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The Impact of Global International Informal Banking on Canada

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Post 9/11, some banks are shutting down the Financial Agents accounts because <str<strong>on</strong>g>of</str<strong>on</strong>g> what is<br />

deemed to be suspicious account activity—and in most cases without giving any reas<strong>on</strong>. This has<br />

compelled the Financial Agents, registered and unregistered, to transact purely <strong>on</strong> trust or through<br />

third party businesses that have not been shut down / refused by the banks, for settlement. <str<strong>on</strong>g>The</str<strong>on</strong>g>se<br />

third party businesses <str<strong>on</strong>g>of</str<strong>on</strong>g>ten bel<strong>on</strong>g to other ethnic cultures and are unc<strong>on</strong>nected to the Afghani<br />

community. <str<strong>on</strong>g>The</str<strong>on</strong>g> Afghani Financial Agents claimed not knowing the reas<strong>on</strong> for banks permitting<br />

these third party businesses to execute the very same transacti<strong>on</strong>s that were refused to them by the<br />

banks because the funds are destined to the same jurisdicti<strong>on</strong>s, are for similar amounts and have<br />

the same frequency. But the other businesses are still ‘in business’ while the Afghani Financial<br />

Agents accounts have been closed by some banks.<br />

This third party transacting poses a serious risk to business. As complained by the registered<br />

Financial Agents, the risk <str<strong>on</strong>g>of</str<strong>on</strong>g> funds getting lost because there is limited or no accountability by the<br />

third party. Other problems encountered are delayed delivery or settlement (i.e., at times it takes<br />

up to 10 days to dispense or settle accounts), opaqueness <str<strong>on</strong>g>of</str<strong>on</strong>g> the third party infra-structure (i.e., the<br />

Afghani Financial Agents do not know the third party trust or bank network). Cumulatively, all<br />

these reas<strong>on</strong>s make transacti<strong>on</strong>s risky and it is bad for business.<br />

<str<strong>on</strong>g>The</str<strong>on</strong>g> inc<strong>on</strong>sistent acts <str<strong>on</strong>g>of</str<strong>on</strong>g> banks have resulted in the Financial Agents going ‘bank shopping’.<br />

Since some banks are more ‘accommodating’ than others, they have ‘flown like a flock’ to those<br />

banks and moved <strong>on</strong> to other banks/instituti<strong>on</strong>s when their accounts have been shut down by the<br />

previous <strong>on</strong>es. An effect <str<strong>on</strong>g>of</str<strong>on</strong>g> ‘bank shopping’ or relying <strong>on</strong> third parties is that the small<br />

independent operators have loosely associated themselves with larger entities in their community.<br />

<str<strong>on</strong>g>The</str<strong>on</strong>g>se small operators assume that the larger entities are registered, have not been shut down by<br />

the banks and that they can ensure transacti<strong>on</strong> completi<strong>on</strong>. However, this is not a soluti<strong>on</strong><br />

because the registered Financial Agents are facing the same problem and carrying the risk<br />

forward by going to third parties. <str<strong>on</strong>g>The</str<strong>on</strong>g>se facts apply to those transacti<strong>on</strong>s wherein the banks<br />

involvement is fr<strong>on</strong>t-ended and direct.<br />

Furthermore, transacting purely <strong>on</strong> trust for small operators has additi<strong>on</strong>al serious limitati<strong>on</strong>s.<br />

<str<strong>on</strong>g>The</str<strong>on</strong>g>se limitati<strong>on</strong>s include a disproporti<strong>on</strong>ate, <strong>on</strong>e way flow-<str<strong>on</strong>g>of</str<strong>on</strong>g>-funds (i.e., <str<strong>on</strong>g>of</str<strong>on</strong>g> remittances, into<br />

Afghanistan), a limited number <str<strong>on</strong>g>of</str<strong>on</strong>g> clients and settlement that is dependent <strong>on</strong> travel and<br />

immigrati<strong>on</strong>. And this has resulted in driving a lot <str<strong>on</strong>g>of</str<strong>on</strong>g> small independent Financial Agents out <str<strong>on</strong>g>of</str<strong>on</strong>g><br />

business or affiliating themselves with larger entities.<br />

5.6. Advertising and Affiliati<strong>on</strong>s:<br />

<str<strong>on</strong>g>The</str<strong>on</strong>g>re has been a decrease in advertising in ethnic newspapers, directories or the internet by all<br />

Financial Agents. Currently, <strong>on</strong>ly the registered Financial Agents advertise. <str<strong>on</strong>g>The</str<strong>on</strong>g> reas<strong>on</strong> for<br />

scaling back or not advertising at all, as explained by the unregistered Financial Agents is because<br />

meeting client needs is difficult given the increased scrutiny and the unwillingness <str<strong>on</strong>g>of</str<strong>on</strong>g> the banks to<br />

participate.<br />

5.7. Competiti<strong>on</strong> / Collaborati<strong>on</strong><br />

<str<strong>on</strong>g>The</str<strong>on</strong>g>re is high competiti<strong>on</strong> between Financial Agents in the community. Originally before 9/11,<br />

there were several independent operators and all <str<strong>on</strong>g>of</str<strong>on</strong>g> them were unregistered. After 9/11, due to<br />

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