analysisBy Edward Paice
In a recent blog "Anti-Money Laundering Regulations: Can Somalia survive without remittances" the World Bank's Sonia Plaza warned of the deleterious and undesirable effects of interrupting remittance flows to Somalia.
This is a timely reminder. Following the inaugural meeting of the UK government's Action Group on Cross-Border Remittances, the Working Group on a Safer Corridor for UK-Somali Remittances starts work on Monday 17 February. The World Bank is part of both the Advisory Group and the Technical Implementation Group for this welcome initiative.
It is worth re-emphasising that the crisis for Somali remittances was caused by a broken banking system and the subsequent response of regulators - not by Somali money transfer operators (MTOs).
This is a point which is certainly acknowledged by DFID and all other participants in the Safer Corridor Group; as is the importance of maintaining the flow of remittances to the Somali regions through existing MTOs, in the absence of any functioning banking sector or alternative channels.
Yet UK government ministers, including the Chancellor of the Exchequer, continue to answer enquiries about the issue in a manner which - knowingly or otherwise - stigmatises the conduct of Somali MTOs and the whole UK remittance sector.
The opening paragraph of official replies usually asserts that "the government recognises the important role that remittances play in supporting the people and economies of developing countries and the use of money service business (MSB) services by UK residents".
All well and good, but then the template continues: "As you will be aware, MSBs are a high risk sector for banks. The Government estimates that £1.5 billion is laundered through MSBs every year".
For those seeking a solution to the Somali situation, this wording is distinctly unhelpful. In effect, it places the blame for the current crisis squarely at the feet of MSBs while exonerating the risk management of UK banks and the oversight of regulators in recent years.
As a blanket statement, it also confers guilt on all MSBs without drawing any sectoral distinctions between, for example, forex brokers, bureaux de change and remittance MTOs.
For companies and sectors unfairly tarnished in this way, mounting an effective defence is the stuff of Franz Kafka's nightmare novel "The Trial", in which Josef K. - who works at a bank - is prosecuted by an unknown authority for an unspecified crime.
Of course the UK remittance sector, like any financial services industry, may have its fair share of criminal and rogue operators. But leading Somali MTOs are adamant that they have complied with every regulatory directive and inspection required of them - and are willing to adhere to even stricter regulation.
In private, the National Crime Agency (NCA) says that the Somali corridor is not one which gives rise to undue concern about exploitation by money-launderers and financiers of terrorist activity; and in public the NCA has stressed that it is counter-productive to deny MTOs access to bank accounts.
As Somali MTOs prepare to work with government, some new wording in official correspondence and statements on Somali remittances which omits the guilty-by-association cast would surely lead to more constructive discussions.
On a related topic, it was announced last week that the African Institute for Remittances (AIR) has chosen Nairobi as the site for its secretariat - four years after its creation was announced by the World Bank, European Commission and African Union Commission.
Somalis no doubt hope that the World Bank, AIR's implementing agency and a key member of the Safer Corridor Working Group, will be mindful of DFID's stated intention of designing and implementing its pilot corridor for Somalia within 12 months.
Edward Paice is Director of Africa Research Institute