Katherine Ross

Nigeria’s Securities and Exchange Commission issued a warning warning targeting a company — Binance Nigeria Limited — operating under the same name as Binance as an unregulated and unregistered exchange.



Because the company is operating without any regulatory oversight, the SEC warned that “any member of the investing public dealing with the entity making such solicitation is doing so at his/her own risk.”



This is the second <a href="https://sec.gov.ng/circular-on-the-activities-of-binance-nigeria-limited/">warning</a> the Nigerian regulator has made, though the SEC’s latter notice specifically targeted Binance.com, which is the URL of the global exchange and not Binance Nigeria Limited.&nbsp;



Blockworks requested clarity from the Nigerian SEC but did not hear back before publication.



“The Commission again reiterates that the activities of Binance, https://www.binance.com and any such other platform through which the Company solicits investors is neither registered nor regulated by the Commission and its operations in Nigeria are therefore illegal,” the July notice said.



In early June, the SEC said it was made aware of Binance Nigeria Limited and ordered the entity to “immediately stop soliciting Nigerian investors in any form whatsoever.”



The second <a href="https://sec.gov.ng/warning-against-investing-with-binance/">warning</a> echoes the June order of asking “platform providers, making such solicitations” to stop soliciting investors in Nigeria.



“We are aware of the circular, however, the entity mentioned in the circular is not affiliated with us. We are therefore seeking clarity from the Nigerian SEC and remain committed to working with them cooperatively on the next steps,” a Binance spokesperson told Blockworks in an email.



“Most importantly, we want to remind users that their assets on Binance are safe, accessible and secure. Our greatest priority will always be to deliver for our users.”



Binance did not immediately respond to a request for comment on the warning issued by its impersonator.



Outside of Nigeria, the real Binance has struggled with the regulatory environment in Europe and the US — despite the fact that Binance.US, not Binance, operates in the US.



Back in June, French authorities made an <a href="https://blockworks.co/news/binance-france-on-site-visit">on-site visit to Binance</a> as reports claimed that the global exchange was facing an investigation by French authorities. The global exchange, however, said that the on-site visit was “part of regulatory obligations to which all financial institutions must adhere.” It added that it spent “considerable time” and resources cooperating with “law enforcement globally.”



Binance has also withdrawn from multiple European countries as it struggles with registration. Europe recently passed the Markets in Crypto Assets Act (MiCA), which aims to regulate the crypto industry.



Last week, Binance “proactively” withdrew its application to operate in Germany, though earlier reports had stated that BaFin — Germany’s regulatory agency — had declined to issue a license last month.&nbsp;



In June, Binance also announced its plans to exit the <a href="https://blockworks.co/news/binance-leaves-netherlands-cyprus">Netherlands</a> and <a href="https://www.cysec.gov.cy/en-GB/entities/crypto-asset-services-providers-casps/casp-register/93362/">Cyprus</a>.&nbsp;



It’s not all bad news for Binance, however, as it did announce that it was <a href="https://blockworks.co/news/binance-dubai-operational-license">one step closer to receiving full approval from Dubai’s regulatory agency</a>. The Virtual Asset Regulatory Authority issued Binance a minimum viable product license on Monday, meaning that it will only need to receive a full market product license to offer more authorized services.



Updated Aug. 1, 2023 at 1:15 pm ET: Added context from the Nigerian SEC circular, including the citation of Binance&#8217;s official website. Headline updated to reflect change.



Updated July 31, 2023 at 5:19 pm ET: Added statement from Binance.



Updated July 31, 2023 at 10:38 am ET: Corrected to clarify that Binance Nigeria Limited is an entity with no ties to the real Binance.



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Nigeria’s SEC issues second ‘Binance’ investor warning, cites exchange website

James Cirrone

On Tuesday, ConsenSys published a survey in partnership with YouGov, focusing on crypto and Web3. The survey findings suggest a contrast between countries with developed economies and those with emerging economies.



The <a href="https://consensys.io/insight-report/web3-and-crypto-global-survey-2023">survey</a> polled over 15,000 people aged 18 to 65 in late April through May of this year. The respondents were also spread out among 15 different nations across Africa, the Americas, Asia and Europe.&nbsp;



A healthy supermajority, 92%, were aware of crypto, but that’s where the similarities ended.&nbsp;



Respondents from developing nations were generally more optimistic on crypto, while developed nations were decidedly more skeptical.&nbsp;



Nigerians were quite keen on owning crypto as a store of value, with 65% of Nigerians feeling this way.&nbsp;



For crypto investors in the US, Germany and the UK, the reasons for owning digital currencies were a bit different.&nbsp;



Americans, Germans and Brits all said one of their top reasons for investing in crypto was because they were “curious” and had a desire to educate themselves on the industry through “experimenting,” a ConsenSys spokesperson told Blockworks.



And 56% of Argentinians were motivated to own crypto for the same reason. They reported feeling that their “local currency is too unstable.” The Argentine peso has reached over 114% inflation, <a href="https://www.nytimes.com/2023/06/19/world/americas/argentina-inflation-peso-restaurants.html">according</a> to the New York Times.&nbsp;



This is something Circle CEO Jeremy Allaire expanded on in a recent Bloomberg <a href="https://www.youtube.com/watch?v=mhvcWogKhTQ">interview</a>, telling the outlet that he sees “enormous demand for digital dollars in emerging markets.”



Allaire was speaking on the news about Circle <a href="https://www.circle.com/en/pressroom/circle-singapore-obtained-major-payment-institution-license">obtaining</a> a license to offer its stablecoin services in Singapore. He noted that Asia has the most demand for such services, which could partially explain why the survey found that respondents from Asian nations were among the most likely to invest in crypto over the next 12 months.



Respondents were also asked which three concepts they most closely associated with crypto. With twelve possible answers, 38% said crypto either makes them think of “the future of money,” an “alternative to the traditional financial ecosystem,” or “the future of digital ownership.”



Broken down further by nationality, 58% of Nigerians, 50% of South Africans, and 44% of Mexicans believe to a certain extent that crypto is the future of money.&nbsp;



Among the Germans and Brits who were polled, less than 20% of them thought the same.&nbsp;



Similarly with NFTs, which is a way <a href="https://blockworks.co/news/how-to-buy-an-nft">some people are trying to create value and get compensated on the internet</a>, developing nations such as Nigeria, South Africa and Vietnam are most familiar with the concept of NFTs.&nbsp;



The most stark comparison on <a href="https://blockworks.co/news/75-percent-crypto-holders-own-nfts">NFTs</a> comes between British and Vietnamese respondents. UK residents were not likely to have owned an NFT, with 76% of them never having bought one. Only 24% of Vietnamese residents reported never having owned an NFT.



However, there was one common thread throughout the survey. Nigeria is by far and away the most bullish on crypto, despite the fact that <a href="https://blockworks.co/news/nigeria-tokenized-securities-crypto">crypto trading is severely limited in the country</a>.



A whopping 70% of Nigerian respondents correctly guessed the definition of a blockchain, which ConsenSys defined as “a secure, decentralized and transparent digital ledger that records and verifies transactions.” Only 36% of Americans and 30% of British residents cracked the right definition.



Also, nearly 80% of Nigerians said they understand what crypto is, with only 1 in 3 people having the same level of understanding in Indonesia and Japan. 



That tracks with the fact that Nigerians have the highest level of crypto ownership, according to the survey. They blow the next highest owners out of the water, which are South Koreans and South Africans. 



Nigeria is also one of the few countries with an active CBDC program, and <a href="https://blockworks.co/news/cbdc-results-may-vary">its citizens haven’t been very receptive to the economic change</a>.



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Attitudes on crypto are geographically divided, ConsenSys survey finds

Casey Wagner

In Nigeria, the country&#8217;s Securities and Exchange Commission (SEC) has opened the door for tokenized asset exchanges, but crypto trading is yet to receive the greenlight.&nbsp;



President Muhammadu Buhari’s special assistant on digital and new media, Tolu Ogunlesi, announced on Twitter this week that the country has “formally approved blockchain use.”&nbsp;



Nigeria has historically limited access to crypto trading by restricting many centralized exchanges and bank access to crypto — which the <a href="https://www.cbn.gov.ng/Out/2021/CCD/Volume%203%20Number%202%20CBN%20Update%20February%202021.pdf" target="_blank" rel="noreferrer noopener">central bank</a> banned in 2021 — but there are some platforms available to residents.&nbsp;



<a href="https://blockworks.co/news/why-emerging-markets-are-leading-the-charge-on-cbdcs" target="_blank" rel="noreferrer noopener">Emerging markets have taken a unique interest</a> in cryptocurrencies in recent years in the face of economic distress, particularly with the development of central bank digital currencies.&nbsp;



Data provider <a href="https://es.statista.com/outlook/dmo/fintech/digital-assets/cryptocurrencies/nigeria" target="_blank" rel="noreferrer noopener">Statista</a> is calling for a 1% user penetration rate for cryptocurrency in Nigeria in 2023, and predicts this will go to 3% by 2027.&nbsp;



<figure class="wp-block-embed is-type-rich is-provider-twitter wp-block-embed-twitter"><div class="wp-block-embed__wrapper">
<blockquote class="twitter-tweet" data-width="550" data-dnt="true">BREAKING: The Federal Executive Council today approved <a href="https://twitter.com/FMoCDENigeria?ref_src=twsrc%5Etfw">@FMoCDENigeria</a>’s National Policy on Blockchain. What this means is that <a href="https://twitter.com/NigeriaGov?ref_src=twsrc%5Etfw">@NigeriaGov</a> has now formally approved blockchain use in Nigeria. Relevant agencies are now expected to develop appropriate usage &amp; regulatory frameworks.&mdash; tolu ogunlesi (@toluogunlesi) <a href="https://twitter.com/toluogunlesi/status/1653769481691299840?ref_src=twsrc%5Etfw">May 3, 2023</a></blockquote><script async src="https://platform.twitter.com/widgets.js" charset="utf-8"></script>
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“When the Turkish lira lost 40% of its value amidst hyperinflation in 2022, Turks turned to Bitcoin and USDT as a safe haven,” Bankless newsletter writer Donovan Choy said.&nbsp;



“The same is true for millions of desperate Venezuelans, Afghans, Argentinians, Ethiopians, or Nigerians whose ability to exit their hyperinflationary domestic currencies has been suppressed by Western financial sanctions or authoritarian local currency controls.”&nbsp;



Nigeria has historically been on the forefront of blockchain adoption. The nation launched its <a href="https://blockworks.co/news/nigeria-cbdc-push-limits-cash-withdrawals" target="_blank" rel="noreferrer noopener">eNaira CBDC pilot</a> in October 2021.



In December 2022, the country limited cash withdrawals in an effort to increase CBDC adoption and use of digital banking channels — a move met with <a href="https://www.theguardian.com/world/2023/feb/15/angry-protests-erupt-across-nigeria-against-scarcity-of-cash">riots</a> and protests in February.



“Customers should be encouraged to use alternative channels…to conduct their banking transactions,” the central bank said in a statement. Those include internet banking, mobile banking apps, debit cards and the country’s CBDC, the eNaira, among other means.



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Nigeria SEC Okays Tokenized Assets, but Crypto Will Have to Wait 

Bessie Liu

Countries are looking to build their own central bank digital currency — though results may vary. 



Roberto Campos Neto, president of Brazil’s central bank, said at BTG Pactual’s CEO Conference on Friday that the pilot for his country’s digital currency will “start right now.”



The project is likely to be ready for its rollout by December of this year.&nbsp;



Banks have been widely cooperative with the project, according to Campos Neto, who added that central bank digital currency (<a href="https://blockworks.co/tag/cbdc" target="_blank" rel="noreferrer noopener">CBDC</a>) implementation will allow each bank to individually issue the state-sanctioned digital asset.



Alongside the development of digital currencies, the Brazil banking head referred to two other prominent projects said to shape the future of finance: PIX, a fiat payments initiative, and <a href="https://ob-public-files.s3.amazonaws.com/20221003_Biannual_Report_OFB.pdf" target="_blank" rel="noreferrer noopener">Open Finance</a> — a project founded on the principle that customers should own their own financial data.



“I think these three things can change the history of financial intermediation in Brazil, transforming our system into something efficient and today in the world there is no one so advanced,” Campos Neto said.



In Japan — which has been notoriously strict on cryptocurrencies — the country’s central bank is planning to pilot its “digital yen” in April.



Proof of concepts will be executed in March to test feasibility and basic functionality, the Bank of Japan said in a <a href="https://www.boj.or.jp/en/paym/digital/dig230217b.pdf" target="_blank" rel="noreferrer noopener">statement</a>.



Private businesses and banks — including three of Japan’s largest banks — will participate in the trial. Transactions are set to to be simulated, meaning no actual retail and consumer transactions are designed to be made during the pilot.



“Whether to issue a CBDC should be decided by discussions among the Japanese public,” the Bank of Japan said. “With a view to facilitating such discussions, the [bank] will continue to make thorough preparations to respond to changes in circumstances in an appropriate manner.” 



Other CBC programs have fared quite differently. Nigeria’s CBDC program has been called “a dark experiment…with deadly consequences.”



<figure class="wp-block-embed is-type-rich is-provider-twitter wp-block-embed-twitter"><div class="wp-block-embed__wrapper">
<blockquote class="twitter-tweet" data-width="550" data-dnt="true">A very dark experiment is under way in Nigeria, with deadly consequences. Since October 2021, 99.5% of Nigerians have refused to use the central bank&#39;s digital currency, the so-called e-Naira, preferring to continue using cash. So what did the central bank do? It doubled down.&mdash; Nick Corbishley (@NickCorbishley) <a href="https://twitter.com/NickCorbishley/status/1626183018791464962?ref_src=twsrc%5Etfw">February 16, 2023</a></blockquote><script async src="https://platform.twitter.com/widgets.js" charset="utf-8"></script>
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The eNaira first launched in October 2021, meeting a chilly reception from Nigerians. It <a href="https://blockworks.co/news/cbdc-project-gives-private-players-unfair-advantage">hasn’t been the only hurdle</a> CBDCs around the world have gone up against.&nbsp;



After the country’s citizens <a href="https://blockworks.co/news/nigeria-cbdc-push-limits-cash-withdrawals">balked at adopting the eNaira and continued to use cash,</a> its central bank began to replace high denomination cash bills in the economy, Nick Corbishley, a financial journalist, <a href="https://twitter.com/nickcorbishley/status/1626183018791464962?s=46&amp;t=7Yb6Crzn9zFgNAGe5mcsNg" target="_blank" rel="noreferrer noopener">tweeted</a>. 



The sentiment led to businesses shuttering and angry protests, he said.



“Unless stopped in its tracks, this monetary experiment is coming to all of us, one way or another,” Corbishley tweeted.



About 114 countries <a href="https://blockworks.co/news/ukraine-bank-finds-stellar-blockchain-brings-key-advantages">have explored CBDCs</a>, according to Atlantic Council’s CBDC tracker. Eleven countries have fully implemented a digital currency, and 17 have CBDCs in the works.



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CBDCs Are Gaining Steam, Though Results May Vary

Sebastian Sinclair

The Central Bank of Nigeria is attempting to drum up the use of its central bank digital currency, or CBDC, by enforcing limits on the amount of cash citizens can withdraw from their local banks.



Nigeria’s central bank asked deposit banks and financial institutions to cap over-the-counter maximum cash withdrawals for individuals to $224 a week, in a <a href="https://www.cbn.gov.ng/Out/2022/CCD/RevisedCashWithdrawal.pdf" target="_blank" rel="noreferrer noopener">directive</a> issued on Tuesday, 



Corporate organizations&#8217; free withdrawals will also be limited to $1,154 per week, the bank said. Withdrawals above those limits will attract processing fees of 5% and 10% respectively. 



“Customers should be encouraged to use alternative channels…to conduct their banking transactions,” the bank said. Those include internet banking, mobile banking apps, debit cards and the country&#8217;s CBDC, the eNaira, among other means.



Central Bank Governor Godwin Emefiele conceded in October that his institution couldn’t account for the use of 85% of Nigeria’s cash in circulation, <a href="https://www.bloomberg.com/news/articles/2022-10-27/cash-clampdown-in-nigeria-seeks-to-curb-currency-hoarding-kidnappings" target="_blank" rel="noreferrer noopener">Bloomberg reported</a>. That, in effect, was jeopardizing monetary policy across the cash-hungry nation of Africa’s largest economy, he said at the time.



The West African nation has also struggled to deal with individuals hoarding cash as it attempts to counter illegal activity, including theft and kidnappings.



Under the directive, a $44 per day limit would apply to those individuals seeking to withdraw from ATMs while over-the-counter third-party checks exceeding $112 would not be accepted.



In rare circumstances, where individuals or organizations require cash for “legitimate” purposes, a limit of $11,226 and $22,452 will apply respectively.&nbsp;



Those will also be limited to one withdrawal per month and subject to rigorous identification and document requests including presenting a driver&#8217;s license and approval by the bank authorizing the withdrawal, among other things.



Nigeria became the first African nation to launch a retail central bank digital currency <a href="https://www.imf.org/en/News/Articles/2021/11/15/na111621-five-observations-on-nigerias-central-bank-digital-currency" target="_blank" rel="noreferrer noopener">in October 2021</a>, with a design aimed at complementing physical cash but not replacing it entirely.



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Nigeria Limits Cash Withdrawals in CBDC Push

<div id="highlights-block_628fba706c69f" class="highlights">
 <ul>
 <li>Emerging markets see potential in central bank digital currencies for increasing financial inclusion and decreasing cash dependency</li>
 <li>Infrastructure and privacy concerns continue to be top barriers</li>
 </ul>
 
</div>



With more than half of central banks worldwide working on digital currency initiatives, the US dollar-dominated payment network may in relatively short order become a thing of the past, according to the <a href="https://www.bis.org/publ/bppdf/bispap123.htm" target="_blank" rel="noreferrer noopener">Bank for International Settlements</a>.&nbsp;



Emerging markets are at the forefront of the central bank digital currency (CBDC) movement, industry leaders say, a trend attributed to these economies having more pressing, fundamental needs than those of more developed markets.&nbsp;



“Emerging economies appear to view CBDCs as a way to jump start their economies,” said Steve Aschettino, a Norton Rose Fulbright partner concentrating on fintech. “More-developed nations have existing and widely adopted electronic payment mechanisms already in place. While one may say this is an advantage, their existing payments technology can also serve as a barrier to the creation and broad adoption of a CBDC.”



Emerging markets looking into CBDCs have similar goals and motivations, the BIS said in a <a href="https://www.bis.org/publ/bppdf/bispap123_a_rh.pdf" target="_blank" rel="noreferrer noopener">report</a> earlier this month.&nbsp;



“Providing a cash-like digital means of payment, in light of reduced cash usage and an increase in private digital payment services, is the most common consideration,” the report said. “Other significant considerations include strengthening competition among payments service providers (PSPs), increasing efficiency and reducing the costs of financial services.”&nbsp;



<a href="https://cms.blockworks.co/jamaica-to-launch-cbdc-this-summer/" target="_blank" rel="noreferrer noopener">Jamaica</a>, Brazil, Nigeria and Haiti are among the countries currently looking into establishing or expanding CBDC pilots. For cash-driven economies such as Jamaica, CBDCs allow for cheaper, safer and more efficient transactions, Central Bank of Jamaica Governor Richard Byles said.&nbsp;



“If you can imagine what it costs a business, especially a high cash-volume business, to manage that cash: to keep it, to store it, to transport it — digital currencies get rid of all that,” Byles said in a recent interview.



CBDC infrastructure provider EMTECH has worked with the Bank of Ghana, the Central Bank of the Bahamas and the Central Bank of Nigeria on CBDC infrastructure projects in recent years. The company most recently partnered with HaitiPay, a Haitian fintech company, to demo a CBDC and fintech proof-of-concept in the region. The goal was to showcase the impact a CBDC can have on the Haitian economy, according to Carmelle Cadet, founder and CEO of EMTECH.  



“Being born and raised in Haiti, I have a view of how many people are unbanked and underbanked,” Cadet said. “When I discovered what blockchain was, I realized that there was a solution that could bypass where people are from and how much money they had and get them access to better financial resources.”&nbsp;



Although interest in digital currency has grown, most CBDCs are still in early pilot stages, and those that have progressed further are not yet widely used, said Kenneth Goodwin, director of regulatory and institutional affairs at Blockchain Intelligence Group. The Central Bank of the Bahamas’ Sand Dollar, which became the world’s first CBDC in 2020, has faced distribution issues, he said.



“I speak to John Rolle, who is the head of the Central Bank of the Bahamas, he&#8217;s not a big fan of the idea of all of this, quite frankly,” Goodwin said. “His job has become a lot more challenging because he&#8217;s taking this digital asset and trying to find a way to implement that into the system where they used to have a fiat currency.”&nbsp;



A huge benefit of CBDCs for central banks, Goodwin said, is the ability to better understand where — and how — people are spending. The transparency, of course, brings up privacy concerns as well.&nbsp;



“Anytime you digitize any platform, you&#8217;ll increase both cybersecurity risk and data privacy risk,” Goodwin said. “Data privacy is very, very key in terms of who owns the data, whether that data is being owned by the individual or is being owned by the central government, and that is a huge issue.”&nbsp;&nbsp;



Infrastructure is also a key concern, Aschettino said. Limited broadband access in many countries looking into CBDCs can significantly limit distribution, he said.&nbsp;



“These countries have to do a full assessment first to see that the citizens have access to the internet,” Goodwin said. “They&#8217;re going to have to do an assessment first and not get caught up with the technology, which is what often happens, they get caught up with the technology, but they don&#8217;t think about the infrastructure.”



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Why Emerging Markets Are Leading the Charge on CBDCs

<div id="highlights-block_61f7623b07be0" class="highlights">
 <ul>
 <li>Binance has restricted 281 Nigerian-based personal accounts</li>
 <li>Of those, around a third have been restricted at the request of international law enforcement.</li>
 </ul>
 
</div>



Binance, the world&#8217;s largest crypto exchange by trade volume, has restricted 281 personal Nigerian accounts with more than a third being at the behest of law enforcement.



In a <a href="https://www.binance.com/en-NG/blog/all/a-letter-from-our-ceo-to-nigerians--our-commitment-to-user-protection-421499824684903365" target="_blank" rel="noreferrer noopener">letter</a> on Saturday, Binance CEO Changpeng “CZ” Zhao said user security remained Binance&#8217;s &#8220;top priority&#8221; before citing that anti-money laundering measures and account restrictions were in place.



Around 79 other cases that were facing restrictions have been resolved while all non-law enforcement-related cases are expected to be resolved within two weeks. More Binance personnel are being deployed to expedite the matter CZ said. 



Of the 281 accounts, 38% have been restricted at the request of international law enforcement, the letter said.



<figure class="wp-block-embed is-type-rich is-provider-twitter wp-block-embed-twitter"><div class="wp-block-embed__wrapper">
<blockquote class="twitter-tweet" data-width="550" data-dnt="true"><a href="https://twitter.com/hashtag/boycottbinance?src=hash&amp;ref_src=twsrc%5Etfw">#boycottbinance</a> Binance is locking NIGERIAN accounts using P2P and related services. They locked plenty accounts already in Nigeria. My 5btc locked in binance. Use binance at ur own risk.<a href="https://twitter.com/hashtag/boycottbinance?src=hash&amp;ref_src=twsrc%5Etfw">#boycottbinance</a> <a href="https://twitter.com/hashtag/BinanceStopScamming?src=hash&amp;ref_src=twsrc%5Etfw">#BinanceStopScamming</a> <a href="https://twitter.com/hashtag/BINANCESTOPSCAMMINGNIGERIANS?src=hash&amp;ref_src=twsrc%5Etfw">#BINANCESTOPSCAMMINGNIGERIANS</a>&mdash; hoseaolu (@honetnetworks) <a href="https://twitter.com/honetnetworks/status/1487381321097830400?ref_src=twsrc%5Etfw">January 29, 2022</a></blockquote><script async src="https://platform.twitter.com/widgets.js" charset="utf-8"></script>
</div></figure>



Last week, users began complaining of issues on <a href="https://twitter.com/Sir_Dubem/status/1486281036812140552?s=20&amp;t=O2nCMRLRqxjEZfy9JszY0w" target="_blank" rel="noreferrer noopener">Twitter</a> revolving around Nigerian-based Binance accounts. #Binancestopscammingnigerians was seen trending before CZ responded with the letter.



In February of last year, Binance briefly suspended deposits in Nigerian naira following orders from the country central bank for local banks to close accounts linked to various cryptocurrency platforms.



Crypto is seen by many in the 190 million-strong population of Nigeria as a means to circumvent monetary controls and to serve the underbanked or unbanked. Crypto exchanges have, for quite a while, offered up a means to transact peer-to-peer at a time when more than half in the country are <a href="https://globalfindex.worldbank.org/sites/globalfindex/files/chapters/2017%20Findex%20full%20report_chapter2.pdf" target="_blank" rel="noreferrer noopener">unbanked</a>.







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