Introduction
The UN 2030 Agenda for Sustainable Development, adopted in 2015, builds upon the Millennium Development Goals of September 2000 and provides the global framework for poverty reduction and development through the end of this decade.Footnote 1 At the heart of the 2030 Agenda are the seventeen SDGs and their 169 related targets.Footnote 2 The “central, transformative promise” of both the 2030 Agenda and the SDGs is the principle of Leave No One Behind (LNOB), a relatively amorphous term, but one that recognizes that factors such as age, sex, disability, race, ethnicity, origin, religion, and economic status contribute to the success or failure of efforts to reduce poverty and provide for basic needs.Footnote 3 Although not specifically named as one of the seventeen SDGs or related targets, the concept of financial inclusion is a key enabler for many of the goals and is the hinge on which many of the LNOB factors turn.Footnote 4 Financial inclusion, according to the World Bank, “means that individuals and businesses have access to useful and affordable financial products and services that meet their needs – transactions, payments, savings, credit and insurance – delivered in a responsible and sustainable way.”Footnote 5 There is a significant academic literature discussing the contours of financial inclusion and the metrics for measuring it, but for purposes of examining efforts at poverty reduction and sustainable development in the Global South, the degree of access to formal financial services remains a critical measuring stick of progress towards the SDGs.Footnote 6
All of this matters because in the discourse surrounding the humanitarian impact of economic sanctions, particularly US sanctions, the effect of those policies on financial inclusion in targeted countries is almost never discussed.Footnote 7 Yet these sanctions, combined with US anti-money laundering and countering the financing of terrorism (AML/CFT) legislation, have a considerable “chilling effect.” This affects the risk calculus that banks engage in while deciding whether to do business at all in Africa. As a result, the measures supposedly targeted towards discrete individuals or countries wind up having a continental effect. The withdrawal of banks from Africa, as well as the increasing skittishness of those that remain to broaden their client base, is no trivial matter. This chilling effect works to hamper efforts at poverty reduction and sustainable development in Africa and is entirely driven by policies made in Washington, not in Africa. And while the particular occupant of the White House may have an impact on whom or what the US sanctions, it does not affect the growing propensity of US presidents to wield them as a preferred policy tool.Footnote 8
Equally problematic is that economic sanctions are often analyzed as a monolith, even when discussing those imposed by the US.Footnote 9 There are key distinctions in terms of transparency, accountability, and due process when the US is imposing multilateral sanctions under the authority and auspices of the UN and when it is acting on its own. US unilateral financial sanctions are one of the most powerful weapons Washington has ever wielded to impose its will abroad, all on account of the strength of the US dollar in the global economy, and it is one of the least understood by the general public. This presents a significant social justice issue that merits much deeper reflection among academics and policymakers, particularly those wedded to the notion that “targeted” or “smart” sanctions have a marginal humanitarian effect, especially when compared with more comprehensive sanctions regimes.Footnote 10
Africa in the Global Financial Order: All Roads Lead to Washington
Although there are other key players on the economic sanctions stage, the UN and the EU being two of the most important, the global hegemon of the international financial order is the US.Footnote 11 According to Jonathan Kirshner, “[t]he United States has been the dominant power in world politics since World War II and the leading influence on the nuts and bolts of how global economic relations are organized.”Footnote 12 All roads lead back to Washington and it is impossible to tell the story of how sanctions affect banking and financial inclusion in Africa without beginning there.
Setting the Stage: US AML/CFT Legislation
The chilling effect of sanctions on banking and financial inclusion has its genesis in US attempts to curb money laundering and to counter the financing of terrorism. AML/CFT legislation forms the superstructure that the US sanctions regime is grafted upon. At its most basic, money laundering “broadly refers to the process of disguising financial assets so they can be used without revealing their underlying illicit source or nature.”Footnote 13 It is, according to the World Bank, the process by which the proceeds from criminal activity are disguised in order to conceal their illicit source.Footnote 14 Terrorist financing, on the other hand, “refers to the process of fundraising, through both licit and illicit means, and financially sustaining terrorist groups.”Footnote 15 While the techniques used to launder money may bear some similarity to how terrorists conceal the source and use of their financing, ultimately the two are distinct, particularly in that terrorists may raise funds from legitimate sources or enterprises.Footnote 16
In any event, AML and CFT in the US were not initially conceptualized either as a common problem or as a single legislative framework. When the Bank Secrecy Act (BSA) and its major component, the Currency and Foreign Transaction Reporting Act, were passed by Congress in 1970, the focus was entirely on AML, which arose out of a concern that bank secrecy laws in place at the time were facilitating illegal activity and tax evasion.Footnote 17 Thus, the purpose of the BSA was “[t]o amend the Federal Deposit Insurance Act to require insured banks to maintain certain records, to require that certain transactions in United States currency be reported to the Department of the Treasury, and for other purposes.”Footnote 18 In doing so, the BSA establishes a framework for AML efforts in the US that is premised on effective implementation by financial institutions, meaning that the responsibility for monitoring and reporting suspicious activity rests with these same institutions.Footnote 19 This is important because US AML legislation, for the first time, put the onus on financial institutions to police compliance with a federal regulatory scheme, albeit with relatively modest penalties for failing to do so.
All of this changed in the wake of the September 11, 2001 attacks on the US. A month after the attacks, the Uniting and Strengthening America by Providing Appropriate Tools to Restrict, Intercept and Obstruct Terrorism Act of 2001 went into effect. More commonly known as the USA Patriot Act, the professed goal of the legislation was to prevent terrorism by expanding the surveillance and intelligence gathering capabilities of domestic law enforcement agencies.Footnote 20 One of the striking features of the Patriot Act is that out of the roughly 150 sections of the legislation, which deal with a myriad of subjects and agencies, 40 of those sections deal with some aspect of money laundering.Footnote 21 Despite this, at the time the Patriot Act was enacted, and for years afterward, the US government was not able to determine the source of the funding for the 9/11 attacks. In addition, many of the AML provisions in the legislation have been disfavored or rejected.Footnote 22 Nevertheless, adoption of the Patriot Act marked a radical expansion of the policing and gatekeeping function of financial institutions under the AML regulatory framework to now encompass CFT efforts as well.
The Long Arm of the Law: The Extraterritorial Reach of the Patriot Act
From a global perspective, the most immediate impact of the Patriot Act was the unprecedented extraterritorial reach the new legislation gave to US AML/CFT efforts.Footnote 23 The most important of these new tools is section 311 of the Patriot Act, which amended the BSA to empower the U.S. Treasury Secretary to designate any foreign financial institution, jurisdiction, or class of transactions as a “primary money laundering concern.”Footnote 24 Such a designation could lead to “special measures” being taken on the part of any domestic financial institution with which it is engaged. If the foreign entity is designated as a “money laundering concern,” its US counterparty may prohibit any new correspondent or payable-through accounts on behalf of the foreign financial entity or terminate any existing ones.Footnote 25
Although this reference to correspondent accounts seems like innocuous financial jargon for technocrats, it is deadly serious. A correspondent account is “an account established to receive deposits from, make payments on behalf of a foreign financial institution, or handle other financial transactions related to such institution.”Footnote 26 In the broadest sense of the term, correspondent banking “refers to formal agreements or relationships between banks to provide payment services for each other.”Footnote 27 In the global economy, correspondent banks play a critical role since they are the means by which cross-border payments are made, as well as wire transfers, check clearing and payment, trade finance, and foreign exchange settlement.Footnote 28 What the termination of correspondent accounts with US institutions means is that foreign financial entities cannot clear dollar-denominated transactions and are effectively cut off from the US banking system. Given the strength and ubiquity of the US dollar in the global financial order, not being able to maintain a correspondent account with a US financial institution or a foreign one permitted to work in the US, is sometimes referred to as “the death penalty.”Footnote 29
Avoiding this death penalty of debarment from the US financial system has become the overriding concern of financial institutions across the globe, spawning an industry of legal and consulting services dedicated to compliance with the US AML/CFT regime.Footnote 30 Risk management has become a key governance mechanism for global financial institutions, affecting every level of the enterprise.Footnote 31 While not all of the increase in financial risk management can be attributed to AML/CFT compliance, the gravity of incurring the death penalty lurking in the USA Patriot Act is too much of a gamble not to take seriously.
Sanctions Enforcement through the AML/CFT Framework
According to former Mexican Foreign Minister Jorge Castañeda the US “has idiosyncratic forms of bringing other countries or civilisations into its orbit – by force, by persuasion, by osmosis, by negotiation.”Footnote 32 Among the most idiosyncratic forms of power that the US wields is Washington’s ability to enforce its will over the global economy through its role as gatekeeper to the Federal Reserve and the US financial system.Footnote 33 The strength of the US dollar as the world’s reserve currency is such that an inability to access the Federal Reserve to reconcile dollar – denominated transactions can be catastrophic for any financial institution working in the international arena. Section 311 of the Patriot Act makes this financial death penalty the pivot on which US AML/CFT rests. Yet, for all of the extraterritorial reach that the Patriot Act provides Washington for its AML/CFT efforts, its true scope was not fully realized until that framework was applied to US economic sanctions enforcement.
Among the package of targeted sanctions which the US deploys, financial sanctions are implemented more easily in banking, given that the industry is already heavily regulated.Footnote 34 This heavy regulation of the banking industry is key because it is the fuel by which the Treasury Department weaponizes the US financial system through its sanctions policy. Whether or not US policymakers consciously understood that by grafting the post-9/11 AML/CFT framework onto its unilateral economic sanctions regime they were creating an economic nuclear weapon is immaterial. The end result is a policy tool with unprecedented coercive potential to get public and private foreign actors to bend to Washington’s will.Footnote 35
At the heart of the US AML/CFT regime are the provisions of the Patriot Act in section 326 which require banks and financial service providers to conduct extensive due diligence and recordkeeping in regard to customer identification.Footnote 36 These “Know Your Customer” (KYC) requirements have become “the principal Patriot Act-related friction point between financial institutions and their customers” and the point where these institutions begin their risk assessment both of the individual customer and the uses to which he or she may put their account.Footnote 37 Because AML/CFT has teeth, especially the debarment “death penalty,” risk assessment and AML compliance have become overriding concerns of the financial industry worldwide.Footnote 38 Theirs is now a world where the line between private commercial interest and the public role of financial regulators is increasingly blurred, with serious consequences for inadequate or incorrect KYC risk analysis.Footnote 39 In short, AML is premised on financial institutions acting as watchdogs and gatekeepers, engaging in a risk calculus that can have significant financial repercussions if they get it wrong.
US financial sanctions work in part by grafting this AML/CFT gatekeeping function into the enforcement framework, putting the burden on financial institutions themselves to make sure that they are not transacting with sanctioned individuals or entities. In the US, financial sanctions are imposed both by statute and executive order, and are implemented by regulations.Footnote 40 The Treasury Department’s OFAC is the primary federal agency tasked with implementing US financial sanctions, although with some programs there is a role for other agencies, including the State Department.Footnote 41 One of OFAC’s key responsibilities is maintaining the SDNs list which contains those “individuals, companies, and other entities whose assets are blocked, generally because they are owned or controlled by, or acting for or on behalf of, sanctioned countries, or are designated under non-country-specific programs, such as those targeting terrorists and foreign narcotics traffickers.”Footnote 42 For example, under the Global Magnitsky program, the SDN list now identifies individuals and entities accused of gross human rights violations or corruption.Footnote 43
US persons are generally prohibited from having any financial transactions with individuals or entities on the SDN list unless the US persons are authorized by OFAC to do so.Footnote 44 At first blush, this would appear to apply only to US nationals and domestic corporations, but under federal law the term “US persons” has an enormously broad definition to include the “foreign branches” of any entity organized under federal of state law.Footnote 45 OFAC expands this definition even further and interprets “U.S. financial institution” to mean not only the foreign branches of any US-based financial entity but also “[a]ny financial institution operating or doing business in the United States.”Footnote 46 Thus, to touch the US financial system, to avail yourself of dollar clearing through the Federal Reserve, or most importantly for our purposes, to maintain a correspondent banking relationship with a US bank, is to submit yourself to OFAC’s authority.
What makes the addition of sanctions enforcement to the AML/CFT framework so risk-laden from the banks’ perspective is that OFAC has not at all been shy in levying enormous penalties against financial institutions that run afoul of OFAC’s interpretation of due diligence. While OFAC has assessed fines for violations of US sanctions laws running in multiple billions of dollars, the penalty assessed against French bank BNP Paribas SA (BNPP) in 2014 was the one that gave financial institutions around the world pause.Footnote 47 BNPP reached an agreement with OFAC and other regulators where it agreed to pay a combined $8.9 billion for violations of US sanctions regulations.Footnote 48 Although the nearly $9 billion dollar fine was massive by any stretch of the imagination, what sent a chill down the spine of bankers around the world was the US triggering parts of its financial “death penalty.” For an entire year, BNPP was prohibited from accessing the Federal Reserve system to clear dollar-denominated transactions related to its oil and gas business.Footnote 49 Knowing full well that this would destroy this aspect of BNPP’s business, the order was stayed for six months to allow BNPP’s clients to move their accounts.Footnote 50
The US AML/CFT regime already had teeth; the Patriot Act had seen to that. What the penalties levied against BNPP taught the global financial industry was that the US was prepared to use its most formidable civil weapon against a foreign bank – in this case the US branches of a French-chartered bank. Irrespective of where your bank is headquartered, or where its principal place of business is located, if you need to clear dollar denominated transactions or otherwise touch the US financial system, you are subject to OFAC oversight for compliance not only with AML/CFT regulations, but with the SDN list as well. Having access to the US financial system be contingent on compliance with OFAC’s interpretation of the SDN list has had dire consequences on the banking industry in Africa over the ensuing years – a chilling effect which seriously hampers efforts at financial inclusion and poverty reduction across the continent.
The Real-World Impact of the Chilling Effect: Banking in Africa
As of 2021, some 1.4 billion people worldwide were unbanked, meaning that they had no access to an account at a financial institution or a mobile money provider.Footnote 51 Because most adults in high-income countries have access to these services, the overwhelming majority of the unbanked are in the developing world, with 54 percent of the unbanked globally being women.Footnote 52 Globally, the unbanked are also disproportionately the poor, with the poorest 40 percent of households making up nearly half of the world’s unbanked.Footnote 53 Although, as the World Bank noted, there are variations in account ownership among economies, certain areas of the world are much harder hit than others, particularly sub-Saharan Africa, where 74 percent of the unbanked have only a primary education or less.Footnote 54
The estimates of unbanked adults show a decline in the last few years. As of 2017, the World Bank put this figure at an estimated 1.7 billion adults, in comparison to the 1.4 billion estimate for 2021.Footnote 55 In part, this reflects the increased use of mobile money. Indeed, as mobile money accounts increased in sub-Saharan Africa, during the same period there was an accompanying decrease in financial institution accounts.Footnote 56 However, financial institutions are more regulated than mobile money, and have higher requirements for transparency.
Access to formal financial services, particularly for consumer banking, is a concern for African policymakers and has a direct impact on efforts towards sustainable development.
McKinsey & Company estimated in 2017 that approximately 300 million Africans were banked, or had access to retail banking services, up from 170 million in 2012.Footnote 57 Although in the aggregate that seems like a sizable figure, that is less than a third of a total population of more than 1.3 billion, and one that is expected to double by 2050.Footnote 58
Yet, financial inclusion through the expansion of retail banking is not as simple as opening a branch on every corner, especially when banks themselves increasingly view the risks of retail operations in Africa as unacceptably high. This aversion to working in Africa has nothing to do with the lack of profit opportunities, particularly in light of the continuing growth of a middle class relative to the population.Footnote 59 Instead, this aversion to the African retail banking market is driven almost entirely by the fear of running afoul of the US economic sanctions regime and incurring the wrath of OFAC.Footnote 60
Far and away, Africa has collectively been the target of more sanctions programs than any other continent.Footnote 61 However, it important to note that US sanctions, in particular, are not always country-specific, such as those which have targeted Cuba or Iran. Instead, many of the approximately 6,300 names on the SDN list are of individuals and entities listed as part of “targeted” counter-terrorism or counter-narcotics programs.Footnote 62 The targeting of individuals, as opposed to countries, has become much more pronounced in the years since the US adopted the legislation creating the Global Magnitsky program. All of this means that the risk calculus for compliance has become much more difficult. Rather than simply having sanctions programs that correspond to discrete countries, when there are more than 6,300 individuals and entities over numerous unrelated programs, compliance becomes exponentially more difficult. For Africa, that problem is magnified in that many of the names on the SDN are of individuals with a marginal nexus to Africa, such as Lebanese nationals connected with Hezbollah, who are alleged simply to have property or interests in African states – quite literally, a form of guilt by association.Footnote 63
All of this matters because the collision between a policy of enforcing US economic sanctions based on an AML/CFT framework and one of fostering financial inclusion in what should be a booming market for retail expansion, results in a no-win situation for financial institutions operating in Africa. The financial risk of miscalculating OFAC’s interpretation of the SDN list or not conducting due diligence to OFAC’s peculiar satisfaction far outweighs the potential rewards the African marketplace can offer or the development goal of greater financial inclusion. The chilling effect on banking services, which US economic sanctions policy engenders, has vast real-world effects.
OFAC’s Presence in Africa: The Lesson of BNP Paribas
OFAC’s $9 billion fine against French bank BNPP in 2014 for violations of US economic sanctions taught financial institutions worldwide a powerful lesson: Ignore OFAC at your peril. Moreover, the BNPP settlement showed that the debarment “death penalty” in the Patriot Act was more than an empty threat when it came to sanctions enforcement. However, the fact that this penalty was levied against France’s largest bank plays differently in Africa than it does in other parts of the world, as well as the fact that a second major French bank, Crédit Agricole, reached a nearly $800 million settlement with OFAC and other agencies for similar conduct the following year.Footnote 64
Sixty years after independence, France continues to maintain a massive economic presence not only in its former colonies but also on the continent as a whole.Footnote 65 If French financial institutions have become more risk averse in serving the African market, that has a much more significant impact on the banking industry in Africa than it would in other areas of the world.Footnote 66 France may resent the extraterritorial reach of US financial regulators, but France’s private financial institutions play the game by OFAC’s rules after the examples of BNPP and Crédit Agricole.Footnote 67 And in the “post-BNPP” sanctions world, global financial institutions will not only comply with OFAC regulations but will also overcomply so as to avoid any risk of massive fines and debarment from the US financial system. Yet the question remains, what makes Africa such a risk-laden market from a sanctions compliance perspective?
Know Your Customer: Easier Said than Done
AML/CFT risk assessment and sanctions compliance are premised on “knowing your customer,” ostensibly so that you are not dealing with somebody on the SDN list, or an entity tied to that individual. This works well enough in the US or in the EU, where you can run government-issued identification cards through national criminal databases. However, how can you possibly conduct this standard of KYC due diligence in a context where these identity documents either do not exist, individuals are not entitled to them, or where these police databases do not exist?
In Africa, customer identification and verification are major obstacles to financial inclusion, largely in the difficulty they pose in KYC due diligence, according to Financial Action Task Force (FATF) Recommendations and Methodology.Footnote 68 A key challenge is the lack of a robust identification structure across the continent, particularly in smaller economies.Footnote 69 This, combined with a lack of flexibility in conducting due diligence, means that many of the targets of financial inclusion efforts, particularly poor women, lack the proper documents to open or maintain formal accounts.Footnote 70
Similarly, NGOs operating in Africa have a particularly difficult time accessing banking services, as they are seen as presenting a high risk from a KYC perspective, in part because they are working with these same undocumented communities. Among the NGOs that have difficulty accessing banking services are those that provide critical services to refugees and victims of human rights abuses, as well as medical and social services. Difficulties in accessing the formal banking sector results in a greater use of paper currency transactions, raising the risk both for the NGO and the individuals served. All of this can be traced to the perceived toxicity of NGOs from an AML/CFT risk assessment perspective.
Correspondent Bank Withdrawal
In 2015, the World Bank produced a report noting a global decline in correspondent banking relationships, with fully 75 percent of the large international banks surveyed reporting a decline.Footnote 71 That decline has only been magnified in the decade that followed.Footnote 72 This is important because correspondent banking is the vehicle by which cross-border payments are made between different currencies.Footnote 73 The 2015 report found that the withdrawal from foreign correspondent banking relationships “is a complex and manifold phenomenon,” and that “[a] bank is completely justified not doing business because of business rationale, compliance costs, or excessive risk.” It also noted that the Middle East and Africa are the jurisdictions where correspondent banking relationships were most frequently terminated “related to concerns with countries that have sanctions imposed against them.”Footnote 74 But the report did not explicitly say that it is the fear of running afoul of OFAC that is driving this withdrawal.
Correspondent bank withdrawal from Africa is not just a problem for multinational business or local banks looking to service customers across borders. This has a direct impact on the ability of people to send and receive remittances from abroad.Footnote 75 Remittance flows to sub-Saharan Africa were estimated to be $54 billion in 2023, and were estimated to increase by at least 2.5 percent over the course of 2024.Footnote 76 Apart from the influx of capital that foreign remittances represent for African economies generally, people who lose access to remittances are more likely to experience food insecurity and increased poverty.Footnote 77 Even if individuals do not have formal bank accounts, bank de-risking affects them directly by the corresponding inability of money transfer operators (MTOs) to complete dollar-denominated wire transfers, if correspondent banks refuse to service them. These individuals are affected as well when MTOs that remain in the market significantly raise the prices they charge.Footnote 78
The inability to receive remittances, or the corresponding price spike for the MTOs that do offer wire transfer services in Africa, are felt sharply by refugees, migrants, and internally displaced persons. According to the UNHCR, “[R]emittances often constitute the first relationship that refugees have with the formal financial system of the host country and represent an important component of their livelihoods.”Footnote 79 As Africa hosts around 30 million internally displaced persons, refugees and asylum seekers live in Africa – almost one-third of the world’s refugee population – issues of financial inclusion as applied to refugees and displaced people have a special importance to African policymakers and civil society.Footnote 80
Although African countries have been trailblazers in the mobile money industry, with Kenya’s M-PESA the most established, mobile money systems are not a perfect solution to the withdrawal of correspondent banking relationships, particularly when it applies to receiving remittances from abroad. This is because remittance service providers are themselves required to perform AML/CFT due diligence and a KYC analysis.Footnote 81 Thus, while mobile money is the force currently driving financial inclusion in sub-Saharan Africa, even this technology is hampered in that endeavor by US sanctions policy.Footnote 82
Accordingly, the chilling effect of overzealous sanctions compliance resulting in withdrawal of banks from the African market, particularly correspondent banks, is felt not only by large businesses, but by ordinary people trying to get remittances from abroad to survive. Ostensibly, targeted “smart” sanctions are supposed to mitigate negative humanitarian impacts on the wider economy or population. However, the indiscriminate, and relatively incoherent, addition of names to the SDN list by OFAC, combined with massive penalties for noncompliance, tips the risk calculus for many financial institutions towards withdrawal from the African retail banking sector altogether. The end result, to which Washington appears oblivious, is a tremendous handicap in achieving financial inclusion and poverty reduction throughout Africa.
Conclusion
In passing the Anti-Money Laundering (AML) Act of 2020, Congress required the GAO to produce a study on financial services and de-risking. That report, published in December 2021, specifically addressed the ability of humanitarian organizations to serve their mission, the ease of sending and receiving remittances, and financial inclusion.Footnote 83 Not surprisingly, the GAO found that bank representatives “limit or deny services to money transmitters and nonprofits largely because of their efforts to comply with Bank Secrecy Act/anti-money laundering (BSA/AML) regulations … cit[ing] the high costs of conducting the due diligence necessary to ensure funds distributed in high-risk countries are not used for illicit purposes.”Footnote 84 Specifically as to sanctions compliance, the report noted that uncertainty with respect to OFAC’s interpretation of the scope of humanitarian exemptions is a key factor in the unwillingness of banks to offer financial services to nonprofits in sanctioned jurisdictions.Footnote 85 Notwithstanding the clarity of the GAO’s findings, it is unclear what effect, if any, they will have on overall US sanctions policy.
The unmistakable reality is that US economic sanctions, despite being sold to the public as targeted or “smart,” have a direct impact on the lives and livelihoods of the people of Africa, even in those states not directly under sanction. As Gordon notes, with US sanctions the combination of ambiguous regulations and very high penalties results is a predictable risk calculus by private actors – resulting in withdrawal from the targeted market.Footnote 86 For Africa, this powerful mix of a massive SDN list (that has been widely criticized for its arbitrariness and inconsistency), combined with the risk of multibillion dollar fines and possible debarment from the US financial system, results in a chilling effect on the retail banking industry on the continent. As correspondent banks withdraw their services, connecting to the dollar economy becomes much more difficult and much more expensive for African customers.
As recognized by the UN, financial inclusion is a key enabler for many of the SDGs which are the framework for poverty reduction and development over the remainder of the decade. The chilling effect of the US economic sanctions policy on financial inclusion efforts in Africa is real, and it is the poorest and most vulnerable people who are suffering. Twenty years after the passage of the USA Patriot Act, a re-evaluation of the paradigm linking AML and counter-terrorism is long overdue, as is a comprehensive examination of how, despite “targeting,” US economic sanctions continue to have devastating collateral effects on populations and economies far beyond their stated objective.
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