THE NEED FOR EFFECTIVE LEADERSHIP IN COMBATING FINANCIAL CRIME IN THE AFRICAN UNION CONTINENTAL FREE TRADE ZONE AREA

Assessing The Impacts of Financial Crime To Africa Trade Development Agenda Page 1

FOREWORD
he Need for Effective Leadership is to Promote the fight against Financial Crime in Africa and help
to advance Africa Trade Development Agenda
Financial Crime is a major African problem, and combating it requires effective leadership at
all levels.
Africa remains at high risk of Financial Crime distress, and the risks have risen in the context of recent
large fiscal deficits...
All sectors of African’s Leadership must either act now or never! African Leaders often say that criminal
activities are like a lifestyle in the African’s continent: but if left undealt with, the consequences will have
adverse effect and will destroy the economic development of Africa and lessen the trust in our Public and
Private Institutions. Similarly, leaders must build up effective Political governance within their institutions,
the Will and capacity needed to crack down on Financial Crime agents or agencies in the areas of Money
Laundering, Counter Terrorism Financing, Fraud, Drug deals, Bribery and Corruption and smugglers, why?
Because these criminals have a lot of criminal strategies to evade our African Territories – for example, if
they are restricted in the land routes – they would use sea routes- when they are restricted on the seas they use
the air. That’s why targeted interventions often have limited impact on Financial Crime and criminal
activities in Africa: we need to look at the Leadership capacities and effectiveness in pursing the African
Continental Free Trade Zone Area agenda as a big picture, besides the good initiatives and benefits therein it
also has negative sides effect of its to tell the whole story of how the criminals are moving on Roads, Seas and
air (aviation industry), and the poor border crossing security Agencies of Nations in Africa. This Book intends
to tell the story of the poor suffering African’s people with few livelihood options. It is a complex story, with
many interconnections; at the heart of which the African Continental Free Trade Zone area lies. While Africa
has spread a plethora of beneficial innovations around the world, it has also had many negative consequences
in both large and small countries through illicit financial outflows: in fact, security problems in the entire
nations of Africa are closely related to the development challenges posed by the Money Laundered to finance
Terrorism and Civil Conflicts of Africa. Though the side effects of Financial Crime are particularly strong in
the African’s poorest countries those least equipped to respond to these impacts are more vulnerable.
This Book looks at how the role of effective Leadership contributes in the fight beyond specific countries
Against Financial Crime and illicit financial flows (fin-iffs) in the African region. The Book zeroed in on
Financial Crime, illicit Financial Flows, like Money Laundering, Bribery and Corruption and illicit trade to
illustrate the larger scale and the need for effectiveness of African Leaders to combat this menaced: criminal
activity is a source of Financial Crime that has a direct relationship to effective Leadership and the dangers it
poses for good governance and delivery of social services in Africa. This nexus has received little scholastic
attention, yet criminal activity continues to pose negative impact on National development in Africa that
hamper effective governance.
T

Why focus on the Leadership of Africa Continental Free Trade Zone Area?
Several countries in the African continent are suffering from extremely low development indicators because
of weak state leaders and their institutions hence the present capacity gaps for developing effective and
efficient regulations to combat Financial Crime. As in many developing countries, a large share of
uncontrollable economic activity takes place in the informal economy. Not everything informal is bad: in fact,
the informal sector often provides precious livelihoods, particularly for the poor. Yet what happens informally
happens outside the checks and balances of regulatory systems. As a result, Financial Crime activities like
illicit or criminal activities are allowed to flourish more easily, with negative implications for good
governance, Educational infrastructure, Health Services, Good Roads, Youth Employment, Agricultural,
Peace, stability and development. Under these conditions, resource diversion and other illegal acts that affect
a country’s development easily thrive, and damage the integrity of institutions, and distort political
governance in ways that disrupt the relationship between citizens and the state thereby put unnecessary
pressure on state leaders. Across the region, Financial Crime and illicit financial flows are known to have
resourced violent and protracted conflicts due to poor leadership and ineffective monitoring; in the sahel, they
resource terrorist groups. Although it is impossible to isolate specific conditions leading directly to criminal
activity, structural factors (such as high unemployment and income inequality, exposure to violence, low
levels of gross domestic product and weak institutional capacities and ineffective leadership) are known to
contribute to a country’s vulnerability. This Book feeds into a strategy of fighting financial Crime and illicit
Financial Flows in the African Continental Free Trade Zone Area (AfCFTA,) mandated with the development
for co-operation to increase the capacity and effectiveness of African Leaders with issues-based evidence in
the area of addressing the risks they pose to National development and insecurity. This strategy started with
the publication of Financial Crime advocacy tool for developing countries: measuring the African Continental
Free Trade Zone Area responses. Looking at some researched and publications work done, and in the process
the Author have discovered that none has written on the Need for Effectiveness of Leadership in Combating
Financial Crime and yet the magnitude of the problem remained wider and broader that needs additional
research work that begs the need for this Book.
The Effective Leadership is a framework for Africa Continental Free Trade Zone Area member countries to
increase their investigations and repatriations of stolen assets to their countries of origin, to do that needs
effective leadership driven concept and that is what this new Book is all about, to reduce the negative impact
of Financial Crime to National Development in Africa Countries and to focus on preventing Financial Crime
and illicit financial flows.
The Book also contributed to a new way of understanding the Impact of Financial Crime and illicit financial
flows for National Development as reflected in the 2030 agenda for sustainable development which
acknowledges Financial Crime and illicit financial flows as inherently linked to hamper development. The
overarching message is timeless: resolving some of the African’s most pressing problems, in this instance
Financial Crime and illicit financial flows, requires responding to development challenges, and working in
countries at all levels of development to address each part of the spectrum – source, transit and destination.
Tackling African challenges requires reforms to happen on all sides.
………………………………………

By Prof. Rudolph Q. Kwanue
Founder, Chancellor and International Director
Rudolph Kwanue University College
Grace Theology Seminary
Monrovia the Republic of Liberia

ACKNOWLEDGEMENTS
The Author acknowledged the valuable partnership with the Rudolph Kwanue University College (RKUC) in
the Capital City of Monrovia Republic of Liberia (RKUC www.rkuclr.com) Africa Union University (AUU
www.auuni.org), IUB University Benin Republic www.iubuniersity.org, E-FOUR and AAF consulting Firm
Lagos, Nigeria. www.e-four-aaf.com, UCCAST University Uganda. International Kingdom-University-USA.
www.ikuniversity.info and the Inter-Governmental Action Group against Money Laundering in Africa
(IGAG), the Africa Union Continental Free Trade Zone (AfCFTA,) and the World Bank. The production of
this Book was initiated by Eliva Press Publication House in Europe, and drawn to a conclusion by Professor
Rudolph Q. Kwanue Sr. Founder, Chancellor and International Director Rudolph Kwanue University College-
Liberia and Grace Theological Seminary working on fighting against Financial Crime in Co-operation with E-
FOUR and AAF Consulting Firm Lagos Nigeria that specialized on Financial Crime, Money Laundering and
Illicit Financial Flows and in advancing the Policy Division of CBN, BSL AfCFTA etc. The Book is
authored by Professor Paul Allieu Kamara a Professional Training Expert on the Need for Effective
Leadership in Combating Financial Crime with the E-Four and AAF Consulting Firm 106, Ikorodu-Ososun
Road, Second Floor at the Right, Fadeyi, Lagos, Nigeria. Email: admin@efour-aaf.com ehieric@efour-
aaf.com. Edited by Prof. Ehi Eric Esoimeme, Chief Editor, E-FOUR and AAF Consulting Firm and Prof.
Rudolph Q. Kwanue Founder, Chancellor and International Director, Rudolph Kwanue College,
Grace Theology Seminary Monrovia the Republic of Liberia, Reza Indian, Prof. Yvonne Bentley
Founder International Kingdom University-USA, and Several Researched work has been taken from
prepared case studies ( published works as papers) and provided the background data for this Book: Financial
Crime and Illicit Financial Flows; Bribery and Corruption and Human smuggling from Africa to Europe –
Illicit narcotics transiting agencies, CBN, NFTIU, FMTI, SCUML, NAICOM, SEC, NCS, NDIC, NFP,
GIABA, CAPARR, CoDA, PALU * The author would like to dedicate this book to all the Suffering People of
Africa as one of the foremost authorities suffering from illicit economies in Africa and the invaluable resource
over the course of this research work, both in person and through our vast collection of scholarly and policy
works. I would like to thank the different peer reviewers who provided expertise at different stages of a
rigorous Ms. Kinniga Ngaima, Faith, Vincent, Millicent Samuel, Dr. Abass Moses Kamara, Joseph T.
Kamara, Mrs. Alima Divine Kamara, Sia Kamara, Paul Umura Bangura

Introduction........................................................................................................................
 What is at stake in the African Continental Free Trade Zone Area?
 About three-fifths of global trade is conducted within multinationals.
 Offshore tax shelters
 Unconscionable acts
 Information scanty and scattered
 Financial crime linked to Nigeria
Chapter 1.Overview.............................................................................................................
I. What is Africa Continent?
 What type of country is Africa?
 What is Union?
 What is Continent?
 What is Free?
 What is Trade?
 What is Zone?
 What is Area?
 What is Financial Crime?
 What is a Shell Corporation?
 Characteristics of Shell Corporations
 Shell Corporations Defined
 What is African Continental Free Trade Zone area is all about?
 What is The AfCTFA?
 Objectives
 Why is this Book looking at Financial Crime, criminal economies and illicit financial
flows in Africa?
 Who Commit this Crimes
 From Illegal activities
 IFFS
 Financial Crime
 Demystification of Financial Crime chronologically
 Financial Crime
 Bribery
 Fraud
 Measures Against Financial Crime
 Featured Agencies
 Provide helpful Legal advice
 Why working together

 WHY LOOK AT FINANCIAL CRIME, CRIMINAL ECONOMIES AND ILLICIT
FINANCIAL FLOWS IN AFRICA?
 THE IMPACT OF FINANCIAL CRIME
 Financial crime linked to Nigeria
 Organized crime:

Chapter Two
1. Why the Need for Effective Leadership in Africa?
 What is Leadership
 Typology of Leadership we need in the African Continent
 All Leaders has different styles
2. Is there a leader in Africa that is communicating effectively or engaging others by being a good
listener
3. What are the Limits of traditional Management styles
4. What is the impact of this new approach to leadership in Africa
5. What is the 5 set-up of Leadership for success
6. Why effective Leadership is so important
7. Characteristics of an effective leader
 Ability to influence others
8. Transparency to an extent
9. Encourage Risk-Taking and innovation
10. Integrity and Accountability
11. Act decisively
12. Continuously assess and Reassess your Leadership approach
13. Assessing your strength
14. Link between effective Leadership and Combating Financial Crime
 The African Continental Free Trade Zone Area
 Basic
15. Development and Demographic looks of Africa
16. Urbanization of the Total Population of African 1950-2010
17. Projection of the total population of African 2020-2050
18. Rapid Population growth
19. High poverty levels
20. Economy and Trade

Chapter 3. Criminal economies and illicit financial flows in Africa Introduction
1. development framework for analyzing harm
2. Towards a prioritization framework
3. Illegal activities
4. Illicit trade in “normally legal” goods
5. Illicit resource extraction
6. The prioritization framework applied to case studies
Chapter 4. Conclusions and Introduction
1. Main findings and conclusions
2. Common development principles should guide IFF responses
3. Policy areas for further work
4. Annex A. Research
5. Methodology
6. Methodology
7. Quantitative research
8. Calculating the scale of internal and external illicit flows
7. Caveats Reference groups and peer-review process

TABLE OF CONTENTS
1. ILLICIT FINANCIAL FLOWS: THE ECONOMY OF ILLICIT TRADE IN AFRICA © OECD
2018
2. Tables Table 1.1. Typology of criminal economies
3. Tables 2.1. HDI ranking in 2016 (out of 187)
4. Table 2.3. AU states ranked according to various indices
5. Table 2.4. Performance on indicators of global competitiveness for some AU countries, 2015-16
6. 2.5. Selected conflicts in Africa.
7. Table 2.6. Selection of regional mechanisms to counter criminal economies and IFFs
8. Table 2.7. Status of AU countries in regard to relevant international conventions
9. Table 2.8. Legislation enacted to combat money laundering and terrorist financing
10. Table 2.9. Number of STRs filed and actions taken in response, 2013
11. Table 3.1. Estimates of all cocaine-related profits laundered in 2009
12. Table 3.2. Gross domestic product in 2009
13. Table 3.3. Status of cybersecurity laws in AU countries
14. Table 3.4. Typology of the organization of trafficking in persons
15. Table 3.5. Anatomy of a typical large-scale oil-theft operation
16. Table 3.6. Sample of alleged protection payments by oil thieves
17. Table 3.7. Customs officers’ perception of the seriousness of illegal wildlife trade by region
18. Table 3.8. Applying an analytical framework to selected criminal economies
19. Table A.1. Interviews conducted for the study
20. Table A.2. Overview of quantitative research
21. Figures Figure 1.1.Bilateral ODA by region
22. Figure 2.1.Evolution of AU countries’ populations in millions, 1960-2030 (projected)
23. Figure 2.2.GDP adjusted for inflation (2010) for AU states
24. Figure 2.3Total goods: Export and import flows between Europe and Africa
25. Figure 2.4.Top ten (non-AU) import partners for all AU countries combined, 2003-15
26. Figure 2.5.Conflict systems in Africa
27. Figure 2.6.Terrorism incidents, 2000-16
28. 3.1.West Africa as a transit hub for cocaine flows from Latin America, 2014
29. Figure 3.2.Criminal incidents along the Gulf of Guinea Coast, 2006-14
30. Figure 3.3.Percentage of individuals using the Internet, 2002-16.
31. 71 Figure 3.4.Arrivals by sea to European borders through the Central Mediterranean route
32. Figure 3.5.Comparative values of trafficking flows, 2009
33. Figure 3.6.Share of anti-malarial medication found to be non-compliant with quality standards,
2012
34. Figure 3.7.Major arms flows in the region
35. Figure A.1. Illustrative estimate of possible IFFs generated by criminal activity; proportion
remaining in the region and leaving the region

INTRODUCTION
What is at stake in the African Continental Free Trade Zone Area?
Africa is considered as the second fastest-growing economy after East Asia, and yet the continent is filled
with people living in abject poverty, and has been referred to as a continent with poor foundations for human
development due illicit activities of criminal agencies or persons. Every year, an estimated amount
approximated as $88.6 billion, equivalent to 3.7% of Africa's GDP, through Financial Crime and Illicit
Capital Flight, (according to UNCTAD Report 2020). Africa is discovered as a net exporter of criminal capital
income through Financial Crime which is far more exceeds inflows of assistance, valued at $48bn, and the
yearly foreign direct investment, and amounted to $54bn. But It is also discovered that $1.2 trillion and
$1.4 trillion has left Africa through Financial Crime between 1980 and 2009—roughly equal to Africa’s
current gross domestic product, that surpassing money received from outside over the same period. Financial
Crime is said to be dirty money earned illegally and transferred for use elsewhere. Such monies are usually
generated from criminal activities, like corruption, tax evasion or tax avoidance, Mis-invoicing, Mispricing,
bribes and transactions from cross-border smuggling etc.
The effective of Financial Crime on sanitation
The African Continental Free Trade Area (AfCFTA)designed a flagship project of Agenda 2063 aimed at
creating a single African market for goods and services facilitated by free movement of persons, capital,
investment to deepen economic integration, promote and attain sustainable and inclusive socio-economic
development, gender equality, industrialization, agricultural development, food security, and structural
transformation.

The AfCFTA is the world’s largest free trade area bringing together the 55 countries of the African Union
(AU) and eight (8) Regional Economic Communities (RECs). The overall mandate of the AfCFTA is to create
a single continental market with a population of about 1.3 billion people and a combined GDP of
approximately US$ 3.4 trillion.
As part of its mandate, the AfCFTA is to eliminate trade barriers and boost intra-Africa trade. In particular, it
is to advance trade in value-added production across all service sectors of the African Economy. The AfCFTA
will contribute to establishing regional value chains in Africa, enabling investment and job creation. The
practical implementation of the AfCFTA has the potential to foster industrialization, job creation, and
investment, thus enhancing the competitiveness of Africa in the medium to long term.
In March 2018, the 10th Extraordinary Session of the African Union Summit held in Kigali, Rwanda, adopted
the Agreement Establishing the African Continental Free Trade Area (AfCFTA). The AfCFTA Agreement
came into force in May 2019. As of March 2023, 46 countries had ratified and deposited the instruments of
ratifications with the African Union Commission. Mozambique has ratified the Agreement but is yet to
deposit the instruments of ratification with the AU Commission. The following countries were yet to ratify the
Agreement, Somalia, South Sudan, Sudan, Eritrea, Madagascar, Benin, Liberia, and Libya. Eritrea donot to
sign the Agreement of that time.
Trading under the Africa Continental Free Trade Area Agreement began on 1 January 2021. As at February
2022, eight countries representing the five regions of the continent - Cameroon, Egypt, Ghana, Kenya,
Mauritius, Rwanda, Tanzania and Tunisia – participated in the AfCFTA’s Guided Trade Initiative, which
seeks to facilitate trade among interested AfCFTA state parties that have met the minimum requirements for
trade, under the Agreement. This initiative supports matchmaking businesses and products for export and
import between State Parties. The products earmarked to trade under the Initiative include: ceramic tiles;
batteries, tea, coffee, processed meat products, corn starch, sugar, pasta, glucose syrup, dried fruits, and sisal
fibre, amongst others, in line with the AfCFTA focus on value chain development.
In the year 2023, the AfCFTA Guided Trade shall also focus on Trade in Services in the five priority areas,
i.e. Tourism, transport, Business Services; Communication Services; Financial Services; Transport Services,
and Tourism and Travel-related Services. The ultimate objective is to ensure that AfCFTA is truly operational
and the gains from the initiative are improved implementation in order to achieve increased inter-regional and
intra-Africa trade that would yield economic development for the betterment of the continent at large.
If not curtailed this efforts will soon be hampered by criminal organizations engaging in Financial Crime, the
number tells only part of the story. It is a story that exposes how highly complex and deeply entrenched the
practices have flourished over the past decades with devastating impact, but barely made it into the news
headlines. “The illicit haemorrhage of resources from Africa is about four times Africa’s current external
debt,” says a joint report by the African Development Bank (AfDB) and Global Financial Integrity, a US
research and advocacy group.
The Financial Crime Problem of Net Resource Transfers from Africa: 1980–2009, found that cumulative
illicit outflows from the continent over the 30-years period ranged from $1.2 trillion to $1.4 trillion. The

Guardian, a British daily, notes that even these estimates—large as they are—are likely to understate the
problem, as they do not capture money lost through drug trafficking and smuggling.
Nonetheless, research and advocacy groups who have worked on Financial Crime or illicit outflows see a
direct link between these outflows and Africa’s attempts to mobilize internal resources. Despite annual
economic growth averaging 5% over the past decade—boosted in part by improved governance and sound
national policies—Africa is still struggling to mobilize domestic resources for investments. If anything, the
boost in economic growth has caused a spike in the Financial Crime or illicit outflow.
About three-fifths of global trade is conducted within multinationals.
“Many developing countries have weak or incomplete transfer pricing regimes,” according to the Guardian,
citing an issue paper authored by the Paris-based Organization for Economic Cooperation and Development
(OECD), a group of high-income economies. The paper says poor countries have weak bargaining power.
“Some [countries] have problems in enforcing their transfer pricing regimes due to gaps in the law, weak or
no regulations and guidelines for companies,” says the OECD paper, adding that poor countries have limited
technical expertise to assess the risks of transfer pricing and to negotiate changes with multinationals.
Offshore tax shelters
According to the OECD paper, member countries are failing to identify company owners who benefit from
money laundering. It criticizes OECD members for not doing enough to crack down on Financial Crime or
illicit outflows. In order to prevent, uncover or prosecute money laundering, says the paper, authorities must
be able to identify company owners. The OECD advises its members to invest in anti-corruption and tax
systems in poor countries, as this has high payoffs.
The bulk of Financial Crime dealings or illicit money today is channelled through international tax havens,
says the Thabo Mbeki Foundation, an NGO set up by the former president to promote Africa’s renaissance.
The foundation accuses “secrecy jurisdictions” of running millions of disguised corporations and shell
companies, i.e., companies that exist on paper only. These jurisdictions also operate anonymous trust accounts
and fake charitable foundations that specialize in money laundering and trade over-invoicing and
underpricing.
“Developing countries lose three times more to tax havens than they receive in aid,” said Melanie Ward,
speaking to the Guardian. Ms. Ward is one of the spokespersons for the Enough Food for Everyone IF
campaign, a coalition of charities calling for fairer food policies, and head of advocacy at Action-Aid, an anti-
poverty group. The money lost, she says, should be spent on essential development of schools, employment,
hospitals and roads, and on tackling hunger, not siphoned into the offshore accounts of companies.
A 2007 joint report by the World Bank and UN Office on Drugs and Crime estimated that every $100 million
returned to a developing country could fund up to 10 million insecticide-treated bed nets, up to 100 million
ACT treatments for malaria, first-line HIV/AIDS treatment for 600,000 people for one year, 250,000
household water connections or 240 km of two-lane paved roads.

Support for new rules to rein in offshore tax shelters has come from an unlikely source—the leaders of eight
of the world’s biggest economies, the Group of Eight (G8). Having been stung by the 2008 global financial
crisis, the G8 leaders at this year’s summit in Lough Erne, Northern Ireland, introduced—for the first time—
rules to fight tax evasion. The rules will now require multinationals to disclose the taxes they pay in countries
in which they operate.
During the run-up to the G8 summit, advocacy groups campaigned to get rich countries to introduce laws on
transparency in corporate taxes. Among them was the Africa Progress Panel, chaired by former UN Secretary-
General Kofi Annan. On the eve of the summit, it published its annual flagship report, Africa Progress Report
2013, strongly criticizing the current rules on corporate transparency.
Unconscionable act
“It is unconscionable that some companies, often supported by dishonest officials, are using unethical tax
avoidance, transfer pricing and anonymous company ownership to maximize their profits while millions of
Africans go without adequate nutrition, health and education,” Mr. Annan wrote in the foreword to the report.
Tax evasion, he said, has cut into African citizens’ fair share of profits from their abundant resources.
In the end, the G8 leaders adopted the Lough Erne Declaration, a 10-point statement calling for an overhaul of
corporate transparency rules. Among other things, the declaration urges authorities to automatically share tax
information with other countries to fight tax evasion. It states that poor countries should have the information
and capacity to collect the taxes owed to them. The declaration further calls on extractive companies to report
payments to all governments, which should in turn publish them.
While the Financial Times embraced the declaration as “an advance” in corporate transparency, Sally Copley,
another spokesperson for the IF campaign, says in a statement, “The public argument for a crackdown on tax
dodging has been won, but the political battle remains.” Copley wants the G8 to impose strict laws on tax
evasion.
For its part, Africa Progress Report 2013 calls for multilateral solutions to global problems because “tax
evasion, Financial Crime and illicit transfers of wealth and unfair pricing practices are sustained through
global trading and financial systems.” It urges African citizens to demand the highest standards of propriety
and disclosure from their governments, and rich countries to demand the same standards from their
companies.
Initiatives by institutions in Africa and the adoption of the Lough Erne Declaration raise hopes for strict rules
against Financial Crime and illicit financial flows from Africa. “Seizing these opportunities will be difficult.
Squandering them would be unforgivable and indefensible,” Mr. Annan warns in his foreword to the panel’s
report. Meanwhile, ECA’s slogan “Track it. Stop it. Get it” aptly captures what needs to be done about
Financial Crime and money flowing illicitly out of Africa.
“The traditional thinking has always been that the West is pouring money into Africa through foreign aid and
other private-sector flows, without receiving much in return,” said Raymond Baker, president of Global
Financial Integrity, in a statement released at the launch of the report earlier this year. Mr. Baker said the

report turns that logic upside down, adding that Africa has been a net creditor to the rest of the world for
decades.
The composition of these outflows also challenges the traditional thinking about Financial Crime and illicit
money. According to estimates by Global Financial Integrity, corrupt activities such as bribery and
embezzlement constitute only about 3% of Financial Crime and illicit outflows criminal activities such as
drug trafficking and smuggling make up 30% to 35% and commercial transactions by multinational
companies make up a whopping 60% to 65%. Contrary to popular belief, argues Professor Baker, money
stolen by corrupt governments is insignificant compared to the other forms of Financial Crime and illicit
outflow. The most common way Financial Crime or illicit money is moved across borders is through
international trade.
Information scanty and scattered
A ten-member high-level panel chaired by former South African President Thabo Mbeki leads research by the
UN Economic Commission for Africa (ECA) into Financial Crime or illicit financial flows, assisted by ECA
Executive Secretary Carlos Lopes as the vice-chair. Other members of the panel include Professor Baker and
Ambassador Segun Apata of Nigeria. The ECA blames Financial Crime and illicit outflows for reducing
Africa’s tax revenues, undermining trade and investment and worsening poverty. Its report was released in
March 2014.
Undoubtedly the panel faces a daunting task. Charles Goredema, a senior researcher at the South Africa–
based Institute of Security Studies, cautions the panel on the challenges ahead. Writing in the institute’s
newsletter, ISS Today, Goredema warns the panel that it will find that in many African countries, data on
Financial Crime and illicit financial flows “is scanty, clouded in a mixed mass of information and scattered in
disparate locations.” He ranks tax collection agencies and mining departments among the bodies most
reluctant to share data.
Goredema lists Transparency International, Global Financial Integrity, Christian Aid and the Tax Justice
Network as some of the advocacy groups that have tried to quantify the scale of Financial Crime and illicit
financial flows. The extent of such outflows remains a matter of speculation, he says, with the figures on
Africa ranging between $50 billion and $80 billion per year. Other estimates by the ECA put the figure at
more than $800 billion between 1970 and 2008.
“The absence of unanimity on [the amount] is probably attributable to the fact that the terrain concerned is
quite broad, and each organization can only be exposed to a part of it at any given point in time,” Goredema
writes, adding, “It is less important to achieve consensus on scale than it is to achieve it on the measures to be
taken to stem illicit financial outflows from Africa.”
Financial crime linked to Nigeria
Financial crime linked to Nigeria is a large and pressing problem for the British authorities, which are short of
the information and resources needed to deal with it. Nigeria-related financial crime has grown in significance
partly because it is not seen as a priority area. Private sector fraudsters and corrupt public officials and British
companies have profited from the general Western focus on terrorist financing, drugs and people-trafficking.

Other types of corruption and money-laundering, some of which involve British business people, have often
been neglected. These general observations could be applied to crimes carried out by the nationals of many
countries, including Britain itself. Criminal activity involves only a small minority of Nigerians, relative to the
size of the country and the number of its national’s resident in Britain or visiting it. Nigeria is Africa’s most
populous nation by far and is a former British colony: Jack Straw, the former foreign secretary, has referred to
estimates that more than one million Nigerians live in Britain. 1 it is precisely because of these strong and
deep links that Nigeria-related financial crime deserves attention. High levels of such crime are very
damaging to the image and standing of the many Nigerians who live honestly in Britain or who visit the
country to do legitimate business. One Lagos banker has described how the level of crime linked to Nigeria
already leads holders of the country’s distinctive green passport to be ‘victimized’ anywhere they go in the
world. Equally, the proportionally small but still substantial numbers of Nigerians who are involved in
financial crime create a risk of what Tarique Ghaffur, a Metropolitan Police assistant commissioner, has
described as large-scale ‘contamination of communities’ by organized crime.2 Extensive anecdotal evidence
suggests that a significant amount of financial crime in Britain is linked to Nigeria. One police officer
working on economic and specialist crime says so much Nigeria-related corruption goes through London that
he could employ his entire command to deal with it. Another, who works on Cheque and credit card fraud,
says Nigerians are in the ‘top three’ of nationalities of offenders with whom his group has to deal.3 The
piecemeal figures on Nigeria-related fraud that do emerge seem at times to echo the recent warning of Bob
Murrill, head of the Metropolitan Police organized crime unit, that criminal gangs are ‘out of control’ in
London.4 On a single day check at Heathrow airport last year, for example, police discovered more than £20
million of forged cheques and postal orders in the courier mail from Lagos. Recent British government
research found that at least 13 per cent of Nigerian applicants for visitors’ visas and at least 17 per cent of
applicants for student visas tried to use some kind of fraudulent documentation, such as forged bank
statements or tax returns.5 Many informed people think a large amount of Nigerian official corruption passes
through Britain. In 2005, the British authorities charged D.S.P. Alamieyeseigha, governor of Nigeria’s
Bayelsa state, with money-laundering after almost £1 million in cash was discovered at one of his London
properties. A Nigerian law enforcement official estimates that between 80 and 90 per cent of the country’s 36
state governors own property in Britain, with many also having bank accounts in their own, their wives’ or
their children’s names. Other important components of Nigeria-related financial crime are the British
individuals and companies operating corruptly in Nigeria. London is increasingly attacked for alleged
hypocrisy in failing to keep its promises to crack down on British corruption in Africa. Privately, British
business people admit corruption is still commonplace: one British executive working in the oil industry says
his company routinely pays immigration officials a bribe worth between 20 and 30 per cent of the cost of
expatriate resident permits. In March 2006, a report by Britain’s All Party Parliamentary Group on Africa
criticized the ‘limbo like state of anti-corruption legislation’, and the ‘fragmentation and under-resourcing’ of
investigatory and enforcing agencies.6 The accusations come more than five years after Britain revealed that
at least $1.3 billion looted by the late dictator General Sani Abacha had been processed through British
financial institutions.7 Nigerians responsible for investigating financial crime in Nigeria have had some
successes, but many are under no illusions about how severe and deeply entrenched the problem is after
decades of autocratic government, rampant corruption and plunging living standards. Nigeria’s Economic and
Financial Crimes Commission (EFCC) estimates that in under four years of operation it has recovered £2
billion of criminal money.8 One of its officials laments that Nigerian internet fraud has become ‘something
huge’ because the authorities never seriously tried to stop it until very recently. The same could happen in
Britain, he warns, if it makes the same mistake.

Corruption is endemic in Sierra Leone.
Sierra Leone is widely considered to be one of the most politically and economically corrupt nations in the
world and international rankings reflect this. Transparency International's 2022 Corruption Perceptions
Index scored Sierra Leone at 34 on a scale from 0 ("highly corrupt") to 100 ("very clean"). When ranked by
score, Sierra Leone ranked 110th among the 180 countries in the Index, where the country ranked first is
perceived to have the most honest public sector.[1]
For comparison, the best score was 90 (ranked 1), the worst
score was 12 (ranked 180), and the average score was 43.[2]
The 2018 Global Competitiveness Report ranked
Sierra Leone 109th out of 140 countries for Incidence of Corruption, with country 140 having the highest
incidence of corruption.[3]
Corruption is prevalent in many aspects of society in Sierra Leone, especially in the
aftermath of the Sierra Leone Civil War. The illicit trade in conflict diamonds funded the rebel Revolutionary
United Front (RUF) forces during the civil war, leading to fighting between the Sierra Leone Army and the
RUF for control of the diamond mines.[4]
Widespread corruption in the health care sector has limited access to
medical care, with health care workers often dependent on receiving bribes to supplement their low pay.[5]
.
In understanding the problems of corruption in African Union Member States we can seek to solve the
current issues in Africa.
Income inequality is rising, while underemployment and the lack of economic opportunities push some
individuals to join criminal groups, gangs or rebel movements, reinforcing the links between inequality,
criminal activity and violence. The United Nations Economic Commission for Africa’s High Level Panel on
Financial Crime and Illicit Financial Flows has estimated that illicit financial flows (IFFs) from Africa could
amount to as much as USD 50 billion (US dollars) per year. Although the figures on IFFs are heavily
disputed, current analyses agree that IFFs exceed the amount of Official Development Assistance (ODA)
provided to Africa. Previous research has largely focused on capturing the volumes and sources of Fin-Crime
and IFFs, and on identifying the commercial practices that contribute to them such as trade misinvoicing,
mispricing, tax evasion and avoidance, and transfer pricing. This Book takes a different approach by seeking
to build the evidence basis on criminal and illicit economies, the Fin-Crime and IFFs these economies
generate, and their impact on development. The Book reviews diverse forms of economies prevalent in
Africa that are usually seen as criminal or illicit, organizing them through a typology according to a range of
illegal activities, from natural resource crimes to illicit trade in normal legal goods. This analysis leads to the
following conclusions: Financial Crime, criminal and illicit economies produce IFFs that undermine country
capacities to finance their development; and criminal economies and IFFs are a potent negative force that
contribute to the degradation of livelihoods and ecosystems, undermine institutions, reinforce clientelist
politics and enable impunity, in different ways across the region’s countries. Key findings Criminal acts are
enabled by a diverse set of actors, including criminal networks, the private sector (both domestic and
international), and state officials. Criminal methods are dynamic processes, changing in response to
opportunities, and to global and local market forces. IFFs and Financial criminality erode the fabric of the
state across the region, and often cause politics, business and crime to converge, creating ambiguity around
governance and rule of law. Certain criminal and illicit economies in the region carry low levels of stigma

within communities, as they are an important source of livelihood, building legitimacy that enables alternative
governance providers to compete with the state and create alternate sources of authority.
CHAPTER ONE
OVERVIEW AND DEFINITIONS
What are some of the main reasons for fighting Financial Crime in the African Continental Free Trade Zone
Area?
Interferes with government revenue:
1. To protect the Resources: As part of protecting the resources of Africa, financial criminals will often
try to avoid paying taxes on goods and services. This gives a country's government less money to
spend on important projects, makes tax collection more difficult, and often results in higher taxation
on legitimate citizens.
2. Some people and groups will do anything for money or other forms of wealth—even resort to
breaking the law. They may try to claim that these financial crimes are justifiable because they have
no victims, or that the victims can afford the losses. In reality, they are still illegal because they can
cause widespread harm—not only in finance, but also in business, politics, and culture.
So what are financial crimes, and what are some common types? Why are they so damaging to so many
areas of society?
And what can organizations expect the battle against financial crime to look like in the near future? We’ll
cover all that and more in this Book.
In other to walk through this Book we have to understand the main definitions and terms that defines this
Book.
Let us look at some Terms and definitions according to the Oxford Languages Dictionary.
African Union Continental Free Trade Zone
What is Africa Continent?
Africa is a Continent: The most important thing to know is that Africa is not a country; it's a continent of 55
countries that are diverse with culturally and geographically different. It's so diverse because Africa is really
big as big as the combined landmasses of China, the United States, India, Japan and much of Europe.

What is Union?
 A union is a state of being united, a combination, as the result of joining two or more things into one:
to promote the union between two families; the Union of African brings all Countries of Africans into
one Union-Called the African Union (AU).
 A union is a workers' organization which represents its members and which aims to improve things
such as their working conditions and pay.
What is a Continent?
What is a simple definition of continent?
A continent is a large continuous mass of land conventionally regarded as a collective region. There are seven
continents: Asia, Africa, North America, South America, Antarctica, Europe, and Australia (listed from
largest to smallest in size)
What is Free?
1. Able to act or be done as one wishes; not under the control of another
 Not or no longer confined or imprisoned.
 Without cost or payment.
 Release from confinement or slavery.
 Remove something undesirable or restrictive from
2. What is Trade?
The action of buying and selling goods and services
Commerce:
 buying and selling
 dealing with traffic or transporting of business
 marketing and merchandising

 bargaining and dealings
 transactions and negotiations
 proceedings
3. A job requiring manual skills and special training. "The fundamentals of the construction trade"
Similar:
 craft occupation
 job day job
 career
 profession
 business
 pursuit living
 livelihood
 line of work
 line of business
 vocation calling
 walk of life province
 field work
 employment
4. What is Zone?
 An area, especially one that is different from the areas around it, because it has different
characteristics or is used for different purposes: a danger/safety zone.
 an area or stretch of land having a particular characteristic, purpose, or use, or subject to particular
restrictions
 An encircling band or stripe of distinctive colour, texture, or character.
5. What is Area?
Area is defined as the total space taken up by a flat (2-D) surface or shape of an object. The space
enclosed by the boundary of a plane figure is called its area. The area of a figure is the number of unit
squares that cover the surface of a closed figure.
What is Financial Crime?
Financial crime is any activity that allows an individual or group to unlawfully gain financial assets (including
money, securities, or other property). It typically involves directly stealing from a person or institution, or else
illegally changing or obscuring who owns an asset.

Financial crime is sometimes referred to as “white-collar crime” because it targets assets rather than people
themselves, and so tends to be non-violent (but not always). In any event, it can still be extremely damaging
to individuals’ financial situations, and even regional or global markets.
What are the types considered a Financial Crime?
Financial crimes can be divided into two categories.
 The first category is an entity generating financial benefits for themselves or others through deceptive
or illicit practices. This can include a business employee using privileged information to
misappropriate some of the company’s or state funds for their own use. Another example would be
criminal taking money or other assets from someone in exchange for a financial instrument (such as a
Cheque or Money order) that turns out to be fake
 The second category is an entity committing a crime that sets them up to commit another crime where
they illegitimately gain a financial advantage or protect their financial benefits through dishonest or
illegal methods. The most recognizable form of the latter is money laundering: putting the proceeds of
crime through a series of complex transactions to make them appear as if they came from a legitimate
source. Another example is people using shell corporations or shell banks to store their money,
obscuring who owns it and therefore helping them avoid paying taxes on it.
What is a Shell Corporation?
A shell Corporation is an entity with no active business operations or assets. These firms are often set up for
illegal activities, such as tax evasion and money laundering, and to maintain anonymity during transactions.
What are the Problems of shell corporation?
Some of problems of Shell Corporations
Shell corps has minimal operations and exists only on paper, with a registered office and nominal
directors/shareholders. They can be established quickly in jurisdictions with favorable regulations for
company formation and privacy.
The primary use of a shell crop is for illegal activities while appearing legitimate. For example, individuals or
organizations may hide assets and launder money by transferring funds through multiple shell corps. Due to
the complex ownership and operations across multiple jurisdictions, it is difficult to trace those behind these
activities.

To prevent abuse, governments should implement measures such as stricter regulatory requirements,
enhanced due diligence, and increased transparency. These efforts aim to prevent criminals from exploiting
shell corps for illegal purposes.
Legitimate firms can also utilize shell corps, such as multinationals creating subsidiaries in different countries
for tax planning or to simplify corporate structures. In these cases, the primary purpose is not illegal activities
but to facilitate legitimate business operations.
To ensure that shell corps, are not misused, regulations should include Know Your Customer (KYC)
procedures when registering new companies. This involves conducting comprehensive background checks on
directors and beneficial owners to verify their identities and credibility.
Authorities should also require more reporting on financial transactions and beneficial ownership structures.
By collecting and sharing this information internationally, law enforcement agencies can better detect and
investigate activities involving shell corps.
Other Shell Corporations Definitions
Shell corporations, or shell entities, are defined by their lack of substantial business operations or assets. They
are inactive and used for various financial transactions. Legitimate uses of shell corporations include tax
planning, asset protection, and confidentiality. But, they can also be used for illicit activities like money
laundering and fraud.
Characteristics of Shell Corporations:
1) Shell corporations usually have no physical presence or employees. They may have a registered
address, but no actual office or staff. This makes it hard to trace the true owners.
2) Nominee directors and shareholders are often used. These people act on behalf of the owners, but
their names are listed in public records. This allows for anonymity.
3) Shell corporations usually have minimal capitalization and nominal assets. They may only hold a
small amount of cash or shares in other companies. This makes it difficult for authorities to seize
assets or hold the entity accountable.
4) Complex financial transactions are often carried out by shell corporations. These transactions are
done to hide funds, evade taxes, or disguise illegal activities. This further complicates investigations.
The Guardian found that, between 1995 and 2015, over 175,000 shell companies were set up in London with
ties to offshore tax havens, such as British Virgin Islands and Panama Papers leak sources.
Legal and Ethical Issues Surrounding Shell Corporations
 Embezzlement Controls

 Cybercrimes embezzlement schemes
Shell corporations can bring a lot of legal and ethical problems. They’re often used for bad stuff, like
money laundering, embezzlement, and dodging taxes. Here’s a breakdown of the main issues:
Money Laundering: People use shell corporations as a way to funnel illegal money.
Tax Evasion: By using overseas shell corporations, people can dodge taxes in their own countries.
Fraud: Shell corporations are sometimes set up for fraud, like Ponzi or pyramid schemes.
Anonymous Ownership: People use shell corporations to hide their identity, making them hard to punish for
bad behavior.
Regulatory Compliance: Shell corporations can manipulate regulations and get away with it.
These aren’t the only problems with shell corporations. Terrorism financing and corruption are also involved.
To crack down on them, regulatory bodies all over the world are keeping an eye out.
Tip: When dealing with others, check if they have any links to shell corporations to avoid the risks.
Types of Financial Crime
Financial crime has a broad definition that sometimes includes all illegal activity targeting financial
institutions, or even any illicit generation or use of money for an advantage. Here are ten common types of
financial crime.
Fraud
Financial fraud crimes encompass any activities intended to gain or protect financial benefits through
deceitful and unethical means. Fraud is a wide category that can include many of the other crimes on this list,
such as impersonation, counterfeiting, identity theft, and falsifying business records.
Money Laundering
Money laundering is a financial crime that aims to cover up the source of the proceeds of crime. Its first
objective is to sneak money generated through illegal activities into a financial system (placement). Its second
objective is to move that money around to build up a transaction history, giving it the appearance of
legitimacy and making it difficult to trace back to its original criminal source (layering/structuring). Its final
objective is to return the money to criminals for them to spend without attracting attention from authorities
(integration).
Terrorist Financing

Terrorist financing refers to entities providing financial assets to terrorists—both individuals and groups.
Their aim is to help terrorists purchase weapons, supplies, and anything else they need to carry out attacks on
innocent civilians.
The penalties for being caught aiding terrorists are very severe, so terrorist financing is somewhat akin to
money laundering. That is, criminals wanting to finance terrorists have to use tricks to sneak assets into
legitimate financial systems, then conceal where the money is coming from and going to.
Embezzlement
Embezzlement is when an entity is entrusted with—or given access to—funds to be used towards certain ends,
with the entity then illicitly using that money for other purposes. They may transfer it to their own accounts or
those of another, creating fake invoices or receipts to try and cover their tracks. Embezzlement often occurs
within organizations and can range from petty theft to multi-million dollar schemes.
Corruption and Bribery
Similar to embezzlement, corruption is when an entity in a position of power acts outside of its mandate in
order to unlawfully gain advantages—including financial ones—for themselves or others. Corruption can
actually involve embezzlement, and it can also involve bribery.
Bribery is the other side of corruption. It’s when an entity illegally gives financial benefits to authorities in
exchange for receiving preferential treatment in decisions affecting the public. An example is a company
paying officials in a country to get them to allow it to operate there without needing to comply with all
necessary regulatory obligations.
Tax Evasion
An entity intentionally not paying their taxes, or paying less tax than they owe, is a financial crime called tax
evasion. There are several ways to commit tax evasion. One is to deliberately fail to report taxable income.
Another is to purposely claim more tax deductions than one is entitled to. Refusing to file a tax return at all
also counts as tax evasion.
An entity may also commit tax evasion by storing or investing their assets in banks or companies in other
countries, or that are “shells” (i.e. they have no physical location and/or no active operations). This allows
them to falsely claim that they have fewer assets than they actually do, in an attempt to illegally pay less tax
than they truly owe.
Insider Trading and Market Abuse
Sometimes, an entity may cheat the stock market by buying or selling securities based on proprietary
information regarding a company’s financial situation. This is called insider trading, and it’s a financial crime
in many places. This is because the entity either was entrusted with the information for other purposes (similar

to corruption and embezzlement) or outright stole it. So they got an unfair advantage by using information the
public wasn't supposed to know (yet).
There are other ways criminals can illegally manipulate stock markets. One example is “wash trading”—
purchasing and then immediately re-selling shares in a company. This creates the illusion that the company’s
stock is seeing a lot of financial activity, which can inflate its price.
Another such scheme is called “pump and dump”. This involves an entity purchasing a low-value stock, then
spreading rumors or other misinformation suggesting that the stock will soon increase in price. Their goal is to
create a flurry of trading activity around the stock, thereby inflating its value. Then they sell off their shares
for a profit before others realize the hype surrounding the stock was fake, and trading activity returns to
normal.
Forgery and Counterfeiting
Other financial crimes involve unlawfully manipulating or duplicating financial assets. These are known,
respectively, as forgery and counterfeiting.
Forgery is illicitly altering a genuine financial asset to create an unintended benefit. In check fraud, for
example, a criminal may name a different payee on the check, or change the amount the check is for. They
may even attempt to fake the signature or other credentials of the check payer or endorser to make it seem like
they authorized the check, when in fact, they did not.
Meanwhile, counterfeiting creates imitations or unauthorized copies of legitimate financial assets. The
criminal’s intention is to spend these fakes as if they were genuine, hoping the other transaction party doesn’t
notice the difference. However, many financial assets now have security features that allow people to tell the
difference between an imitation and a genuine one, or when a genuine one has been illegally copied.
Identity Theft
While identity theft doesn’t involve directly stealing financial assets, it’s often considered a financial crime
anyway. This is because it’s typically used as a means of committing other financial crimes.
The goal is for a criminal to steal someone’s private identity or account access credentials, then use them to
forge the person’s authorization for transactions. This allows the criminal to illegally profit while the victim
bears the costs.
A criminal can use many different methods for identity theft. A common one is phishing, where they trick
victims into revealing their credentials with an enticing and/or urgent request—often appearing as if it came
from a legitimate and authoritative source. They can also break into online accounts to steal credentials or
impersonate victims. Or they may simply purchase credentials exposed by data breaches from the black
market.
Cybercrime

As more financial activity moves online, so too does financial crime. Fraudsters are turning to digital channels
for stealing money and authorization credentials, exposing sensitive information, forging and counterfeiting
financial assets, manipulating markets, and committing many different types of fraud.
Virtual currencies are proving to be especially popular tools for financial crime. Reasons for this include a
current lack of financial regulations surrounding them, as well as most transactions being semi-anonymous. In
addition, many virtual currencies have non-centralized administration on the block-chain, making transactions
difficult to undo once recorded.
All of this has made virtual currencies ripe for schemes such as market manipulation, money
laundering, terrorist financing, tax evasion, and other forms of fraud.
• Market Abuse and Insider Dealing:
Market abuse and insider dealing involve using inside information to make financial gains or manipulate
markets. This can include insider trading, spreading false rumors, or manipulating stock prices.
• Information Security:
Information security involves protecting sensitive information from unauthorized access or disclosure. This
can include theft of personal information, hacking into computer systems, or corporate espionage.
Financial Crime Statistics and Trends to Watch For
According to the Price Water house Coopers 2022 Global Economic Crime and Fraud Survey, about 46% of
organizations worldwide encountered some kind of financial crime that year. Financial crime is tending to
target larger organizations—52% of those targeted in 2022 had annual revenues over $10 billion US, as
opposed to 38% of companies with less than $100 million US annual revenue.
And financial crime is becoming more costly, more often. Of larger companies experiencing fraud, 18% had
their biggest incident of financial crime in 2022, costing them over $50 million US. And 22% of smaller
companies experiencing fraud said their most disruptive financial crime experience cost them at least $1
million US.
Here are some other financial crime trends to watch for in the coming years.
The rise of financial crime in cyberspace
While global financial crime statistics show an overall downward trend, one notable exception is in
cybercrime. The COVID-19 pandemic fueled the demand and adoption of instantaneous remote financial
services, including neo-banks, virtual currency trading, and embedded finance.
However, these services tend to prioritize smooth user onboarding and interface experiences at the expense of
more robust security and risk assessment programs. This leaves them more vulnerable to bad actors—
especially hackers, online fraudsters, and other external parties.

A renewed importance for sanctions screening
Incidents such as Russia’s invasion of Ukraine in February of 2022 have put a spotlight back on sanctions
list compliance. Organizations are scrambling to avoid being penalized for illegally dealing with dangerous
individuals, groups, and countries—both directly and throughout their supply chains. This will be made more
difficult by the increasing popularity of decentralized financing, such as through virtual currencies and crowd
funding.
AI and other changing financial crime prevention procedures
Regulators and compliance teams continue to realize that if they want to keep up with modern financial crime,
they need to do things differently. That includes adopting machine learning models to more accurately
identify signs of financial crime, as well as prioritize the alerts most likely to be true positives.
It also includes taking a more holistic, organization-wide approach to fighting financial crime. That involves
stronger communication between departments to assess customer risk across both onboarding and ongoing
financial activity. It also involves more stringent auditing processes to ensure all parts of an organization are
on board with its overall compliance efforts.
Consequences of Money Laundering and Financial Crime
Again, while financial crime is typically non-violent, it can be used to cover up violent crimes that involve
criminals taking what doesn’t rightfully belong to them. Beyond that, financial crime can have far-reaching
socio-economic impacts that can threaten the administrative stability of entire countries, and even the world.
Here are some reasons why.
 Unfairly disadvantages legitimate private businesses: Individuals and groups that engage in
financial crime sometimes conceal their activities behind “front” businesses. Since these businesses
are backed by substantial amounts of illegal money, they can often offer their products or services
at costs that legitimate businesses just can’t match.
 Warps industry supply and demand: Financial criminals invest in crime to profit. So when they
do invest in legitimate industries, it’s often as a means of protecting their assets through money
laundering and not because they expect returns. This false demand can put industries in danger of
collapsing when criminals decide to move their money somewhere else.
 Threatens the stability of financial institutions: Financial institutions that house the proceeds of
financial crime tend to see large amounts of money move around quickly. This is usually either to
launder the funds or to keep them away from investigating authorities. That can cause liquidity
problems for the FI, which in turn can cause customers to panic and go on bank runs.
 Interferes with government revenue: As part of protecting their proceeds, financial criminals will
often try to avoid paying tax on them. This gives a country’s government less money to spend on

important projects, makes tax collection more difficult, and often results in higher taxation on
legitimate citizens.
 Hampers the economic growth of developing countries: Countries emerging as players on the
world economic stage tend to be focused on growing their financial systems as opposed to
regulating them. This makes them attractive to financial criminals, which makes them less
attractive to people and companies looking to legitimately do business.
 Hijacks control of economic policy: Another danger of financial crime being popular in lightly-
regulated developing countries is that its proceeds may exceed the budgets of governments in those
countries. This effectively means that criminals are in control of the country’s economy instead of
the legitimate government.
 Contributes to moral breakdown: If financial crime is left unchecked in a country, it encourages
more people to become involved. This results in more victims of criminal activities—such as drug
distribution and human trafficking—who may eventually turn to crime themselves out of isolation
and desperation. This cycle can subvert a country’s rule of law, and even its democratic principles.
Examples of Financial Crime
To illustrate what financial crime looks like in real life, here are a few famous examples of financial crimes
that received significant media attention.
Bernie Madoff’s Ponzi Scheme
Bernie Madoff founded a legitimate investment firm in the 1960s, but it eventually morphed into the biggest
Ponzi scheme in history. It took money from investors and used the funds to pay out dividends to clients who
had come earlier; instead of to back what customers actually wanted to invest in. The fraud, worth $65 billion,
was publicly exposed in 2009. Madoff was sentenced to 150 years in prison, and died in 2021.
Enron’s Accounting Fraud
At the turn of the 21st century, the American energy company appeared to be one of the most profitable
corporations in the world. The reality, however, was that the business was deeply in debt. The company’s
executives—along with accounting firm Arthur Andersen—had been hiding Enron’s money woes behind
misleading financial reporting, accounting loopholes, and off-books subsidiary shell corporations.
By late 2001, investors and journalists had exposed Enron’s fraud, putting the business on the verge of
bankruptcy. The company’s collapse cost investors upwards of $74 billion US, and several executives from
both Enron and Arthur Andersen were sentenced to long prison terms. The scandal led the US government to
pass the Sarbanes-Oxley Act in 2002 to impose stricter regulations on corporate financial reporting.
Martha Stewart’s ImClone Insider Trading Scandal
The famed retail entrepreneur, author, and TV personality was involved in a very public insider trading
scandal in the early 2000s. Her former stockbroker, Peter Bacanovic, illegally told her that ImClone—a
biotechnology company she had shares in—was about to have an experimental cancer treatment rejected by

the Food and Drug Administration. Knowing this would drive down the company’s stock price, Stewart sold
her shares a day before the announcement went public.
The Securities and Exchange Commission launched an investigation, refusing to believe this move was mere
coincidence. In mid-2003, both Stewart and Bacanovic were charged with insider trading. Stewart was found
guilty and served 5 months in prison.
Financial Crime Prevention: How Governments and Businesses Can Stop Financial Crime
Today, many criminals who commit financial fraud, launder money, and engage in terrorist financing are
incredibly sophisticated and agile, allowing them to continue their criminal activity without detection.
For businesses to avoid exposure to these sorts of illegal actions, they must take preemptive actions,
including investing in the infrastructure and systems needed to prevent and identify any kind of criminal
activity.
Many of these financial crimes require cross-border transactions. Unfortunately, the current international
financial network makes sophisticated criminal activity even more challenging to trace and prosecute. Money
launderers leverage differences in regulations to move money between countries, clouding the trail.
And those financing terrorist activities need to transfer money in and out of countries to execute their attacks.
To complicate matters further, in-country connections such as government officials, bank employees,
accountants, and others make it easier for these illegal cross-border transactions to go undetected.
Most countries have deployed comprehensive regulations to enable financial institutions to help detect,
investigate, and report suspicious activity.
Banks and financial institutions must comply with the Bank Secrecy Act (BSA) in the US. In addition, the UK
has instituted the Proceeds of Crime Act (POCA), while the EU has put in place the Anti-Money Laundering
Directives (AMLD). All of these regulations are consistent with the guidance provided by the
intergovernmental organization, the Financial Action Task Force (FATF).
By complying with these regulations, financial institutions can help prevent financial crimes such as fraud,
money laundering, and the financing of terrorist activity. On top of this, teams can optimize operations
and reduce false positives. Compliance generally falls into detecting suspicious activity, investigation, and
reporting to the appropriate government entity.
Unit21’s Anti-Fraud and AML Infrastructure is Here to Help You Guard Against Financial Crime
There’s no denying that it takes a lot of work to stop financial crime. Compliance with national and
international detection and prevention standards is a good start. However, this is often easier said than done.

New types of financial crimes are constantly appearing as policies, procedures, and technologies change.
So regulations—and, consequently, organizations’ compliance programs—have to adapt as well.
Ultimately, countering financial crime is about risk management: knowing how and where an organization is
vulnerable, and implementing the proper controls where reasonable—including identity
verification, transaction monitoring, and case management. This helps the organization not only limit the
chance of being victimized by financial crime but also work quickly to control the damage financial crime
causes if it actually happens.
Of course, using digital tools like Unit21’s is much more efficient than trying to handle everything
manually. Contact us for a demo of how our infrastructure can save an organization time, money, and other
resources.
What is African Union Continental Free Trade Zone is all about?
 What is the AfCFTA?
AfCFTA by simply definition can be described as an interest ground that came together to defend the
continental resources and trade right. The AfCFTA is composed of almost all African countries. With Nigeria
and Benin having agreed to join in, only Eritrea is yet to sign. Eritrea’s government declared that they will
most likely come on board. This would result in a continental trade agreement and the largest FTA.
The AfCFTA is an ambitious trade pact to form the world’s largest free trade area by creating a single market
for goods and services of almost 1.3bn people across Africa and deepening the economic integration of
Africa. The trade area could have a combined gross domestic product of around $3.4 trillion, but achieving its
full potential depends on significant policy reforms and trade facilitation measures across African signatory
nations.
The AfCFTA aims to reduce tariffs among members and covers policy areas such as trade facilitation and
services, as well as regulatory measures such as sanitary standards and technical barriers to trade.
The agreement was brokered by the African Union (AU) and was signed by 44 of its 55 member states in
Kigali, Rwanda on March 21, 2018. The only country still not to sign the agreement is Eritrea, which has a
largely closed economy.
As of May 2022, 46 of the 54 signatories had deposited their instruments of ratification with the chair of the
African Union Commission, making them state parties to the agreement.
Figure 1.1 Leadership and Trade-nexus

The AfCFTA Secretariat, an autonomous body within the African Union based in Accra, Ghana, and led by
secretary general Wamkele Mene, is responsible for coordinating the implementation of the agreement. (1.
https://african.business/2022/05/trade-investment/what-you-need-to-know-about-the-african-continental-free-
trade area#:~:text=The%20AfCFTA%20is%20an%20ambitious,the%
Objective:
The main objectives of the ACFTA are to create a single continental market for goods and services, with free
movement of business persons and investments, and thus pave the way for accelerating the establishment of
the Customs Union.
Why is this Book looking at Financial Crime, criminal economies and illicit financial flows in Africa?
Financial crimes can have serious consequences or impacts for the African Union Leaders, individuals and
society as a whole, including economic instability, loss of public trust in financial institutions, and erosion of the
rule of law.
Organized criminal groups, however, may also adopt terrorist tactics of indiscriminate violence and large-
scale public intimidation to further criminal objectives or fulfill special operational aims. Organized criminal

groups and terrorist organizations may build alliances with each other. The nature of these alliances varies
broadly and can include one-off, short-term, and long-term relationships. With time, criminal and terrorist
groups may develop a capacity to engage in both Financial Crime and Illicit Financial outflows into their
criminal and terrorist activities, thus forming entities that display the characteristics of both groups.
Financial crime is a broad term used to describe criminal activities that involve money or other financial
resources. It refers to any illegal activity that involves the use of financial systems, institutions, or instruments for
illicit purposes, typically with the goal of generating profits for the perpetrators.
Financial crimes can take many different forms:
1. Money laundering
2. Fraud,
3. Embezzlement,
4. Insider trading or Fraud
5. Cybercrime.
6. Bribery and Corruption
Who Commit these Crimes?
These crimes are often committed by:
 Individuals
 groups of People
 Governmental and Non-Governmental Organizational
 Banking and other Financial Institutions Seeking to profit
From illegal activities,
 Such as drug trafficking,
 Human trafficking, or
 Terrorism.
 Rebel Wars
Figure 1.2 Crime-terror nexus

Financial crime is a complex and ever-evolving problem that requires a multifaceted approach to combat. This
includes all Leadership sector, the Law enforcement agencies, regulatory bodies, and financial institutions all play
important roles in detecting and preventing financial crimes. Leaders should implement Effective measures to
combat financial crime include strengthening anti-money laundering and counter-terrorist financing regulations,
enhancing cross-border cooperation, and leveraging technology and data analytics to identify suspicious
activities.
Financial Crimes are criminal activities carried out by individuals or criminal organizations to provide
economic benefits through illegal methods. Financial crimes, which have become a critical issue in recent
years worldwide, cause significant harm to the economy and society of Africa. Income from financial crimes
corresponds to a substantial proportion of global GDP. Therefore, regulatory bodies constantly develop new
tactics to combat financial crimes. In addition, with the development of technology, criminals develop new
tactics. Today's most common financial crimes are terrorist financing, money laundering, corruption,
and fraud.
Money laundering is the process of turning earnings from crime into legal earnings. Cartels and gangs are the
most common money launderers. Some sophisticated techniques may include different financial institutions
such as accountants, shell companies, and financial and consulting institutions. These criminal organizations
use assets that make money laundering and increase complexity to finance money laundering in illegal money
transfers between countries and terrorism. As a result, regulators have obliged financial institutions to
implement various controls to prevent financial crimes. These are commonly referred to as "anti-money

laundering obligations." Organizations that do not fulfill their AML obligations are punished with fines by
regulatory bodies.
THE ILLICIT TRADE FINANCIAL OUTFLOWS IN AFRICA
Financial crime
Demystification of Financial Crime Chronologically
 Financial crime is crime committed against property, involving the unlawful conversion of the
ownership of property (belonging to one person) to one's own personal use and benefit. Financial
crimes may involve fraud (cheque fraud, credit card fraud, mortgage fraud, medical fraud, corporate
fraud, securities fraud (including insider trading), bank fraud, insurance fraud, market manipulation,
payment (point of sale) fraud, health care fraud); theft; scams or confidence tricks; tax
evasion; bribery; sedition; embezzlement; identity theft; money laundering;
and forgery and counterfeiting, including the production of counterfeit money and consumer goods.
Financial crimes may involve additional criminal acts, such as computer crime and elder abuse and
even violent crimes such as robbery, armed robbery or murder. Financial crimes may be carried out by
individuals, corporations, or by organized crime groups. Victims may include individuals,
corporations, governments, and entire economies.
Law enforcement often classifies larger forms of financial collusion as criminal syndicates.
 Bribery
The U.S. introduced the Foreign Corrupt Practices Act in 1977 to address bribery of foreign officials. This
legislation dominated international anti-corruption enforcement until around 2010 when other countries
began introducing broader and more robust legislation, notably the United Kingdom Bribery Act
2010.[1][2]
The International Organization for Standardization introduced an international anti-bribery
management system standard in 2016.[3]
In recent years, cooperation in enforcement action between
countries has increased.[4]
Main Types of Financial Crime
 Money Laundering:
Money laundering is a financial crime that involves disguising the proceeds of illegal activities such as drug
trafficking, bribery, or fraud as legitimate funds. The goal is to make the funds appear legitimate so they can
be used without detection. This process usually involves a series of transactions that makes it difficult to trace
the origin of the funds.

 Terrorist Financing:
Terrorist financing is the process of providing funds or financial support to individuals or groups who carry
out terrorist activities. This can include providing money to purchase weapons or fund terrorist attacks.
 Fraud:
Fraud is a type of financial crime that involves intentionally deceiving someone for personal or financial gain.
Examples of fraud include identity theft, investment scams, and insurance fraud.
 Cybercrime:
Electronic crime, also known as cybercrime, is a type of financial crime that involves the use of computers or
the internet to commit fraudulent activities. This can include hacking into computer systems to steal personal
information, credit card fraud, or phishing scams.
 Bribery and Corruption:
Bribery and corruption are financial crimes that involve offering or accepting money or other benefits in
exchange for favors or preferential treatment. This can occur in government, business, or other sectors.
 Tax Evasion:
Tax evasion is the illegal non-payment or underpayment of taxes by individuals or businesses. This can
involve failing to report income, claiming false deductions, or hiding assets.
 Embezzlement:
Embezzlement is the theft or misappropriation of funds that have been entrusted to someone. This can occur
in a variety of settings, such as in the workplace or in nonprofit organizations.
Market Abuse and Insider Dealing:
Market abuse and insider dealing involve using inside information to make financial gains or manipulate
markets. This can include insider trading, spreading false rumors, or manipulating stock prices.
• Information Security:
Information security involves protecting sensitive information from unauthorized access or disclosure. This
can include theft of personal information, hacking into computer systems, or corporate espionage.
Demystified details of financial crime
For most countries, money laundering and terrorist financing raise significant issues with regard to
prevention, detection and prosecution. Sophisticated techniques used to launder money and finance terrorism
add to the complexity of these issues. Such sophisticated techniques may involve different types of financial

institutions; multiple financial transactions; the use of intermediaries, such as financial advisers, accountants,
shell corporations and other service providers; transfers to, though, and from different countries; and the use
of different financial instruments and other kinds of value-storing assets. Money laundering is, however, a
fundamentally simple concept. It is the process by which proceeds from a criminal activity are disguised to
conceal their true origin. Basically, money laundering involves the proceeds of criminally derived property
rather than the property itself. Money laundering can be defined in a number of ways, most countries
subscribe to the definition adopted by the United Nations Convention Against Illicit Traffic in Narcotic Drugs
and Psychotropic Substances (1988) (Vienna Convention) and the United Nations Convention Against
Transnational Organized Crime (2000) (Palermo Convention):
i. The conversion or transfer of property, knowing that such property is derived from any
(drug trafficking) offense or offenses or from an act of participation in such offense or
offenses, for the purpose of concealing or disguising the illicit origin of the property or of
assisting any person who is involved in the commission of such an offense or offenses to
evade the legal consequences of his actions;
ii. The concealment or disguise of the true nature, source, location, disposition, movement,
rights with respect to, or ownership of property, knowing that such property is derived from
an offense or offenses or from an act of participation in such an offense or offenses, and;
iii. The acquisition, possession or use of property, knowing at the time of receipt that such
property was derived from an offense or offenses or from an act of Participation in such
offense or offenses.
iv. The Financial Action Task Force on Money Laundering (FATF), which is recognized as
the international standard setter for Anti-money Laundering (AML) efforts, defines the
term "money laundering" briefly as "the processing of criminal proceeds to disguise their
illegal origin" in order to "legitimize" the ill-gotten gains of crime.
In 2005, money laundering within the financial industry in the UK was believed to amount to £25bn a
year.[5]
In 2009, a United Nations Office on Drugs and Crime (UNODC) study [6]
estimated that criminal
proceeds amounted to 3.6% of global GDP, with 2.7% (or USD 1.6 trillion) being laundered. [7][8]
The Irish Department of Housing urged minister Darragh O’Brien to “ask in the strongest terms for the UAE
to account for its relationship to Daniel Kinahan” a drug kingpin charged along with his brother, Christopher
Kinahan in 2018 by the High Court of controlling and managing the daily drug operations in Ireland. The
Kinahan brothers are sons of the Kinahan Cartel founder, Christy Kinahan Senior, who smuggled drugs and
firearms into the UK, Ireland, and mainland Europe for a long. For several years, the Kinahan leadership had
been residing in Dubai, where Daniel denied his involvement in organized crime by defending himself as a
‘high-profile businessman in the professional boxing industry’. According to Panorama investigation, Daniel
has operated in the boxing industry through MTK and simultaneously operated Europe’s biggest money
laundering, drug trafficking, and gangland executions networks from Dubai. A spokesperson for minister
O’Brien said, “respect for human rights is a cornerstone of Ireland’s foreign policy,” when asked if the
minister would raise the concerns regarding Daniel’s presence and operations in Dubai on his visit in March
2022 for St Patrick’s Day.[9] [10]

Fraud
In 2005, fraud within the financial industry was estimated to cost the UK £14 billion a year.[5]
Law enforcement agencies
There are law enforcement agencies whose main enforcement activities focus on criminal violations of their
country's tax code and related financial crimes, such as money laundering, currency violations, tax-related
identity theft fraud, and terrorist financing. Some of these law enforcement agencies are:
 Australia - Australian Taxation Office
 Canada - Canada Revenue Agency
 Mexico - Unidad de Inteligencia Financiera
 Netherlands - Fiscale Inlichtingen- en Opsporingsdienst
 Nigeria - Economic and Financial Crimes Commission
 United Kingdom - Her Majesty's Revenue & Customs
 United States of America - Internal Revenue Service, Criminal Investigation
 Black market
 Credit card fraud
 Financial Crimes Enforcement Network
 Financing of terrorism
 Fraud
 Greenmail
 Grey market
 Mafia
 Money laundering
 Organized crime
 Securities fraud
 Skimming (casinos)
 Skimming (fraud)
 Structuring (smurfing)
 Tax haven
 White-collar crime
 World Bank residual model
 Wood laundering
MEASURES AGAINST FINANCIAL CRIMES
USA-
There are many national and global organizations to combat financial crimes. For instance, The Financial
Crimes Enforcement Network (Fin-CEN) is a US and Treasury Department's office that collects and analyzes

financial transactions to combat national and international money laundering, terrorist financing, and other
financial crimes. These organizations publish regulations that companies have to comply with. Regulators
impose penalties on organizations that do not comply with regulations. Financial institutions must comply
with compliance regulations such as AML and KYC requirements.
With the development of technology, methods of combating financial crimes are developing. With the
developing Reg-Tech sector in recent years, solutions to combat financial crimes have increased. AML
solutions, developed with artificial intelligence and machine learning methods, enable the detection and
prevention of financial crimes. AML solutions are increasing year by year because manual control methods
are dysfunctional and waste a lot of time.
KENYA, ITALY
The OECD, Kenya, Italy and Germany launched the pilot Africa Academy for Tax and Financial Crime
Investigation at the G20 Africa Partnership conference on 13 June 2017 in Berlin, Germany. Representatives
of the four partners signed a Declaration of Intent to launch this academy, which seeks to strengthen the
capacity of tax and financial crime investigators in tackling illicit financial flows. The sums lost to these
flows, including tax evasion, money laundering, bribery and corruptions are vast. In Africa alone, the 2015
Mbeki report estimates the losses in excess of 50 billion US dollars per year due to illicit financial flows.
Illicit financial flows all thrive in a climate of secrecy, inadequate legal frameworks, tax regulation, poor
enforcement, and weak inter-agency co-operation. Technology and an increasingly borderless world have also
facilitated globalized financial crime, creating further challenges for those charged with investigating and
prosecuting such crimes.
This initiative, supported by the G7 Bari Declaration (May 2017), aims to provide demand-driven
training addressing the specific needs of African countries and building on Africa-wide experiences and best
practices in tackling Financial Crime and illicit financial flows. The Africa Academy Programmes will cover
all aspects of conducting and managing financial investigations, including complex money laundering and the
role of tax investigators, investigative techniques, identifying, freezing & recovering assets, managing
international investigations, and also specialty topics such as VAT/GST fraud.
The Africa Academy is hosted at the Kenya School of Monetary Studies (KSMS) in Nairobi, Keny
SIERRA LEONE
Sierra Leone’s main institutional frameworks for AML/CFT include the following:
 Ministry of Justice (MOJ) is in charge of the legislation on criminal law, as well as on company law and law
on associations and foundations. It also coordinates criminal prosecutions, including those related to ML/TF
and plays some roles in international cooperation, including giving effects to MLA and extradition requests.
 Ministry of Finance (MOF) provides general support and ensures adequate funding for effective
implementation of AML/CFT measures. The Minister is the chair of the Inter-Ministerial Committee which is
the highest oversight body on AML/CFT in the country.

 Ministry of Foreign Affairs (MOFA) is responsible for the communicating designations made by the United
Nations Security Council related to terrorism and proliferation, including notification of changes, to relevant
competent 39 3rd follows up Report of Sierra Leone, May 2010 SIERRA LEONE MUTUAL
EVALUATION REPORT │ 32 authorities. It also serves as the point of contact between Sierra Leone and
the relevant UN Committees.
 Financial Intelligence Unit (FIU) is responsible for receiving and analyzing STRs and other information,
and disseminating the resultant financial intelligence to relevant competent authorities. The FIU is also
GIABA’s focal point on AML/CFT matters in Sierra Leone.
 National Revenue Authority (NRA) is responsible for the implementation of revenue and customs
legislation within Sierra Leone. It is also tasked with the collection of non-tax revenues. The Revenue
Investigation and Intelligence Unit of the NRA handle all investigations which fall within the NRA’s
mandate.
 National Drug Law Enforcement Agency (NDLEA) is mandated to coordinate all issues relating to drug
control, eradicate drug abuse and the primary causes of drug abuse, illicit drug supply and drug-related crime.
Its mandate extends to investigating narcotic offences and related ML.
 Anti-Corruption Commission (ACC) is responsible for investigating allegations of corruption and to take
steps to eradicate or suppress corrupt practices including examining of the practices and procedures of
Government Ministries and other public bodies to identify vulnerabilities for corruption and to perform public
education. It also has power under Section 71 of AML/CFT Act to investigate and prosecute ML cases.
 Sierra Leone Police (SLP) is primarily responsible for law enforcement and crime investigation throughout
Sierra Leone. Its mandates include to prevent crime, protect life and property, detect and prosecute offenders,
maintain public order, ensure safety and security, enhance access to justice and to ensure police primacy for
internal security and safety. The investigative functions of the SLP, including investigation of financial crimes
are conducted by the Criminal Investigation Department (CID).
 Central Intelligence and Security Unit (CISU) functions include the collection and assessment of any
intelligence that may constitute a threat to the security of Sierra Leone and protecting the country from
threats, including terrorism, money laundering and other serious crimes. It also coordinates the
implementation of the Terrorism Prevention (Freezing of International Terrorists Funds and Other Related
Measures) Regulations, 2013.
 Transnational Organized Crime Unit (TOCU) is an inter-agency Unit with mandate to fight illicit trafficking
of drugs and organized crime, including ML. It also supports international and cross-border cooperation
efforts to counter illicit trafficking and other forms of organized crime.
 Courts are responsible for resolving conflicts, prosecuting crimes, suppressing violations of democratic
legality and ensuring the protection of the rights of citizens. The High Court of Sierra Leone has original
jurisdiction for adjudication of cases relating to ML/TF.

 National Minerals Agency (NMA) is responsible for the regulation and supervision of the mining industry.
Amongst other tasks, it issues artisanal miner, dealer and exporter licenses. In respect of applications for
exporter SIERRA LEONE MUTUAL EVALUATION REPORT │ 33 licenses, basic background checks are
conducted including determining the financial status of the applicant. Also the Agency is tasked with the
prevention of mineral smuggling. One part of this role is conducted by Mines Monitoring Officers who have
the authority to search vehicles and persons for illicit minerals. Another component is the reconciliation of the
transaction receipts for the minerals, which is used to demonstrate their origin for export purposes.
 National Tourist Board (NTB) is the prudential regulator for casinos, hotels, restaurants, night clubs, and
tourism handling agency or travel agency. It licenses and regulates the activities of these operators.
 AML/CFT Regulatory and Supervisory Bodies are broadly responsible for the regulation and supervision of
AML/CFT compliance by reporting institutions. The Bank of Sierra Leone supervises financial institutions
and currency exchange and transmission businesses; the Sierra Leone Insurance Commission supervises the
insurance industry; the General Legal Council to supervises legal practitioners; the Institute of Chartered
Accountants of Sierra Leone supervises auditing firms and chartered accountants, while for other reporting
entities which do not have a designated supervisory authority, the AML/CFT Act designates the FIU as the
temporary supervisor until appropriate supervisory authority is designated by law. The Inter-Ministerial
Committee (IMC) is the highest AML/CFT coordination body in Sierra Leone. It is comprised of the Minister
of Finance (Chair); The Attorney General; The Minister of Internal Affairs; Governor of the Central Bank;
and Director of the FIU, and is supported by the Technical Committee which comprises 19 of Sierra Leone’s
key AML/CFT institutions40 (see IO.1).
2. Sierra Leone Extractive Industries Transparency Initiative - https://eiti.org/sierra-leone
3. NMA / Statistics Sierra Leone, 2019
4. NMA
5. Mining Journal, September 2018 supplement. www.mining-journal.com
6. NRA
7. A Report of the Informal Economy in Sierra Leone by Osman Awoto Soltani-Koroma
https://ecastats.uneca.org/acsweb/Portals/0/Economic%20Statistics/AGNA%20Addis/2ESNA%202014/59.pd
f
8.Sierra Leone 2015 Population and Housing Census – Thematic Report on Economic Characteristics,
https://www.statistics.sl/images/StatisticsSL/Documents/Census/2015/sl_2015_phc_thematic_report_on_econ
omic_characteristics.p

NIGERIA
The government of Nigeria has established independent anti-corruption agencies in different sectors of the
economy to fight corruption. In addition, major financial institutions or equity related registrars have
established forms of cooperation with departments involved in the investigation and prosecution of corruption
cases. Even though there is an overlap in duties of the anti-corruption agencies, there are no linkages or any
organizational chart between the agencies; they are all independent of each other. However, the agencies do
exchange information between each other and there exists internal organizational charts in most. This report
sets out to provide an “as detailed as possible” view of each agency, their respective duties, contribution and
interaction with other agencies which are related directly or indirectly to the “Anti-Corruption” fight in
Nigeria.
Featured Agencies
The featured agencies are those which were considered to play a large part within the investigation and
prosecution process, either practically or by providing sufficient and regulated
Paper trails or information:
1. The Independent Corrupt Practices and other related Offences Commission (ICPC)
2. The Economic and Financial Crimes Commission (EFCC)
3. The Code of Conduct Bureau (CCB) and Code of Conduct Tribunal (CCT)
4. The Nigerian Police Force (NPF)
5. Nigerian Extractive Industries Transparency Initiative (NEITI)
6. Bureau of Public Procurement (BPP)
7. The Federal Ministry of Justice (FMJ)
8. The Nigerian Financial Intelligence Unit (NFIU)
9. Special Control Unit Against Money Laundering (SCUML)
10. Public Complaint Commission (PCC)
11. Central Bank of Nigeria (CBN)
12. Other Agencies
13. Other agencies added to the map are interactions which only occur to cement evidence or
Provide helpful legal advice:
14. Real Estate Developers Association of Nigeria (REDAN)
15. Nigerian Bar Association (NBA)
16. Corporate Affairs Commission (CAC)
17. The Securities and Exchange Commission (SEC)
18. Association of Chief Audit Executives of Banks in Nigeria (ACAEBIN)
UK Financial Intelligence Unit
The UK Financial Intelligence Unit (UKFIU) has national responsibility for receiving, analyzing and
disseminating intelligence submitted through the Suspicious Activity Reports (SARs) regime, to share with

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