The Kabul to Dubai Pipeline: Lessons Learned From the Kabul Bank Scandal

Table of Contents

For almost two decades now, billions of dollars in corruption proceeds have been funneled from Afghanistan, a country devastated by four decades of conflict, to Dubai. These outflows have played a part in stunting Afghanistan’s economic and political development, facilitating the resurgence of the Taliban, and exacerbating regional instability. They have also largely negated the effects of huge sums of development aid and stabilization funds spent by the international community in Afghanistan. These critical observations are evidenced by the multitude of illicit finance cases and credible reports that highlight the cross-pollination of criminality between Afghanistan and Dubai. There is, perhaps, no case that illustrates these linkages better than the notorious Kabul Bank scandal.

Along Comes a Money Launderer

For many observers, the story of the Kabul Bank scandal begins with the August 2010 revelation that the bank’s leadership and a handful of political elites had embezzled close to $1 billion through fraudulent loan schemes.¹ Asset recovery efforts, sometimes corrupt themselves, continue almost a decade later. Hundreds of millions of dollars have not yet been reclaimed. While some of this money is still tied up in real estate assets—many in Dubai—much of it has simply been lost through handsome bribe payments, ill-devised underbidding schemes intended to squash competition, and wasteful purchases by the scandal’s main protagonists.

For others, however, the story of the Kabul Bank debacle begins much earlier than 2010 . . . [it] begins in Russia during the mid-1980s, when a young Afghan named Sherkhan Farnood who was studying at a Moscow textile institute started a small hawala (money transfer service) out of his dorm room.

For others, however, the story of the Kabul Bank debacle begins much earlier than 2010, well before it received its Afghan banking license under murky circumstances back in 2004 and even before the Taliban was driven out of Kabul in late 2001. The story actually begins in Russia during the mid-1980s, when a young Afghan named Sherkhan Farnood who was studying at a Moscow textile institute started a small hawala (money transfer service) out of his dorm room.²

By the late 1990s, the service was handling money transfers among Russia, Central Asia, and Afghanistan, and Russian authorities had begun to suspect it was a money laundering scheme—a fact unknown to Afghan authorities when Farnood secured the banking license for Kabul Bank.³ Farnood fled Russia, but cognizant of the potential opportunities in Dubai, he quickly began setting up his new base of operations in the city. He first established his own general trading company around 1996.⁴ Later, in 1998, his mature hawala operation was effectively legitimized when he secured a money-changer license from the UAE’s Central Bank.⁵

With the assistance of just a handful of employees, Farnood rapidly established himself as one of the region’s preeminent financial conduits between Dubai and Afghanistan. And with his hawala connections, he was capable of moving—or laundering—funds anywhere in the Middle East, Central Asia, China, Europe, and even the United States.⁶ Farnood had employees or partners working out of small offices all over the globe.

Farnood rapidly established himself as one of the region’s preeminent financial conduits between Dubai and Afghanistan.

In the years immediately following the international community’s 2001 venture into Afghanistan, and in the confused rush to modernize Afghanistan’s infrastructure and economy, Farnood and others saw many opportunities for expansion and profit, but one in particular truly resonated with him. When the Taliban’s currency printing press began to transform—with international assistance—into Afghanistan’s central bank, Da Afghanistan Bank (DAB), Farnood saw the superficially functional yet immature and corruptible entity as a golden opportunity to vastly expand his now licensed Dubai-based hawala operation, the Shaheen Money Exchange. (It is important to note that the Shaheen Money Exchange changed ownership in late 2014 or early 2015 and there is no suggestion that the firm currently operating under that name is connected in any way to the matters discussed in this report.)

Once the DAB began issuing private banking licenses, Farnood and a small group of investors—mostly Afghan businessman also based in Dubai—successfully obtained the first post-Taliban Afghan commercial banking license in 2004.⁷ Though the actual specifics of the initial capitalization of Kabul Bank remain unclear, Farnood once claimed that the $5 million start-up money required by the DAB to obtain a banking license was actually paid but later withdrawn.⁸ Though seemingly impossible, this feat is believable, given the bank’s relatively brief history of operations.

Farnood and a small group of investors—mostly Afghan businessman also based in Dubai—successfully obtained the first post-Taliban Afghan commercial banking license in 2004.

So why was Farnood so keen to get a banking license? Why did he believe owning a bank would vastly expand his burgeoning group of companies? Put simply, he wanted to “borrow” (in other words, embezzle) money from hapless depositors and invest it in Dubai real estate, as well as launder the ill-gotten gains of corrupt, high-profile clients.

Kabul Bank Takes Off

There was, in reality, an ingenious and complex strategy underlying the Kabul Bank scheme. As a world-class hawaladar and money launderer, Farnood knew very well something that is widely misunderstood: money remitters, hawaladars, and similar service providers generally rely on the formal banking system to move money. Monies collected at various hawala or money exchange branch offices are often pooled and moved to their interim or final destination via a bulk wire transfer initiated at a bank. This process allows hawaladars to offer their clients relatively low transfer fees. The business model is simple: the hundreds of individual transfer fees collected by a hawaladar are greater in value than the cost of initiating one large bulk wire transfer. And the bigger the hawala operation, the more reliant on banks that hawala becomes.

Like other Dubai-based money exchangers, Farnood relied on banks—and those banks’ correspondent banking relationships—to move monies denominated in U.S. dollars and other currencies globally via wire transfer.

Like other Dubai-based money exchangers, Farnood relied on banks—and those banks’ correspondent banking relationships—to move monies denominated in U.S. dollars and other currencies globally via wire transfer.⁹ Whether those accounts were held in the name of the Farnood-owned Shaheen Money Exchange or other entities, the reality is that monies associated with Farnood’s hawala operations were ultimately being wired all over the world to accommodate his clients’ needs.¹⁰ People living in the un-banked or un-bankable areas of the world gain access to the global banking system via hawaladars like Farnood, who serve as their proxy bankers.

Connected to Dubai’s network of international banks, the Farnood-owned Shaheen Money Exchange had immediate access to the Society for Worldwide Interbank Financial Telecommunication (SWIFT) and the formal global financial sector.¹¹ With the vast commercial trade networks at his disposal, Farnood had plenty of opportunities to conduct trade-based money laundering when it was profitable or required. But once he obtained his banking license in Afghanistan, the Farnood-owned Shaheen Money Exchange—using the fronts of both Kabul Bank and his Kabul-based hawala, the Kabul Exchange—quietly became a significant unregulated component of the international banking system. The dorm room hawala had evolved into a licensed, seemingly legitimate bank, with its own access to SWIFT, U.S. dollar-denominated correspondent banking relationships, credit card products, and a host of other products and services. One of these turned out to be as tempting and ultimately destructive as depositor monies and loans.

Once he [Farnood] obtained his banking license in Afghanistan, the Farnood-owned Shaheen Money Exchange . . . quietly became a significant unregulated component of the international banking system.

Farnood no longer needed to rely on other banks to keep the financial conduits of the Farnood-owned Shaheen Money Exchange flowing with licit and illicit funds. He had his own bank, which, ironically, had its own anti–money laundering (AML) compliance department. For Farnood’s money laundering empire, it is difficult to imagine a more favorable operating landscape. In Dubai, very lax regulatory enforcement allowed the Farnood-owned Shaheen Money Exchange to launder money through Dubai unchecked. In Afghanistan, incompetent, politically weak, or corrupt regulatory bodies and regulators could not—or would not—do anything to challenge Farnood’s bank.

Meanwhile, Kabul Bank’s activities were being fueled by the money international donors were pouring into Afghanistan’s economy. Business opportunities in Afghanistan abounded, stemming from lucrative construction projects and the international community’s increasing needs for fuel and other supplies. As a result, Farnood’s nest egg of depositor money for Dubai real estate purchases grew larger on a daily basis. Other members of the Afghan Business Council in Dubai—established in 2005—were looking for easy access to cash for real estate investments there.

Copycats Emerge

Farnood’s rivals soon emulated his business model. After the ribbon cutting for Kabul Bank in 2004, the landscape of Afghanistan’s new private banking sector began to take shape. For example, in 2006, much to Farnood’s annoyance, Mirwais Azizi—an on-again, off-again business partner and later rival—obtained a license from the DAB to launch Azizi Bank, which Azizi allegedly used to finance multimillion dollar real estate projects in Dubai.¹² Documentation by the United States Agency for International Development reveals that Abdul Qadeer Fitrat, DAB governor at the time of the Kabul Bank scandal, requested in early 2010 that the U.S. Department of the Treasury arrange forensic audits of both Kabul Bank and Azizi Bank.¹³ A key concern raised by Fitrat and other senior Afghan officials was the sheer amount of monies—tens or hundreds of millions of dollars—continuing to flow from both banks into Dubai property investments.¹⁴ Azizi Bank was subjected to a forensic audit undertaken by the DAB in the aftermath of the Kabul Bank scandal.¹⁵ Though the audit’s results were not made public, there is no indication that the DAB identified any wrongdoing and both Azizi and Azizi Bank have denied all allegations of impropriety.¹⁶

Farnood’s rivals soon emulated his business model.

Perhaps the most ill-fated Farnood copycat scheme was carried out by the New Ansari network. In 2010, the New Ansari Money Exchange was Afghanistan’s largest money service business, capable of transferring funds just about anywhere in the world. In 2007, the owners of the exchange sought to mimic Farnood’s strategy by obtaining a banking license from the DAB and opening Afghan United Bank (AUB). Most of the then shareholders of the exchange owned stakes in the AUB.¹⁷ (It is important to note that the AUB fully changed ownership in 2011. Its current owners are in no way connected to the bank’s activities during the 2007–2010 period discussed in this report.)¹⁸

By 2009, the U.S. interagency Afghanistan Threat Finance Cell (ATFC) and Afghan law enforcement had compiled information indicating that the New Ansari Money Exchange was involved in significant money laundering activities, likely tied to regional narcotics trafficking.¹⁹ The exchange was the primary mechanism by which actual cash currency was physically transported via couriers from Afghanistan to Dubai. That exchange house and others like it moved billions in hard cash—mostly Saudi riyals and U.S. dollars—from Kabul directly to Dubai.²⁰ Those cash exports consisted of legally derived monies co-mingled with the proceeds of public corruption, extortion operations, contract fraud, drug trafficking, and other criminal activities.²¹ Anyone needing to send cash from Kabul to Dubai during that period likely used the New Ansari Money Exchange. Even Farnood and his co-conspirators did so.

Cash exports consisted of legally derived monies co-mingled with the proceeds of public corruption, extortion operations, contract fraud, drug trafficking, and other criminal activities.

When, as part of a joint ATFC investigation of the New Ansari network, Afghan police executed search warrants on the exchange’s primary Kabul office in Shahazada Market, the investigators not only uncovered evidence of money laundering at the exchange but also connections to Farnood.²² Thus, it was this investigation that led the ATFC to talk to Farnood. Had the ATFC and Afghan law enforcement not investigated the New Ansari network in 2009 and early 2010, the story of Kabul Bank would likely have unfolded much differently.²³

The Kabul Bank scheme resulted in close to $1 billion in illicit financial outflows from Afghanistan, according to the Independent Joint Anti-Corruption Monitoring and Evaluation Committee.²⁴ Of this sum, $410 million was transferred to the United Arab Emirates, some of which funded the purchase of eight villas on the Palm Jumeirah island and other properties.²⁵

Farnood Tells All

Fortunately for the AFTC, Farnood told its investigators just about everything he knew.²⁶ By at least 2009, there was somewhat of a symbiotic relationship between Farnood’s business interests and the New Ansari network. One of Farnood’s proudest moments was in 2008 when he, with a roughly $100 million loan from Kabul Bank, acquired his own airline, Pamir Airways.²⁷ The private carrier operated one of the few coveted Kabul to Dubai routes.²⁸ New Ansari Money Exchange cash couriers could now more easily transport money embezzled from a Farnood-controlled bank (Kabul Bank) on a Farnood-owned airline (Pamir Airways) and deliver it to a Farnood-owned exchange house (Shaheen Money Exchange) in Dubai.²⁹

The New Ansari Money Exchange was moving money to Dubai for its own clients as well. It had two key offices in Dubai: Al Adal Exchange and Greenleaf General Trading.³⁰ When the Farnood-owned Shaheen Exchange was short on cash in Dubai, it was able to easily borrow cash from its friends at the Al Adal Exchange. Farnood reciprocated by allowing the New Ansari Money Exchange to open nominee accounts at Kabul Bank.³¹ This became particularly useful during the 2008–2010 period, when the international community—almost completely unaware of the hawala-bank dynamic described here—was discouraging Afghan banks from holding accounts for hawalas and other similar service providers.

The Truth Gets Out

In late summer 2010, the most important bit of information the ATFC had was that Farnood had fallen out with some Kabul Bank shareholders and Khalilullah Ferozi, his former driver whom he had promoted to chief executive officer of Kabul Bank.³² Farnood explained to the ATFC that he, Ferozi, certain shareholders, and Kabul Bank’s more influential clients had looted hundreds of millions in depositor funds through a nominee loan scheme.³³ He also revealed that Ferozi, without his permission, was taking bribes to issue even more such loans and that Pamir Airways—due in part to a crash in May 2010 that resulted in the deaths of thirty-nine passengers—was in serious trouble financially. Furthermore, Ferozi and other shareholders wanted him out as chairman of the bank. Furious with the other shareholders for stealing without his permission and pursuing their own business ventures, Farnood told the ATFC just about everything about his illicit activities.³⁴

Over the course of the next few months, with the DAB’s removal of Farnood and Ferozi as the chairman and chief executive officer of Kabul Bank, respectively, and subsequent runs on the bank by depositors, the Afghan government and international community scrambled to avoid catastrophe. Kabul Bank had over one hundred branches across Afghanistan and was the primary means by which Afghan soldiers, police officers, and other public officials were receiving their internationally funded salaries. It held roughly $1 billion in depositor monies, but most of that was tied up in Dubai real estate, Pamir Airways aircraft, or failing business ventures or had simply vanished.³⁵ Depositors wanted their money back.

A controversial government bailout and questionable receivership process soon followed. And while the international community struggled to overcome then president Hamid Karzai’s opposition to its attempts to save Afghanistan’s financial system, the ATFC sought to tie up its loose ends with the New Ansari network.³⁶ However, because Karzai had handicapped the country’s anticorruption units’ ability to pursue money launderers and the corrupt public officials protecting them, the ATFC had limited options for disrupting the New Ansari network’s money laundering schemes. Recognizing this, the ATFC opted to leverage U.S. sanctions that could not be stymied by Afghan government officials.³⁷

Disrupting the Kabul-Dubai Pipeline

On February 18, 2011, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) levied financial sanctions against the New Ansari Money Exchange and fifteen affiliated individuals and entities under the United States’ Foreign Narcotics Kingpin Designation Act. The public statement of the case highlighted the following as the underlying rationale for the sanctioning action:

The New Ansari Money Exchange is at the center of an unofficial network of individuals, money exchange houses and other businesses operating throughout Afghanistan and in the United Arab Emirates. Between 2007 and 2010, the New Ansari Money Exchange used the billions of dollars it transferred in and out of Afghanistan to conceal illicit narcotics proceeds. The New Ansari Money Exchange transfers money to its Dubai subsidiaries, Green Leaf General Trading LLC and Al Adal Exchange, also designated today, which then transfer money through the U.S. and international financial systems.³⁸

Since the 2011 sanctioning of the New Ansari network, similar U.S. and UN sanctions have been imposed. The sanctions have targeted money launderers facilitating the operations of drug trafficking organizations, terrorist groups, and transnational criminal organizations. Almost all the cases have had some connection to Dubai’s financial sector. In 2012, the OFAC levied counterterrorism finance sanctions under Executive Order 13224 against the Haji Khairullah Haji Sattar Money Exchange and the Roshan Money Exchange for moving money on behalf of the Taliban. Both hawalas operated primarily in Afghanistan and Pakistan but had offices in Dubai. The same day the United States sanctioned both exchange houses and their owners, the UN added them to its 1988 list of individuals and entities associated with the Taliban that posed “a threat to the peace, stability and security of Afghanistan.”³⁹

In November 2015, leveraging its executive order–based sanctioning authority that targets transnational criminal organizations, the OFAC sanctioned the Altaf Khanani Money Laundering Operation (MLO), described in Chapter 3. The public statement of the case issued for this action outlined a now familiar pattern:

The Khanani MLO facilitates illicit money movement between Pakistan, the United Arab Emirates, United States, United Kingdom, Canada, Australia, and other countries, and is responsible for laundering billions of dollars in organized crime proceeds annually. The Khanani MLO offers money laundering services to a diverse clientele, including Chinese, Colombian, and Mexican organized crime groups and individuals associated with Hizballah. The Khanani MLO has also laundered funds for designated terrorist organizations.⁴⁰

Beyond these sanctions, U.S. authorities have also levied considerable fines against UAE-based banks or their affiliate offices. In October 2018, Dubai-based Mashreqbank agreed to pay $40 million to the New York State Department of Financial Services for its New York office’s failure to maintain and make available records of transactions related to the execution of its sanctions compliance program.⁴¹ More recently, the London-based Standard Chartered Bank (SCB) announced it would pay $639 million to settle potential civil liabilities for apparent violations of U.S. sanctions as identified by the OFAC. Compliance program failures in SCB’s Dubai office figured prominently. According to the U.S. Department of the Treasury:

From June 2009 until May 2014, SCB processed 9,335 transactions totaling $437,553,380 that were processed to or through the United States. All of these transactions involved persons or countries subject to comprehensive sanctions programs administered by OFAC (including Burma, Cuba, Iran, Sudan, and Syria). The majority of the conduct concerns Iran-related accounts maintained by SCB’s Dubai, UAE branches (“SCB Dubai”), including accounts at SCB Dubai, held for a number of general trading companies and a petrochemical company. SCB Dubai processed USD transactions to or through SCB’s branch office in New York or other U.S. financial institutions on behalf of customers that sent payment instructions to SCB Dubai while physically located or ordinarily resident in Iran. SCB also processed online banking instructions for residents of comprehensively sanctioned countries.⁴²

In 2013, Farnood and Ferozi were convicted for a breach of trust and sentenced to five years in prison in connection with the collapse of Kabul Bank. Farnood died unexpectedly in 2018 while still serving his sentence in an Afghan prison. A prolific criminal, he was charming, calculating, and highly intelligent. His decisions to create a hawala-bank hybrid and take a dispute among shareholders into the public realm not only reshaped the financial sector landscape in Afghanistan but also revealed how Dubai is used to facilitate international money laundering operations.

Looking Ahead: Mended Ways or More of the Same?

It is unlikely that Dubai’s approach to combating international money laundering will change anytime soon.⁴³ As such, its banks and large money exchange houses are unlikely to willingly adopt a culture of proactive compliance. That said, genuine signs of progress include the UAE’s recent removal from the European Union’s list of noncooperative tax jurisdictions and its decision to require financial institutions to use the UNODC-developed AML software system for reporting suspicious transactions.⁴⁴ The Financial Action Task Force’s recent evaluation will only heighten the pressure on Dubai to undertake further reforms.

Ultimately, Dubai must resolve the inherent tension between its two identities. On the one hand, it is a major, global financial center with laws, regulations, and attitudes sculpted to attract commerce. On the other hand, it is a financial secrecy jurisdiction that—along with the rest of the UAE—ranked tenth in the 2020 Tax Justice Network’s Financial Secrecy Index, behind other major financial centers and financial secrecy jurisdictions like the United States, Hong Kong, Singapore, and Switzerland.⁴⁵ Its laws and regulations are technically sound, and its enforcement personnel are capable enough to combat illicit financial flows. As a well-policed and tightly governed state, the UAE has the capacity—if not the political will—to combat money laundering more effectively. Its laws just need to be enforced more consistently and aggressively, and some of the more prolific money launderers must be successfully investigated and prosecuted.

Until the UAE embraces a culture of proactive enforcement that is more developed and entrenched in other major global financial hubs, Dubai will remain a desirable destination for illicit financial flows from across the globe.

The UAE’s AML enforcement bodies need to record a few wins. Their investigators need experience, momentum, and more familiarity with international law enforcement practices. The UAE’s national FIU Anti-Money Laundering and Suspicious Cases Unit needs to be faster and more helpful when it comes to answering other national FIUs’ requests for financial intelligence on cases related to the UAE. However, until the UAE embraces a culture of proactive enforcement that is more developed and entrenched in other major global financial hubs, Dubai will remain a desirable destination for illicit financial flows from across the globe.

Notes

¹ Grant McLeod, “Responding to Corruption and the Kabul Bank Collapse,” United States Institute of Peace, December 2016, https://www.usip.org/sites/default/files/SR398-Responding-to-Corruption-and-the-Kabul-Bank-Collapse.pdf; and Kay Johnson, “Karzai Brother, Others Still Owe Millions to Kabul Bank: Afghan Watchdog,” Reuters, October 2, 2014, https://www.reuters.com/article/us-afghanistan-bank-watchdog/karzai-brother-others-still-owe-millions-to-kabul-bank-afghan-watchdog-idUSKCN0HR1MU20141002.

² Ben Farmer, “Kabul Banker Who Almost Brought Afghanistan to Its Knees Dies in Prison,” National (UAE), August 26, 2018, https://www.thenational.ae/world/asia/the-kabul-banker-who-almost-brought-afghanistan-to-its-knees-dies-in-prison-1.763900; and Joshua Partlow, A Kingdom of Their Own: The Family Karzai and the Afghan Disaster (New York: Penguin Random House, 2017).

³ “The Report of the Public Inquiry Into the Kabul Bank Crisis,” Independent Joint Anti-Corruption Monitoring and Evaluation Committee, November 15, 2012, https://www.globalsecurity.org/military/library/report/2012/ijacmec-kabul-bank-inquiry.pdf; and Andrew Higgins, “In Afghanistan, Signs of Crony Capitalism,” Washington Post, February 22, 2010, http://www.washingtonpost.com/wp-dyn/content/article/2010/02/21/AR2010022104317.html.

⁴ Ibid.

⁵ According to the UAE Central Bank website, the Shaheen Money Exchange was licensed in 1998. See https://www.centralbank.ae/sites/default/files/2018-10/List-of-Moneychangers30092014_2.pdf.

⁶ Edwina A. Thompson, Trust Is the Coin of the Realm: Lessons From the Money Men in Afghanistan (Karachi: Oxford University Press, 2011), 267–68.

⁷ Ibid., 267.

⁸ Author communications with various Afghan businesspeople between 2008 and 2015.

⁹ A completed list of licensed UAE-based exchange houses or money changers is available on the UAE Central Bank website.

¹⁰ McLeod, “Responding to Corruption and the Kabul Bank Collapse”; and “Unfinished Business: The Follow-Up Report on the Kabul Bank,” Independent Joint Ant-Corruption Monitoring and Evaluation Committee, October 2, 2014, http://www.afghandata.org:8080/xmlui/bitstream/handle/20.500.12138/20338/azu_acku_pamphlet_jq1765_a55_u635_2014_w.pdf?sequence=1&isAllowed=y.

¹¹ SWIFT provides a network that enables financial institutions worldwide to send and receive information about financial transactions in a secure, standardized, and reliable environment.

¹² Abdul Qadeer Fitrat, The Tragedy of Kabul Bank (New York: Page Publishing, 2018); Andrew Higgins, “Banker Feeds Crony Capitalism in Afghanistan,” Financial Times, February 22, 2010, ft.com/content/c73eeaf2-1f85-11df-8975-00144feab49a.

¹³ United States Agency for International Development, Office of the Inspector General, “Review of USAID/Afghanistan’s Bank Supervision Assistance Activities and the Kabul Bank Crisis (Report No. F-306-11-003-S),” March 16, 2011, https://fas.org/sgp/eprint/usaid-kabul.pdf.

¹⁴ Fitrat, The Tragedy of Kabul Bank.

¹⁵ Bradley Hope, “Second Afghan Bank in Inquiry,” National (UAE), March 22, 2011, https://www.thenational.ae/business/second-afghan-bank-in-inquiry-1.421781.

¹⁶ Ahmad Shah Ghani Zada, “Afghan MPs Warn on Azizi Bank Collapse,” Khaama Press News Agency, July 12, 2011, www.khaama.com/afghan-mps-warn-on-azizi-bank-collapse/; and Hope, “Second Afghan Bank in Inquiry.”

¹⁷ “Afghan United Bank Ceo Stresses His Humanitarian Activities,” Wikileaks Public Library of U.S. Diplomacy, Afghanistan Kabul, February 6, 2010, https://wikileaks.org/plusd/cables/10KABUL455_a.html; and “Treasury Designates New Ansari Money Exchange,” U.S. Department of Treasury, accessed December 5, 2019, https://www.treasury.gov/press-center/press-releases/Pages/tg1071.aspx.

¹⁸ “Afghan United Bank: Financial Statements for the Year Ended 31 December 2010,” KPMG Afghanistan Limited, May 12, 2011, www.afghanunitedbank.com/wp-content/uploads/2015/05/Financial-Statements-of-AUB-31st-Dec-2010.pdf.

¹⁹ Dexter Filkins, “The Afghan Bank Heist,” New Yorker, February 3, 2011, https://www.newyorker.com/magazine/2011/02/14/the-afghan-bank-heist; and Craig Whitlock, “Consumed by Corruption,” Washington Post, December 9, 2019, https://www.washingtonpost.com/graphics/2019/investigations/afghanistan-papers/afghanistan-war-corruption-government/.

²⁰ Partlow, A Kingdom of Their Own.

²¹ Whitlock, “Consumed by Corruption.”

²² Partlow, A Kingdom of Their Own.

²³ Dexter Filkins, “Troubles at Afghan Bank Jolt Financial System,” New York Times, August 31, 2010, https://www.nytimes.com/2010/09/01/world/asia/01kabul.html.

²⁴ “Unfinished Business: The Follow-Up Report on Kabul Bank,” Independent Joint Ant-Corruption Monitoring and Evaluation Committee, 10.

²⁵ “Unfinished Business: The Follow-Up Report on Kabul Bank,” Independent Joint Ant-Corruption Monitoring and Evaluation Committee, 10; and Hadeel al Sayegh, “Kabul Bank to Auction Villas on Palm Jumeirah in Dubai,” National (UAE), November 11, 2012, https://www.thenational.ae/business/kabul-bank-to-auction-villas-on-palm-jumeirah-in-dubai-1.411559.

²⁶ Matthew Rosenberg, “Trail of Fraud and Vengeance Leads to Kabul Bank Convictions,” New York Times, March 5, 2013, https://www.nytimes.com/2013/03/06/world/asia/afghanistan-convicts-21-in-kabul-bank-scandal.html; and Partlow, A Kingdom of Their Own.

²⁷ Pamir Airways is reportedly defunct. See Matthew Rosenberg, “An Afghan Mystery: Why Are Large Shipments of Gold Leaving the Country?” New York Times, December 15, 2012, nytimes.com/2012/12/16/world/asia/as-gold-is-spirited-out-of-afghanistan-officials-wonder-why.html.

²⁸ Bradley Hope, “Suspended Afghan Airline ‘Owes Kabul Bank $90m,’” National (UAE), March 18, 2011, https://www.thenational.ae/business/suspended-afghan-airline-owes-kabul-bank-90m-1.437901.

²⁹ Author interview with former Afghanistan Threat Finance Cell staffer.

³⁰ “Treasury Designates New Ansari Money Exchange.”

³¹ Author interview with former Afghanistan Threat Finance Cell staffer.

³² Emma Graham-Harrison, “Kabul Bank Fraud Verdicts Raise Fears About Official Indifference to Corruption,” Guardian, March 5, 2013, theguardian.com/world/2013/mar/05/kabul-bank-chiefs-jailed-fraud; and author interview with former Afghanistan Threat Finance Cell staffer.

³³ Filkins, “Troubles at Afghan Bank Jolt Financial System.”

³⁴ Author interview with former Afghanistan Threat Finance Cell staffer.

³⁵ Dexter Filkins, “Depositors Panic Over Bank Crisis in Afghanistan,” New York Times, September 2, 2010, https://www.nytimes.com/2010/09/03/world/asia/03kabul.html.

³⁶ Alissa J. Rubin, “Fraud Trial Begins in Multimillion-Dollar Afghan Bank Scandal,” New York Times, November 17, 2012, https://www.nytimes.com/2012/11/18/world/asia/fraud-trial-begins-in-kabul-bank-scandal.html; and Filkins, “The Afghan Bank Heist.”

³⁷ Filkins, “The Afghan Bank Heist.”

³⁸ “Treasury Designates New Ansari Money Exchange.”

³⁹ “Treasury Targets Money Exchange Houses for Supporting the Taliban,” U.S. Department of the Treasury, June 29, 2012, https://www.treasury.gov/press-center/press-releases/Pages/tg1627.aspx.

⁴⁰ “Treasury Sanctions the Khanani Money Laundering Organization,” U.S. Department of the Treasury, November 12, 2015, https://www.treasury.gov/press-center/press-releases/Pages/jl0265.aspx.

⁴¹ “Dubai-based Mashreqbank Reaches $40 Million Settlement With New York Regulator,” Reuters, October 11, 2018, https://www.reuters.com/article/us-mashreqbank-regulator/dubai-based-mashreqbank-reaches-40-million-settlement-with-new-york-regulator-idUSKCN1ML0LG.

⁴² “U.S. Treasury Department Announces Settlement With Standard Chartered Bank,” U.S. Department of the Treasury, April 9, 2019, https://home.treasury.gov/news/press-releases/sm647.

⁴³ “Financial Secrecy Index 2018: Narrative Report on the United Arab Emirates (Dubai),” Tax Justice Network, 2018, http://www.financialsecrecyindex.com/PDF/UnitedArabEmirates_Dubai.pdf.

⁴⁴ Anwar Ahmad, “New System to Curb Money Laundering in UAE,” Gulf News, June 23, 2019, https://gulfnews.com/uae/crime/new-system-to-curb-money-laundering-in-uae-1.64791567.

⁴⁵ “Financial Secrecy Index: 2020 Results,” Tax Justice Network, accessed April 17, 2020, https://fsi.taxjustice.net/en/introduction/fsi-results.