In this Interview The Sentry’s Policy & Analysis Director Joshua White and Deputy Megha Swamy, answer questions posed by Financial Crime News on the work of the Sentry, its aims, achievements and what FI’s can do to help and how the Sentry can help them.
FCN: What is the Sentry and what’s its purpose?
JW/MS: The Sentry is an investigative and policy team that tracks the financing of conflict in East and Central Africa. We follow the dirty money connected to African war criminals and transnational war profiteers and seek to shut those benefiting from violence out of the international financial system. We were co-founded by George Clooney and John Prendergast and launched in 2016. We currently focus on East and Central Africa, specifically South Sudan, Sudan, the Democratic Republic of Congo (DRC), and the Central African Republic.
For the kleptocrats and their enablers, nothing is more precious than their wallets.
Cutting them out of the international financial system can bring about real change, creating leverage for peace and good governance efforts.
Our aim is to help bring this about through anti-money laundering measures, compliance actions by banks, network sanctions, and the prosecution of financial crimes linked to human rights abuses. By targeting the networks of violent kleptocracies in East & Central Africa, we can dismantle the systems in these countries that not only allow corrupt elites to personally enrich themselves but also enable many other crimes to flourish. Corruption enables the illegal wildlife trade, the trafficking of people as modern day slaves, forced child labour and drug trafficking which impoverish citizens and rob them of their futures
FCN: How does the Sentry do its work and is able to both follow the money and build compelling cases against those responsible for corruption in those parts of Africa you cover?
JW/MS: The Sentry’s team does extensive investigative research on the individuals, entities, and networks connected to grand corruption and mass atrocities, exposing who is benefitting from the violent kleptocratic systems both in the countries on which we focus but also their commercial enablers and financial facilitators around the world. We utilize field-based research, open-source data, corporate records, forensic financial investigations, and a variety of other tools to uncover illicit financial flows from our focus countries. Our findings are then presented in public reports or submitted in private dossiers to relevant government authorities and banks.
Global banks and FIs are key allies in our work. We provide them with insight into the typologies of illicit financial activities illustrated by grand corruption in these countries and present deep-dive case studies based on our investigations. We also develop actionable technical recommendations for what banks, policymakers, regulators, and law enforcement can do in response to our findings to create consequences for those profiting from violence in the parts of Africa we cover
FCN: What kind of experience and talent does the Sentry have and deploy to do its work?
JW/MS: We’ve brought together a team of financial investigators, international human rights lawyers, and regional experts, as well as former law enforcement agents, intelligence officers, policymakers, investigative journalists, and banking professionals to synergize a diverse set of skills and experiences that is leveraged for investigative work and policy engagement.
FCN: Can you give a few examples of the work of the Sentry and why the Sentry is important?
JW/MS: Our September 2016 launch report, “War Crimes Shouldn’t Pay,” exposed several top South Sudanese officials such as President Salva Kiir and former Vice President Riek Machar who have profited from massive corruption while fueling a civil war as their nation’s people suffered from hunger and horrific violence. In October 2018, our report “The Golden Laundromat” tracked how gold mined from conflict areas in eastern Congo may be entering global markets and ending up in the supply chains of some of the world’s largest companies. The illicit gold trade is one of the main funders of armed groups responsible for mass atrocities in the country.
In our October 2018 report entitled “Banking on War,” we detailed how politically exposed persons (PEPs) in South Sudan have hijacked several of the country’s banks for personal benefit. It exposed the pervasive risks and political control in the country’s banking sector and laid out recommendations for steps that can be taken by IFIs.
Amidst the growing upheaval in Sudan, we released an alert in early April, “Sudan’s Anti-Corruption Whitewash,” that provided an in-depth technical assessment of the country’s deficient domestic system to combat money laundering and terrorist financing.
The current situation in Sudan and the heightened risk of capital flight from corrupt officials makes this reporting particularly timely. In September of last year, our co-founder John Prendergast briefed the UN Security Council during their first-ever session focused on the nexus between conflict and corruption.
In a joint visit to Nairobi in June 2018, John and U.S. Treasury Under Secretary for Terrorism and Financial Intelligence Sigal Mandelker, who was on her historic visit to East Africa, called on Kenya and Uganda to close loopholes that allow the abuse of their financial system by corrupt elites in South Sudan, who are widely known to own property in the two countries.
These are of course just a few highlights from our extensive public reporting and engagement.
We fill a crucial gap by uncovering evidence of grand corruption in our focus countries which, while available, would be undiscovered since they are not always a focus for collection and action by governments, law enforcement, and banks. We also leverage our expertise to provide actionable analyses and policy measures based on our findings to combat the corrupt networks affecting the region.
FCN: What’s the effect of the Sentry – what have you achieved so far?
JW/MW: Corrupt officials highlighted in The Sentry’s reporting, along with their facilitators, have been sanctioned by the U.S. Treasury Department, the European Union, and the U.N. Security Council. For example, Obac William Olawo and Gregory Vasiliy, both named in The Sentry’s reports for their role in South Sudan’s conflict, were sanctioned in December 2018. The Sentry reported extensively last year on the red flags in Congo’s electoral process in the run-up to the flawed December elections. In March this year, three top-ranking Congolese election officials were sanctioned.
The Treasury Department’s Financial Crimes Enforcement Network, FinCEN, has issued advisories warning of the money laundering risks presented by political corruption in South Sudan and separately the money laundering risk presented by corrupt senior foreign political figures and facilitators involved in human rights abuses around the world. These advisories should help inform FI’s understanding of the critical connection between grand corruption and grave human rights abuses.
Overall, The Sentry’s work has helped shut down money-laundering routes and led to corrupt officials and their facilitators being cut off from the international financial system, banned them from traveling abroad, and frozen their ill-gotten assets.
FCN: Why focus only on a small but important piece of Africa?
JW/MS: The region we focus on has seen the deadliest violence since WWII. The countries we cover demonstrate a direct nexus between grand corruption and mass atrocities. Corruption has not only undermined good governance, but also led to years of deadly violence and poverty, as elites fight to control and loot natural resources and state coffers.
This greed-fueled violence is also directly connected to the U.S. and the international financial system, which provides western and regional banks and governments with real leverage. And as we mentioned earlier, The Sentry is focused on filling a crucial gap in evidence and expertise on grand corruption in this region and providing recommendations that can help dismantle kleptocratic networks.
FCN: What’s next for the Sentry?
JW/MS: While we are seeing consequences imposed on those benefiting from mass atrocities, much more needs to be done to alter the incentive structure from war to peace in the violent kleptocracies in East and Central Africa. Our upcoming reports will continue to expose and help disrupt corrupt transnational networks. We’re also working on strengthening our engagement in Europe and in East Africa, especially Kenya and Uganda.
FCN: What would you recommend FI’s do more if? They can make a difference?
JW/MS: While only a handful of Western banks maintain a physical presence or direct correspondent banking relationships with financial institutions in the countries on which we focus, FI’s around the world can be indirectly effected by the illicit financial flows from those responsible for mass atrocities and human rights abuses in East and Central Africa. FI’s have outsized influence and are crucial in affecting the financial behavior of the ruling elites in these countries, and with the support of The Sentry’s investigative findings and expertise in the typologies of illicit finance in the region, banks have begun to take important steps. FI’s should further strengthen scrutiny of transactions involving PEPs and high-risk sectors of these countries’ economies in addition to monitoring activity from other places where violent kleptocrats stash their assets such as Kenya, Uganda, and the Gulf. FI’s should also work closely with civil society and regulators to enhance their understanding of how their institutions may be exposed to the activity described in our reports, and incorporate that information into their compliance screening practices to effectively identify and disrupt the proceeds of financial crime from flowing through their banks. The Sentry is here to partner with banks on these efforts.
Focusing on corrupt leaders and their networks and cutting them out of the financial system can have an outsized impact in addressing greed-fueled conflict. FI’s are integral to this work and therefore can help make a huge difference.
FCN: Where can someone find out more?
JW/MS: Our website is a great place to find out more. It features the in-depth investigative and analytical reports on all the countries we focus on. Our latest updates can also be found on our Facebook, Twitter, and LinkedIn pages.
Joshua White serves as the Director for Policy and Analysis of The Sentry and The Enough Project. Joshua joined these organizations after eight years with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), where he was most recently the first Chief for Human Rights and Corruption in its targeting division. During his time at OFAC, Joshua worked on nearly every sanctions program administered by the United States government and led the team of investigators responsible for collecting information and building designation packages targeting persons for designation under human rights, corruption, and other relevant sanctions authorities. Prior to his work on the Human Rights and Corruption team, Joshua served as the first Senior Sanctions Coordinator for Iran and Yemen, worked as a Sanctions Investigator assigned to a wide spectrum of sanctions programs, and spent a year in Treasury’s Office of Terrorist Financing and Financial Crimes as its Policy Advisor for Afghanistan, India, and Nepal.
Megha Swamy recently started her role as the Deputy Director of Policy and Analysis at The Sentry. She was previously the Deputy Director of Communications at The Sentry and the Enough Project. Megha has several years of experience working in research and communications in the nonprofit space. She has also worked and interned at a German magazine and an international newswire service. Megha has a bachelor’s degree in Mass Media (Journalism) from the University of Mumbai and a master’s degree in International Affairs from the George Washington University’s Elliott School of International Affairs, where she focused on conflict and conflict resolution. As a graduate student, she completed capstone coursework on formulating effective U.S. policy to prevent genocide. She is originally from Mumbai and speaks English, Hindi, Marathi, and Tamil.