太平洋岛国代理银行的衰落：知识状况和解决问题的方法（英）

STATE OF KNOWLEDGE AND WHAT CANBE DONE TO FIX THE PROBLEMS J U L Y2 0 2 3 CONTENTS Executive summary05 1 Background to the study11 2 Introduction and purpose12 2.1 De-risking and de-banking2.2 De-risking and CBRs2.3 ML/TF/PF risk in the Pacific151820 243 Recent developments of relevance to the Pacific 274 The extent of CBR decline in the Pacific 335 Impact of decline in CBRs on exports 346 Impact of decline in CBRs on remittance costs 3841427.1 Improving ML/FT/PF risk management7.2 Improving the enabling environment for CBR services7.3 Countering the effects of complete de-banking 438 Stocktake of solution initiatives undertaken to-date 434749508.1 Improving ML/FT/PF risk management8.2 Improving the enabling environment for CBR services8.3 Recommended initiatives not yet actively explored by PIF members8.4 Stocktake summary 609 Recommendations 6610 List of background Technical Papers KEY ACRONYMS IN THIS REPORT MLMoney LaunderingMTOMoney Transfer OperatorNPONon-profit OrganizationNRANational Risk AssessmentPFProliferation FinancingPFICPacific Financial Intelligence CommunityPFTACPacific Financial Technical Assistance CentrePIPayment InstitutionPIFPacific Islands ForumPIRIPacific Islands Regional InitiativePSPPayment Service ProvidersRBAReserve Bank of AustraliaRBNZReserve Bank of New ZealandRSPRemittance Service ProviderSPGMSouth Pacific Governors MeetingSWIFTSociety for Worldwide Interbank Financial TelecommunicationsUKUnited KingdomUSUnited States of AmericaWBWorld Bank EXECUTIVE SUMMARY Background At the Pacific Islands Forum (PIF) Economic Ministers meeting heldin Vanuatu in August 2022, Ministers were concerned to note thecontinued withdrawal of correspondent banking relationships (CBRs)in the Pacific, which is one of the effects of “de-risking”. Correspondent banking is the provision of payment banking servicesby one bank to another bank where both institutions are basedin different countries. These relationships are at the core of theglobal payments system, enabling cross-border payments suchas remittances and export revenues. In particular, the Ministersexpressed grave concerns regarding the potential impact onaccessible and affordable banking services in the region. MaintainingCBRs is a prerequisite to attracting investment, promoting trade, andreceiving remittances. The meeting participants also noted the impactof losing CBRs on the lives of Pacific Islanders, including seasonalworkers, small and medium enterprises, and other vulnerable groups. As an immediate action, the PIF Secretariat decided to conducta study on the closure of CBRs in the region, with the aim ofunderstanding the current situation in member countries, the remedialactions undertaken, the lessons learnt and potential remedial actions,and remedies that might prevent further de-risking. The Secretariatrequested the World Bank’s assistance with this task. This report consists of a main report and eight technical papers (TPs)and lays out recommended actions for the Pacific Islands (PIs) forcombatting de-risking at a regional level. The report considers thedevelopments in relation to the Cook Islands, Fiji, French Polynesia,Kiribati, Nauru, New Caledonia, Niue, Papua New Guinea, Samoa,Solomon Islands, Tonga, Tuvalu, and Vanuatu. De-risking and why it matters Through their CBRs, banks access financial services in other jurisdictions and provide cross borderpayments services to their customers, supporting international trade and financial inclusion. De-riskingis the withdrawal of banking services, partly in response to anti-money laundering (AML), combating offinancing of terrorism (CFT) and proliferation financing (CPF) concerns. It is defined by the FinancialAction Task Force (FATF), the global standard-setting body for AML/CFT/CPF, as: “the phenomenon of financial institutions terminating or restricting business relationships with clientsor categories of clients to avoid, rather than manage, risk in line with the FATF’s risk-based approach”(FATF 2014). De-risking results in not only fewer and lesser quality CBRs but potentially also in more limited servicesbeing rendered at a higher cost. Thus, it can hamper remittances and prevent segments of the populationfrom accessing the financial system efficiently, or it can delay the transfer of international developmentfunds, and humanitarian and disaster relief. It can also drive financial activity out of the regulatedfinancial system into informal channels. A lower number and quality of CBRs can also have a broad economic impact. Econometric analysiscarried out for this study found evidence that the decline in CBRs has had an impact on exportperformance. Detailed analysis of remittance flows also identified high costs relative to Southeast Asiaand South Asia, findings that were reinforced by our econometric analysis (TP 6). How important is de-risking? The extent to which correspondent banking facilities have been withdrawn from PIF countries is recordedin dat