Remittances to Fragile Countries:
Treasury Should Assess Risks from Shifts to Non-Banking Channels
GAO-18-313: Published: Mar 8, 2018. Publicly Released: Mar 8, 2018.
People who send money from the United States to their families—especially to those in poor countries—see these "remittances" as a lifeline. However, remittances and other global payments can be used to hide money laundering and other financial crimes.
Money transfer companies have used banks to transfer money worldwide. But some banks want to limit their exposure to the risk of financial crimes, and refuse or restrict transfer companies' accounts.
Now, some transfer companies are bypassing the bank by taking cash over borders. We recommended that Treasury assess the risks of these transfers, which are harder to monitor for criminal activity.
Example of Remittance Transfer Using a Cash Courier
Diagram of a cash-to-cash transfer, showing the money's path across borders to the recipient.
What GAO Found
Stakeholders, including money transmitters, banks, and U.S. Department of the Treasury (Treasury) officials, reported a loss of banking access for money transmitters as a key challenge, although remittances continue to flow to selected fragile countries. All 12 of the money transmitters GAO interviewed, which served Haiti, Liberia, Nepal, and particularly Somalia, reported losing some banking relationships during the last 10 years. As a result, 9 of the 12 money transmitters reported using channels outside the banking system (hereafter referred to as non-banking channels), such as cash couriers, to move funds domestically or, in the case of Somalia, for cross-border transfer of remittances (see figure). Several banks reported that they had closed the accounts of money transmitters because of the high cost of due diligence actions they considered necessary to minimize the risk of fines under Bank Secrecy Act regulations. Treasury officials noted that despite some money transmitters losing bank accounts, they see no evidence that the volume of remittances is falling.
Example of a Cash-to-Cash Remittance Transfer Using a Cash Courier
U.S. agencies have taken steps that may mitigate money transmitters' loss of banking access. For example, several agencies have issued guidance to clarify expectations for providing banking services to money transmitters. In addition, Treasury is implementing projects to strengthen financial institutions in some fragile countries. However, U.S. agencies disagreed with other suggestions, such as immunity from enforcement actions for banks serving money transmitters, since those actions could adversely affect goals related to preventing money laundering and terrorism financing.
Treasury cannot assess the effects of money transmitters' loss of banking access on remittance flows because existing data do not allow Treasury to identify remittances transferred through banking and non-banking channels. Remittance data that U.S. agencies collect from banks do not include transfers that banks make on behalf of money transmitters. Additionally, the information Treasury collects on transportation of cash from U.S. ports of exit does not identify remittances sent as cash. Therefore, Treasury cannot assess the extent to which money transmitters are shifting from banking to non-banking channels to transfer funds due to loss of banking access. Non-banking channels are generally less transparent than banking channels and thus more susceptible to the risk of money laundering and terrorism financing.
Why GAO Did This Study
The United States is the largest source of remittances, with an estimated $67 billion sent globally in 2016, according to the World Bank. Many individuals send remittances through money transmitters, a type of business that facilitates global money transfers. Recent reports found that some money transmitters have lost access to banking services due to derisking—the practice of banks restricting services to customers to, in part, avoid perceived regulatory concerns about facilitating criminal activity.
GAO was asked to review the possible effects of derisking on remittances to fragile countries. This report examines (1) what stakeholders believe are the challenges facing money transmitters in remitting funds from the United States to selected fragile countries, (2) actions U.S. agencies have taken to address identified challenges, and (3) U.S. efforts to assess the effects of such challenges on remittance flows to fragile countries. GAO selected four case-study countries—Haiti, Liberia, Nepal, and Somalia—based on factors including the large size of U.S. remittance flows to them. GAO interviewed U.S.-based money transmitters, banks, U.S. agencies, and individuals remitting to these countries and also surveyed banks.
What GAO Recommends
Treasury should assess the extent to which shifts in remittance flows to non-banking channels for fragile countries may affect Treasury's ability to monitor for financial crimes and, if necessary, should identify corrective actions. GAO requested comments from Treasury on the recommendation, but none were provided.
For more information, contact Thomas Melito at (202) 512-9601 or MelitoT@gao.gov.
Recommendation for Executive Action
Comments: In May 2018, Treasury described its plans to address our recommendation. Treasury noted that its existing mechanisms to communicate with private and public sector stakeholders allow it to monitor risks and take corrective action, if needed. Additionally, Treasury provided a study it had conducted to explore the feasibility of a pilot program to encourage banks to provide services to money transmitters serving Somalia. In its study, Treasury found that banks remained unwilling to provide services-such as international wire transfers-to money transmitters serving Somalia, even if money transmitters provided more information on their transactions to banks. The findings of this study highlight that money transmitters, in particular those serving Somalia, are likely to continue using nonbanking channels in the absence of banking services to transfer funds overseas. Therefore, our recommendation still remains relevant. We will continue to review any efforts that Treasury undertakes to address the recommendation and provide periodic updates.
Recommendation: The Secretary of Treasury should assess the extent to which shifts in remittance flows from banking to non-banking channels for fragile countries may affect Treasury's ability to monitor for money laundering and terrorist financing and, if necessary, should identify corrective actions.
Agency Affected: Department of the Treasury