Regulatory Alerts2009-10-30 | BSD/DIR/GEN/CIR/03/027Revised CBN Anti-Money Laundering/Counter Terrorism Financing (AML/CFT) Manual, 2009 (Draft)
Financial institutions must be vigilant against money laundering and terrorist financing activities by identifying unusual or suspicious activities. Here is a list of "red flags" to help detect such activities, organized under the following categories: Customer Identification Program (CIP), Bank Secrecy Act (BSA) Reporting Requirements, Transaction Monitoring, Trade-Based Money Laundering, Lending Activity, and Terrorist Financing. Some of the key red flags include customers maintaining multiple accounts with no apparent business reason or large volumes of activity without a clear purpose. Additionally, trade-based money laundering can be identified by over/under invoicing of goods, inconsistent shipments, and lending activities such as loans secured by third parties. Finally, some "red flags" involve unusual or suspicious behaviors from employees exhibiting a lavish lifestyle that cannot be justified by their salary to embassy accounts funded through substantial currency transactions."