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Executive Summary

It would have been hard to understand the significance of Kwanza Capital just by looking at the company’s headquarters in a commercial garage in Kinshasa’s business district. No sign marked its presence. There was nothing to indicate the company was shuffling over one hundred million dollars through accounts held at a bank linked to the family of Joseph Kabila, who served as president of the Democratic Republic of Congo (Congo) from 2001 to January 2019. Nor would onlookers have had reason to suspect that the company was controlled by members of Congo’s former first family and its close allies. Individuals with knowledge of the company’s activities told The Sentry it maintained a low profile by design and the individuals behind Kwanza Capital apparently sought to minimize their public association with the company. Kwanza Capital, which is now reportedly under liquidation, gained only fleeting public notice as it made unusual maneuvers in the country’s banking sector, but its story is more expansive than the public record would suggest.

An investigation by The Sentry into Kwanza Capital’s activities provides a new glimpse into how members of Kabila’s family and inner circle have done business. The Sentry examined the firm’s operations, finances, apparent beneficiaries, business partners, and relationships with government agencies and officials. In addition to maintaining extensive links to a bank run by members of Kabila’s family, Kwanza Capital participated in multiple acquisition attempts in the Congolese banking sector. These attempts also involved a host of additional individuals and companies, including a Swiss-Angolan financier, a Chinese conglomerate, and a lawyer formerly affiliated with the French office of a U.S.-based law firm. While each attempt to take over a bank ultimately failed, a review of Kwanza Capital’s financial records and those of its minority shareholder reveals several indicators of money laundering as well as signs these companies may have received millions of dollars in misappropriated funds from the Congolese government. In total, the records reviewed by The Sentry indicate that as much as $140 million may have circulated through these accounts and that they appear to have functioned as a ready source of cash for family members and friends of former President Kabila.

The Sentry’s investigation suggests that exercising control of the domestic banking and finance sector in Congo was a major priority for members of the Kabila family and its inner circle.

The Sentry’s investigation suggests that exercising control of the domestic banking and finance sector in Congo was a major priority for members of the Kabila family and its inner circle. In fact, according to documents reviewed and interviews conducted by The Sentry, Kwanza Capital and its allies sought to control banks that amounted to around 28 percent of the country’s roughly $5 billion banking sector. * Such control of banks by Kwanza Capital and its allies would have constituted a crucial element of Congo’s kleptocratic system by affording the individuals behind this system the means to launder the proceeds of rampant corruption. * While such control by politically exposed persons is not necessarily illegal in Congo, it is nevertheless problematic for reasons illustrated in this report and in other disclosures about the scope of the Kabila family’s business interests. * But the risks detailed in this report apply well beyond Congo. According to the Financial Action Task Force (FATF), an independent inter-governmental body that develops and promotes policies to protect the global financial system, when individuals entrusted with a prominent public function, their family members, or their associates—collectively known as politically exposed persons—control financial institutions, this can undermine the integrity of the domestic banking and finance sector as well as place the entire global anti-money laundering and countering the financing of terrorism system at risk. * When politically exposed persons directly or indirectly control such institutions, the FATF notes, they will have effectively “rigged the game” and made it even more difficult for foreign banks and regulatory authorities to understand the source and destination of money passing through these elite-controlled entities. * Part of this risk stems from the access politically exposed persons have to public funds, and part from the know-how they generally possess related to control of government  budgets, state-owned enterprises, and contracting. *

The Sentry’s investigation also illustrates how important it is for financial institutions to exercise enhanced due diligence in transactions involving politically exposed persons, their associates, and their companies. It is essential for banks to be able to clearly document the beneficial ownership of customers with whom they have a relationship in order to understand who ultimately derives financial or other benefits from a company or transaction. * The financial records and other investigative information reviewed by The Sentry indicate that Kwanza Capital may have been intended to serve as a vehicle to obfuscate links to the Kabila family and its inner circle as a means of evading such scrutiny, even if some international actors saw through it. The Congolese government has a role in ensuring beneficial ownership transparency to avoid just these kinds of risks, but international banks should also consider the risk that companies and individuals for whom they process transactions in Congo are merely serving as proxies for politically exposed persons to evade enhanced due diligence compliance measures.

The Congolese government must make it a priority to improve compliance standards at banks and institute safeguards against corruption at key government agencies and regulatory bodies that govern the country’s financial sector. As The Sentry recommended in its August 2018 Alert, “A Window for Kleptocrats,” the Congolese government should issue guidance on anti-money laundering and countering the financing of terrorism recommendations and encourage banks to file suspicious transaction reports. * The Congolese government should also include guidance on politically exposed persons and money laundering typologies related to the mining and oil industries. While the country’s evolving political landscape may provide an opportunity to push through key reforms, the stakes are not merely political; failing to address chronic concerns in the financial sector could result in reduced access to the international banking system and, in turn, have devastating consequences for the country’s economy writ large. Congo already struggles to ensure its citizens have access to bank services. In fact, a 2017 study found that only six percent of the population had access to these services, which is less than one-quarter the average across sub-Saharan Africa. *

Key Recommendations: The Sentry is making the following key recommendations in the wake of this investigation. The full text of The Sentry’s recommendations appears at the end of this report.

  • Anti-Money Laundering (AML) Measures: The U.S. Department of the Treasury and European financial intelligence units should investigate the banking relationships described in this report and, if warranted, issue advisories to banks and other institutions. In particular, these entities should consider whether to issue advisories in relation to the past conduct of BGFIBank DRC—discussed throughout this report—and more broadly related to overall money laundering risk present in the Congolese banking sector. *
  • Targeted Sanctions: The United States and European Union should investigate and, if appropriate, impose and implement targeted sanctions pursuant to existing Congo sanctions authorities against members of former President Kabila’s network and others in connection with the transactions described in this report.
  • Bank Due Diligence: U.S. and international financial institutions should employ a range of actions to improve due diligence on transactions involving Congolese companies and politically exposed persons or individuals known to operate on their behalf. The Sentry also recommends that these institutions take appropriate follow-up actions if they have processed transactions in connection with the individuals and entities outlined in this report and that these same institutions should, where appropriate, emphasize that Congolese correspondent banking partners more robustly conduct enhanced due diligence.
  • Internal Reforms and Accountability Measures: The Sentry is also recommending a range of internal actions by the Congolese government and other partners. Specifically, The Sentry recommends the current government take concerted steps to empower Congo’s financial intelligence unit, investigate potential malfeasance by the Central Bank of Congo and state-owned enterprises, enforce a public asset declaration by government officials, and boost beneficial ownership transparency with a complete and accessible corporate registry. The Sentry further recommends that the U.S. government encourage the Congolese government to ask the International Monetary Fund (IMF) to restart an Extended Credit Facility in Congo to improve financial transparency.


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