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The impact of bank de-risking on the humanitarian response to the Syrian crisis

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Stuart Gordon, Alice Robinson, Harry Goulding and Rawaad Mahyub

Executive summary

The Syrian crisis is a complex environment for aid agencies wishing to move funds for humanitarian purposes into the country, or through neighbouring states supporting regional humanitarian efforts. The combination of counter-terrorist financing (CTF) legislation and international sanctions have made it very difficult for humanitarian organisations to move and access funds. The largest Syrian banks are under sanctions by the United States, the European Union (EU) and other states, and the banking system in areas outside of government control has largely been destroyed.

Syria’s immediate neighbours (Turkey, Lebanon and Jordan) have challenging regulatory arrangements and financial systems; Turkey, for example, has closed down several non-governmental organisations (NGOs) and substantially increased the bureaucratic processes to which humanitarian organisations are subject.

In combination, these challenges have seriously affected the ability of humanitarian organisations to arrange straight-line, direct bank-to-bank transfers to Syria or neighbouring states via the global correspondent bank network. This has made it difficult for them to pay local staff and suppliers and run programmes, and has added significantly to their costs. Bank de-risking, the shedding of NGO customers on the basis of exponential growth in regulatory penalties associated with CTF legislation and the low profitability of NGO accounts have shaped the geographical distribution of assistance, and encouraged NGOs to use less formal and less regulated transfer mechanisms.

Overall, we estimate that, within 60 of the organisations interviewed, as much as a third of donor funds was held at any one time between correspondent and recipient banks for between four and six months. All but six NGOs admitted to having reorganised programming priorities to focus on the least contentious areas, and projects that were less vulnerable to bank obstruction.

We conclude that bank de-risking has reduced the cash available to the NGO community at any one point in time by at least 35%, and that these funds remain unavailable for between three and five months longer than has historically been the case.

This research suggests that humanitarian organisations operating in Syria face significant challenges in moving money into the country. The principal challenges are with:

• moving money through the correspondent banking system;

• the consequences of banks closing accounts;

• increased and inconsistent due diligence requirements;

• increased transaction costs associated with international financial transactions;

• the interaction of CTF legislation with neighbouring states’ legislative and regulatory arrangements (Turkey) or issues of political economy (Lebanon); and • engaging with the informal financial sector (principally the hawala system) in Syria.

Recommendations

Much work still needs to be done to find a more appropriate balance between the security purposes of CTF legislation and its unintended impacts on humanitarian outcomes. In particular, international standards as to what constitute acceptable risk thresholds for the humanitarian community – and what due diligence should look like – are clear and urgent priorities. Respondents largely agreed on the changes that could make the regulatory system work more effectively from both a humanitarian and CTF perspective:

  1. Banks agree a due diligence code of conduct on the types of information that are routinely required, and what constitutes ‘sufficient’ information. Banks make this code of conduct available.

  2. Donors agree to be more flexible with the currencies used in transactions.

  3. A mechanism for agreeing a list (operated by NGOs) of acceptable organisations from which NGOs can purchase supplies and commodities, and with which they can conduct financial transactions.

  4. An agreed code of conduct between banks and NGOs on what constitutes sufficient compliance and transparency in terms of systems and recordkeeping, and the exceptions that are possible in the most dire circumstances.

  5. An international humanitarian financial clearing system to supplement the work of correspondent banks.

  6. Putting hawala banking channels on a clearer regulatory basis in conditions where they are the only viable means of moving money into areas of significant humanitarian need.

  7. Donors recognise the higher overhead costs associated with operating in Syria and increase their coverage of these costs for local NGOs.

Read the full report on ODI-HPG