CBN (Administrative Sanctions) Regulations, 2018 Download

Extraordinary

Federal Republic of Nigeria
Official Gazette
No. 17 Vol. 105
Government Notice No. 1 Lagos-2nd February, 2018

The following is published as supplement to this Gazette:

S.I. No. Short Title Page
1 Central Bank of Nigeria Anti-Money Laundering and Combating the Financing of Terrorism (Administrative Sanctions) Regulations, 2018 B1-29

Printed and Published by The Federal Government Printer, Lagos, Nigeria FGP 14/022018/2,200 Annual Subscription from 1st January, 2018 is Local: N35,000.00 Overseas: N45,500.00 [Surface Mail] N69,500.00 [Second Class Air Mail]. Present issue ₩2,000.00 per copy. Subscribers who wish to obtain Gazette after 1st January should apply to the Federal Government Printer, Lagos for amended Subscriptions.

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MONEY LAUNDERING (PROHIBITION) ACT, 2011
(AS AMENDED)
CENTRAL BANK OF NIGERIA ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM (ADMINISTRATIVE SANCTIONS) REGULATIONS, 2018 Regulation:
ARRANGEMENT OF REGULATIONS
PART I-OBJECTIVES AND APPLICATION

1. Objectives.
2. Application.
   PART II-ADMINISTRATIVE SANCTIONS AND PENALTIES
3. Administrative sanctions.
4. Penalties.
5. Conditions for the imposition of administrative sanctions.
   PART III-CIRCUMSTANCES TO DETERMINE SANCTIONS TO APPLY
6. Determination of the nature and seriousness of contravention.
7. Conduct of the regulated financial institution or person concerned in
   its management after the contravention.
8. Previous record of the financial institution or person concerned in its
   management.
9. General considerations.
   PART IV-MISCELLANEOUS
10. Interpretation
11. Citation
    SCHEDULE

B 2

B 3
S. I. No. 1 of 2018
MONEY LAUNDERING (PROHIBITION) ACT, 2011
(AS AMENDED)
CENTRAL BANK OF NIGERIA ΑΝΤΙ-ΜΟΝEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM (ADMINISTRATIVE SANCTIONS) REGULATIONS, 2018 [1st Day of February, 2018] Commence- ment. In exercise of the powers conferred on me by section 23 (2) (e) of the Money Laundering (Prohibition) Act, 2011 (as amended) and all other powers enabling me in that behalf, I, ABUBAKAR MALAMI SAN, Attorney-General of the Federation and Minister of Justice make the following Regulations-
PART I-OBJECTIVES AND APPLICATION
1.-(1) These Regulations are made in furtherance of the Money Objectives. Laundering (Prohibition) Act, 2011 (as amended) and Central Bank of Nigeria (Anti-Money Laundering and Combating the Financing of Terrorism for Banks and Other Financial Institutions in Nigeria) Regulations, 2013. (2) These Regulations provide Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) compliance administrative sanctions regime for financial institutions under the supervisory purview of the Central Bank of Nigeria (CBN).
2. These Regulations shall apply to financial institutions under the Application.
supervisory purview of the CBN.
PART II-ADMINISTRATIVE SANCTIONS AND PENALTIES
3. From the commencement of these Regulations and subject to the Administrative
relevant provisions of the- Sanctions.
(a) Money Laundering (Prohibition) Act, 2011 (as amended); (b) Terrorism (Prevention) Act, 2011 (as amended); (c) Terrorism Prevention (Freezing of International Terrorists Funds and Other Related Measures) Regulations, 2013; and (d) Central Bank of Nigeria (Anti-Money Laundering and Combating the Financing of Terrorism for Banks and Other Financial Institutions in Nigeria) Regulations, 2013, the Central Bank of Nigeria shall apply the administrative sanctions and penalties for contravening the provisions of these Regulations by financial institutions under the supervisory purview of the CBN as set out under the
Schedule to these Regulations.

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Penalties.
Conditions of the imposition of administrative sanctions.
Determination of the nature and seriousness of contravention.
4. Without prejudice to the provisions of regulation 3 of these Regulations,
the penalties that the CBN shall apply for contraventions of the- (a) Money Laundering (Prohibition) Act, 2011 (as amended); (b) Terrorism (Prevention) Act, 2011 (as amended); (c) Terrorism Prevention (Freezing of International Terrorists Funds and Other Related Measures) Regulations, 2013; and (d) Central Bank of Nigeria (Anti-Money Laundering and Combating the Financing of Terrorism for Banks and Other Financial Institutions in Nigeria) Regulations, 2013, shall include administrative sanctions and penalties as listed out under the
Schedule to these Regulations.
5.-(1) The administrative sanctions under these Regulations shall be imposed consequent upon- (a) the examination of a financial institution and observance of contraventions by CBN Examiners; or (b) the recommendation of relevant agencies. (2) In determining the sanctions to apply, all the circumstances of the case shall be taken into account including the nature and seriousness of the contravention, conduct of the regulated financial institution or person concerned in its management after the contravention, previous record of the financial institution or person concerned and other general considerations.
PART III-CIRCUMSTANCES TO DETERMINE SANCTIONS TO APPLY
6. In determining the nature and seriousness of any contravention
observed, the CBN shall consider-
(a) whether the contravention was deliberate, dishonest or reckless; (b) the duration and frequency of the contravention; (c) the amount of any benefit gained or loss avoided due to the contravention; (d) whether the contravention reveals serious or systemic weaknesses of the management systems or internal rules relating to all or part of the business; (e) the nature and extent of any money Laundering or financing of terrorism crime facilitated, occasioned or otherwise attributable to the contravention; (f) whether there are a number of smaller issues, which individually may not justify administrative sanction, but would apply when taken collectively; and

(g) any potential or pending criminal proceedings in respect of the contravention which may be prejudiced or barred where a penalty is imposed pursuant to the Schedule to these Regulations.
7. In considering the conduct of the regulated financial institution or
person concerned in its management after the contravention, the CBN shall consider- B5 Conduct of the regulated financial institution or person concerned in its management after the contravention. (a) how quickly, efficiently and effectively the financial institution or person concerned in its management brought the contravention to the attention of the CBN or any other relevant regulatory authority; (b) the degree of co-operation with CBN examiners or other supervisory agency during the examination; (c) any remedial step taken when the contravention was identified, including disciplinary action taken against the staff involved, where appropriate, addressing any systemic failure and taking action designed to ensure that similar problem do not arise in the future; (a) the likelihood that the same type of contravention will reoccur where no administrative sanction is imposed; and (e) whether the contravention was admitted or denied.
8. In considering the previous record of the financial institution or person
concerned in its management; the CBN shall consider- Previous record of the financial institution or person concerned in its management. (a) whether it has taken any previous action resulting in a settlement, sanction or whether there were relevant previous criminal conviction; (b) whether the financial institution or person concerned in its management has previously been requested to take remedial action; and (c) the general compliance history of the institution or person.
9. (1) In addition to the provisions of regulations 6, 7 and 8 of these General
Regulations, the CBN shall consider- considerations.
(a) the prevalence of the contravention;
(b) the action taken by it in previous similar cases; and (c) any other relevant consideration. (2) Where the Board, a director or officer responsible for ensuring compliance with any relevant provision of these Regulations has been penalized in three consecutive examination cycles and the breach continues, the CBN may suspend or remove the Board, director, or officer of that institution. (3) The bank shall disclose in detail the penalty paid as a result of the contravention in its published Annual Report.

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Interpretation.
PART IV-MISCELLANEOUS
10. In these Regulations----
"beneficial owner" means-
(a) the natural person who ultimately owns or controls a customer; (b) the natural person on whose behalf a transaction is being conducted; and (c) a person who exercises ultimate effective control over a legal person or arrangement; "business relationship" means a business, professional or commercial relationship between a relevant person and a customer, which is expected by the relevant person, at the time when contact is established, to have an element of duration; "cash" means notes, coins or travellers' cheques in any currency; "control" means a power under the trust instrument or by law, whether exercisable alone, jointly with another person or with the consent of another person, to- (a) dispose of, advance, lend, invest, pay or apply trust property; (b) vary the trust; (c) add or remove a person as a beneficiary or to or from a class of beneficiaries; (d) appoint or remove trustees; or (e) direct, withhold consent to or veto the exercise of a power such as is mentioned in paragraphs (a), (b), (c) or (d). "Customer due diligence measures" means (a) identifying the customer and verifying the customer's identity on the basis of documents, data or information obtained from a reliable and independent source; (b) identifying, where there is a beneficial owner who is not the customer, the beneficial owner and taking adequate measures, on a risk-sensitive basis, to verify his identity so that the relevant person is satisfied that he knows who the beneficial owner is, including, in the case of a legal person, trust or similar legal arrangement, measures to understand the ownership and control structure of the person, trust or arrangement; and (c) obtaining information on the purpose and intended nature of the business relationship. "Financial Institution" include banks, body corporates, associations or group of persons, whether corporate or incorporate which carries on the business of investment and securities, a discount house, insurance institution,

B7 debt factorization and conversion firm, bureau de change, finance company, money brokerage firm whose principal business includes factoring, project financing, equipment leasing, debt administration, fund management, private ledger service, investment management, local purchase order financing, export finance, project consultancy, financial consultancy, pension funds management and such other business as the Central Bank or other appropriate regulatory authorities may from time to time designate; "money laundering" is as defined in the Money Laundering Prohibition Act, 2011 (as amended); "politically exposed person" has the meaning given to it under the Money Laundering (Prohibition) Act, 2011 (as amended) and the Terrorism (Prevention) Act, 2011 (as amended); "shell Company" means an incorporated company that possesses no significant asset and does not perform any significant operations; and "terrorist financing" means an offence under Part II of the Terrorism (Prevention) Act, 2011.
11. These Regulations may be cited as the Central Bank of Nigeria Citation.
Anti-Money Laundering and Combating the Financing of Terrorism (Administrative Sanctions) Regulations, 2018.

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[Regulations 3, 4, 5 and 6]
SCHEDULE
ADMINISTRATIVE SANCTIONS AND PENALTIES
A. CORPORATE GOVERNANCE AND ROLE OF THE BOARD/MANAGEMENT S/No. Required Action Infraction Administrative Sanction/Penalty Administrative Sanction/Penalty Deposit Money Banks Other Financial Institutions (DMBs) (OFIs)

1. AML/CFT programme * Failure to establish A minimum penalty as follows: A minimum penalty on the Other Financial
   that clearly outlines the written AML/CFT * N20million on the Deposit Institutions (OFI) as follows:
   AML/CFT policies and policies and Money Bank (DMB). * N300,000-Unit Micro Finance Bank procedures of the procedures. (MFB). institution. * N500,000 - Finance Company (FC)/ Bureau De Change (BDC)/State MFB.

• NImillion - State Primary Mortgage
  Bank (PMB)/National MFB.
• N5million - National PMB.

2. Approval of written * Failure to approve the A minimum penalty as follows: A minimum penalty each on each member
   AML/CFT policies and AML/CFT policies and * NImillion on each member of the of the Board as follows:
   procedures. procedures. Board. * N200,000-Unit MFB

• N20million on the DMB. * ₩300,000-FC/BDC/State MFB
• N500,000 - State PMB/National MFB
• N1million-National PMB
  A minimum penalty on the OFI as follows:
• N300.000 - Unit MFB
• N500,000-FC/BDC/State MFB
• Nimillion- State PMB/National MFB
• N5million - National PMB

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3. Periodic review and * Failure to review/ A minimum penalty as follows: A minimum penalty on the Chief
update of the AML/ update the AML/CFT * N750,000 on the Executive Compliance Officer as follows:
CFT policies and policies and Compliance Officer in the first * N100,000 - Unit MFB procedures at least procedures at least instance and N750,000 for each * N200,000-FC/BDC/State MFB every three (3) years. every three (3) years. year that the contravention * N300,000-State PMB/National continues. MFB-

• N500,000 on the Chief * N500,000 National PMB
  Compliance Officer in the first instance and N500,000 for each A minimum penalty on the OFI in the year that the contravention first instance as follows:
  continues. * N300,000- Unit MFB
• N5million on the bank in the first * N500,000-FC/BDC/State MFB
  instance and N1,000,000 for each Nimillion State PMB/National year that the contravention MFB continues. * National PMB-N2million. A minimum penalty on the OFI for each day the contravention continues as follows:
• N10,000-Unit MFB
• N20,000-FC/BDC/State MFB
• N50,000-PMB/National MFB.

4. Communication of the * Failure to A minimum penalty as follows: A minimum penalty on the Chief
   AML/CFT program communicate the * N750,000 on the Executive Compliance Officer as follows:
   across the institution AML/CFT program Compliance Officer. * N100,000-Unit MFB. and ensuring that it is of the organization to * N500,000 on the Chief * N300,000-FC/BDC/State MFB. effectively employees. Compliance Officer. * N500.000-PMB/National MFB. implemented. * N10million on the DMB. A minimum penalty on the OFI as follows:
   N300,000-Unit MFB.

• N500,000-BDC/FC/State MFB.
• N1million State PMB/National
  MFB.
• N3million-National PMB.

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5. Supervision of * Failure of the Board A minimum penalty as follows: A minimum penalty on each member of
implementation of the or its Committee to * N500,000 on each member of the Board as follows:
AML/CFT program, supervise and ensure the Board. * ₩100,000-Unit MFB. risk management and the effective * N10million on the DMB. * N300,000-FC/BDC/State MFB. reporting requirements implementation of the * N500,000-PMB/National MFB. by the Board. AML/CFT program. A minimum penalty on the OFI as follows:

• ₩300,000-Unit MFB
• N500,000-BDC/FC/State MFB
• Nlmillion State PMB/National
  MFB
• N3million ---National PMB

6. Receive, review and * Failure of the Board A minimum penalty as follows: A minimum penalty on each member
   provide feedback on to review and * N500,000 on each member of of the Board as follows:
   periodic reports on provide feedback to the Board. * N100,000-Unit MFB AML/CFT issues Management on * N5million on the DMB. * N300,000-FC/BDC/State MFB submitted by senior reports that it * N500,000-PMB/National MFB. management. receives on AML/ A minimum penalty on the OFI As CFT issues. follows:

• N300,000-Unit MFB
• N500,000-BDC/FC/State MFB
  *N1million-State PMB/National MFB
• N3million-National PMB

7. Generate periodic * Failure of the Officer * A minimum penalty as follows: A minimum penalty on the Chief
   reports on AML/CFT to generate periodic N750,000 on the Executive Compliance Officer as follows:
   issues to the Board or reports on AML/CFT Compliance Officer. * ₩100,000-Unit MFB its relevant issues to the Board * 500,000 on the Chief * N300,000-FC/BDC/State MFB Committee(s). or its relevant Compliance Officer. * N500,000-PMB/National MFB. Committee. * N5million on the DMB.

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8. Formulation and * Failure to formulate A minimum penalty ofN5million on A minimum penalty on the OFI as
issuance of Code of issue and ensure the the DMB. follows:
Conduct/Ethics to staff observance of a Code of * N300,000-Unit MFB- that include observance conduct/ethics that * N500,000-BDC/FC/State MFB of ethical requirements includes AML/CFT by * NImillion State PMB/National relating to AML/CFT. staff. MFB-

• N2million-National PMB

9. Put in place *Failures to put in place A minimum penalty ofN5million A minimum penalty on the OFI as
   management an information systems on the DMB. follows:
   information system to to monitor, detect, *N300,000-Unit MFB monitor, detect, analyze analyze and generate * N500,000-BDC/FC/State MFB and generate reports on reports on suspicious *N1million-State PMB/National MFB suspicious transactions. transactions. * N2million-National PMB B. RISK MANAGEMENT:
   Required Action Offence Sanction/Penalty Sanction/Penalty DMBS OFIs
10. Embedding of ML/TF * Failure to recognize A minimum penalty of N5 million A minimum penalty on the OFI in the
    Risks in overall Risk ML/TF risks in the Risk on the DMB in the first instance first instance as follows:
    Management Management Framework. and 1 million for each year that the * ₩300,000 - Unit MFB Framework of the contravention continues. * N500,000- FC/BDC/State MFB financial institution. * Nimillion State PMB/National MFB. *N2million-National PMB

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11. Put in place ML/TF * Failure to classify ML/ * A minimum of 1 million on the A minimum penalty on the OFI for
risk classification TF risk in the bank. Chief Risk Officer of the DMB. each year the contravention system. * Failure to put in place continues as follows:
guidelines for risk N200,000-Unit MFB. assessment and N500,000-FC/BDC/State MFB. profiling of N1million-PMB/National MFB. customers in the A minimum penalty on the Managing institutions' AML/ Director or the Head of Risk CFT board approved Management of the OFI as follows:
program. * N100,000- Unit MFB.

• Failure to carry out risk * N300,000-FC/BDC/State MFB.
  assessment and * N500,000-PMB/National MFB. profiling of each A minimum penalty on the OFI for account. failure to put in place guidelines for risk assessment and profiling of customers in the AML/CFT program as follows:
• N300,000 - Unit MFB.
• A minimum penalty of * N500,000-FC/BDC/State MFB.
  N3million on the DMB for Nimillion - State PMB/National failure to put in place MFB. guidelines for risk assessment * N2million-National PMB. and profiling of customers in the AML/CFT program.
• A minimum of 100,000 per A minimum penalty per account on the
  account for failure to carry out OFI for failure to carry out risk risk assessment and profiling assessment of the account, as follows:
  of the account. N20,000-Unit MFB.
  N30,000-FC/BDC.
  N50,000-State/National MFB/PMB.

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12. Put in place policy for * Non-existence of policy A minimum penalty as follows: A minimum penalty on each member
the prohibition of on prohibition of * NImillion on each member of of the Board as follows:
numbered accounts, numbered the Board * N100,000-Unit MFB anonymous accounts, anonymous accounts, * N15million on the DMB. * N300,000-FC/BDC/State MFB or accounts in fictitious accounts in fictitious * N500,000-PMB/National MFB. names and shell names, and shell A minimum penalty on the OFI as companies. companies, from doing follows:
business with the bank. * N300,000-Unit MFB

• N500,000-BDC/FC/State MFB.
• N1million State PMB/National
  MFB
• N3million-National PMB

13. Establishment of * Failure to establish A minimum penalty of A minimum penalty on the OFI as
    screening mechanism screening mechanism N15million on the DMB. follows:- for PEPS, UN sanctioned for PEPS, UN * N300,000-Unit MFB persons/entities list, sanctioned persons/ * N500,000-BDC/FC/State MFB other official lists, and entities list, other * NImillion - State PMB/National internally generated lists official lists, and MFB- of high risk customers. internally generated * N3million-National PMB. lists of high risk customers.
14. Consideration of ML/TF * Failure of the Board A minimum penalty of N2million A minimum penalty on the OFI as
    risks in approving and Management to on the DMB. follows:
    expansion of business consider and * ₩100,000-Unit MFB. e.g. new branches, and document ML/TF risks * N200,000-BDC/FC/State MFB. markets (domestic and as part of the approval * N300,000- State PMB/National foreign), new products/ process for the MFB. services. expansion of business * N500,000-National PMB. (including introduction of new products and services).

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C. POLICIES AND PROCEDURES ON CUSTOMER DUE DILLIGENCE (CDD):
Sanction/Penalty Sanction/Penalty
Required Action Offence DMBS OFIs
15. Establishment of written * Failure to establish A minimum monetary penalty as A minimum penalty on each member
and Board-approved written policies and follows: of the Board as follows:
policies and procedures procedures on CDD/ * Nlmillion on each member of the * N100,000- Unit MFB on CDD/KYC KYC requirements. Board. * ₩200,000-BDC/FC/State MFB requirements. * N15million on the DMB. * N300,000 State PMB/National

• Where the contravention MFB
  persists after three consecutive * N500,000-National PMB. penalties, the Board may be suspended or removed.

16. Implementation of * Failure to implement A minimum of 1,250,000 on the A minimum penalty on the Chief
    AML/CFT policies and AML/CFT policies and Executive Compliance Officer Compliance Officer as follows:
    procedures in all procedures in all A minimum penalty of ₩1,000,000 *N100,000- Unit MFB branches including, branches (including on the Chief Compliance Officer. *N200,000-FC/BDC/State MFB foreign branches and foreign branches and A minimum penalty of++20million * N500,000-PMB/National MFB. subsidiaries, if subsidiary). on the DMB. A minimum penalty on the OFI as applicable. follows:

• N300,000-Unit MFB
• N500,000-BDC/FC/State MFB
• Nimillion State PMB/National
  MFB
• N3million-National PMB.

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17. Implementation of CDD * Failure to implement * A minimum of N750,000 on the A minimum penalty on the Chief
measures for Customer CDD measures for Executive Compliance Officer. Compliance Officer as follows:
Identification (whether Customer * A minimum penalty of 500,000 * ₩100,000 - Unit MFB. permanent or Identification. on the Chief Compliance Officer. * N200,000-FC/BDC/State MFB. occasional, natural or * A minimum penalty of 1million * N300,000-PMB/National MFB. legal persons, or legal per customer.

• N500,000 National PMB
  arrangements, etc.).

18. Implementation of * Failure to implement * A minimum of N750,000 on the A minimum penalty on the Chief
    CDD measures for CDD measures for Executive Compliance Officer. Compliance Officer as follows:
    Verification of Verification of * A minimum penalty of¥500,000 *N100,000- Unit MFB Customer Customer on the Chief Compliance Officer. *₩200,000- FC/BDC/State MFB- Identification using Identification. * A minimum penalty of 1 million * N300,000-PMB/National MFB. reliable, independent per customer. A minimum penalty on the OFI as source documents, follows:
    data or information. * N300,000-Unit MFB-
    *N500,000-BDC/FC/State MFB-
    *N1million-National MFB/State PMB

• N3million-National PMB.

19. Obtain information on * Failure to obtain * A minimum penalty of1,250,000 A minimum penalty on the Chief
    the beneficial owner of information on the on the Executive Compliance Compliance Officer as follows:
    accounts, where a beneficial owner Officer. *N200,000- Unit MFB. customer is an * A minimum penalty of N1million *N300,000-FC/BDC/State MFB. intermediary or on the Chief Compliance Officer; * N500,000-PMB/National MFB. authorized representative * A minimum penalty of1million of another party, including per customer.

B 16 but not limited to the following information listed in Regulation 15 of CBN AML/CFT Regulations, 2013:
(a) Legal relationship and authority, such as evidence of assignment, power of attorney, resolution and similar mandates. (b) Information on the source of funds/wealth of the ultimate beneficial owner. (c)Identity of management and principal owners/ controllers of a company being represented. A minimum penalty on the OFI as follows:

• N300,000-Unit MFB
  *N500,000-BDC/FC/State MFB
• N1million- National MFB/State
  PMB
• N3million-National PMB.

(a) Similar information on the procedure for acceptance of individual customers.
20. Classification of * Failure to classify * A minimum penalty of₩750,000
customers into customers into on the Executive Compliance designated risk designated risk Officer. categories and apply categories and apply * A minimum penalty ofN500,000 customer due diligence customer due diligence on the Chief Compliance Officer; CDD accordingly. (CDD) accordingly. * A minimum penalty ofN7million on the DMB

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A minimum penalty on the OFI as follows:-
*N300,000-Unit MFB

• N500,000-BDC/FC/State MFB
  *NImillion-National MFB/State PMB
• N3million - National PMB
  D. POLICIES AND PROCEDURES ON MAINTENANCE OF RECORDS:
  Required Action Offence Sanction/Penalty Sanction/Penalty DMBS OFIs

21. Maintenance of CDD * Failure to maintain A minimum penalty of 10million A minimum penalty on the OFI as follows:
    and transaction records obtained on the DMB. * N300,000-Unit MFB records (in electronic/ through CDD *N500,000-BDC/FC/State MFB- paper form, onsite/ measures and *N1million-National MFB/State PMB- offsite storage) for at transaction records * N3million - National PMB. least 5 years. for at least 5 years after cessation of relation-ship in hard and soft copies.
22. Establish a record * Failure to establish a A minimum penalty of N5million on A minimum penalty on the OFI as follows:
    keeping system that is record-keeping system the DMB. * N200,000-Unit MFB easy to retrieve on a that facilitates easy * N300,000-BDC/FC/State MFB timely basis. retrieval of records on * N500,000- National MFB/State PMB a timely basis * N1million - National PMB.

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E. MONITORING OF SUSPICIOUS TRANSACTION REPORTING Required Action Reporting Offence Sanction/Penalty Sanction/Penalty DMBS OFls
23. Maintenance of an * Failure to maintain an A minimum penalty of 10million A minimum penalty on the OFI as
internal system internal system for on the DMB. follows:
(automated/manual) for detecting and * N200,000- Unit MFB. detecting and reporting reporting unusual and * N500,000-BDC/FC/State MFB. unusual and suspicious suspicious activities. * N1million-National MFB/State activities. PMB.

• N2million - National PMB.

24. Rendition of Suspicious * Failure to render * A minimum penalty as follows: A minimum penalty on the Chief
    transaction reports to report on suspicious * N2,500,000 on the Executive Compliance Officer as follows:
    relevant authorities. transactions to the Compliance Officer: * ₩200,000 - Unit MFB NFIU. * N2,000,000 on the Chief * N300,000-FC/BDC/State MFB. Compliance Officer. * N500,000-PMB/National MFB.

• N20million on the DMB.

25. Rendition of other AML/ * Failure to render AML/ * A minimum penalty as follows