Legacy Issues - Afghanistan, AML and CFT

Money Laundering Bulletin (published 20 January 2015)
http://www.moneylaunderingbulletin.com/jurisdictions/asia/legacy-issues---afghanistan-105785.htm

(Photo by Todd Huffman - Wiki Commons)

British forces have already left Afghanistan and the US plans withdrawal of all combat troops by the end of 2016. President Ashraf Ghani must now divide his time between working to preserve security against the threat of Taliban resurgence and delivering on promised structural reform: the heroin trade and endemic corruption will be fixtures on his agenda but he might not have expected that AML compliance in the shape of local banks’ response to a massive fraud dating back to 2010 would also be a priority. Paul Cochrane reports.

A new chapter

Afghanistan is undergoing a transition of sorts. A new president has taken office who is keen to curb corruption and bolster business, while US-led forces are slated to be reduced, albeit a full withdrawal is not happening as expected. Meanwhile, Kabul managed to not be blacklisted by the Financial Action Task Force (FATF) in 2014, although major challenges remain in the war-torn country and the country remains on FATF’s watch list.
It has been over 13 years since the United States led a coalition to overthrow the former Taliban government and ouster Al-Qaeda militants in Afghanistan following the September 11, 2001 terrorist attacks. Afghanistan has been at the forefront of the US-led “global war on terror” ever since, being under international sanctions in relation to the Taliban, Al-Qaeda and a plethora of other terrorist groups, and the focus of counter-insurgency (COIN) policies, including combating the financing of terrorism (CFT).
The US and its allies having spent more than US$1 trillion pacifying and developing the country, deploying one million soldiers and civilians in the process. Washington has announced that US troops will depart by the end of 2016, ushering in a new era for Afghanistan after 35 years of conflict and foreign intervention. However, while US troops are to be scaled down and cut in half by the end of this year, in November, 2014, the Afghan parliament has approved a US troop presence “through 2024 and beyond.”
The Afghan economy will remain dependent on development aid – US$16 billion was pledged through to 2015 at a 2012 Tokyo Conference on Afghan aid. International non-governmental organisations (NGOs) will continue to operate in the country and related military expenditure and assistance from the US will flow, helping balance the books in Kabul, with government revenues for 2014 projected at US$2.5 billion compared to expenditures of US$7.5 billion. Additionally, any ongoing presence of American troops might well scupper domestic efforts to bring the Taliban to the table to hash out a political solution that has so far evaded COIN strategies; such talks are strongly opposed by Washington.
Afghanistan is ranked second in the Global Terrorism Index 2014, with 1,148 incidents in 2013, and the Taliban responsible for 75% of terrorism fatalities. The index noted that “terrorism is increasing in Afghanistan, with 10 percent more terrorist attacks and 13 percent more fatalities in 2013 than 2012.”

Opium and economic dependency

The opium trade is also set to continue, going by recent trends. Despite the US having spent more than US$7.5 billion over the past decade to eradicate the trade, opium poppy cultivation rose 7% between 2013 and 2014, according to a report by the United Nations Office on Drugs and Crime (UNODC). With Afghanistan accounting for 90% of the world's heroin supply, the trade is estimated to be one-fifth as large as the country's legitimate gross domestic product (GDP), making it a US$8 billion-a-year business.
After a four month delay due to issues of electoral fraud, President Ashraf Ghani was inaugurated in September 2014, replacing long-time leader Hamid Karzai. Ghani, a former professor, World Bank official and Afghan minister, ran on a platform to introduce the rule of law, good governance and eliminate corruption, as well as create an accountable judicial system and a viable economy.
Ghani has arguably got off to a good start, signing a bilateral security agreement (BSA) with the US, which is slated to bolster foreign investment, while making unscheduled visits to police stations, hospitals and prisons to check on staff attendance.

Bank fraud revisited

The most attention-grabbing move was a decision to retry figures involved in the Kabul Bank scandal, which rocked the country in 2010 with almost US$1 billion embezzled from the institution via a Ponzi-type scheme. While 21 people were convicted in March, 2013, only a few offenders were jailed and the sentences were considered light. In November, 2014, the court tripled the sentence of former chairman Shekhan Farnood and former CEO Khalilullah Ferozi from an initial five years to 15 years – five years for money laundering and 10 years for embezzlement.
After announcing the re-trial, Ghani's public “approval rating was 84 percent,” said Sanzar Kakar, Chairman of Afghanistan Holding Group (AHG), which provides professional business services, including accounting, auditing and taxation. “There is a huge amount of hope with the new administration, and a lot of good things have already been done.”
However, missing from the latest trial was the brother of the former president, Mahmood Karzai – who had borrowed US$22 million from the bank - and Haseem Fahim, the brother of former Vice President Marshall Muhammad Qasim Fahim, who died of a heart attack last March.
The collapse of Kabul Bank affected over a million depositors, and had a negative impact on the country's 17 banks, driving away potential clients. “It had a big impact on the perception of the banking industry, nobody can deny it,” said Hedayatullah Yahya, CEO of Afghan United Bank. Less than 5 percent of Afghanistan's 27 million people are banked, according to the IFC.

Compliance blocks business

The scandal has certainly made it hard to launder money through Afghan banks, but they have become so wary of falling foul of the Attorney General's office and customer identification checks are now such that it has impeded their general operations. “The scandal has caused banks to be quick to find an excuse for anything – not the original passport, or if the signature doesn't exactly match. They are afraid of scrutiny,” said Kakar.
If a bank account is not used for two months, a letter is required from the finance ministry to re-open the account, “which is nearly impossible,” said Kakar, while heightened international scrutiny is affecting financial transfers. “Banks have struggled with procedures and some still have a lot of trouble as they can't receive funds,” he added.

Brinkmanship with FATF

Further impacting the financial sector and the economy at large was FATF's decision to put Afghanistan on a watch-list in 2012, following a Mutual Evaluation Report (2011) for failing to meet its standards. Pressure came to a head in early 2014, with FATF threatening to place Afghanistan on its “high-risk and non-cooperative jurisdictions” list in June if it did not address deficiencies.
With the country undergoing political transition, the outgoing president Karzai having refused to sign the BSA, and growing international pressure on the few international banks with a local presence, there was serious concern that Afghanistan would be blacklisted unless FATF extended the deadline.
A decision in the balance, there was major flight of capital, which has not abated. “It was a nightmare scenario that took its toll, having a big negative impact on business. Wealthy people by the droves are going to Dubai and investing there rather than here. More and more people are saying, can you pay me outside of Afghanistan?” said Kakar.
With the country at risk of political and economic collapse if it was cut off from the international financial system, Kabul eventually enacted AML and CFT legislation in June 2014, and FATF held off black-listing the country at its October plenary.
Both laws follow FATF recommendations and methodology. With regard to AML, the statute replaced legislation from 1963 on proceeds of crime and is called 'Amendments to the anti-money laundering and the proceeds of crime' law (see (www.centralbank.gov.af/pdf/AMLLawEnglish.pdf). Its purpose is to “protect and promote the financial integrity of Afghanistan” and “fight against use of financial institutions and designated non-financial businesses and professions … for money laundering, proceeds of crime, the proliferation of weapons of mass destruction and the financing of terrorism.” Another new law, No. 839 on Combating the Financing of Terrorism is designed to implement the UN International Convention for the Suppression of Financing of Terrorism (1999) and successor conventions; prevent the provision of funds or property for terrorist acts, terrorist organisations, or terrorist/s; and implement UN Security Council resolutions on combating financing of terrorism and the financing of proliferation of weapons of mass destruction (see www.centralbank.gov.af/pdf/CFTLawEnglish.pdf).
“In reality the politics were able to go through, and at the eleventh hour the Afghan government scrambled to get something [for FATF], but if you look at the details I don't think Afghanistan should have qualified from a technical perspective,” said Kakar.
Indeed, at the October plenary, FATF kept Afghanistan on its list of jurisdictions with strategic AML/CFT deficiencies. FATF has also called on Kabul to improve enforcement and implementation, criminalise money laundering and terrorist financing, and to establish a financial intelligence unit (FIU).
In the 2014 Basel AML Index, released by the Switzerland-based Basel Institute on Governance, Afghanistan was ranked second worldwide as a jurisdiction of high risk. “The index shows a lack of infrastructure and enforcement capacities, and in the proxy indicators shows the weaknesses and the challenges it faces, which is more than legislative, it is enforcement,” said Selvan Lehmann, project manager of the Basel AML Index.
The country is also struggling with rampant corruption, a large informal economy, narcotics, and terrorism. The UNODC reported that from 2009 to 2013, total corruption costs increased by some 40% to US$3.9 billion, with more than half of Afghan citizens paying a bribe for a public service. “We are in one of the worst situated countries worldwide, we are next to Iran, in a recession, and trade and corruption are problems,” said Yahya.
While Afghanistan has managed to stave off joining global AML pariah states like North Korea, the Kabul Bank scandal and enhanced domestic banking scrutiny has instead reinforced the informal banking sector, with the few Afghans that used banks withdrawing salaries to stash at home, and using alternative remittance systems like hawala instead of the formal financial sector.
“From the point of view of the legitimate economy, it is a big hassle having to go through additional hoops but for the illegitimate economy it is bad news as it is harder to launder money unless you have an active business licence, and hard to transfer money over USD10,000 without the right paper work,” said Kakar. “Yet while Afghanistan has cleaned up its act quite a bit, there comes a point where, if you stop all transactions due to AML concerns, people find another route, so the banking sector becomes irrelevant. There needs to be a balance, as many Afghans felt there was too much freedom prior to the Kabul Bank scandal - with the oversight not there and corruption - but now the pendulum has swung too far in the other direction as banking has become too difficult.”


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HSBC revelations expose politicized nature of global bank regulation

Op-Ed, Global Times

http://www.globaltimes.cn/content/909119.shtml

Illustration: Liu Rui/GT

The scandal around banking giant HSBC's Swiss subsidiary being a conduit for tax evaders has opened a can of worms in London. It is not just the media revelations that the bank profited from doing business with tax evaders, dictators and criminals for decades. It is also that the tax evaders - prominent businessmen and the like - were major donors to political parties. It has added further pressure on a sector that is far from popular with the public due to the government bailouts of major banks in 2008 at the same time as tough austerity measures were introduced.

The scandal further highlights the less than level playing field of financial compliance. Over the past 15 years, the US, Britain and the OECD's Financial Action Task Force (FATF) have forced jurisdictions around the world to pass regulations to improve anti-money laundering (AML) and countering the financing of terrorism (CFT) laws. However, the HSBC case and others in recent years have poked holes in the arguments of jurisdictions dictating to others what they need to do.

Indeed, you cannot require other countries to improve their regulations and oversight if you are not squeaky clean yourself. The balance of power though is clearly in the favor of the major financial hubs of the world, which, for now, are in the West and its sphere of influence.

The jurisdiction all countries are wary of is the US Treasury. It has teeth and has been dishing out fines in recent years to financial institutions not in compliance. Take the case of Lloyds Bank, fined $350 million for flouting sanctions on Sudan and Iran. HSBC is again a case in point, fined $1.92 billion in 2012 for deficiencies in its AML regime.

Banks in other jurisdictions are not so lucky however. In 2011, the Lebanese Canadian Bank disappeared from the face of the earth for being, in the words of the US Treasury, a bank of "prime money laundering concern" for connections to the Lebanese militant group Hezbollah. The bank didn't have a chance to pay a fine. It is evidence of the politics at play in AML and CFT, and where the financial power lies.

The US' Foreign Account Tax Compliance Act (FATCA) is a further example. Implemented last year, it requires all financial institutions (FIs) to report to Washington any American account holders in order to collect tax outside of the US. To implement FATCA, it is estimated to cost FIs around $8 billion - roughly the same amount the US will collect in tax revenues from the Act over 10 years. Yet it is a bill FIs will have to foot to act as tax enforcers for the US, or face being blocked from the US market.

The elephant in the room is that the biggest tax havens on the planet, and where the most money laundering and financial crime occurs are where most capital is transacted - New York, London and Switzerland. London handles a staggering 11 percent of the world's banking. The state of Delaware is a major hub for tax evaders due to its low corporate governance requirements, as is Wyoming. The British Channel Islands and other dodgy tax havens are home to trillions of dollars in illicit and black money.

On top of it all, the major financial centers only get middling scores in the Basel AML Index Country Risk Ranking 2014, the criteria based on adherence to standards and risk categories such as financial regulations, public transparency, corruption and rule of law. The US for instance is ranked 110 out of 203 jurisdictions, Britain 135 and Switzerland 96.

For legislation to truly work and for jurisdictions to willingly, rather than coercively, implement such regulations, the world's financial centers need to be clean. A good push would be for political financial support from tax evaders to immediately stop, followed by more stringent adherence to the rules at home as well as at foreign subsidiaries. Indeed, it was not the Swiss or British regulators that exposed the malpractice and dubious financial ethics of HSBC. It was whistle-blowers and investigative journalism.

Such exposures are good news though. It will force the financial sector to be more ethical, and to realize they are under greater public scrutiny. And it will push institutions, regulators, and politicians to practice what they preach.

Brutal IS propaganda video part of wider strategy of cultivated savagery

Viewpoint - The Global Times
http://www.globaltimes.cn/content/907043.shtml

"The Management of Savagery: The Most Critical Stage Through Which the Umma will Pass"

The savagery seems not to stop when it comes to Islamic State (IS). The burning to death of the Jordanian air pilot Moath al-Kasasbeh last week was yet another brutal killing by the group, adding to its lengthy tally of beheadings, stonings and executions, be it journalists, soldiers, civilians, or even its own disgruntled members, as the recent killings of three Chinese members for wanting to desert showed.

Such spectacles for public consumption are not going to stop until IS itself is crushed. However, they are not going to stop when getting widespread media coverage that gives IS such sustained air time. But that is what these videos are meant to do.

They are high-quality films, Hollywood-esque in choreography, style and even backdrop. Sickening they are, but certainly slickly done.

In Egypt, and throughout the region, the video showing the burning of al-Kasasbeh went viral on social media. I was shown it within hours of its breaking, and anecdotally, lots of people seem to have watched it and been horrified.

Airing such graphic violence is rare in the West and elsewhere, although Fox News posted the video in full, but Middle Eastern media have never been squeamish about showing such violent imagery, which over the past decade has been used to highlight the actions of the US in Afghanistan and Iraq.

Lately, with the events of the "Arab Spring," gruesome images are frequently coming out of Syria and Iraq showing the actions of IS, al-Nusra Front and other groups. It is a brutality that is morally indefensible yet serves a warped purpose. It is part of a strategy attributed to Abu Bakr Naji's 2004 book, popular with the Jihadi movement, The Management of Savagery: The Most Critical Stage Through Which the Umma will Pass.

In the text, which advocates the creation of an Islamic caliphate, violence is to be utilized between Muslims to create "regions of savagery" that leads locals in areas, in this case controlled by IS, to capitulate to Islamic rule to have order and stability, while drawing in enemies, in this case the Syrian government, and on a wider scale, the US and its regional allies, Jordan and the Gulf states. The brutal videos are an integral part of this strategy, as laid out in the text, as a propaganda tool to spread fear and provoke a reaction.

IS hopes to provoke a response that is intended to go beyond military air strikes, which the book in fact anticipates,  and lead to states committing ground troops for a prolonged war that will create more instability in the region.

The air strikes, underway by the US-led coalition since August last year, have weakened but clearly not "cut the head off the snake." Killing journalists, civilians and Iraqi, Syrian and Lebanese soldiers is one thing; a pilot from the coalition has effectively upped the game. The US has pledged to increase military support to Jordan, which is out for "punishment and revenge."

The US appears unwilling to commit ground troops, with the American public weary after 14 years of the "war on terror," so it is to be left to its regional allies.

The US is unwilling, like Saudi Arabia and others, to support or engage with Syria to eliminate IS, especially in its stronghold of North-East Syria.

Only a concerted, unified effort will tackle IS, but Yemen is in chaos, Lebanon is struggling with the Syrian crisis, Egypt is going through a turbulent transition, Saudi Arabia has a new king, and Libya is mired in conflict.

What would diminish the reach of IS would be if the media ignored or even marginalized such propaganda videos. But as the old newsroom saying goes, "if it bleeds, it leads."

Indeed, to counter IS' "management of savagery" requires good regional and national management and the establishment of alternative forms of order to the tyranny of IS and other militants.

Syria, Refugees and Pharmaceuticals: Nobody Wins

Manufacturing Chemist magazine
www.manufacturingchemist.com

The war in Syria has not only decimated the country’s healthcare infrastructure, but has also failed to benefit the pharma industry in the neighbouring countries coping with a refugee influx.

With the conflict in Syria now in its fourth year, the pharmaceutical and healthcare sectors in the country have been decimated. While an estimated nine million people have been displaced, more than three million refugees have fled Syria to neighbouring Turkey, Lebanon, Jordan and Iraq, according to the United Nations High Commissioner for Refugees (UNHCR) office.
But the massive influx of refugees into these countries has yet to translate into higher demand for pharmaceuticals from local manufacturers or importers – even in Lebanon, which has refused to set up camps, preferring refugees to settle within established communities. This is primarily due to aid agencies and governments providing medicine to refugees, with tenders being sourced internationally, alongside requests for donations from pharma manufacturers.
In general, the conflict in Syria is having a negative effect on the region’s pharmaceutical manufacturers and importers alike, compounded by political instability and weak economic growth in Iraq, Yemen, Egypt and Libya. Indeed, according to World Bank figures, the economic effects of the ‘Arab Spring’ revolts on Egypt, Tunisia, Syria, Yemen, Libya, Jordan and Lebanon have caused estimated losses of US$168bn during 2011–2013, equivalent to 19% of these countries’ combined GDP.
‘When looking at [pharma] sales volumes throughout the region, there were different levels of impact on private and government tenders from one country to another. Government ones were the most impacted in areas like oncology and therapies, leading (overall) to a 30–50% drop for us in sales, while with the private sector we have managed to alleviate the damage somewhat, but it is still down by 25–30%,’ said Samer Al-Ansari, Marketing Director for the Middle East and North Africa (MENA) at Hikma, one of the region’s leading pharma-ceutical manufacturers and exporters, based in London and Jordan. ‘In some countries, like Yemen, we lost all government sales in 2013 compared with the previous year.’
Syria was not a major market for regional manufacturers, with local producers having met 90% of local demand prior to the conflict, which started in early 2011. While local production has dropped by up to 70%, according to the World Health Organization (WHO), with pharmaceutical plants damaged or closed, especially in northern Syria, this has not resulted in greater exports for regional producers. This is due to the difficulties of distribution, particularly in areas not under government control, while fluctuations in the Syrian currency complicate payments and financial guarantees, such as letters of credit.
Frequent border closures have also made transit of goods through Syria from Turkey and Lebanon to the rest of the region more complicated, while planes have been re-directed from Syrian airspace, adding on extra transportation time. According to Al-Ansari, it is not easy to deliver anything to Syria and on to Lebanon. The company is facing up to two hours of extra flight time to avoid Syrian territories, he said.
Jordan-based Hikma has faced discrimination in trying to access the Iraqi and Syrian markets due to Jordan’s governmental support of Syrian rebels. ‘The boycotts in Iraq and Syria have put constraints on our business,’ added Al- Ansari.
In Syria’s close neighbour Lebanon, more than a million Syrian refugees have been registered – in a country whose pre-crisis population was 4.5 million. The government has not allowed camps to be set up, so the refugees are dotted around the country. With healthcare predominately private practice in Lebanon, refugees are given assistance by non-governmental organisations (NGOs) and aid agencies. In a survey carried out by Médecins Sans Frontières (MSF) in December 2012, almost 15% of refugees could not afford the fees – up to 25% of the cost, with the rest covered by the UNHCR – while nine out of 10 interviewees said the price of prescription drugs was a barrier to accessing medical care.
Lebanese pharmaceutical producers and manufacturers told Manufacturing Chemist that the influx of refugees has not created extra demand for medicines in the $969m Lebanese market, according to US-based data provider IMS Health and Lebanese Pharmaceutical Importers Association (LPIA) figures.
This is attributed to the aid agencies providing medicines, while pharmacists were not keeping track of sales to Syrians, making it hard statistically to gauge the impact of the refugees.
Armand Phares, President of the LPIA, has asked his members if there had been a rise in sales due to the Syrians, but all distributors consistently told him there had been ‘no impact’.
‘With the population increasing by over a quarter, there should have been an increase in turnover by 10–20%, but there has not been any special demand from the refugees because of the aid agencies, which are providing their own supplies,’ said Phares. ‘Individual sales are not reflected in sales as they cannot be identified,’ he added.
As far as the small local production sector is concerned – which accounts for only 8% of pharmaceutical products sold in the country - Lebanese pharmaceutical producer Pharmaline, part of the Malia Group, stated that there had not been any affect, as did Algorithm, another Lebanese medicine maker. 'There has been no impact on our products, as refugees take donations or buy from dispensaries, and we don't sell to them. There are tenders from the UN, and that is it,' said a Algorithm spokesperson.
That said, there was a rise in pharmaceutical imports in 2013, according to a report by Lebanon-based bank BankMed, stating that ‘mounting cases of Syrian refugees’ infections have increased demand for vaccine imports, where the value rose by 16.9% from $90.5m imported in the first nine months of 2012 to $10.5m in the same period in 2013’. As with other data, the report was not certain that any increases were due to the Syrian refugees. For instance, the value of imported vaccines and toxins rose by 12% in the same period, to $117.6m, which ‘may be attributed to the increased demand on vaccines by Syrian displaced nationals’, stated the report.
There is a similarly negative situation for Jordan’s pharma sector regarding the influx of refugees. While many here are in camps, there are also refugees living within the community, making assessments complex. Indeed, for Lebanon, Turkey, Jordan and Iraq, 65% of Syrian refugees live outside the camps, according to the UNHCR.
In Jordan (pre-crisis population 6.4 million), there are now an estimated 1.2 million refugees, more than 100,000 of whom live in the giant Za’atari camp.
The rise in refugees and the negative impact on the Jordanian economy has, similar to in Lebanon, not resulted in extra sales, with aid agencies not sourcing most tenders locally.
‘There were some small tenders, with lower prices, but there have not been the tenders to the degree that you would expect. With more than one million refugees, which represents one fourth of the population, we are not feeling that demand in the market has increased, and that is clearly demonstrated in total sales. What is surprising is that the total Jordan market is stagnant, and as the market leader we feel that. The impact of refugees has not helped because sales are through third parties and with low prices,’ said Al-Ansari.
While aid agencies are providing medicines, they have also reached out to manufacturers for donations. ‘Most companies now give donations, and Hikma is with all [its] medicines: cardiovascular, respiratory, antibiotics, and specialised treatments, like our oncology line, plus injectables,’ added Al-Ansari.
Turkey, by contrast, is a much more populous country (75 million) and hence better able to cope with the refugee influx. According to the UNHCR, as of October, there are an estimated 1.5 million refugees in the country, with around 220,000 in camps. Alongside aid agencies, the Turkish government is footing the bill for medicine through its Social Security Institution (Sosyal Güvenlik Kurumu), which is the main health system financier and principle purchaser of healthcare services. In January 2013, a Cabinet decree allowed Syrians to be treated free of charge at public hospitals, and in October, identity cards were issued to Syrians to access government services.
The Turkish pharmaceutical market, worth $6.92bn, grew by 0.6% in unit sales and by 0.4% in value terms in 2013 on the previous year, while per capita drug spending declined by 1% to $105.2, according to IMS Health.
As in Jordan and Lebanon, there are no statistics on whether demand has risen for medicines because of the influx of Syrians. ‘There is demand from that side, although there are not any numbers,’ said Turgut Tokgöz, Secretary General of the Pharmaceutical Manufacturers Association of Turkey (IEIS). ‘Domestic sales are big enough that we would recognise a surge in terms of volume per capita just based on demand from refugees. But the government covers quite a bit of the cost of pharmaceutical expenses.’
Ankara has allocated extra funding to meet the healthcare needs of Syrian refugees. ‘Some 80% of local consumption is met by Turkish producers,’ added Tokgöz.
As elsewhere, manufacturers are being called on for donations, and have had minimal tenders from aid agencies. ‘We have had regular calls from the Turkish authorities to donate drugs, and we actively call on our members to do so. We have also been approached by some international organisations to build a network between us and members to supply some medicines, such as basic pharmaceuticals, which they are having a hard time accessing,’ added Tokgöz.
While the domestic market has not been significantly affected by the refugees, exports have risen, in part due to regional instability, he said: up by 18.2% in 2013 on 2012, according to the Turkish Statistical Institute (TUIK – TurkStat), to $818m.
‘The conflict in the area has had an impact for some time. Iraq and Iran are our number one and two export markets, but I don’t know for Syria. We have had some complaints about parallel trade given the low price of many goods in Turkey, which might be traded around the border areas of Syria and Iraq where prices may be higher,’ said Tokgöz.
Ultimately, the impact of the Syrian refugees on the MENA pharmaceutical sector might be better assessed in the near future once data is collected. In the meantime, aid agencies continue to request more funds to cater to the needs of the refugees, with the UNHCR estimating that $384.4m is required for healthcare as part of its $3.74bn 2014 regional response plan.