are in the main index. The GFCI is compiled using 151 instrumental factors. These quantitative measures are provided by third parties including the World Bank, the Economist Intelligence Unit, the OECD and the United Nations.

The instrumental factors are combined with financial centre assessments provided by respondents to the GFCI online questionnaire. GFCI 31 uses 66,121 assessments from 11,038 respondents.

GFCI 32 Results

Leading Centres

• New York leads the index, with London second, ahead of Singapore in third place, which has overtaken Hong Kong in fourth position.
• Paris returned to the top ten in the index, replacing Tokyo which fell to 16th place, perhaps reflecting a comparatively slow consumer recovery following the Covid-19 pandemic.

Western Europe

• London continues to lead in the region, and rose 5 points in the ratings.
• Other leading Western European centres also gained in the ratings. Berlin, Stuttgart, Lugano, Malta, Reykjavik, Guernsey, and Liechtenstein rose more than 10 rank places, while Madrid and Brussels fell more than 10 ranking places.

Asia/Pacific

• Performance in Asia/Pacific centres was balanced, with half of these centres maintaining or improving their rank, and half falling in the rankings. Leading centres in the region tended to perform better than those in the lower ranks.
• Singapore has overtaken Hong Kong by just one rating point to take the lead in the region, and third place in the index overall. Shanghai, Beijing, and Shenzhen also feature in the world top ten.
• Continuing travel restrictions in places like Hong Kong and Tokyo affect their ability to conduct normal levels of business.

North America

• New York, San Francisco and Los Angeles now feature in the world top 10.
• Canadian centres performed less well than US centres in this region.
• Atlanta and San Diego both rose more than 10 places in the rankings.

Eastern Europe & Central Asia

• Prague, Warsaw, and Nur-Sultan overtook Moscow to take the leading positions in Eastern Europe & Central Asia.
• Continuing the trend in GFCI 31, the majority of centres in the region fell in the rankings in GFCI 32.
• Moscow, Istanbul, Almaty, Athens, and St Petersburg fell more than 10 rank places.

Middle East & Africa

• Dubai and Abu Dhabi take first and second places in the region, with Dubai stable in the rankings at 17th place and Abu Dhabi dropping one ranking place.
• Casablanca continues to be the leading African centre, maintaining its 54th position overall, while other African centres fell in the rankings.

Latin America & The Caribbean

• The majority of centres in the region fell in the rankings after a more positive performance in GFCI 31.
• Cayman Islands, Santiago, and Bermuda overtook Mexico City to lead the region.
• Mexico City, Sao Paulo, Rio de Janeiro, Bogota, and Bahamas fell over ten places in the rankings.

FinTech

• We are able to assess 113 centres for their Fintech offering.
• New York retains its leading position in the Fintech ranking, followed by San Francisco, Los Angeles, and London, with Shanghai and Beijing in fifth and sixth place.
• Chinese, US, and German centres performed well in the Fintech ratings, with Atlanta, Chengdu, Berlin, Stuttgart, San Diego, Tianjin, Dalian, Nanjing, Hangzhou, and Wuhan improving more than 10 rank places. Outside of these countries. Helsinki, Oslo, and Lugano also gained more than 10 rank places.

Zimbabwe’s Disappearing Gold: The Case of Mazowe and Penhalonga

Illicit financial flows (IFFs) in the artisanal mining sector in Zimbabwe are responsible for leakages of an estimated 3 tonnes of gold, valued at approximately USD157 million every month. The sector has now spread its tentacles from alluvial gold deposits along rivers and dry riverbeds to large scale disused mines that are now patronized by politicians and ruling party officials.

Offshore Pilot Quarterly (June 2022, Volume 25 Number 2)

A Need for Reflection and Circumspection

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Mauritius: FSC issues Investor Alert against Healy Consultants Group Plc

The Financial Services Commission (the "FSC") reiterates the particulars of its Investor Alert issued in 2018 and urges the public to be cautious while dealing with Healy Consultants Group Plc and with any other individuals and/or entities allegedly claiming to be licensed / authorised / registered by the FSC.

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Offshore Pilot Quarterly (March 2022, Volume 25 Number 1)

25 Years on: Changes and Constants

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The Sentry: Legal Tender? The Role of Sakunda and the Reserve Bank of Zimbabwe in Command Agriculture

Possibly unlawful payments from Zimbabwe’s central bank to presidential advisor Kudakwashe Tagwirei’s companies formed up to one-third of the $280 million his firms received while running the Command Agriculture program, according to new analysis by The Sentry.

From 2016 to 2019, Tagwirei’s firm Sakunda Holdings ran Zimbabwe’s Command Agriculture program, which was intended to boost agricultural production through the provision of inputs such as seed and fertilizer to commercial farmers. Sakunda—an oil trading company—was appointed to run the billion-dollar project without an open tendering process.

The Sentry’s investigation found that, over the course of the three-year program, Sakunda received $1.28 billion total—$230 million in hard currency and over $1 billion in Treasury Bills—while providing inputs worth $1 billion: an apparent surplus of $280 million.

One of the Treasury Bills was improperly redeemed at a favorable exchange rate by the Reserve Bank of Zimbabwe (RBZ) after a new law had reduced the US dollar value of such assets. While others saw the US dollar value of their Treasury Bills fall, the RBZ protected Tagwirei’s asset from this reduction in value when it was cashed in: the central bank sent more Zimbabwean dollars to his firms than it was obliged to by the new law. This decision was worth—in US dollars—at least $50 million, and perhaps up to $100 million, for the oil tycoon’s companies. The International Monetary Fund reportedly blamed the Reserve Bank’s treatment of this Treasury Bill for bloating the money supply and contributing to inflation and the rapid decline in the value of Zimbabwe’s new currency from mid-2019.1

Sakunda, which denies any wrong-doing, testified in Zimbabwe’s Parliament that it received the favorable rate so that it could repay foreign suppliers—particularly of chemicals—in hard currency.2 However, it appears that the Treasury Bill was given a preferential exchange rate partly to allow one of Tagwirei’s firms to pay the government for some gold mines and a Zimbabwean military-controlled company for its share of a platinum mining joint venture with a Russian conglomerate. In effect, the publicly owned RBZ was printing money for private companies to buy publicly owned assets.

Command Agriculture was the product of a behind-closed-doors culture: the procurement process for this billion dollar program, the preferential treatment of the Treasury Bill, and the selection of recipients of inputs were all hidden from public view. The Sentry’s recommendations therefore include procurement transparency measures that could allow Zimbabwean citizens to see how their money is spent.

An Offshore Cold War: Forging a Democratic Alliance to Combat Transnational Kleptocracy

Transnational kleptocracy is a growing threat to democracy with urgent consequences for national security, human rights, and human development. Kleptocracy combines 19th-century autocracy with 21st-century finance, which empowers dictators to enrich themselves and their cronies, hide the proceeds offshore, and use that wealth to corrode both foreign and domestic institutions. While authoritarian leaders divert public resources to their own pockets and park them overseas, democracies have largely focused on their internal problems rather than acting as a united front to address this peril effectively.

Kleptocratic forces exploit this disunity to cement their repressive rule at home and advance their own, anti-democratic agendas overseas. Year after year, Freedom House’s annual “Freedom in the World” rankings show that the countries that are deemed “least” free in their ranking are often those that have heavily entrenched kleptocratic networks that have taken over as the system of governance. Traditional forms of accountability are curtailed, coopted, or eliminated as kleptocratic regimes seek to prevent their theft from being exposed by journalists and their governance from being monitored by civil society organizations.

Democracies may believe that their institutions are strong enough to resist kleptocratic influence, but the evidence warns otherwise. Russia under President Vladimir Putin, for example, has used massive wealth stolen from its people to coopt foreign leaders and businesses, spread large-scale and corrosive disinformation campaigns, and interfere in democratic elections. The focus on the strength of democratic institutions misses a larger point: as more kleptocratic wealth infiltrates democracies, it corrupts individuals and members of government, which will eventually degrade independent institutions.

Many democracies appear to be waking up to the threat posed by transnational kleptocracy and enacting policies designed to combat it. The Biden administration in the U.S. has made tackling corruption a top priority, and the U.K. and EU have signaled intentions to do the same. But because kleptocracy is a transnational, networked, and entrenched form of corruption, individual or atomized responses are insufficient. Democracies must be unified and networked in their fight against it. Transnational kleptocracy will always identify weaknesses in the global network of regulation and squeeze through them, meaning the whole network must be strengthened if it is to resist infiltration. Otherwise, the money would just move to the country that remains open to it, and the problem would continue.

To fight kleptocracy effectively, we must act together. Democracies should focus on their shared fundamental values—political and personal freedom, free markets, free speech, independent judicial systems, and freedom of expression—to develop a unified response to this top order challenge, much as they did during the fight against communism during the Cold War. That sense of democratic solidarity, where all major political parties understood and recognized the threats communism posed to democratic values, should be repurposed and reinvigorated to fight kleptocracy.

As Oliver Bullough warns in this paper, the very future of democracy is at stake.

U.S. Treasury Releases Study on Illicit Finance in the High-Value Art Market

Today, the U.S. Department of the Treasury published a study on the facilitation of money laundering and the financing of terrorism through the trade in works of high-value art. This study examined art market participants and sectors of the high-value art market that may present money laundering and terrorist financing risks to the U.S. financial system, and identified efforts that government agencies, regulators, and market participants could undertake to further mitigate the laundering of illicit proceeds through the high-value art market in the United States. The study was mandated by Congress in the Anti-Money Laundering Act of 2020.

Several qualities inherent to high-value art – the way it is bought and sold and certain market participants – may make the high-value art market attractive for money laundering by criminals. These include the high dollar value of transactions, transportability of goods, a longstanding culture of privacy and use of intermediaries (e.g., shell companies and art advisors), and the increasing use of high-value art as an investment class.

“As we tackle systemic challenges like corporate transparency and other loopholes that allow criminals to abuse the US financial system, we will look at what else might be needed to address money laundering risks specific to other industries, including the art industry,” said Scott Rembrandt, Deputy Assistant Secretary for Strategic Policy in the Office of Terrorist Financing and Financial Crimes.

The study found that while there is some evidence of money laundering risk in the high-value art market, there was limited evidence of terrorist financing risk. The participants most vulnerable to money laundering in the art market are businesses that offer financial services, such as art- collateralized loans, but are not subject to comprehensive anti-money laundering/countering the financing of terrorism (AML/CFT) obligations. Asset-based lending can be used to disguise the original source of funds and provide liquidity to criminals.

Entities which have lower levels of annual sales turnover (such as small galleries), and entities that only occasionally transact high-value art (such as third-party online marketplaces, museums, other non-profits) may present lower risk, while entities which have larger annual sales turnover and regularly transact in high-value art in the ordinary course of business may present a higher risk. Further, the emerging digital art market, such as the use of non-fungible tokens (NFTs), may present new risks, depending on the structure and market incentives.

To address the identified risks, the study recommends consideration of several non-regulatory and regulatory options:

• Encouraging the creation and enhancement of private sector information-sharing programs to foster transparency among art market participants;
• updating guidance and training for law enforcement, customs enforcement, and asset recovery agencies;
• using FinCEN recordkeeping authorities to support information collection and enhanced due diligence; and
• applying AML/CFT requirements (such as suspicious activity reporting and know-your-customer procedures) to certain art market participants and/or obligating them to create and maintain AML/CFT

In considering these steps, Treasury will take into account how these measures could mitigate identified money laundering risk, the potential burden on smaller art market participants, privacy considerations, as well as progress on addressing systemic AML/CFT issues, such as the abuse of shell companies. In developing the study, Treasury conducted dozens of interviews with art market participants, such as auction houses, galleries, financial institutions, art advisors, art subject matter experts across the U.S. government, international partners that regulate or are regulating the art sector, and academic and non-governmental organizations.

Europol Spotlight - Cryptocurrencies: Tracing The Evolution Of Criminal Finances

Cryptocurrencies are a technical and financial innovation that offer major potential for the global economy. At the same time, they are being used for criminal purposes such as money laundering, fraud, and the online trade of illicit goods and services. The ways criminals use cryptocurrencies is evolving, and it is spreading to all forms of serious and organised crime.

Following these developments, Europol has undertaken an analysis of the criminal use of cryptocurrencies to support law enforcement and its response to changing trends in this area. The resultant report contains core definitions, case examples, and details of the challenges authorities face in combating the illicit use of cryptocurrency.

Europol: Shadow Money – The International Networks Of Illicit Finance

The Pandora Papers was a leak of nearly 12 million documents that took place in 2021. The documents detailed financial practices employed by criminal actors, financial elites, and other groups to obscure ownership of assets and monies, and to shift illegally-gotten funds into the legitimate economy. Financial and economic crimes are major priorities for Europol as we work to tackle organised crime and the driving factors behind it. 

Following the leak of the documents, Europol undertook its own analysis to understand the significance of the Pandora Papers for our own work and for the wider law enforcement sector. This has been collated into a report that contextualises the Pandora Papers amongst similar major leaks of financial data, and details policy recommendations that arose from our analysis.

Chatham House: The UK’s kleptocracy problem

The growth of London as a centre for financial and professional services coincided with the collapse of the USSR and the rise of post-Soviet kleptocracies in the 1990s. These states and their elites have since become a major source of clients for UK-based services firms and of investors in UK assets.

In keeping with global standards, the UK has officially adopted a risk-based approach to anti-money laundering. However, failures of enforcement and implementation of the law – plus the exploitation of loopholes by professional enablers – have meant that little has been done in practice to prevent kleptocratic wealth and political agendas from entering Britain.

Based on extensive research on the laundering of money and reputations by elites from the post-Soviet successor states, this paper details how the UK is ill-equipped to assess the risk of corruption from transnational kleptocracy, which has undermined the integrity of important domestic institutions and weakened the rule of law. It concludes by calling for the UK government to adopt a new approach to this problem focused on creating a hostile environment for the world’s kleptocrats.

Outcomes FATF Plenary, 19-21 October 2021

Under the German Presidency of Dr Marcus Pleyer, delegates representing 205 members of the Global Network and observer organisations, including the International Monetary Fund, the United Nations and the Egmont Group of Financial Intelligence Units, took part in a hybrid meeting of the FATF Plenary.

New York & London Lead The Global Financial Centres Index 30 While Asia/Pacific Centres Falter

The 30th edition of the Global Financial Centres Index 30, was published today by Z/Yen Group in partnership with the China Development Institute (CDI). The launch webinar for GFCI 30 linked London and Busan.

New York held onto the top position in the index and has now been in first place for three years.

London remained in second place, while Hong Kong and Singapore in third and fourth position both fell 25 points in the ratings.

Overall the average rating fell 12.9 points (2.05%). While a small change, this is the third consecutive fall in the average rating.

The fact that overall ratings continue to fall against the levels that we saw in 2019 reflects the continuing uncertainty around international trade, the impact of the covid-19 pandemic, and geopolitical and local unrest.

Asia/Pacific centres generally fell in the ratings in GFCI 30, and assessments from people based in Asia/Pacific suggest that they judge Chinese centres in particular less favourably than before. This might suggest that the economic gains in the region arising from covid-19 may be levelling off.

North American centres performed well in GFCI 30. This is likely to reflect renewed optimism about the US and Canadian economies as they move forward from the pandemic.

The relatively strong performance of New York and London suggests that the financial services sectors in these cities managed to sustain their performance despite radical changes in working practices during the last 18 months.

Kigali and Lagos join the index for the first time, recognising the growth of financial services in Africa.

The top 20 centres in GFCI 30 are shown in the table below.

FinTech

New York and Shanghai retained first and second positions in the GFCI 30 FinTech ranking, with London rising two places to third place.

In the top 40 positions, Western European centres performed well, with most gaining rank position.

Professor Michael Mainelli, Executive Chairman of Z/Yen, said:

We see two patterns in the results for GFCI 30 – confidence in the recovery of the North American and Western European economies following the shock of 2020; and a levelling off following the rapid rise of Asia/Pacific centres and their economic stability in the covid-19 pandemic. Competition remains tight. Outside the top two centres, only five points on a 1,000 point scale separate the centres ranked third to eighth.

Democracy Capture and the Shadow State in Africa

On World Democracy Day, September 15, 2021, the Ghana Center for Democratic Development (CDD-Ghana) and Democracy in Africa (DIA) release two major reports about the capture of supposedly democratic political systems by private networks that work in their own interest, rather than that of the public.

Using evidence from new interviews, data collection and network mapping, a team of 10 researchers will report the extent to which political and economic decisions in African democracies are shaped by individuals or groups that are often unelected and work to subvert the formal institutions of the state to push their own interests and agendas. Together, the reports demonstrate that in many – but not all – African countries some of the most important political and economic decisions are not taken by individuals accountable to citizens, but by networks comprising insiders in the executive, political fixers, the president’s family, judges, businessmen, senior civil servants, military leaders, and international financiers, among others. In a number of cases, these networks traverse national borders, either through deep ties to international companies or through integration into transnational organized criminal networks, so that significant resources are taken out of the country. 

The reports also demonstrate that the extent of democracy capture varies significantly. It is relatively lower or less pronounced in countries such as Ghana, with an experience of multiple transfers of power through competitive elections, and much higher in states such as Zimbabwe where the government has never changed hands. The shape that networks take also varies tremendously and no two shadow states are the same:

In Uganda, the shadow state is run by an axis of President Museveni’s family and the country’s “military aristocracy”, along with a select number of interlocutors in the business community.

In Benin, things look very different, as President Patrice Talon has exploited the weakness of the legal system, the judiciary and the legislature to turn one of the continent’s most vibrant democracies into a near one-party state.

In the DRC, the international military alliances around former President Joseph Kabila played a critical role in creating a shadow state that was intimately connected to transnational smuggling networks.

In Zambia, the security forces have been less relevant and instead democracy capture has been driven by the nexus between civilian politicians, government officials, and private businessmen.

In Zimbabwe, the importance of the military has grown since the early 2000s, penetrating further areas of the state and the economy, raising questions about whether President Emmerson Mnangagwa or army leaders really hold power.

Understanding how democracy is captured is critical because it helps to explain the lack of progress in many countries towards democratic consolidation, how poorly performing governments are able to remain in power, why development programmes often fail to meet the needs of ordinary citizens, and why the gap between the “haves” and “have nots” continues to grow.

Key insights and findings include:

The way that “billionaire judges” in Nigeria make fortunes by taking bribes to exonerate political leaders and criminal organizations, facilitating corruption and creating a culture of impunity that undermines both democratic accountability and the rule of law.

How security officials, bank managers, electoral officials, judges and journalists collude with members of the ruling party to prevent opposition parties from being able to effectively campaign in elections in countries such as Mozambique, Uganda and Zimbabwe, preventing a transfer of power.

The way the police and military in the DRC set up command posts near newly productive mining shaft, not to protect workers but instead to issue unofficial “taxes”, so that some mine operators have to pay 40 regular fees – only 9 of which are official levies of the national government.

How companies with connections to the ruling party and the military in Zimbabwe have used their connections to artificially create a fuel shortage that has enabled them to inflate their prices at the expense of motorists, creating major challenges for businesses and ordinary citizens.

The way that Presidents such as Uganda’s Yoweri Museveni issue tax waivers to their business allies in return for financial contributions to their election campaign “war chest”, denying the Treasury hundreds of millions of dollars in revenue, and reducing the funds available for health and education.

How the partial capture of democracy in Ghana has contributed to the emergence of a distinctive class of super privileged Ghanaians, who have become rich in part due to their privileged access to the state, including governing and opposition party politicians and their cronies in the business sector and leadership of state bureaucratic and parastatal agencies.

According to Professor H. Kwasi Prempeh, Executive Director of CDD-Ghana, “Rather than a government of the people, by the people and for the people, democracy in Africa, including the legitimacy it confers on governments, appears captured to serve interests other than the people’s, thus leaving many people increasingly questioning democracy’s relevance. The future of democracy in Africa depends on our ability to reverse this picture.”

On his part, Nic Cheeseman, Professor of Democracy at the University of Birmingham said, “the growth of shadow states – powerful networks of unelected individuals that use their access to the government to pursue their own interests at the expense of the public – represents the most significant political challenge facing African countries today, and is the root cause of the democratic backsliding that we have seen in many states over the last ten years”.

John Githongo, a noted Kenyan anti-corruption campaigner was also of the view that “these reports represent the most comprehensive and insightful analysis of the way that democracy and economic and subverted in Africa available to date. They reveal that shadow states and democracy capture are the root causes of corruption, inequality and development failure.”

The countries covered in this project include Benin, the Democratic Republic of Congo, Ghana, Kenya, Mozambique, Nigeria, Uganda, Zambia, and Zimbabwe.

Democracy Capture in Benin, Ghana, Kenya, Mozambique, and Nigeria

The Shadow State in the Democratic Republic of Congo, Uganda, Zambia, and Zimbabwe

Basel AML Index 2021: Four things holding back the global fight against money laundering

Released today, the 10th annual edition of the Basel AML Index raises grave questions about whether jurisdictions are serious about tackling their money laundering and terrorist financing (ML/TF) risks, and what is holding them back.

The Basel AML Index is an independent annual ranking that assesses ML/TF threats around the world and the capacity of jurisdictions’ anti-money laundering and counter financing of terrorism (AML/CFT) measures to address their risks.

The average global money laundering risk score increased from 5.22 to 5.3 out of 10, as assessed across all 110 jurisdictions in the 2021 Public Edition of the Basel AML Index. Even among jurisdictions whose risk scores improved this year, none managed to improve by even one point out of 10. Half of improvements were 0.3 of a point or less.

What is holding jurisdictions back from effectively tackling their ML/TF risks and avoiding being the weak spot in regional and international financial systems? This year’s Basel AML Index report looks at four areas of AML/CFT policy that urgently need more attention.

1 – A STRONGER RESPONSE TO THREATS FROM VIRTUAL ASSETS

The use of virtual assets such as cryptocurrencies is exploding – for legitimate as well as illicit purposes. This year’s Basel AML Index report analyses data from the Financial Action Task Force (FATF) on how jurisdictions are responding to ML/TF threats related to virtual assets.

The answer: not well at all. Most jurisdictions assessed or re-assessed in the last year have worsened their scores for technical compliance with FATF Recommendation 15 on virtual assets and virtual asset service providers. Average compliance levels have dropped by 10 percentage points globally.

2 – EFFECTIVE PREVENTION, NOT JUST ENFORCEMENT

Previous editions of the Basel AML Index have lamented that many jurisdictions have AML/CFT systems that are mostly compliant with FATF technical recommendations but are ineffective in practice.

This year’s report looks at the distinction between compliance with technical recommendations vs effective implementation. Does the problem prevail for both prevention and enforcement?

The analysis reveals that:

• once again, jurisdictions score rather badly for effective implementation across the board;
• the discrepancy between technical compliance and effective implementation is even worse in relation to prevention.

These findings should ring an alarm bell for policy makers. Jurisdictions should invest more resources in the prevention of ML/TF, without reducing resources for enforcement.

3 – BENEFICIAL OWNERSHIP TRANSPARENCY

Beneficial ownership transparency is directly related to the effectiveness of a jurisdiction’s AML systems and the essential role of these systems in preventing, detecting, prosecuting and sanctioning financial crimes.

The Basel AML Index report analyses the implementation of beneficial ownership registers around the world. It shows how slow and ineffective implementation of beneficial ownership transparency measures continues to provide safe havens for dirty money.

This is damaging for individual jurisdictions, but more importantly undermines all global efforts to combat money laundering.

4 – ADDRESSING ML/TF VULNERABILITIES BEYOND THE FINANCIAL SECTOR

The final issue highlighted by the Basel AML Index data analysis is the generally weak application of AML/CFT preventive measures by lawyers, accountants, real estate agents and other designated non-financial businesses and professions non-financial entities (DNFBPs).

This means that there is a significant risk that such businesses and professions remain open to abuse by criminals and corrupt individuals wishing to launder their money. Moreover, there is increasing concern among regulators that:

• some DNFBPs are advising and assisting criminal clients with hiding and laundering illicit funds;
• as some high-profile cases have shown, accountants are used as intermediaries to avoid scrutiny.

At a minimum, more supervision over DNFBPs is urgently needed. Certain jurisdictions should also tighten their regulatory framework – and ensure that it is effectively enforced – over selected groups of DNFBPs in line with their risk exposure.

Regional deep dives

For a second year, the report offers profiles of money laundering risks in different regions.

Our regional infographics show how jurisdictions score in relation to each other – and in too many cases let their neighbours down.

Policymakers should analyse their respective jurisdictions’ risks and make plans for serious reform. No jurisdiction is doing well. We call on all jurisdictions to step up their game.

EIA - The Italian Job: How Myanmar timber is trafficked through Italy to the rest of Europe despite EU laws

Italy has been exposed at the heart of an ongoing trade in illicit timber from Myanmar, in defiance of both EU trade regulations and sanctions imposed in response to the violent military coup earlier this year.

In this report, EIA identifies a total of 27 Italian timber traders importing teak timber products.

Raconteur: Future of Payments 2021

The payments industry has undergone rapid innovation as spending has shifted online. This has facilitated new systems with customer convenience at their heart but also led to a rise in fraud and scams that the industry is trying to address.

Nespresso Launches Organic Blend from The Democratic Republic of The Congo To Revive The Coffee Sector and Communities in Kivu

Nespresso launched KAHAWA ya CONGO – a smooth and fruity organic coffee made possible only through the unique brand’s Reviving Origins program, which aims to revitalize coffee production in regions impacted by adversities ranging from climate change to conflict. The first organic blend under the Reviving Origins program, KAHAWA ya CONGO, is from the Lake Kivu region, where the once-thriving coffee farming community has been devastated by decades of political and economic instability.

Since its launch in 2019, the Reviving Origins program has enabled the production of exquisite coffees from areas of Zimbabwe, Uganda, Colombia and now, the DRC, to become available as seasonal coffees for Nespresso coffee drinkers.

In 1980, coffee was the second most important export for DRC and ranked among the world’s finest but declined in the early 2000s due to years of instability that had a devastating impact on the industry. Volumes have since dropped by 10 times.

Nespresso, together with global non-profit TechnoServe, the U.S Agency for International Development (USAID) and coffee trader Virunga Coffee/Olam International, is working with 2,500 farmers in South Kivu to improve coffee quality and yield, and embed sustainable farming practices, while increasing incomes. Nespresso is also in the process of expanding the program across North Kivu to potentially include up to 1,700 organic certified farmers.

Paulo Barone, Head of Coffee Sustainability and Origins Development at Nespresso, said: “Kivu has the potential to be among the world’s great coffee regions but has faced extremely challenging conditions in recent years. Through our Reviving Origins program, we’re working closely with Congolese farmers to revitalise the sector, restore Kivu as a leading source of high-quality, exceptional Arabica coffee and rebuild sustainable livelihoods, while bringing vital social support to enhance the welfare of the communities behind our KAHAWA ya CONGO coffee.”

Paul Sabatine, Mission Director for USAID/Democratic Republic of the Congo, said: “Nespresso’s partnership with USAID to revitalize DRC’s coffee sector is critical for Congolese farmers, who now have better coffee quality, improved productivity and higher incomes. Communities have experienced stronger economic development due to the partnership, in a region where absence of sustainable livelihoods fuels conflict.  We look forward to a continued collaboration with Nespresso as we jointly seek to improve farmers’ livelihoods.”

Will Warshauer, President and CEO of TechnoServe, added: “This coffee represents the incredible spirit of Congolese farmers who have overcome so much to build a better life for their families. In working with these farmers to improve their coffee crops, TechnoServe has seen how dedicated buyers like Nespresso, who pay higher prices for higher quality, can transform the livelihoods of thousands of people in this conflict-affected region. We’re looking forward to a bright future for Congolese coffee and for the hardworking farmers who produce it.” 

Kivu coffee farmer, Turanyi Kabasura, said: “I see my remaining days being better than those in the past, because I am going to work, assured of receiving regular pay and a bonus each time after the coffee sale. In my whole life, no one has ever given me such a bonus. I can use that to develop other strategies, such as raising small livestock, or my wife can run a small business. I am starting to see the results of my work.”

REVIVING COFFEE AND COMMUNITIES IN KIVU

In Kivu, decades of conflict have led to many farmers fleeing their homes, and the region continues to face significant economic and healthcare challenges. Today, 58% of households in DRC lack access to clean water systems, and 15% of children do not reach their 5th birthday, with preventable and treatable diseases such as water-borne illnesses, acute respiratory infections and malaria among the leading causes.

In partnership with the Eastern Congo Initiative (ECI), Nespresso is investing CHF 1 million to support the establishment of 23 water access points across the region, in addition to one primary and five mobile health clinics, which will deliver 13,000 health consultations per year to local communities, helping in the fight against cholera, a major health issue in the country.

Abraham Leno, ECI Executive Director, said: “Eastern Congo has suffered through decades of fighting. During those years in addition to terrible loss of countless people, the economy collapsed and public institutions’ capacity to care for the people of Congo was greatly depleted. But farmers kept working their fields and tending their coffee trees, because they knew that it was their path to a brighter future for their families. That is the true spirit of Congo. Nespresso’s funding of Asili, the social enterprise powered by ECI, will help farmers secure that future – building meaningful livelihoods and bringing world-class essential services, like clean drinking water and affordable healthcare, to families. It’s transformational change like this that allows hope to flourish and communities to heal.”

Nespresso’s unique sustainable sourcing model in coffee producing countries, the Nespresso AAA Sustainable Quality™ Program, provides the foundation for its work in Reviving Origins regions and involves more than 120,000 farmers across the world. Overall, Nespresso is investing a total of CHF 10 million in the Reviving Origins program over a period of five years (2019-2023).

KAHAWA ya CONGO is available online and at Nespresso boutiques, alongside Reviving Origins coffees AMAHA awe UGANDA, TAMUKA mu ZIMBABWE and ESPERANZA de COLOMBIA – returning for 2021. The long-term objective of the Reviving Origins program is to establish these under-threat coffees as permanent blends, available all year round for consumers.

KAHAWA ya CONGO: “Hope of Congo”

The rain-rich volcanic soils along the Kivu lakeshores of Eastern Congo provide an ideal environment for growing specialty Arabica coffee. The first organic coffee in the Reviving Origins range, KAHAWA ya CONGO is a smooth, seasonal coffee with a mild, fruity note, and alluring sweet cereal and nutty aromas.