Mongolia and the Financial Action Task Force

By John Grogan
October 6 2020

Mongolia has a world beating record on combating the coronavirus with currently no recorded deaths. Moreover, the Mongolian Government has suspended all commercial flights into the country for the last six months. All the more noteworthy then that last week a Mongolian Airlines plane took off from London Heathrow bound for Ulaanbaatar for the first time since 2013. Seven years ago, the passengers were the military band of the Mongolian army heading home after a successful debut at the Edinburgh Tattoo. This time on board were five representatives of the Financial Action Task Force (FATF) with a mission to Mongolia of crucial significance to the nation’s economy. Experts from the U.K., USA, Japan, China and Russia were considering whether Mongolia should be removed from the organisations grey list.

Based in Paris the FATF is an intergovernmental organisation founded in 1989 on the initiative of the G7 to develop policies to combat money laundering. Since 2000 FATF has maintained a blacklist and a grey list. Like the blacklist, countries on the FATF grey list represent a much higher risk of money laundering and/or terrorism financing but unlike those on the blacklist they have formally committed to working with the FATF to develop action plans that will address their deficiencies.

Dulguun Bayarsaikhan writing in the UB Post in October 2019 summed up Mongolia’s recent relations with the FATF which resulted in the nation being added to the grey list for the second time in 2019.

‘Mongolia entered FATF’s grey list in 2013, but narrowly slipped out of it with specific conditions as the country managed to meet some of the requirements and made specific commitments.

In 2016, FATF strongly urged Mongolia to enforce the laws with a set of recommendations. The recommendations included enhancing economic transparency, improving oversight on the financial market, and holding those who break laws accountable. Complying with the recommendation, the Mongolian government formed the National Council to Combat Money Laundering and Terrorism in April 2017.

However, failing to produce the desired outcomes, Mongolia was put under strong scrutiny from the FATF.’

The importance of getting off the grey list to the people of Mongolia is clear from the fact that last week the Prime Minister, Finance Minister and Chairman of the State Great Khural (Parliament) separately made presentations to the FATF officials socially distanced behind screens in the Kempinski hotel. Mongolia has borrowed heavily on the world’s bond markets over the last decade and between 2021 and 2024 much of this will come to term. Refinancing costs will be much more affordable if the country can establish a reputation for financial integrity and honesty.

The signs look promising that the Government under Prime Minister Khurelsukh which has recently achieved a stunning election victory is prepared to walk the walk as well as talk the talk. Substantial progress seems to have been made on implanting the necessary technical regulations. There is also the need to ensure that for the first time there are the institutions with the resources available to implement the law and the fearless independence to do so. This is surely in the interests of the Mongolian people but also Mongolian as well as foreign investors. Ministers know that the proof of the pudding is in the eating though and have also set up a special unit within the Cabinet office to speak directly with international investors who have been the victims of fraud and money laundering. There are a number of well documented cases of wrongdoing which thanks to Mongolia’s free press have received some attention within the country itself. The issue of the Zasag Chandmani Mine is one that also needs to be resolved. British investors are owed $50m+, which they have been trying to recover for a long time, whilst the Mongolian owner of the project has evaded arrest and fled the country. Such stories detract from the incredible success of Mongolia’s entrepreneurs in establishing a thriving private sector in just thirty years with many dynamic companies boasting both substantial growth and impeccable business practices.

Mongolia also needs to put behind it the jibe of ‘Hotel Mongolia ‘which is a reference to a number of foreign investors who in dispute with powerful business interests have found themselves put behind bars. It would be a gesture of strength and goodwill for example if the British Australian businessman Mo Munshi who is in poor health could be released having completed half of his seven-year sentence.

Mongolia has the potential to be a great democratic success story and deserves the full support of the international community. The amazing success in combating the Coronavirus is the world’s underreported story of 2020. The imminent opening of a new international airport and a new rail line into China will strengthen the country’s infrastructure. Coking coal transported from the Gobi area into the Chinese market will now have a significant price advantage over Australian exports. The price of copper essential to the development of green energy is rising which is good news for the flagship mine at Oyu Tolgoi operated by Rio Tinto. The project could alone account for nearly a third of national output by 2027. When I visited the mine as the plane took off in a snowstorm from Ulaanbaatar I got chatting to the passenger sitting next to me. He was an engineer of about 30 who had been brought up in the Ger district at the edge of the capital and had won a scholarship. Now he had a well paid position of real responsibility at Oyu Tolgoi and had a family of his own. That has to be a success story for all involved.

Furthermore, with gold priced at over $2,000 per ounce, Mongolia should prioritise policies and initiatives which stimulate the sustainability of this sector so that the country’s gold reserves held by international banks for safe-keeping can stand tests of probity and help to strengthen the legitimate wealth of the nation which can be borrowed against to finance development projects. There are still gold investments made by international investors which remain blocked by the inconsistent application of policy and regulation. There is also the real social issue concerning the welfare of up to 100000 artisanal gold miners which must be addressed by all involved in the industry. As elsewhere economic conditions are currently tough, but most analysts predict significant growth in 2021. Pride in the nation means that many qualified Mongolians return from study and professional work abroad to make their own contribution to development. The Government was elected on a social democratic platform and there is a healthy debate about the boundaries between state intervention and the market and the best way to combat poverty and expand opportunity. The new Parliament has already held an Investors Roundtable which will help dialogue going forward. The people are weary of corruption and it is worthy of note that no less than four former Mongolian Prime Ministers have recently received jail sentences in relation to this.

The 2020’s could be a decade of rising prosperity for Mongolia with a rapid rise in GDP per capita from the current $4500 per head. The imminent decision to remove Mongolia from the grey list will be a real boost. If Mongolia is to become a magnet for much needed foreign investment it is essential that the country fully commits to a new era of transparency and probity. Never again must the nation find itself on the FATF grey list – twice is already two times too many. In return those with capital to invest need to fully respect the traditions and democracy of the land of the blue sky. The second verse of the Mongolian National Anthem perhaps provides a good text for all to work to:

‘With all honest nations of the world
Strengthen our bonds
With all our will and strength
Let’s develop our beloved Mongolia’

John Grogan
Mongolian British Chamber of Commerce

October 7, 2020