VZCZCXRO5207
PP RUEHDBU RUEHPW RUEHSL
DE RUEHBUL #0711/01 0590635
ZNY EEEEE ZZH
P 280635Z FEB 10
FM AMEMBASSY KABUL
TO RUEHC/SECSTATE WASHDC PRIORITY 5917
RUEATRS/DEPT OF TREASURY WASHINGTON DC 0991
INFO RUCNAFG/AFGHANISTAN COLLECTIVE
RUEABND/DEA HQS WASHINGTON DC

UNCLAS E F T O SECTION 01 OF 03 KABUL 000711 
 
NOFORN 
SENSITIVE 
SIPDIS 
 
DEPT PASS AID/ASIA SCAA DRAY 
TREASURY FOR DCOHEN, LMCDONALD, MNUGENT, JCASAL, AKIFAYAT 
 
E.O. 12958: N/A 
TAGS: EFIN ECON SNAR KTFN KCOR KCRM PGOV PINS AF
SUBJECT: CORRECTED COPY: Treasury A/S Cohen Urges Major Afghan Banks 
to be more Vigilant 
 
REF: A. KABUL 551 
     ¶B. KABUL 455 
 
--------- 
SUMMARY 
--------- 
 
¶1. (SBU//NF) In meetings with the heads of Kabul Bank, Azizi Bank 
and Afghan United Bank on February 11, Treasury Department Assistant 
Secretary for Terrorist Financing David Cohen strongly encouraged 
the Afghan banking sector to implement stronger controls against 
money laundering and terrorist financing, and urged the banks to be 
more vigilant, especially if they want to pursue linkages with U.S. 
and other international institutions.  A/S Cohen expressed 
particular concern about Kabul Bank's correspondent relationship 
with banks in Iran, as well as Afghan United Bank's association with 
the New Ansari Hawala network, an organization under investigation 
by Afghan law enforcement for its alleged involvement with illicit 
finance cash flows and narcotics traffickers.  A/S Cohen also met 
with Minister of Economy Haji Abdul Hadi Arghandewal to emphasize 
the need to strengthen the Ministry's oversight of NGOs and 
charities operating in Afghanistan.  A/S Cohen delivered a strong 
message to both the banks and Ministry of Economy on the need to 
dramatically enhance efforts to combat illicit financing in 
Afghanistan.  End Summary. 
 
-------------------------------------- 
KABUL BANK, AFGHANISTAN'S LARGEST BANK 
-------------------------------------- 
 
¶2. (SBU//NF) Treasury Assistant Secretary for Terrorist Financing 
David Cohen travelled to Afghanistan as part of the delegation led 
by Treasury Deputy Secretary Neal Wolin.  On February 11, A/S Cohen 
met with several Afghan banking leaders, beginning with Kabul Bank 
President Khalil Frozi, Director of Internal Audit Raja 
Gopalakishnan, Compliance Director Mahboob Frotan and Head of 
International Banking, Samir Cena.  With the most extensive branch 
network and over $1.05 billion in deposits, Kabul Bank is the 
largest bank in Afghanistan.  Frozi reported that the bank has 
approximately one million customers and provides services for 
approximately 350,000 civil servants in the form of electronic 
salary transfers/payments.  Bank officials added that its primary 
international customers are foreign NGOs, the U.S. Embassy, the U.S. 
Army and ISAF. 
 
----------------------------- 
KABUL BANK AML/CFT COMPLIANCE 
----------------------------- 
 
¶3. (SBU//NF) President Frozi maintained that his bank's compliance 
practices are strong and that it regularly submits reports of 
suspicious and large cash transactions (exceeding Afs 500,000 - 
equivalent to USD 10,000) to FinTRACA, Afghanistan's financial 
intelligence unit.  Additionally, he asserted that the bank profiles 
its larger account holders every six months to ensure there are no 
unusual transactions.  Asserting that Kabul Bank understands the 
importance of combating terrorist financing, Frozi requested that 
Treasury provide the bank with more specific details/identifiers 
associated with "blacklisted" individuals, particularly from the UN 
list. 
 
¶4. (SBU//NF) In response to Frozi's comment that his bank is working 
to develop its capacity to match international standards and gain 
access to U.S. markets, A/S Cohen expressed support for this 
approach but reminded the bank officials that the risk of money 
laundering and terrorist financing in Afghanistan is unusually 
significant.  He commended Kabul Bank for establishing stronger 
controls, but urged the bank to be extraordinarily vigilant against 
money laundering and terrorist financing. 
 
¶5. (SBU//NF) Kabul Bank indicated it is preparing to introduce 
plastic "stored value" cards to transfer cash/value to diminish the 
role of money exchangers and service providers in Afghanistan. 
(Note: While Kabul Bank aims to diminish the role of money service 
providers, it maintains bank accounts for many of these providers. 
We also know, for example, that Kabul Bank uses Shaheen, a hawala 
controlled by a key Kabul Bank shareholder, to move money between 
Kabul and Dubai.  End Note) 
 
------------------------- 
KABUL BANK'S TIES TO IRAN 
------------------------- 
 
¶6. (SBU//NF) A/S Cohen discussed the risks of doing business with 
Iranian financial institutions and urged Kabul Bank to exercise 
 
KABUL 00000711  002 OF 003 
 
 
vigilance.  Kabul Bank acknowledged correspondent banking 
relationships with several Iranian banks, including the Export 
Development Bank of of Iran, a bank designated by the U.S. for its 
involvement in Iran's proliferation program, as well as Post Bank of 
Iran (Ref A).  (Note: In an earlier meeting with Kabul Bank, its 
leadership indicated a desire to conduct business with Post Bank of 
Iran and asked for U.S. Treasury's position.  End Note)  A/S Cohen 
stated that U.S. and international financial institutions will 
carefully consider the risks of maintaining correspondent 
relationships with foreign banks that facilitate transactions for or 
on behalf of Iran.  Kabul Bank explained that Iran is one of 
Afghanistan's largest trading partners, with some $3 billion per 
annum worth of trade between the two countries.  Frozi responded 
that Kabul Bank will immediately cease its dealings with all Iranian 
institutions and close any existing accounts, adding that his bank 
would provide Treasury with a record of all transactions from the 
Iranian accounts.  (Note:  The Treasury Attache office will follow 
up on Kabul Bank's offer.  End Note) 
 
---------------------------- 
AZIZI BANK, A DISTANT SECOND 
---------------------------- 
 
¶7. (SBU//NF) Following his meeting with Kabul Bank, A/S Cohen met 
with Azizi Bank President Noor Khan Haider, Deputy CEO Inayatullah 
Fazli, and Branch Operations Manager Frogh Lateef.  Haider said 
Azizi Bank has 230,000 accounts, and is Afghanistan's second largest 
bank after Kabul Bank.  (Note: Azizi Bank is the second largest in 
terms of account holders, but third in terms of assets; Afghan 
International Bank is second in total assets.  End Note)  Haider 
asserted that Azizi Bank is fully compliant with Afghan Central Bank 
rules and regulations regarding illicit finance and regularly 
reports large cash transactions to FinTRACA. 
 
¶8. (SBU//NF) A/S Cohen asked about Small and Medium Enterprise (SME) 
lending and Azizi Bank's issuance of stored value cards. Haider 
responded that, per a request from the Minister of Agriculture, 
"Azizi is in the process of looking into SME lending, that it is 
very risky," but that the Minister had agreed to share some of the 
risk.  (Note: We are not aware of an agreement between the Ministry 
of Agriculture, Irrigation, and Livestock (MAIL) and Azizi Bank for 
SME lending -- or of an agreement to share risk.  A broader 
agriculture finance plan of action is under discussion between 
Embassy Kabul and Washington.  End Note)  Azizi Bank also complained 
that USAID funds are not held in Afghan banks and are instead 
immediately transferred to foreign banks operating outside of 
Afghanistan.  Bank officials argued that keeping this money in 
Afghan banks would provide an indirect benefit to both the financial 
sector and broader economy. 
 
¶9. (SBU//NF) A/S Cohen explained that Afghanistan is a high risk 
country for terrorist financing and urged Azizi Bank officials to be 
vigilant and to raise their threshold of awareness for terrorist 
financing and money laundering.  As with Kabul Bank, Azizi Bank is 
pursuing correspondent relationships with U.S. Banks (specifically 
Citibank) but were (according to Azizi Bank officials) told by Citi 
that Afghan government standards are unsatisfactory.  Azizi 
maintains correspondent relationships with Commerzbank (Germany) and 
Habib American Bank (U.S.). 
 
------------------------------ 
OVERVIEW OF AFGHAN UNITED BANK 
------------------------------ 
 
¶10. (SBU//NF) A/S Cohen then met with Afghan United Bank (AUB) 
Chairman Mohammad Jan, CEO Mohammad Hassan and Deputy CEO Haji 
Bashir Ahmad.  AUB reported that it is in the process of purchasing 
and customizing new Oracle software to ensure compliance with 
anti-money laundering and combating the financing of terrorism 
(AML/CFT) controls.  A/S Cohen r--------------- 
AFGHAN UNITED BANK'S LINK TO THE NEW ANSARI NETWORK 
--------------------------------------------- ------ 
 
¶12. (SBU//NF) A/S Cohen expressed particular concern that AUB is 
part of the Ansari Financial Network, the hawala which is under 
investigation by Afghan law enforcement.  He asked how AUB is 
protecting itself against the potential for illicit financial flows 
associated with the New Ansari Hawala.  CEO Mohammad Hassan 
responded that "AUB is not involved with the hawala network nor 
influenced in any way by New Ansari."  However, when A/S Cohen asked 
whether New Ansari Hawala had accounts with AUB, Hassan replied 
affirmatively, stating that New Ansari Hawala and other licensed 
money service providers have deposit accounts with AUB, but that 
international money transfers are prohibited via AUB.  AUB Chairman 
Mohammad Jan explained that only eight years ago, all financial 
transfers in Afghanistan were done through hawalas, but Afghans had 
begun to use banks, adding that the Central Bank should "tax hawala 
transfers" to encourage people to move money into banks (Ref B). 
A/S Cohen noted that Treasury would like to encourage the banking 
sector to expand and to assist in the broader efforts to bring the 
regulation of hawalas in line with the regulation of the formal 
financial sector.  Stressing that hawalas are higher risk bank 
customers, he said more enhanced procedures are needed, including 
ongoing monitoring of hawala accounts.  A/S Cohen encouraged AUB 
officials to work closely with law enforcement and the Central Bank 
to make sure they are in compliance with international law and best 
practices.  Hassan reiterated that AUB is cooperating and will 
continue to do so. 
 
--------------------------------------------- ---- 
STRENGTHENING MINISTRY OF ECONOMY'S NGO OVERSIGHT 
--------------------------------------------- ---- 
 
¶12. (SBU//NF) A/S Cohen also met with Minister of Economy Abdul Hadi 
Arghandewal to follow up on concerns regarding the Ministry of 
Economy's (MOE) role in monitoring the Afghan NGO sector, as 
charities are required to register with the MOE, which also has 
responsibility for supervising the sector. 
 
¶13. (SBU//NF) A/S Cohen emphasized that limited NGO oversight is a 
serious vulnerability in Afghanistan, and noted that NGOs can be 
manipulated by insurgent finance networks for fundraising in 
jurisdictions with limited regulatory oversight or insufficient CFT 
controls.  Arghandewal responded that there are 1,625 registered 
NGOs in Afghanistan and acknowledged that, of these, some are 
actually for-profit entities and that the Ministry of Economy does 
not monitor the operations of many.  Observing that he has only been 
in his position for 20 days and is therefore "starting from 
scratch," he noted that capacity throughout the MOE is very low and 
Ministry does not have enough capable staff or the appropriate 
institutional mechanisms to monitor projects properly.  A/S Cohen 
stressed that the Ministry of Economy should play a key role moving 
the Government in a direction that results in better supervision of 
this important sector. 
 
-------- 
COMMENT 
-------- 
 
¶14. (SBU//NF) Assistant Secretary Cohen's visit sent a powerful 
message on "increased vigilance" to the Afghan financial sector, 
which many consider the country's most powerful business grouping. 
While the Central Bank's financial supervision department has made 
progress, serious concerns remain in the sector, in particular the 
level of due diligence exercised by those banks transacting business 
with domestic and international customers, which requires further 
tightening at both the bank and financial regulator levels.  It was 
also clear from these meetings that the MOE needs to strengthen NGO 
and charity oversight functions immediately. 
 
EIKENBERRY 
 
KABUL 00000711  003 OF 003 
 
 
KPMG, PricewaterhouseCoopers, Ernst and Young, and Deloitte to 
better understand their relationships with their parent companies 
and other area audit firms.  End Note) 
 
--------------------------------------------- ------ 
AFGHAN UNITED BANK'S LINK TO THE NEW ANSARI NETWORK 
--------------------------------------------- ------ 
 
¶12. (SBU//NF) A/S Cohen expressed particular concern that AUB is 
part of the Ansari Financial Network, the hawala which is under 
investigation by Afghan law enforcement.  He asked how AUB is 
protecting itself against the potential for illicit financial flows 
associated with the New Ansari Hawala.  CEO Mohammad Hassan 
responded that "AUB is not involved with the hawala network nor 
influenced in any way by New Ansari."  However, when A/S Cohen asked 
whether New Ansari Hawala had accounts with AUB, Hassan replied 
affirmatively, stating that New Ansari Hawala and other licensed 
money service providers have deposit accounts with AUB, but that 
international money transfers are prohibited via AUB.  AUB Chairman 
Mohammad Jan explained that only eight years ago, all financial 
transfers in Afghanistan were done through hawalas, but Afghans had 
begun to use banks, adding that the Central Bank should "tax hawala 
transfers" to encourage people to move money into banks (Ref B). 
A/S Cohen noted that Treasury would like to encourage the banking 
sector to expand and to assist in the broader efforts to bring the 
regulation of hawalas in line with the regulation of the formal 
financial sector.  Stressing that hawalas are higher risk bank 
customers, he said more enhanced procedures are needed, including 
ongoing monitoring of hawala accounts.  A/S Cohen encouraged AUB 
officials to work closely with law enforcement and the Central Bank 
to make sure they are in compliance with international law and best 
practices.  Hassan reiterated that AUB is cooperating and will 
continue to do so. 
 
--------------------------------------------- ---- 
STRENGTHENING MINISTRY OF ECONOMY'S NGO OVERSIGHT 
--------------------------------------------- ---- 
 
¶12. (SBU//NF) A/S Cohen also met with Minister of Economy Abdul Hadi 
Arghandewal to follow up on concerns regarding the Ministry of 
Economy's (MOE) role in monitoring the Afghan NGO sector, as 
charities are required to register with the MOE, which also has 
responsibility for supervising the sector. 
 
¶13. (SBU//NF) A/S Cohen emphasized that limited NGO oversight is a 
serious vulnerability in Afghanistan, and noted that NGOs can be 
manipulated by insurgent finance networks for fundraising in 
jurisdictions with limited regulatory oversight or insufficient CFT 
controls.  Arghandewal responded that there are 1,625 registered 
NGOs in Afghanistan and acknowledged that, of these, some are 
actually for-profit entities and that the Ministry of Economy does 
not monitor the operations of many.  Observing that he has only been 
in his position for 20 days and is therefore "starting from 
scratch," he noted that capacity throughout the MOE is very low and 
Ministry does not have enough capable staff or the appropriate 
institutional mechanisms to monitor projects properly.  A/S Cohen 
stressed that the Ministry of Economy should play a key role moving 
the Government in a direction that results in better supervision of 
this important sector. 
 
-------- 
COMMENT 
-------- 
 
¶14. (SBU//NF) Assistant Secretary Cohen's visit sent a powerful 
message on "increased vigilance" to the Afghan financial sector, 
which many consider the country's most powerful business grouping. 
While the Central Bank's financial supervision department has made 
progress, serious concerns remain in the sector, in particular the 
level of due diligence exercised by those banks transacting business 
with domestic and international customers, which requires further 
tightening at both the bank and financial regulator levels.  It was 
also clear from these meetings that the MOE needs to strengthen NGO 
and charity oversight functions immediately. 
 
EIKENBERRY