AML/CFT

1. WELCOME
Prof. Godwin Emmanuel, Oyedokun
HND (Acct.), BSc. (Acct. Ed), BSc (Acc & Fin), MBA (Acct. & Fin.), MSc. (Acct.), MSc. (Bus & Econs.), MTP (SA), PhD (Fin), PhD (Acct), FCA,
FCTI, ACIB, ACS, MNIM, CNA, FCFIP, FCE, FERP, CICA, CFA, CFE, CIPFA, CPFA, ABR, CertIFR, FFAR
godwinoye@yahoo.com
+2348033737184, +2348055863944 & +2348095491026
Managing Partner
Oyedokun Godwin Emmanuel and Co
(Chartered Accountants, Tax Practitioners & Forensic Auditor)

2. BRIBERY AND CORRUPTION: THE NEW AML AND CFT RULES
BY
PROFESSOR GODWIN OYEDOKUN
BEING A VIRTUAL PAPER PRESENTATION AT THE
ASSOCIATION OF CERTIFIED FRAUD EXAMINERS, LAGOS CHAPTER SEMINAR
HELO ON SATURDAY, OCTOBER 10, 2020.

3. PRESENTATION OUTLINE
▪ INTRODUCTION
▪ CONCEPT OF BRIBERY AND CORRUPTION
▪ CONCEPT OF MONEY LAUNDERING AND TERRORIST FINANCING
▪ NEXUS BETWEEN CORRUPTION AND MONEY LAUNDERING
▪ ANTI MONEY LAUNDERING AND CFT COMPLIANCE RULE
▪ IMPACT OF ANTI MONEY LAUNDERING AND CFT RULE COMPLIANCE
▪ ELEMENTS OF EFFECTIVE AML AND CFT COMPLIANCE AGAINST
BRIBERY AND CORRUPTION
▪ CONCLUSION AND RECOMMENDATION

4. INTRODUCTION
➢ Corruption has fierce impacts on economic and societal development and is
subject to a vast range of institutional, jurisdictional, societal, and economic
conditions.
➢ Over time, Corruption has been exploited to facilitate commission of other
crimes such as drug trafficking, small arms trafficking and illegal currency
trafficking.
➢ It has destroyed the myth that corruption is a domestic political issue amenable
within individual states borders.
➢ Hence the design of anti-corruption and bribery policy like the Anti-Money
laundering (AML) and Combatting the Financing of Terrorism (CFT) rules aimed
at incorporating effective implementation of anti-bribery and corruption
strategy.

5. CONCEPT OF BRIBERY AND CORRUPTION
Corruption, when applied as a technical term, is
a general concept describing any organized,
interdependent system in which part of the
system is either not performing duties it was
originally intended to, or performing them in an
improper way, to the detriment of the system’s
original purpose.
WHAT IS
CORRUPTION
?

6. CONCEPT OF BRIBERY AND CORRUPTION {CONT}
POLITICAL
CORRUPTION
BUREAUCRATIC
CORRUPTION
BRIBERY
FRAUDEMBEZZLEMENT
EXTORTION
FAVOURITISM
DIMENSIONS OF
CORRUPTION

7. CONCEPT OF BRIBERY AND CORRUPTION {CONT}
1 CULTURE AND WEIRD VALUE
SYSTEM
Corruption is at times a motivated
behavior responding to social
pressures to violate the norms, so
as to meet the set goals and
objectives of a social system.
CAUSES OF CORRUPTION
2 POOR REWARD SYSTEM
Cultures that stress economic
success as an important goal but
nevertheless strongly restrict
access to opportunities will have
higher levels of corruption.
3 POOR LEADERSHIP
Bad rules and ineffective taxing system
also makes it difficult to track down
people’s financial activities, and it
breeds corruption.

8. CONCEPT OF MONEY LAUNDERING AND
TERRORIST FINANCING
Money Laundering can be defined as “the act of
disguising the source of any funds, a way of
converting or hiding the source or of moving
any funds contrary to the law.
▪ The money can be from legal or illegal resources.
▪ It might be criminal profits, kickbacks or bribes, or
money hidden to avoid taxes.
▪ Thus through money laundering individuals, companies
or political structures (when corrupt) make use of
illegal profits, obtained through illegal means and
conceal this by making their winnings look lawful
MONEY LAUNDERING?

9. CONCEPT OF MONEY LAUNDERING AND
TERRORIST FINANCING {CONT}
STAGES OF MONEY
LAUNDERING
THE PLACEMENT STAGE
This is the most important because not only
represents the method in which the money
laundering process starts but also because it
gives public authorities the best possibility of
controlling the laundering process by identifying
it and stopping it.

10. STAGES OF MONEY
LAUNDERING
THE LAYERING STAGE
Financial transactions are restructured in order
to conceal or disguise the trail of the illegal
profits, for example by creating a false origin of
the goods. Despite the first stage which gives
the authorities a good chance to identify the
criminal, this stage is more complex for both
parties because often it involves an
international movement of funds.
CONCEPT OF MONEY LAUNDERING AND
TERRORIST FINANCING {CONT}

11. STAGES OF MONEY
LAUNDERING
THE INTEGRATION STAGE
This is the stage through which illegal funds gain
a legitimate origin. Once these funds enter into
the legitimate economy they return to the
criminal through apparent legal means and can
be used for any purposes.
CONCEPT OF MONEY LAUNDERING AND
TERRORIST FINANCING {CONT}

12. CONCEPT OF MONEY LAUNDERING AND
TERRORIST FINANCING {CONT}
TERRORISM
FINANCING
?
Terrorism Financing includes
both legitimate and
illegitimate money
characterized by
concealment of the origin or
intended criminal use of the
funds.

13. CONCEPT OF MONEY LAUNDERING AND
TERRORIST FINANCING {CONT}
SOURCES OF TERRORIST
FINANCING
DRUG TRAFFICKING
RACKETEERING
ABDUCTIONS WITH
RANSOM DEMANDS
TRAFFICKING IN
PRECIOUS STONES
TRAFFICKING IN
HUMAN BEINGS

14. NEXUS BETWEEN CORRUPTION AND MONEY
LAUNDERING
➢ Corruption offenses, such as bribery or theft of public
goods, generate significant amounts of proceeds that
need to be laundered - or “cleaned” - to enter the
financial system without the stigma of illegality.
➢ At the same time, corruption may facilitate money
laundering by using corrupt officials to influence the
process by which proceeds (regardless of the asset-
generating crime they derive from) are laundered,
and enable launderers to escape all controls and
sanctions.
Corruption and
money laundering
are closely linked.

15. ANTI MONEY LAUNDERING AND CFT COMPLIANCE
RULES
➢ Nigeria’s AML/CFT regulatory framework consists of regulatory and
supervisory bodies empowered by their establishment act and other
AML/CFT laws to regulate the entry and operational activities of
their respective operators including issuance of sector specific and
AML/CFT regulations and guidelines, application of administrative
sanctions, etc.
➢ The regulators and supervisors are responsible for the supervision
of the financial institutions and designated non-financial institutions
(DNFIs).
➢ Other bodies which perform supervisory roles such as self-
regulatory bodies, accrediting institutions and other administrative
authorities empowered to regulate the various sectors of the
economy in relation to AML/CFT in Nigeria form part of the
regulatory framework.

16. ANTI MONEY LAUNDERING AND CFT COMPLIANCE
RULES
REGULATORS OF AML AND CFT
CBN
NAICOM
SEC
SCUML
PENCOM
CAC

17. ANTI MONEY LAUNDERING AND CFT COMPLIANCE
RULES
• This must be
done before
any financial
transaction
KNOW YOUR
CUSTOMER
• Risk Evaluation
must be donewhen
dealing with PEPS
POLITICALLY
EXPOSED PERSONS
(PEPs • There should be
due diligence in
identifying
suspicious
transaction
TRANSACTION
REPORTING
• All must be
kept for not
less than 5
years or more
RECORD KEEPING
• Employees must
be trained and
there must be in
line with
compliance of the
rule
AWARENESS AND
TRAINING
AML/CFT RULES

18. ▪ To prevent the financial system from being used for
purposes of money-laundering, particularly through a
general requirement to precisely identify originators, as
well as placing and limitations on certain transactions that
serve as vehicles for money-laundering;
▪ Detection of money-laundering operations through
legislative provisions allowing for the centralization of
information by authorities charged with combating such
operations (reporting suspicions) and implementation of
specialized investigative measures (access to computer
systems and banking information, etc.);
▪ suppression of money-laundering activities and associated
crimes, as well as confiscation measures that are
complements to enforcement, and preventive measures
such as freezing and seizing assets.
OBJECTIVES OF AML/CFT RULES
ANTI MONEY LAUNDERING AND CFT COMPLIANCE
RULES

19. IMPACT OF ANTI MONEY LAUNDERING AND CFT
RULE COMPLIANCE
▪ Detecting illicit activity through AML/CTF practices can lead to the
apprehension not just of one criminal, but a whole string of them –
drug traffickers, terrorists, identity thieves and others who bring
unmeasured heartache and loss to innocent people.
▪ AML/CTF compliance also protects organisation integrity. It
safeguards banks from the reputational damage, penalties and
vulnerabilities that banks experience when concentrations of illicit
funds increase.
▪ AML/CTF compliance actually helps legitimate customers have a
better, more enduring customer experience.

20. ELEMENTS OF EFFECTIVE AML AND CFT AGAINST
BRIBERY AND CORRUPTION
1 ENGAGING PROFESSIONALS
A professional ensures that
reported issues can be addressed in-
house and within a time frame that
would not further expose the
organization to more risk.
2RISK ASSESSMENTS
Risk assessments are important because
they provide an organization on how
significant a risk can be to their AML/CFT
goals.
3. POLICIES AND PROCEDURES
Policies will address key issues,
risk appetites and behaviour
deemed acceptable by the
organisation.
4REPORTING
Having an internal escalation process in
the organisation to report any AML/CFT
or related issues efficiently and swiftly,
without causing necessary disruptions to
business efficiency.
5 MONITORING
An Internal And External Review
Should Be Carried Out Annually To
check Compliance adherence

21. ▪ The responses to the condemnable act of corruption have generated a
reform agenda that will make significant impact on policy making especially
in the regulatory and supervisory sphere.
▪ The challenge will be to look for synergies among the standards and in their
implementation to reduce costs, maximize effectiveness and focus on the
areas that matter most for individual jurisdictions, and those at greater
money laundering risk.
▪ To this end a Robust and effective compliance to AML/CFT regimes/rules is
an important pillar of the international regulatory and supervisory system
that will ensure the protection of societies against the corruption plague.
CONCLUSION