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Capitalizing on Trust CAPITALIZING ON TRUST Harnessing Somali Remittances for Counterterrorism, Human Rights and State Building BY JAMES COCKAYNE WITH LIAT SHETRET Copyright © 2012 Center on Global Counterterrorism Cooperation All rights reserved. For permission requests, write to the publisher at: 803 North Main Street Goshen, IN 46528, USA ISBN: 978-0-9853060-0-7 Design: Stislow Design Front cover photo credit: © Jim Mone/ /AP/Corbis Somali Americans rally at the Minnesota State Capitol to protest the closure of money service businesses Friday, Jan. 6, 2012, in St. Paul, Minn. They are asking banks to restore relations with the companies wiring money to millions of Somali refugees in the Horn of Africa. Suggested citation: James Cockayne with Liat Shetret. “Capitalizing on Trust Harnessing Somali Remittances for Counterterrorism, Human Rights and State Building.” Center on Global Counterterrorism Cooperation. March 2012. Table of Contents About the Center on Global Counterterrorism INTERNATIONAL EFFORTS: BETWEEN Cooperation . ii FORMALIZATION AND PARTNERSHIP . 36 NATIONAL EFFORTS: PRAGMATIC CONVERGENCE? . 38 Research Team . ii Challenges in Implementation . 41 Acknowledgments . .. iii HOW DO YOU KNOW YOUR CUSTOMER? . 41 WHAT IS A SUSPICIOUS TRANSACTION? . 44 Glossary and Acronyms . iv WHO IS A POLITICALLY EXPOSED PERSON IN SOMALIA? . 45 WHERE DO BANKS FIT IN? . 46 Executive Summary . v WHERE DO TRADE ASSOCIATIONS FIT IN? . 47 Introduction . 2 Regulatory Confusion? . 48 Methodology . 5 Terminology . 6 3 . Harnessing the Potential of Somali Difficulties for and Limitations Remittances . 51 of the Research . 7 Capitalizing on Trust: From Confidence Building Implications of the Research Beyond to State Building . 51 Somali Remittances . 7 How Do We Get There? Recommendations for Action . 53 1 . BUILDING CONFIDENCE THROUGH A 1 . How Are Somali Remittances Organized? . 9 REMITTANCE ROUNDTABLE PROCESS . .. 53 2 . REGULATOR-REMITTER COLLABORATION ON A Traditional System in a Modernized JOINT OUTREACH, RISK ANALYSIS, AND EARLY Setting . 9 WARNING . 53 A System Powered by Trust . 12 3 . HARNESSING THE POWER OF REMITTANCES Why Remit? . 14 fOR SOMALI RECONSTRUCTION . 55 Economic Impacts and Functions . 15 How Much Moves? . 16 How Do Remittances Move? . 17 Bibliography . .58 Business Models . 21 CHARITY AND FAMILY NETWORKS . 21 Appendix 1: Personal Interviews and Survey RETAIL SROS . 21 Responses . .63 COMMERCIAL CLEARINGHOUSES . 23 SRO Geography: Streams and Hubs . 25 Appendix 2: Online Financial Intelligence Unit Political Impacts: SRO Corridors . 26 Questionnaire . .64 Looking Ahead . 29 MOBILE MONEY . .29 FORMAL FINANCIAL SERVICES AND SOMALI RECONSTRUCTION . 30 2 . How Are Somali Remittances Regulated? . 32 Self-Regulated Trust Networks . 33 A Decade of Distrust . 34 AL-BARAKAAT . 35 Capitalizing on Trust About the Center on Global Counterterrorism Cooperation the center on global counterterrorism cooperation is a nonpartisan, nonprofit research institute. We work with governments, civil society, the private sector, the United Nations, and regional organizations to strengthen partnerships against terrorism. See www.globalct.org. Research Team TEAM LEADER AND AUTHOR james cockayne is Co-Director of the Center and leads its work on East Africa. Trained as a lawyer, James’ research focuses on international responses to transnational threats. His books include Peace Operations and Organized Crime: Enemies or Allies? (coedited with Adam Lupel) (2011) and Beyond Market Forces: Regulating the Global Security Industry (2009). He was previously a senior fellow at the International Peace Institute; chair of the Editorial Committee of the Journal of International Criminal Justice; an editorial committee member of the Journal of International Humanitarian Legal Studies; principal legal officer in the Transnational Crime Unit of the Australian Attorney-General’s Department. He also worked in war crimes trials in Sierra Leone and Tanzania. COAUTHOR liat shetret is a Programs Officer at the Center. Liat developed the regulator questionnaire and conducted interviews with Somali remittance organizations in Dubai. She contributed substantially to the background research for this report and assisted with its drafting. She has expertise in terrorism, counterterrorism, and violent radicalization issues and political psychology, as well as Middle Eastern, East African, and Horn of Africa affairs. Liat previously served as the Harold Rosenthal Fellow in International Affairs to the U.S. House of Representatives Committee on Homeland Security. She holds a BA in political science and psychology from the University of Illinois and a Master of International Affairs degree from Columbia University’s School of International and Public Affairs. RESEARCH ASSISTANT joshua weaver is a researcher based in Goshen, Indiana, who served as a research consultant to the project during the literature review. He is a graduate of Associated Mennonite Biblical Seminary where he earned an MA in theological studies, with a concentration in theology and ethics. ii Acknowledgments This project was made possible by a number of supporters and partners, many of whom must remain anonymous. The support of the Royal Government of Denmark was absolutely central. Ambassadors Jørgen Gammelgaard in Copenhagen and Pernille Dahler Kardel in Addis Ababa were integral to the conception, design, and birth of the project. Adam Ravnkilde, Pernille Mortensen, Anders Andersen, Line Hall Hansen, and Joanne Bell all played crucial roles in its execution. The support, cooperation, and guidance of Jens Madsen, the Danish state prosecutor for serious economic crimes, and Jens Kauffeld Andreasen in the Danish Financial Supervisory Authority also proved game-changing. We are grateful to them all. We are particularly thankful for the constructive critique of an earlier draft of this report provided by the participants in a workshop in Copenhagen on 8–9 December 2011. This included numerous Somali remittance organization personnel and national regulators, as well as Simon Davis, Clément Gorrissen, Laura Hammond, Eliawony Kisanga, David Landsman, Edwina Thompson, and Dominic Thorncroft. Friends in East Africa made a major impact on the project. Our ongoing collaboration with the Intergovernmental Authority on Development Security Sector Program opened numerous doors and greatly enriched our understanding of that region’s financial life. Commander Abebe Muluneh and Richard Barno deserve specific mention and our thanks. The financial intelligence units around the world that responded to our survey request made a major contribution to our research. Many of them put significant effort into collating data and formulating collective responses. We are also grateful to the dozens of government colleagues in the United States, the United Kingdom, Europe, East Africa, and the United Arab Emirates who patiently entertained our requests and helped us find our way through the complexities of government- Somali remittance relations. Simon Davis was the ultimate fixer. We owe him gratitude for helping us engage in a genuine dialogue with numerous nodes in the Somali remittance community. Most important were the remittance organization professionals themselves. We cannot thank them enough for the time they spent explaining their world to us and for the willingness they showed to engage in frank and constructive policy discussion. We greatly admire the entrepreneurial vitality and resilience of this complex transnational community and hope that our research will make a small contribution to improving their chances of bringing peace and prosperity to the Somali nation. iii Capitalizing on Trust Glossary and Acronyms agent An individual who receives value from a remittance PEP Politically Exposed Person sender and/or distributes payment to the recipient bank wire stream Ongoing flow of nontrade financial AML Anti–money laundering transactions such as personal remittances, used in this report to connote the movement of remittances from bah The principal domestic unit, traditionally consisting OECD countries via formal bank wire channels to a of uterine siblings trade hub (e.g., Dubai or Eastleigh, Nairobi); see also CFT Countering the financing of terrorism “trade stream.” clan Strong lineage-based social units that provide the SAR Suspicious activity report principal source of identity and security in Somali society SFSA Somali Financial Services Association corridor A particular route, whether physical or virtual, SOMTA Somali Money Transfer Association along which remittances habitually flow SRO Somali remittance organization, which is run by diya Clan-based compensation payment; also called mag Somalis or operates in Somalia or Somali communities FATF Financial Action Task Force and conducts nonbank financial transfers involving cash payments at one end of the transaction FERG Foreign Exchange and Remittance Group (UAE) STR Suspicious transaction report FIU Financial intelligence unit TFG Transitional Federal Government of Somalia franco valuta A process of remitting wealth and importing goods prominent in Somalia in the 1970s and 1980s, trade stream Ongoing flow of trade finance transactions which relies on a person importing goods based on a as a method of transferring value from one area to another, foreign currency account abroad without foreign exchange used in this report to connote the movement of remittance expenditures from the local bank value from a trade hub (e.g., Dubai or Eastleigh) to the final recipient FSA Financial Services
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