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A survey and analysis of current capital market activities, the demand for capital, the basic
infrastructure and government debt markets.
January 2010
Copyright 2010 Afghanistan Financial Services. Funded by the United States Agency for International Development (USAID). All rights reserved. No part of
this publication, including electronic materials, may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic,
e
mechanical, photocopying, recording, or otherwise, without full attribution.
Table of Contents
Key Findings .................................................................................................................................................................................................................................................. 3
Introduction .................................................................................................................................................................................................................................................. 4
Methodology ................................................................................................................................................................................................................................................. 4
I. Current Capital Market Activities ........................................................................................................................................................................................................... 9
Level of activity in current capital markets ......................................................................................................................................................................................... 10
Significance in raising capital for private enterprise ........................................................................................................................................................................... 11
Economics of current capital markets ................................................................................................................................................................................................. 12
Informal markets that are currently raising capital for private firms ............................................................................................................................................... 13
Typical types of private firms that access and use these markets ..................................................................................................................................................... 14
II. Demand for Capital................................................................................................................................................................................................................................. 15
Level of demand for funds for private enterprise finance .................................................................................................................................................................. 15
Private firms that would be candidates for debt and equity ............................................................................................................................................................. 16
Potential investor base for a capital market ........................................................................................................................................................................................ 18
Current markets for debt finance at the enterprise level ................................................................................................................................................................... 19
III. Basic Infrastructure .............................................................................................................................................................................................................................. 20
Business registration .............................................................................................................................................................................................................................. 21
Level of accounting and auditing that exists...................................................................................................................................................................................... 22
Fiscal, legal and regulatory infrastructure .......................................................................................................................................................................................... 25
IV. Debt Markets ........................................................................................................................................................................................................................................ 27
Current capital notes program ............................................................................................................................................................................................................ 27
Expanding the government securities market ................................................................................................................................................................................... 28
Level of potential feasibility ................................................................................................................................................................................................................. 29
Potential major investor groups .......................................................................................................................................................................................................... 30
Case Study: Sarafi Haji Abdul Qayoom ..................................................................................................................................................................................................... 31
Case Study: Maiwand Bank ........................................................................................................................................................................................................................ 32
Annex 1. Identifying Business Information
Annex 2: Survey Questionnaire
Annex 3: Frequencies
Annex 4: Capital Investment Amounts: Disaggregated by Individual Businesses
Key Findings
Introduction
Afghanistan Financial Services (AFS) was tasked to undertake a range of research and analysis activities
of capital markets in Afghanistan by the United States Agency for International Development (USAID)
Office of Economic Growth (OEG). This assessment includes current capital market activities, the
demand for capital, the basic infrastructure to support capital markets, and government debt markets.
As part of the assessment, a survey was conducted in six major cities of Afghanistan - Herat, Kabul,
Kandahar, Kunduz, Mazar-e-Sharif and Jalalabad.
The 22-question survey targeted businesses with at least 30 employees or initial capital investments of
$250,000 or over, and sought to understand the level of activity in various markets, their significance in
raising capital for private enterprise, and the overall formality and/or informality of such markets. In
addition, business owners were asked to comment on any barriers in the market, what could be done to
make markets more transparent and stable, and what they would like to see in terms of future financial
products and markets. Business sectors surveyed included agriculture, construction, banking
institutions, sarafi (money exchangers), manufacturing, real estate, retail, telecom, trade & distribution,
and transportation.
Two detailed case studies were also conducted at both ends of the capital market lending spectrum one of a sarafi business and one of a formal institutional bank.
In total, 285 businesses were interviewed over a 10-day period in January 2010. The number of
businesses in each sector was chosen based on a sampling estimate of such businesses in Afghanistan,
using a number of internal business databases. The questionnaire was conducted via in-person
interviews by 28 field enumerators targeting the six major urban centers of Afghanistan.
Methodology
Questionnaire Development
Implementation of the right data collection tool is critical to any successful survey. The survey
instrument was designed by AFS and approved by USAID. Those working on the survey included a
researcher with quantitative and qualitative research experience, an Afghan national with strong
statistical analysis and survey training background, and staff with a multitude of experience in the
financial sector in Afghanistan and abroad. Staff also had experience working on USAID-funded
projects in the areas of monitoring and evaluation, and survey design, implementation and analysis.
The survey questionnaire was composed of 21 closed-ended quantitative questions, and one open-ended
qualitative question. Questions were asked in very simple language appropriate to the cultural and
religious context of the local communities. The questionnaire was initially written in English and then
translated into Pashto and Dari for the purpose of the survey administration by field enumerators. In
addition to focusing on capital markets, the questionnaire also collected basic contact and geographical
information for businesses in urban centers throughout Afghanistan for follow-on and verification
purposes.
Survey respondents
Herat
24
Kunduz
30
Mazar
39
Kandahar
45
Jalalabad
53
Kabul
94
0
20
40
60
80
100
Stratification
Stratification according to sector was done prior to undertaking the survey. Stratification was done to
ensure representation across all sectors, as it was assumed that USAID is interested in a range of
business sectors.
The stratification by sector was done through analyzing the official Afghanistan Investment Support
Agency (AISA) database in addition to an internal venture capital database held by AFS, with the
assumption that it was representative of business types in Afghanistan. Overall, approximately 20% of
companies in the AISA database fit the criterion of $250,000 start-up capital. The team then chose a
sample of each business type according to general representation in the database. At least one of each
type of company was surveyed, regardless of how few companies there were in the sector. It should be
noted that, while more than half of businesses in the databases were categorized as construction, in
order to have representation across industries, a smaller percentage of construction companies than
other sectors was sampled for the survey. For other sectors, a much larger resulting percentage of the
sector was surveyed in some cases. For example, the survey only interviewed three private Afghan banks,
but the result was 30% of private Afghan banks, since there are only ten (excluding international
subsidiaries) in the country.
The table shows the total number of business type in the database and the sample taken of each. It
should be noted, that since many businesses are not registered with AISA, the numbers in the database
were assumed to be representative, although not exhaustive or encompassing of every business in
Afghanistan. The AISA database also did not categorize trade and distribution companies, although it
is widely considered to be a major sector Afghanistan. Overall, given the number and breadth of
businesses surveyed across the major urban centers, the results can be reasonably extrapolated to the
business landscape of Afghanistan.
Randomization
In each city, team leaders were given overall daily targets for business sectors. Enumerators were then
deployed throughout the city, and asked to randomly select businesses through random walk method
in a pre-assigned area of that city. Only businesses meeting the criteria of 30 employees or $250,000
start-up capital were used. Once targets for each sector were achieved, enumerators were asked to skip
businesses in that sector. In some cases, enumerators surveyed companies that did not meet one of
these criteria; those were excluded from the data herein. Each day different sections of the city were
assigned to different enumerators. These city sections were based on a grid of printed maps.
Afghanistan Information Management Services (AIMS) maps were used for process purposes.
Target
Sample
Actual
Sample
Agribusiness
138
15
16
Construction
1,274
80
83
654
50
53
Sarafi
Manufacturing
Real estate
Retail
Telecom
Trade/Distr.
Transport
Other
104
25
27
75
72
35
12
10
Bank
10
Total
2,219
269
285
Limitations
The main disadvantage of the approach used here was its reliance on incomplete and inaccurate lists;
however, the size of the sample helped to made up for anomalies and outliers. The stratification method
employed could also skew results towards a non-representative sample if the sectors are not
representative of the business landscape in Afghanistan. Using random walk method may bias the
sample towards more heavily-trafficked areas, or those businesses on the main roads, although this is
not a major issue in the cities, where the survey was employed, and enumerators were instructed to
cover as much of their grid as possible to reduce bias to the extent possible. In Kandahar, security
limited the sample area to a secure portion of the central part of the city, limiting results in that city to a
particular area. It should also be noted that few women-owned businesses were included in the survey,
due to their general scarcity as well as unavailability in open areas of cities.
As a general rule, relying on self reports of people always introduces respondent recall bias into the
results, which are likely present here.
Finally, sampling businesses with 30+ employees or $250,000 of capital or more were arbitrary
classifications to target larger businesses, and should not necessarily be used as categorizations when
designing interventions for the business community.
Significant Events
Significant events that may have affected the survey are as follows:
At the time of the survey, the Ministry of Finance within the Government of Afghanistan had recently
begun enforcing the Afghanistan Tax Law in earnest, for the first time since 2001. As a result, according
to enumerators, team leaders and businesses owners, some businesses were reluctant to share financial
information, particularly annual turnover information, worried that the surveyors were either from the
Ministry of Finance and sent to collect information, or that the information could be shared with the
Ministry of Finance through a third party.
On 18 January 2010, during the field portion of the survey implementation, a major attack on Kabul city
by militant forces ensued. Survey teams had been deployed in central Kabul where the attacks took
place, including one surveyor who was in an upscale shopping area, which suffered damage from the
attacks.
14%
12%
10%
10%
6%
2%
10%
9%
7%
8%
4%
13%
11% 12%
4% 4%
1%
2%
0%
3%
Data Quality
Maintaining high quality of the data was imperative, including ensuring data reliability and reducing or
eliminating survey bias to the extent possible. Necessary measures were taken at different stages of the
survey as described below.
Trained surveyors: Educated and well-qualified personnel were hired to take part in the survey. Most
surveyors were hired based on the previous survey experience with the Research Partner and other
donor agencies and were well known to the project team undertaking the survey.
Training workshop: A two-day workshop to explain the designed data collection tool to these
qualified surveyors was delivered. Various practical sessions were conducted within the workshop to
practically exhibit/display the interview between a surveyor and a business owner. Necessary feedback
was given by the trainer and oversight of the workshop was provided by senior management.
Business person contact number: Each surveyor provided the contact number of the person
interviewed by the surveyors. These contact numbers were regularly called, and the Project Team Leader
asked if a surveyor had been to the business, and to cross check some of the information on the
questionnaire on the telephone.
Double-checking filled questionnaires: Filled questionnaires submitted were cross-checked by the
Project Team Leader and his assistant to see if any inconsistency and inaccuracy existed. In case of any
inaccuracy, both the business person and the surveyors were contacted to get the right information.
Trained data-entry clerks: Two full-time data entry clerks were hired to enter the received
information into the database designed in SPSS. These data entry clerks participated in the training
workshop and were closely supervised by the Project Team Leader during the data entry phase.
Turnover ($)
Count
285
278
Mean
62
3,549,108
Median
20
290,000
Mode
10
100,000
Std. Dev.
151
21,505,137
Minimum
20,000
Maximum
1400
343,000,000
Lender-Borrower Relationship
Lenders
Intermediaries
Capital Markets
Borrowers
Individuals
Companies
Banks
Insurance Companies
Pension Funds
Mutual Funds
Interbank
Stock Exchange
Money Market
Bond Market
Foreign Exchange
Individuals
Companies
Central Government
Municipalities
Public Corporations
10
1.074
Real estate
1.129
Trade/ Distribution
1.576
Agriculture
1.582
Transportation
Of those borrowing money for their business, the largest sources that were used for capital were friends
and family. Analysis by province shows that Herat and Kabul had the most reliance on external capital
from friends and family. This is likely due to the fact that there are more high-net-worth individuals in
these cities so people are more easily able to access capital from their friends and family members. All
businesses interviewed in Kunduz relied entirely on their own capital.
Further analysis by sector shows that construction companies, retailers, trade/distribution companies,
transportation and other categories showed the highest reliance on friends and family. Notably, sarafi,
real estate, telecommunications and banks did not rely at all on friends or family for capital. There is
some indication that even larger banks relied heavily on friends and family for capital investment, with
the only difference being that bank investors were organized into formal legal shareholders.
Overall, only 4.9% of all businesses relied on banks for some type of capital.
100% of
telecommunications companies relied on banks for some of its capital, 33% of banks did the same.
Other areas using banks included agriculture, construction, manufacturing, and trade/distribution.
In looking at those companies who used banks for capital, unsurprisingly, their capital investments were
much larger than the average capital investment of the survey. On average, people invested a total of
$2,607,504. However, those borrowing from banks invested an average of $10.4 million, illustrating the
use of the banking sector by larger companies.
Sarafi, or money changers, are part of the capital markets in Afghanistan, although largely unregulated.
They are responsible for changing currencies and moving large sums of capital around Afghanistan. In
the survey, approximately 1% of people had borrowed money from sarafi. Smaller businesses may be
borrowing money from sarafi, however, this survey focused on larger businesses. Indeed, most of the
businesses borrowing from sarafi, borrowed relatively small sums from them, although they did indicate
that they planned and would like to borrow again from sarafi in the future.
2.024
Sarafi
2.200
Manufacturing
2.639
Construction
2.780
Other
3.522
0
1
2
3
Source: Survey for Afghanistan Capital Markets
Assessment, January 2010.
$0.06
Sarafi
$1.19
Family
$2.18
Friends
$4.41
Banks
$14.81
Others
$54.05
Self
$148.17
$0
$50
$100
$150
$200
11
80%
60%
40%
20%
0%
19%
4%
3%
Very
Important
Little
Not
Important
Important Important
Source: Survey for Afghanistan Capital Markets
Assessment, January 2010.
39%
35%
Very
Difficult
Difficult
11%
11%
Less
Difficult
Not
Difficult
25%
16%
20%
17%
14%
12%
10%
10%
6%
0%
0%
20%
40%
60%
80%
100% 100%+
12
28.7%
26.4%
17.2%
13.8%
11.5%
2.3%
Free
1-5%
2%
5%
Stop my company
5%
17%
No more capital
31%
No penalty
41%
0%
Source: Survey for Afghanistan Capital Markets
Assessment, January 2010.
50%
6%
Other
11%
In court
12%
No disputes
13%
Fines
16%
Shura
42%
0%
20%
40%
60%
13
Informal markets that are currently raising capital for private firms
The survey found that the vast majority of people relied on their own capital to start their business. A
total of 205 of the 285 people (72%) relied exclusively on their own capital. 94.7% of people used at least
some of their own capital to start their business. This held true across regions and all sectors. The
average investment by self was $2,133,682. The mode for this category was $250,000. The only notable
exception to the rule were the banks, who were organized into a more formal group called
shareholders, although in most cases these shareholders were in fact made up of self, family and
friends.
It should also be noted that, while they were available as answers on the survey, nobody reported
accessing capital from elders and only one from a donor. In addition, only 14 (4.9%) of surveyed
businesses had sourced any capital from a bank. Including sarafi financial institutional sources increased
this number to 17 (6%).
Overall, the survey found that 28% of people relied on capital other than themselves (external capital).
The degree to which people relied on external capital, however, varied by province and by sector.
Businesses in Herat relied on external capital the most, 58% of businesses reported such reliance. About
one-third of businesses in Balkh and Kabul relied on external capital, while 25% of businesses in
Kandahar and 15% in Nangarhar reported relying on external capital. Notably, n0 businesses in Kunduz
reported reliance on any capital other than self.
Cross referencing this information with the Investment Climate Survey (ICS) conducted by the World
Bank and DFID in 2008, the data is highly similar. 12% state to receive capital from friends (vs. 14.4%),
and 3% from banks (vs. 4.9%). The minor differences can be accounted for because the ICS survey asked
where working capital was sourced, while this survey asked for initial capital sources. If an external loan
was taken, 68% listed family and friends inside Afghanistan as their source. Taking 94.7% self funded
capital sources out of our survey, we are left with 29% family and 48% friends, or a combined 77% from
family and friends. In a survey conducted in November among 500 heads of SMEs nationwide, 70%
stated that it was difficult to borrow money, 83% stated that they started the business with family
money, and 59% said they needed additional credit to keep their business going.
In conclusion, the vast majority of businesses in Afghanistan rely exclusively on their own capital (72%).
Those that do manage to obtain external financing are served by mainly family and friends (23.2%).
Banks make up only a fraction (4.9%) of the capital market activities, and sarafis half that (2.1%).
Sarafi Family
2.1%
8.8%
Bank
4.9%
Friends
14.4%
Self
94.7%
Multiple selections allowed in responses. Source:
Survey for Afghanistan Capital Markets Assessment,
January 2010.
12%
10%
10%
3%
5%
1%
0%
Friends Suppliers
Banks
Others
land
owner,
3%
Family &
friends
inside AF
68%
14
Typical types of private firms that access and use these markets
Two case studies are included at the end of this survey to provide detailed snapshots of typical types of
private firms that access and use capital markets in Afghanistan at either end of the formal/informal
spectrum. Here we highlight themes on the current activities of capital markets discussed so far in Part I
in Afghanistan which create a profile of the private firms involved, before moving on analysis in Part II.
Food purchases
Business investment
Health emergency
Home improvement
Home construction
Wedding
Other
Funeral
Land purchase
Agricultural inputs
First, according to the National Risk and Vulnerability Assessment by the Central Statistics
Organization, 45% of loans are used for food purchases. This survey is concerned with only the 12% that
use loans for business investments and only for large businesses at that. This eliminates 88% of the
loans that are made nationally.
Second, the businesses we interviewed had a strong aversion to interest based debt, as shown by their
preference for Sharia-compliant based products. The ICS confirms this finding, indicating that of those
who needed financing, Islam was far and away the number one reason they did not apply for a loan.
High interest rates came in second.
Third, while we interviewed businesses across nearly every sector, the typical types of private firms
needed financing the most were also in the capital intensive sectors: construction, manufacturing and
sarafi. These types of firms were the hungriest for capital. However this did not match the 2006
outstanding loans portfolio of the country, where transport, agriculture and energy/mining held the top
three loan sector types. This may indicate a mismatch between the sectors needing capital and those
that the banks are willing to finance.
Thus, we begin to profile the businesses that currently access and use these highly informal, severely
undeveloped capital markets in Afghanistan.
45%
12%
10%
9%
9%
6%
5%
3%
1%
1%
0%
20%
40%
60%
Source: National Risk and Vulnerability Assessment,
Central Statistics Organization, 2007/8.
223.2
223
135
89.6
75
40
35.4
25
22
5
0
100
200
300
1%
26%
4%
3%
4%
8%
3%
0%
10%
20%
30%
15
2nd Priority
3rd Priority
12%
Musharaka
31%
32%
6%
Murabaha
23%
13%
2%
No need
5%
2%
2%
Stock Exchange
13%
10%
1%
Ijara
20%
20%
1%
4%
2%
Qarzi Sood
0%
10%
20%
30%
40%
$4.09
Stock Exchange
$5.32
Musharaka
$40.44
Mudaraba
$4.74
Ijara
$4.74
Qarzi Sood
$2.00
$0
$20
$40
$60
16
Telecom
Bottlers
Kabul Bank
Bank-e-Millie
Arian Bank
Afghan Telecom
Cristal
Panjsher
Airliners
KamAir
Azizi Bank
Pashtany Bank
Afghan Wireless
Coca Cola
Salang
Safi Airways
Roshan
Sadat Cola
Zamzam
Pamir Airways
Maiwand Bank
Bank Alfalah
Etisalat
Super Cola
Pamir
Ariana Airlines
Ghazanfar Bank
MTN/Areeba
Watani
Noshak
Common trade names used, instead of full legal names. Source: Afghanistan Financial Services, 2010.
No. of
employees
Kabul
Kabul
180
375
Kandahar
Kabul
M Saleem Sadat
Shirkat Sakhtumani Onix
Shirkati Mujtaba Faqeer Yar
Balkh
Balkh
Balkh
Company name
Asir Nabi Zada
Geo Map
Ittihad Plastic
Jahim Printing Press
Initial
capital ($)
Capital from
banks ($)
% capital
from banks
Construction
Construction
1,010,000
15,000,000
500,000
500,000
50%
3%
Debt 6-10%
Debt 16-20%
35
30
Manufacturing
Other
260,000
300,000
260,000
150,000
100%
50%
Debt 6-10%
Undisclosed
Balkh
40
Construction
350,000
80,000
23%
Debt 1-5%
Kabul
20
Construction
12,000,000
10,000,000
83%
Debt 11-15%
35
Construction
2,580,000
40,000
2%
Debt 1-5%
30
Manufacturing
280,000
30,000
11%
Debt 6-10%
35
Trade/ Distribution
4,080,000
60,000
1%
Debt 6-10%
Business type
Cost of capital
17
Ministry of Defense
Slaughterhouse Enterprise
Construction Material Production
Ministry of Culture and Information
Afghan Advertisement
Azadi Printing Enterprise
Ariana Printing Enterprise
Afghan Tour Enterprise
Ministry of Energy and Water
Brishna Organization
Spin Ghar Construction
Power Construction
Jadid Entergy Enterprise
Helmand Construction
Metal Components Production
Ministry of Transportation
Millie Bus
Center Kamaz Enterprise
Kamaz Enterprises
Technical Services Enterprise
Hotels Enterprise
Ministry of Finance
Security (Sukuk) Printing Enterprise
Source: Various ministries in the Government of the Islamic Republic of Afghanistan, July 2007.
18
55%
45%
40%
20%
0%
Yes
No
Source: Survey for Afghanistan Capital Markets
Assessment, January 2010.
3%
Personal Connection
14%
Cost/Benefit Analysis
30%
Audited Financials
11%
Business plan
43%
0%
20%
40%
60%
Source: Survey for Afghanistan Capital Markets
Assessment, January 2010.
56.9%
27.6%
12.2%
3.3%
$5K-10K
$10K-25K
$25K-$100K
$100+
19
Other
12%
Private
banks
45%
Non-bank
financial
institution
29%
Source: Investment Climate Survey, World Bank and
DFID, 2008.
The demand for any product in a market depends, upon the amount of supply there is in the market.
But the more important aspect is the existence of proper and efficient market, which could cater for the
needs of different businesses.
The situation is the same for debt finance markets in Afghanistan. The lack of financial institution which
specializes in the debt products is one of the main concerns. There are no major debt finance products
available in the market, which could benefit large enterprises. The reason for this may be because
government sector wants to priorities long term debt financing with a view of long term investment by
businesses that would in return, improve the economy. But the rules, regulation, cost and Islamic point
of view about interest laden debt surrounding the provision of the debt eradicates its effectiveness and
popularity among the enterprises. Another factor could be the criterion for creditworthiness of the
businesses; banks mostly rely on audited and verified financial records and as highlighted by the survey
most of the businesses that are registered with AISA lacked proper independent external audited
financial records.
According to the survey concentration of loans taken out or applied for vary significantly according to
different sectors of the economy. The highest concentration relates to commerce that is almost 90% of
the whole sector, and the rest shared between mortgage, consumer, agriculture and others collectively.
This highlights the business preferences of the enterprises. But in the hind sight it signifies the fact that
other participants with in the sector are either unaware or lack proper tools to take a grab at the facility
or they are simply not interested.
Mortgage
2.28%
Other
6.74%
Agri.
0.14%
Commerce
88.67%
20
GDP growth
20%
The legal and regulatory infrastructure for Afghanistan capital markets are missing constituents for the
longer term creation and evolution of a more formal capital market in the country. It needs an increased
regulatory and enforcement capacity aimed at developing a fairer and more efficient capital market and
facilitating market innovation. A substantial program of law reform has to be undertaken in recognition
of the important influence of the regulatory framework on the growth and development of capital
markets.
In addition to these infrastructural obstacles, Afghanistan has far from completed its reform of the legal
and regulatory environment for investment. The government is in the process of transforming the entire
legal and regulatory environment, including drafting a contract law, arbitration law, company law and
partnership law, all of which are currently absent, inadequate, or require extensive revision. These laws are
expected to be in place by 2010. It may be unrealistic to expect many investors, especially foreign investors,
to express interest in SOEs before these laws are in place. Source: Putting the Cart Before the Horse?
Privatization and Economic Reform, Afghanistan Research and Evaluation Unit, November 2006.
16.4%
15.1%
15%
11.5%
9.4%
10%
8.0%
5%
0%
1383 1384 1385 1386 1387 1388 1389 1390
Source: Central Statistics Organization, 1383-1390.
Industry
Agriculture
20%
15%
9.0% 9.0%
6.1%
10%
5%
0%
-5%
7.8%
1.3%
5.2%
1382
3.1%
5.7%
6.3%
6.1%
-3.9%
1383
5.4%
5.8%
7.3%
1384
-8.6%
1385
-10%
The government should introduce various measures to enhance market infrastructure and put in place
an appropriate regulatory framework. These would include the above mentioned and could add on to
the establishment of a credit rating agency, guidelines on debt securities issues, bond information
dissemination system etc. DAB may perhaps try to develop a market infrastructure for debt securities,
improving the trading, clearing, settlement and depository systems. State-of-the-art Computerized
trading system, electronic clearing and settlement, and central depository systems are crucial to provide
a fair, transparent, efficient and cost effective market for the investors.
The market infrastructure for the equity market needs to be developed, but transparency, disclosure,
and corporate governance need to be improved. In particular, speedy and frequent disclosure of
appropriate information is essential. In addition, the details of asset value and off-balance-sheet items
should also be disclosed.
Since disclosure practices and corporate governance in Afghanistan do not conform to international
standards, legal enforcement needs improvement. Most investors are focused on short-term placements,
$199
1383
$252
1384
$300
1385
$335
1386
$383
1387
$433
$433
1388
1389
21
making it difficult to enhance corporate governance. The public has to be encouraged to make longterm investments. An increase in dividend payments could be considered. Dividends are subject to
withholding tax. Due to the withholding tax, companies, particularly major shareholders, are reluctant
to pay high dividends. They prefer to use the profit for further expansion, which leads to an increase in
asset values (capital gains). In addition, they tend to maximize their returns by injecting their family
assets into the company. If they were exempted from the tax on dividends, companies would increase
their payout ratios and investors would be encouraged to hold shares for longer periods. In this case,
shareholders must pay more attention to the management of companies in order to receive better
dividends. This could, in turn, improve corporate governance. Lowering of the effective tax rates,
exemptions from Business Receipt Tax (BRT) and capital gains tax would be very commendable steps.
This move will likely help in boosting the confidence of the long term investors.
Overwhelmingly, growth is strongly influenced by infrastructure to support information gathering and
by enforcing business dealings based on such information. Highest standards of accounting, disclosure
and transparency are prerequisites for efficient working of the capital market. Thus, rotation of auditors
by companies after every five years, restriction of auditors to provide non-audit services to their audit
clients and enhancement of penalties on auditors in case of professional misconduct would add to
transparency of the markets.
Business registration
AISA registration is the official business registration in Afghanistan, and by law, all businesses are
required to register with the agency. A total of 71% of surveyed businesses reported having AISA
registration whereas 29% reported that they did not have AISA registration. While many small
businesses cannot afford the fee ($180), these results indicate that even large businesses do not register
with the government.
Business registration
Not
registered
19%
AISA
31%
Other
3%
Municip.
22%
Other Gov
Ministries
17%
Ministry of
Commerce
20%
Source: Investment Climate Survey, World Bank and
DFID, 2008.
Foreign
3000
380
2000
1000
101
249
1474
1137
2003
2004
300
171
2123
1746
1925
2005
2006
2007
No
Yes
Kandahar
Kabul
0%
100%
11%
89%
Mazar
36%
Herat
38%
Kunduz
Jalalabad
64%
63%
47%
53%
64%
36%
0%
50%
100%
Source: Survey for Afghanistan Capital Markets
Assessment, January 2010.
150%
22
None, 1%
Excel
31%
Paper 65%
Self
Auditor
2.10%
50%
40%
29.80%
28.10%
No
Yes
0%
15%
11%
16%
18%
18%
9%
Very
Somewhat Willing Not willing
willing
willing
Source: Survey for Afghanistan Capital Markets
Assessment, January 2010.
23
Due to the abovementioned issues, the accountants of Afghanistan have stepped up and joined hands to
form the Afghanistan Association of Professional Accountants (AAPA). This Association is registered
with the Government of Afghanistan and has the legal status to represent the accounting profession.
The establishment and financing of the Accounting Standards Committee within AAPA will enable the
following nonexclusive list of project objectives to be achieved:
Develop national accounting and auditing standards that are in line with international standards.
Facilitate discussions on noted critical accounting and auditing problems faced by professionals.
Assist the Government in developing the law of external audit requirements.
Support the Afghanistan Universities and other training providers in curriculum development in
accounting, auditing and financial management and negotiate with Government universities to
incorporate the Association of Chartered Certified Accountants (ACCA)s fundamental
curriculum in the undergraduate economics degree program.
As a result, local entities will be advised to prepare, maintain and present their financial statements in
according to standards which will enable the financing institutions to evaluate their financial statements
and this will increase the chance of businesses to access the capital markets. The accounting standards
committee will develop accounting standards to be implemented by all business entities. Clarification
on standards will speed up compliance. The Committee will assist the GoA in developing transparent tax
laws and audit regulations which will be implemented by the GoA and applicable to all business entities.
It will also assist the GoA in developing the financial reporting requirements for State Owned
Enterprises (SOEs) and make sure that corporate organization to practice Code of Corporate
Governance.
AAPA has put this discussion with Ministry of Finance (MoF) and MoF is in agreement with this project
and has proven it is commitment by means of an official support letter. MoF and several other relevant
influential Governmental authorities (Ministry of Justice, Ministry of Higher Education, Audit and
Control Office, Central Bank, Member of the Parliament, Afghanistan Chamber of Commerce) will be
member of the Standards Committee.
The Association will seek membership of International Federation of Accountants (IFAC) and may
receive technical support from its International Standards Board to develop local regulations. As it will
be providing support to the current accounting students of ACCA, it is expected that it will be supported
by ACCA in terms of resources and professional guidelines. ACCA has already shared its discussion
paper with AAPA for supporting development in Afghanistan which addresses accounting areas such
as (Accounting Legislation, Structure and Governance, Audit Quality Review, Education and Training,
Adopting IFRS, and more.)
Beneficiaries of reform
Businesses: This will improve investment in
Afghanistan and investors confidence in
accountability by demonstrating a successful and
effective accounting society. As the standards
are in place this is expected to promote cooperation between government, the accountancy
profession, the international financial
institutions, regulators, standard setters, capital
providers and issuers. Financiers will be more
inclined to extend vendor credit if the financial
condition of client firms can be verified through
independent audit of qualified accountants and
auditors.
Government: The standards committee of AAPA
will assist the Government of Afghanistan to
develop, the accounting curriculum, tax law and
audit regulations in manner that is more
appropriate and applicable in the country. Also
the standards committee will assist the GoA to
develop the financial reporting requirements for
State Owned Enterprises (SOEs).
Civil Society: Well trained and certified Afghan
accountants will be able to replace international
accountants. As such, in increasing the desire
for greater accountability and transparency, the
cost of auditing and accountancy will more
effectively align with local ability to pay. This is
also expected to promote the importance of
accountancy and professional accountants in
general and to influence ways of thinking about
professional practice.
International Community: The result and
outcomes will contribute to strategic objectives
of international community, regulated society,
building capacity, increased incomes through
economic growth, progress toward sustainability.
Source: Afghanistan Financial Services, 2010.
24
The role of reforming accounting and auditing in Afghanistan could have a serious impact:
Reduced transactions costs in dealing with government: Financial reporting to the Ministry of
Finance with respect to taxation etc. should be reduced. In effect, having more qualified local
accountants/auditors that understand the current financial reporting environment should facilitate ease
of communication with various government entities.
Avoidance or at least reduced corruption: Reporting of financial accounts along international
accountancy standards will increase transparency of accounts and could reduce corruption. Enabling
more local Afghan consultants to have an awareness of how to present accounts in an internationally
acceptable manner should facilitate a reduction in corruption.
Reduced investment risk: Transparent financial reporting undertaken by skilled and more
importantly certified accountants will increase the confidence of local and international investors in the
local business community.
Increased productivity and lower operating costs: A positive by-product in training more local
accountants and auditors is that the use of international accountancy expertise will become more
strategic in nature. As such, the local cost structure, for developing international caliber financial
reports, will more readily align with the local labor pool.
80%
Retailers
49%
Manufacturing
45%
Other Services
44%
Professional
32%
0%
50%
100%
Source: Investment Climate Survey, World Bank and
DFID, 2008.
5%
Pakistan
63%
Jordan
94%
Afghanistan
51%
0%
Increased profitability of local content: One of the primary functions is to increase the competency,
and number of certified, locally trained accountants and auditors. A positive by-product in training
more local accountants and auditors is that the use of international accountancy expertise will become
more strategic in nature. As such, the local cost structure, for developing international caliber financial
reports, will more readily align with the local labor pool.
Easier access to local and international markets, generating higher sales and export revenue:
Business entities producing financial statements that meet international standards requirements will
have increased chance to enter into partnership with international partners and do business in the
international markets.
50%
3%
Jodan
3%
Syria
4%
Yemen
9%
Egypt
Easier access to capital: Local entities will be advised to prepare, maintain and present their financial
statements in according to standards which will enable the financing institutions to evaluate their
financial statements and this will increase the chance of businesses to access the capital markets.
100%
Afghanistan
11%
2%
0%
5%
10%
15%
Source: Investment Climate Survey Full Report,
World Bank and DFID, 2008.
25
$2.900
$1.283
$0.425
$1.662
$2.064
$0.820
Da Afghanistan Bank has been particularly successful in its fiscal policies - albeit in part by the opium
and donor inflows into the country. Gross foreign exchange reserves have steadily increased year on
year, and inflation has been controlled from over 50% to under 20%. In particular, value of the Afghani
has been very constant at around 50 Afghani to the dollar since 2003. The international financial crisis
left Afghanistan largely unscathed.
40
20
0
1381
1382
1383
1384
1385
1386
While the fiscal and regulatory infrastructure is relatively favorable for supporting capital markets, the
legal court system is completely broken. The average civil case takes three years to go through the
extremely corrupt courts, and enforcement of contracts or government regulations is seen as very weak.
In addition to insecurity, poor land tenure, and corruption, the high level of uncertainty and risk facing
investors in Afghanistan comes from the absence of a clear legal framework. In Afghanistan's uncertain
business environment, individual firms experience many benefits from having close ties to influential
commanders. The formal court system barely functions and most people rely on informal dispute
resolution mechanisms. Despite ongoing efforts at legal reform, the legislative process is slow and a
number of important laws have been languishing, awaiting parliamentary approval, final drafting, or
implementation. Above all, the government must be consistent and predictable. Source: The Investment
Climate in Afghanistan, World Bank, 2008.
Inflation
60%
40%
20%
0%
-20%
-40%
Source: Central Statistics Office, 1381-1386.
26
Currency Control: Businesses mentioned that the government should do more to enforce transactions
in Afghani rather than other currencies (Pakistani Rupee and US dollar were cited).
Reliance on Imports/Internal Capacity: Businesses mentioned that help from the donor community
and the Government of Afghanistan to improve local manufacturing/production capacity as well as
provide controls on similar imports was welcome.
Taxes: In part due to the fact that the Government of Afghanistan has recently begun enforcing the tax
law in Afghanistan, many business owners said that they cannot afford high taxes, and that the
government ought to encourage business investment by suspending taxes on companies that provide
jobs and meaningful contributions to the economy.
External Budget
28%
40%
34%
21%
8%
10%
11%
1382
1383
1384
10%
22%
10%
1385
1386
Electricity: Electricity was repeatedly cited as a large barrier to improving profit margins and
expanding business operations, with business owners requesting expanded electricity or alternative
energy investments. These requests were particularly prevalent in Nangarhar.
Security: Security was cited as a concern by businesses, particularly in Kandahar and Kabul. Some
businesses noted that the volatile political landscape prevented them from investing further sums of
money into Afghanistan, and didnt allow them to make long-term capital investment decisions in fixed
assets.
Legal Framework: Reduced levels of corruption/bribing as well as a more transparent legal framework
for capital markets was cited as an important foundation for investment in formal capital markets
throughout Afghanistan. Banks in particular mentioned that a transparent and cohesive legal
foundation was necessary for improvements in the banking sector, as well as any other formal capital
sectors developed in the future.
17%
29%
55%
64%
22%
32%
37%
43%
45%
0%
20%
40%
60%
80%
27
1
2
28
24
11
72
41
3
3
4
2
3
23
40
70
30
12
3
14
2
5
27
30
59
22
0
4
0
47
50
100
28-day
0.0
0.5
27.1
3.0
14.0
0.0
4.0
131.1
65.8
112.7
37.5
123.7
2.2
77.5
2.5
66.4
0.6
3.0
17.3
20.4
10.0
72.1
15.4
79.5
0.7
1.1
0.0
5.0
0
100
200
*Afghanistan International Bank was an outlier,
having purchased $405m in 28 day notes and $83.7m
in 182 day notes. Source: Market Operations
Department, Da Afghanistan Bank, March 2007-2009.
28
Deadline
Dec 2010
Dec 2009
Jan 2010
Dec 2010
Dec 2010
Dec 2012
29
Private
20
State-owned
Foreign
15
10
4
3
4
5
3
4
1384
1385
5
0
5
3
5
3
1386
1387
State-owned
Foreign
1000
While conventional bond is a promise to repay a loan, Sukuk constitutes a partial ownership in a debt
(Sukuk Murabaha), asset (Sukuk Ijara) and business (Sukuk Musharaka). These securities tend to be
bought and held and, as a result, a little of the securities enter the secondary market allowing them to be
traded. Furthermore only public Sukuk are able to enter the secondary market, as they are listed on
stock exchanges.
400
200
135
65
194
84
47
51
520
1384
1385
1386
Source: Da Afghanistan Bank, 2010.
84
652
1387
Conservative estimates by the Ten-Year Framework and Strategies suggest that over $1.2 trillion of assets
are being managed according to Islamic investment principles. Such principles form part of Shariah,
which is often understood to be Islamic Law. In the Persian Gulf and Asia, Standard & Poor's estimates
that 20 per cent of banking customers would now spontaneously choose an Islamic financial product
over a conventional one with a similar risk-return profile.
218
74
600
As majority of Afghans are Muslims whose teaching prohibit payment of interest, many are reluctant to
invest in interest-bearing instruments. Motivated primarily by the interest issue, the Government may
focus on Sharia-compliant products. These could be Sukuks, Islamic bonds and Khazanah bonds which
are based on Islamic concept (no coupon or interest payment).
286
800
State-owned
Foreign
1385
1386
150%
101%
100%
50%
65%
23%
0%
Considering the results of the survey, and the assessment of the basic infrastructure components
needed, the potential feasibility for establishing a government Sukuk market in the next three to five
years remains fairly high.
-50%
-17%
-46%
-55%
-100%
Source: Da Afghanistan Bank, 2010.
30
2,500
Iran
1,000
EU
250
200
Central Asia
200
Gulf
100
USA
100
Canada
45
Austrailia
30
0
31
32