Thread by @PuntlandPirates

@GI_TOC issued a detailed statement earlier today in response to Amal Express's claims (attached below). But in my personal capacity as the author of the report, I will respond here with some additional thoughts.

(1/14)

https://twitter.com/khadarHared/status/1315215422862618624

In its 9 October 2020 press release, Amal Express disputed the authenticity of an October 2019 remittance receipt published in my report. The receipt detailed the transfer of $19,500 by an arms dealer in Bosaso to an individual under US Treasury (OFAC) sanction. (2/14)

Amal's statement contained several inaccuracies, but the most personally damaging was the claim that I had ignored evidence the company had presented to me proving this remittance slip to be a "forgery." (3/14)

To set the record straight: I interviewed a senior representative of the company on 11 July 2020, at which point I made him aware of the October 2019 transfer. On the same day, I emailed the company the transaction details and offered an opportunity for further comment. (4/14)

At no point from 11 July onwards, including up to the present moment, have I (or GI-TOC) received any subsequent communication from Amal Express. (5/14)

The report research process involved the collection of hundreds of MTO remittance receipts in Puntland dating to between 2014 and 2020. The receipts were collected by multiple independent sources.

63 of these slips pertained to Amal transactions. (6/14)

But, for the sake of a neutral comparison, I recently asked a friend in Puntland to send me a random Amal remittance slip dating to around the same time (late 2019) as the transaction disputed by the company.

The appearance of these two receipts is identical. (7/14)

To be charitable to Amal, it is my supposition that the company is simply unaware of the activities of its agents in Bosaso. Indeed, my report highlighted how the decentralized nature of the 'hawala' system leads to agents failing to comply with parent company policy. (8/14)

It is a positive step that Amal has offered to submit to an audit by the Central Bank of Somalia; the value of such an exercise may be debatable, however, if the company's central systems themselves do not contain the relevant financial data. (9/14)

Amal's statement also inaccurately claimed that the GI-TOC report referred to the use of Amal's services by individuals on an unspecified "UN Black List". As noted above, the transaction published in the report concerned an individual under OFAC, not UN, sanction. (10/14)

Nowhere did the report claim that Amal Express, or any other named MTO, had violated UN sanctions. (11/14)

The fact that Amal's statement (which was presumably reviewed by the company's compliance department and its lawyers) conflated UN and OFAC sanctions speaks volumes in itself of the company's grasp of AML/CFT regulation. (12/14)

As noted in the GI-TOC statement, we stand ready to engage with Amal, or any other MTO operating in #Somalia, about the report's findings and its recommendations regarding AML/CFT compliance in such challenging environments. (13/14)

The critical importance of remittances to vulnerable populations in Somalia, facilitated by MTOs like Amal, is indisputable. However, it is possible to strengthen Somalia's financial systems in order to prevent their abuse by criminal elements. (14/14)