Money Laundering Controls in Nigeria

INTRODUCTION

This dissertation makes a contribution to the worrying issues of money laundering in Nigeria and the control mechanism within the economy. Money laundering is a global problem which warranted a declaration by the United Nations. The declaration strongly condemns money laundering because it aids the use of financial systems for illicit drug trafficking and other serious crimes such as terrorism. For example the work of Okogbule on (Official corruption and the dynamics of money laundering in Nigeria 2007), and the work Chukwumerie on (Nigeria’s Money Laundering (prohibition) Act, 2004: A tighter noose, 2004), and the work of Chibuike (Ethics in Nigerian Banking, 2004), all these scholars did not give a look at the banking sector in regard to money laundering compliance and if Nigeria, is really regulating according to international practicing. Therefore, that gives the researcher more effort in looking inwards to the banks, since that is where large transaction takes place.

OVERVIEW OF MONEY LAUNDERING

The research project is on Money laundering Control in Nigeria, and how it has been a very serious problem in that country especially in recent times during the civilian administration, (Chukwuemerie, 2006). But it is not only Nigeria, which it’s affecting, it is a menace in the whole world that even requested the United Nations making a declaration strongly condemning laundering of money through the illicit drug trafficking and other serious crime, as well as the use of the financial systems of the states for that purpose, (UN Resolution S- 20/4 D)

Evidence from around the world proves this view. According to Walker, (1999), around “$2.85bn” is been laundered yearly around the globe. Again, for example the United Kingdom Government recently issue a cheque of One hundred and fifty thousand (150,000) pounds to the Attorney General of Nigeria, as part of the proceeds laundered by a former Governor in Nigeria (Joshua Dariye), also a cheque for $2 million belonging to former governor of Bayelsa State, Chief Diepreye Alamieyeseigha, was also returned to Nigeria by the British government and promised to returned the sum of Fourty Million (40,000,000) pounds recovered from some Nigerian Government Officials; (Oyedele, 2008)

THE INTERNATIONAL FIGHT AGAINST MONEY LAUNDERING

Money laundering has been a global problem since the beginning of the 20th century. Uche (2007) relate that there were 12 multilateral drug treaties between 1912 and 1972. These treaties helped in regulating the manufacturing and trading of drugs worldwide (United Nations, 1987). For instance, Nadelemann (1988) reports the United Nations’ adoption of the ideals of Vienna Convention on illicit traffic of narcotic drugs and psychotropic substances. The convention emphasises on tracking down the wealth of money launderers.

Article 5(2) of the Vienna convention provides that each party must enact domestic laws to enable it to identify, trace, seize, freeze, and forfeit all manner of profit derived from or used in Money laundering offences. Further all member nations are required to assist other member within their territory in the fight against money laundering offences; (Article 5(4b)).

In 1990, the Council of Europe convention on Laundering, search, seizure and confiscation of the proceeds from crime was adopted. And one of the notable differences is that it goes beyond drug related crimes.

The wolfsberg, this are group of eleven banks that came together to fight money laundering. The group was formed in the year 2000, at Chateau Wolfsberg in north east of Switzerland; the group released their anti money laundering principles to their correspondence banks, all in order to fight money laundering.

The Financial Action Task Force (FATF) is an inter-governmental body whose purpose is the development and promotion ofnational and international policies to combat money laundering and terrorist financing.The FATF is therefore a ‘policy-making body’ created in 1989that works to generate the necessary political will to bring aboutlegislative and regulatory reforms in these areas. The FATF has published 40+9Recommendations in order to meet this objective.

For example, the case of former Nigerian Head of State (Gen. Sani Abacha), $675.2m; 75.3m GBP; were all recovered by the government of Nigeria, with the assistance of the other countries were the money was laundered; (Shehu, 2004).

MONEY LAUNDERING IN NIGERIA

Okogbule (2007) argue that money laundering was relatively unknown in Nigeria up to the mid 1980’s. Further, he relate that it is now being used as a means of corruption in every segment of Nigerian society. For this reason, the military government enacted a decree (which decree and when was it enacted) . Thereafter, the civilian administration that came in 1999 repealed the decree and came up with the Money Laundering (Prohibition) Act of 2004 which gave birth to the Economic and Financial Crimes Commission (EFCC). Pursuant to the Act, the commission is empowered to investigate and prosecute any person or corporate body who commit any act of money laundering. For instance, a former governor in Nigeria was charged with money laundering offence for bringing into the United Kingdom the sum of 3.2 Million Dollars in 2005 (Guardian Newspaper, 2005).

Reiterating the laundering issue, the Chairman of Economic and Financial Crimes Commission (EFCC), Mrs. Farida Waziri mentioned that the Nigerian government lost over 285 Billion Naira in 10 years. These tend support the argument that there is a regulation gap in the regulation of money laundering in Nigeria. It is in context that this research intends to look at money laundering regulations in Nigeria, so as to contribute towards developing the country.

THE SCOPE OF THE STUDY

The scope of the study will focus on the effectiveness money laundering regulation in the Nigerian Banking sector, and whether the Nigerian authorities have anything to learn from, how Money laundering is dealt with in the world (International Standard)?

AIMS OF THE STUDY

The main focus of the dissertation is to find out the effectiveness of money-laundering regulations in regards to banks in Nigeria, and compare it with the international standard.

The extent of money laundering in Nigeria

The effectiveness of money laundering regulations in Nigeria

The international standard on Money laundering Control

What lessons Nigeria can learn from that

Chapter Two: LITERATURE REVIEW

CONCEPT OF MONEY LAUNDERING

“Money laundering can generally be defined as the process of converting or transferring Criminal proceeds with the intention of disguising their illicit origin (UN, 2000: Art. 3(a)(i)). The extent of the problem becomes clear, considering that, in 1996, the International Monetary Fund (IMF) estimated the money laundering business at around 2-5 per cent of the world’s gross domestic product (Camdessus, 1998), which amounts to up to US$1.5 trillion (Financial Action Task Force – FATF, 2007). Moreover, it is claimed that the money laundering business is the third biggest industry worldwide following “the international oil trade and foreign exchange” (Preller, 2007, pp 234).

In one of the definitions it says conversion transfer of any property, knowing such property is gotten from drug related offense or even acting in the scheme to conceal the true information of the origin of such property in order to protect such person from facing the legal consequences of his/her action.

FATF organization defines money laundering as a concise “the processing of …criminal proceeds to disguise their illegal origin” in order to “legitimize” the ill gotten gain of crime.

Law Dictionary (1990) refers to it as an “investment or other transfer of money flowing from racketeering, drug transactions, and other illegal sources into legitimate channels so that its original source cannot be traced”.

Money laundering has been defined as a way funds obtained from illegal sources, and put into an account that cannot be traced for possible action; Okogbule, (2007). It has also been described as “the processing of funds derived from illegal or illegitimate sources, through legal financial channels with a view to legitimizing and concealing or disguising the source of such funds” (Osinbajo and Ajayi, 1991, Okogbule, 2007).

THE EXTENT OF MONEY LAUNDERING IN NIGERIA

Money laundering was not a prominent crime in Nigeria until the late 1980s, during the period of an oil boom with a tremendous increase in the level of revenue and commercial activities in the country (Okogbule, 2007, pp 52).

Therefore, the issue of money laundering in Nigeria it is now through the official corruption, which has been exploited by public officers in Nigeria, who incorporate companies and use as a conduit pipe by awarding some phoney contracts and lodge the money through the companies bank accounts, both in Nigeria and abroad, several millions or even billions of naira are transferred from the government treasuries (Okogbule 2007).

The former Chairman of the Economic and Financial Crimes Commission (Nuhu Ribadu), told the BBC in 2006, that $380bn had been stolen or wasted in Nigeria since independence.

“That $140m had been recovered from one unnamed former Nigerian leader and that nearly $400m of illegally gained assets had been identified in the possession of a former governor of Bayelsa State. Last year, Nigeria recovered $458m found in Swiss bank accounts linked to the country’s late military ruler Sani Abacha. Mr Abacha was in power from 1993 to 1998 and is thought to have embezzled billions of dollars. Last year his son, Abba Sani Abacha, was charged with money laundering and fraud after being extradited to Switzerland”.

According to Chukwuemerie, (2006), rate of financial crimes in Nigeria project a bad image abroad. And how Nigerians are been treated with disdain in the foreign land, again he talks about the crimes related to opening of account by customers, because in Nigeria, before the Money laundering prohibition act 2004, anyone can go and open account without a proper identification.

However, the main issue is “corruption that wears many faces, which are nepotism, bribery, treasury looting, and inflation contract prices, money laundering and advance fee frauds” and most of these crimes are destroying the economy of the country; (Ajayi and Ososami, 2007).

The case of former Head of Sate Gen. Sani Abacha, he was accused with his cronies of “embezzling over $5bn” and which out of the money $2.3bn were stolen direct from the government treasury and the remaining were received as a bribes for contracts. The money was laundered in various foreign bank accounts in UK, USA, Switzerland, Luxembourg, Hong Kong; (Ige, 2002, Shehu, 2004).

“Investigation by the UK financial services authority (FSA), the London Metropolitan Police confirmed that over $1.3bn of Abacha money passed through London”; (Chamberlin, 2002, Shehu, 2004, pp).

Furthermore, according to a study conducted by the Nigerian Trade and Investment Center in UK, shows that about two million Nigerians living in United Kingdom have investments worth almost Ninety four Billion (94bn GBP) pounds. And out of these amounts of money 84bn is in real estate, 7bn in vehicles, while the remaining 3bn is in stocks and shares; (Adesina and Madunagu, 2004, Malgwi, 2004).

Malgwi, (2004), in his paper gives an example of former Head of State Late Gen. Sani Abacha, fakes daughter who duped an American the sum of Seven Million ($7) dollars, with the pretence that her late father left the sum of $100m in the central bank of Nigeria, and the account is coded. Therefore, she need his assistance with some money to bribe the officials of the apex bank to get the money out and he will get thirty (30%) percent of the money.

Quite recently, a serving chief of staff to the governor of Rivers State (Ezebunwo Nyeson Wike), was caught by the Economic and financial Crimes Commission (EFCC), laundering the sum of N4.670 Billion (Four Billion, Six Hundred and Seventy Million Naira), which the commission believes was public money that was diverted into his personal account (Babafemi, 2009). He has since been charged by a court to explain the sources of the money. This is the problem with the country people in position of authority are abusing the trust people repose on them, everyday it is happening even with the money laundering regulation in place.

There is no exact statistics of the amount of money been laundered in Nigeria, but below are some of the high profile cases been prosecuted by the economic and financial crimes commission from 2007 to 2009;

CHAPTER THREE: MONEY LAUNDERING REGULATIONS IN NIGERIA

The phrase money-laundering was not in the Nigerian dictionary, until in the 1980’s which was when it was recognised and efforts were made to deal with the problem by the government. Therefore, there were decrees set by the government of Generals Muhammad Buhari, Ibrahim Babangida and Sani Abacha as heads of state and military president respectively, prohibiting activities related to money-laundering (Exchange Control (Anti Sabotage) Decree No 7 of 1984, National Drug Law Enforcement Agency Decree No 48 of 1989, now Caps No 29 Laws of the federation of Nigeria, 2004; Okogbule, 2007).

1995 decree corrected one of the defects of these laws which limited the activities to Drug traffickers in order to avoid loophole which gave way for the accused person to escape justice when the case is not drug trafficking; (Adekunle, 1999; Okogbule, 2007). It was in this recognition of the defect or inadequacy of the previous Decrees to cover all the aspects of money laundering that gave birth to the enactment of the money-laundering (prohibition) Act, 2003 which covers everything relating to the offence. And after One year of its enactment it was amended through the money-laundering prohibition (Amendment) Act 2004, in order to give the agencies more power to institute an investigation and prosecute offenders (Okogbule, 2007).

However, the amendment was based on two philosophies. Firstly, it was on the need to control the practice of huge financial transactions in Nigeria, since the country is known as a cash society. In the amended Act, it states that no person or corporate body shall make or accept cash payment of sum exceeding N500, 000 or its equivalent in the case of individuals, while in the case of corporate bodies the amount is N2, 000,000, unless the transaction is done through a financial institution, the provision is design to enhance the monitoring capabilities of the regulatory institutions over huge financial transactions and encourage the use of financial institutions (Okogbule, 2007).

However in the second philosophy in the act, it is a directive requiring disclosure of any financial transaction exceeding a certain sum of money.

“Section 2(1) of the Act, state that: A transfer to or from a foreign country funds or security exceeding the sum of $10,000 or its equivalent shall be reported to the central bank of Nigeria”.

And it further said that a report should be made pursuant to the above provision to indicate the nature and amount of transfer, the names and addresses of the sender and receiver of the funds or securities (Okogbule, 2007).

REGULATION OF INSTITUTIONS IN NIGERIA

The money laundering (Prohibition) Act 2004, of Nigeria in section 1 states that no person or corporate body shall, except through transactional institutions, make or accept deposit of a sum exceeding, A, for an individual the sum of N500, 000 or its equivalent in other currency and B, the sum of 2,000,000 for a corporate body, that anything above this should be made through the financial institution likewise for the individual costumer.

In section 2 of the prohibition of money laundering act states that any transaction from or to foreign country of funds or securities exceeding the sum of US $10,000 shall be reported to the central bank of Nigeria (in the act refer to Central Bank) or security and exchange commission.

Again in section 2 sub section 1, states that the report should indicate the nature and the amount of the transfer, the names and addresses of the sender and receivers of the funds or securities.

CUSTOMER DUE DILLIGENCE

However, it is provided in section 5(1) of the Act that before opening an account for or issuing passbook or even entering into any business relationship with a potential customer, the financial institution shall verify the customer’s identity and address.

For individual, he is required to provide proof of his identity by presenting to the financial institution a valid original copy of an official document bearing his names and photograph; Secondly, he is to show proof of his address, by presenting to the financial institution the originals of receipts his/her utilities issued within the last three months by public institution (example, electricity or water bill).

In the case of a body corporate, its proof of identity shall be provided by the presentation of its certificate of incorporation and other valid official documents attesting to the existence of the body corporate. Where a manager, employee, or assignee is delegated by a body corporate to open or operate an account, such a person shall in addition to the requirements specified for private individuals also show proof of a power of attorney granted to him for that purpose.

One important provision in the Act designed to facilitate the detection of money laundering activities is section 6(1). It provides as follows:

When a financial institution is requested to carry out a transaction, whether or not it relates to the laundering of the proceeds of a crime or an act, the financial institution shall seek information from the customer as to the origin and the destination of the funds, the aim of the transaction and the identity of the beneficiary.

In order to make this surveillance function more effective, financial institutions are required within seven days of the transaction to carry out the following actions:

1. Draw up a written report containing all relevant information about the transaction as well as the identity of the principal and where applicable, those of the beneficiary.
2. Take appropriate action to prevent the laundering of the proceeds of a crime or an illegal Act.
3. Send a copy of the report and action taken to the Central Bank, the Commission, the Securities and Exchange Commission, or such other appropriate regulatory authority, as the case may be.

Significantly, any financial institution which fails to comply with the above provisions is guilty of an offence and liable upon conviction to a fine of N1, 000,000 each day for as long as the offence continues.

In order to emphasize the importance of records of transactions, it is provided that these records are to be kept and preserved for at least a period of 10 years, and that the records shall be communicated to the Central Bank, National Drug Law Enforcement Agency (NDLEA), judicial authorities, Customs Officers, and such other persons as the Central Bank may from time to time specify.

However, the mandatory disclosure requirement concerning financial transactions is contained in section 10 of the Act. It is to the effect that a financial institution or casino shall report to the Agency in writing, lodgement or transfer of funds in excess of One million (N1, 000,000) Naira or its equivalent in the case of an individual and Five million (N5, 000,000) Naira or its equivalent in the case of a body corporate. This report is to be submitted within seven days of any single transaction.

And even an ordinary citizen other than a financial institution may voluntarily give information on any transaction, lodgement, or transfer of funds involving the amounts set out above. This ensures that even when a financial institution fails to report as required, information about the transaction still gets to the Agency (See Chukuemerie, 2004, Okogbule, 2007b).

The intent of the provisions is to enable the Agency ascertain the origin of the funds and determine whether to direct a stoppage of the transaction or not. This it can do when acknowledging receipt of such disclosure, report or information received in furtherance of the provisions. If the Agency is unable to ascertain the origin of the funds within a period of 72 hours, it may make a request to the Federal High Court for an order that the funds, accounts, or securities referred to in the report be blocked, and an order made by the Court in pursuance of this provision shall be enforced forthwith.

Section 9(1) of the Act provides that every financial institution shall develop programmes to combat the laundering of proceeds of a crime or other illegal act. These shall include:

1. The designation of compliance officers at management level at its headquarters and at every branch and local office;
2. Regular training programmes for its employees;
3. The centralization of the information collected;
4. The establishment of an internal audit unit to ensure compliance with and ensure the effectiveness of the measures taken to enforce the provisions of the Act

In order to ensure compliance with this provision, the Governor of the Central Bank of Nigeria is empowered to impose a penalty of not less than one million Naira on any financial institution which fails to comply with the above provisions. And that makes it a very important provision since the threat of immediate sanction which could be suspension of the bank’s operating license can engender compliance with the statutory provision.

THE MONEY LAUNDERING OFFENCE IN NIGERIA

The actual money laundering offences are provided for in sections 14 – 18 of the Act which also specify the penalties for such offences. Thus, section 14(1) provides as follows:

Any person who

1. converts or transfers resources or property derived directly or indirectly from illicit traffic c in narcotic drugs or psychotropic substances or any illegal act, with the aim of either concealing or disguising the illicit origin of the resources or property or aiding any person involved in the illicit traffic c in narcotic drugs or psychotropic substances or any other crime or illegal act to evade the legal consequences of his action; or
2. collaborates in concealing or disguising the genuine nature, origin, location disposition, movement or ownership of the resources, property or rights thereto derived directly or indirectly from illicit traffic c in narcotic drugs or psychotropic substances or any other crime or illegal act, commits an offence under this section and is liable on conviction to imprisonment for a term of not less than 2 years or more than 3 years.

Significantly, a person who commits an offence under this subsection shall also be subject to the same penalty notwithstanding the fact that the various acts constituting the offence were committed in different countries or places. It is not difficult to ascertain the rationale behind this provision since, very often; money laundering entails the perpetration of some of the acts in one country and the others in other countries. This brings to the fore the transnational nature of money laundering which has given rise to international concern for its regulation.

Section 16 of the Act provides that any person who:

1. Whether by concealment, removal from jurisdiction, transfer to nominees or otherwise retains the proceeds of a crime or an illegal act on behalf of another person knowing or suspecting such other person to be engaged in a criminal conduct or has benefited from a criminal conduct; or
2. Knowing that any property either in whole or in part directly or indirectly represents another person’s proceeds of a criminal conduct, acquires or uses that property or has possession of it, commits an offence under this Act and is liable on conviction to imprisonment for a term of not less than 5 years or to a fine equivalent to 5 times the value of the proceeds of the criminal conduct or to both such imprisonment and fine.

It is difficult to fashion the rationale for this marked variation in the punishment specified under this section and that provided for in section 14 of the Act relating to the actual conversion or transfer of funds from such criminal or illegal activities which is stated to be not more than three years. Although it may be said that the opportunity created by a willing receptacle could have emboldened the suspect and thus facilitated the commission of the offence, it is nevertheless incongruous to have such marked disparity in the punishment for both kinds of offences, when the level of moral reprehensibility is more for the actual converter or transferor of such illegal funds than the receiver.

THE EFFECTIVENESS OF MONEY LAUNDERING REGULATION IN NIGERIA

The government of former president Obasanjo, of Nigeria was able to start the fight against corruption and money laundering, by presenting the bill Money laundering (Prohibition) Act 2004, before the national assembly which was accented by the government and put into use immediately in order to fight the menace in the country.

However, by the year 2006, the EFCC was able to secure the conviction of the former inspector general of police, Mr Tafa Balogun for several offence mostly on money laundering, by showing that ACT that no one is above the law in the country and it shows that it has the political will to tackle the canker worm of money laundering in all its ramifications (Okogbule, 2007, Chukwuemerie, 2006).

Furthermore, within the first two years of creating the Economic and Financial Crimes Commission in Nigeria, they proved effective and were able to “recovered [sic] more than $1.5bn (N203.5bn) of looted funds and arrested more than 200 people” and out of the 200, 50 people were convicted and recovered $37.1M (N5bn) from import malpractices (Malgwi, 2004).

Again the EFCC was able to secure a plea bargain with a former governor of Edo State of Nigeria, Mr Lucky Igbinedion, which in the agreement consented in refunding the sum of N500M stolen funds and forfeit some of his properties. It was not only Igbinedion that got the plea bargain, Mr Nwude, Mr DSP Alamieyeseigha former governor of Bayelsa State of Nigeria, also enjoy the gesture (Alli, 2008).

However, recently the Chairman of the financial crimes commission in Nigeria, admit that they are not fully enforcing the money laundering regulation in the country while hosting stock broking firms in her office. Waziri said the anti-graft agency would start the immediate enforcement of the provisions of the Money Laundering (Prohibition) Act 2004, and prosecute all stock broking firms that default in their obligation to the suspicious transactions reports and currency transaction reports (Akinsunyi, 2009).

“Under Section 23 of the Money Laundering Act, firms carry on the business of investment and securities (this includes stock broking firms) are designated as financial institutions and there is an obligation on them to file with the Nigerian Financial Intelligence Unit all suspicious transactions, and file with the Nigerian Financial Intelligence Unit all currency transactions above N500, 000 for individuals and the N2 million for companies.”

But all that is done by stock broking firms in the country. And up to extent a an investment firm took a loan of N90 Billion from a bank in order to manipulate the market, but that is between Bank and it is customer, but the utilization of the loan is different which is contrary to Section 20 of the BOFIA and the regulations of the Central Bank of Nigeria (CBN) and carries a jail term of between two and three years. It is also a breach of the Investment and Securities Act (see Thisday Newspaper, August, 2009).

However, this bring us to the issue of reporting system adopted by the Financial Action Task Force and was even part of the Nigerian Money Laundering (Prohibition) Act 2004, which is in section 6 sub-section 1(a) that direct financial and non – financial institutions to draw up a written report on any illegal transaction and submit within seven days to the relevant authorities. That means the Act, is not been followed by the Banks and stock broking firms.

FACTORS FOR AND AGAINST MONEY LAUNDERING REGULATION IN NIGERIA

There is no doubt that with the enactment of the Money Laundering Act 2004 the Nigerian Government has taken a bold step in its efforts to fight against money laundering in the country. However, it is effort and resourcefulness may not bear the required results if the well-known problems of enforcement of law in the country are not adequately addressed in the provisions.

It is a common feature in Nigeria that individuals and institutions prefer to subvert laid down rules rather than comply with them, for example the recent banks audit conducted by the new Central Bank Governor, it shows how reckless the banks are operating, given out a loan of N490 Billion without a collateral, which form part of analysis in given out to loan to any customer by a bank and is used to settle out the debt in case the loan goes bad, but they ignore that and give out the money without following the laid down rules. The assurance being that even when they fail to comply, officials from the regulatory institutions will always compromise their positions. This brings to the fore the popularity of corruption in the country as such officers are often ‘settled’ to overlook noncompliance with statutory provisions (Okogbule, 2007).

In such situation, there is usually an unethical alliance between regulatory officers on the hand and the defaulting financial institutions. Therefore, there will be inadequate or ineffective enforcement of the rules, to the detriment of the country.

However, recently an upright officer (Barrister Abubakar Abba Umar) with the Corporate Affairs Commission (CAC) in Nigeria lost his life in the course of his duty. He was involved in making the organisation a very good place that it suppose to be, because to get a company registered in Nigeria, it might take you two to three months, but his coming within a day after full verification you can get your company registered. While in course of investigation of certificate fraud in the organisation, he was forced to hand over some lawyers involve to EFCC for prosecution (see Leadership newspaper, 2009), seeing all this thing happening nobody will like to give himself up in order to do a good job in fighting money laundering in Nigeria.

According to Andrew (2004, pp 173), he argues that the Act “is faithfully implemented by Economic and Financial Crimes Commission, the Central Bank of Nigeria, the National Drug Law Enforcement Agency and the Minister of Commerce”, this relevant authorities are the ones in positions to see the implementation of the Act to the later. However, if they did not enforce the implementation concurrently together, there is every chance that the Act, will not be effective as it suppose to be in checkmating the money laundering activities in the country.

There is also problem of regular monitoring of the activities of these financial institutions.

Inspectorate and Compliance Officers are known to be lax in their monitoring of the operations of these institutions, due to the fact that they are conniving together to subvert the law regulating the institutions (see Okogbule, 2007).

The bankers are not reporting illegal transaction to the relevant authorities even if they knew where or how the money comes about; all they are after is to have a customer with a large amount to deposit with their bank due to stiff competition in the banking sector of the country. According to Andrew (2004), opined that some "banks might count themselves lucky to have large volume of illicit funds deposit with them" (Andrew, 2004, pp 179) and such banks collide with the money launderers in order to keep the money safe and will even keep it away the regulatory agency, which they are directed to report to on such illegal activities, for example the sum of N7.5 Billion, was found in one account of the former Inspector General of Police in a bank. The banks really don't report any illegal activities within their businesses, but recently the Central Bank of Nigeria issue a circular directing all the banks to appoint a reporting officer and be reporting any irregular activity within the banks (see Dailytrust Newspaper).

One of the effective regulations is the provision of Section 12, which empowers the commission to tap any telephone line or place it under surveillance, obtain access to computer system, place any bank account under surveillance or obtain communication of any authentic instrument or private contract together with bank, financial and commercial records. All this can be used if the person suspected use account, telephone, computer to perpetrate his/her crimes (Andrew, 2004).

Chapter Four: The International Standard

THE INTERNATIONAL STANDARD ON MONEY LAUNDERING CONTROL

There is no exact figure of money laundering around the globe, but as suggested by the former International Monetary Fund managing Director Camdesus in 1998, around $800 billion to $2 trillion is been laundered which is around 2 - 5 percent of the global GDP (Reuter and Truman, 2005).

Therefore, the fight against money laundering within the international community is long standing. In the year 1990 the Financial Action Task Force brought out the forty recommendations in the fight against money laundering, which were endorsed by over 130 countries. By 2001, it expanded it is mandate in order to deal with the issue of terrorism financing after September 11, 2001 attack (Shanin, 2006).

However, by the year 2000, a number of world leading banks (known as wolfsberg) came together to compliment the effort of the Financial Action Task Force, in conjunction with transparency international, to set a goal in the fight against the money laundering activity within the banking sector, with the aim of improving the standard applied in combating money laundering. Though the principles are a non - binding set of goals, they are regarded as best guidelines for governing and maintaining a relationship between Banks and customer (Hinterseer, 2001; Haynes, 2004).

Furthermore, the reason for the coming together of these world major leading banks was to create common standards to reduce the uncertainties and complexities resulting from running multinational banks across disparate anti money laundering regime. Again the set of requirements are more tasking than what is practice in most of the states where the banks operate (Haynes, 2004).

FINANCIAL ACTION TASK FORCE RECOMMENDATIONS

CUSTOMER DUE DILIGENCE AND RECORD KEEPING

Recommendation 1 - 3 of the Financial Action Task Force, is all about criminalising the Money Laundering offence, as it was declared at the United Nation conference, that all countries should criminalise money laundering.

Nigeria, have since criminalise the all these according to the directive of the United Nation which it is a member, and is been carried out diligently by the relevant authority with the responsibility. Again a specific punishment of six months in prison was declared, but the Nigerian Money Laundering (Prohibition) Act 2004, seven years was stated and option of fine which is going to be twice what was laundered or serve both punishment.

The first principle of the Wolfsberg, which is the primary objective of the financial institutions groups, is to ensure that the services offered by banks and their world -wide operations are not abused for criminal purposes. This means that banks should only accept clients whose sources of funds and wealth are established as legitimate (Hinterseer, 2001). And when you look at the principle and that of Financial Action Task Force (FATF) which is in Recommendation 5 "Should not keep anonymous accounts or accounts obviously with fictitious names" said know your client, and by means no bank should keep an anonymous account and should not enter into or maintain commercial relationship with a counter party whose true identity cannot be readily identified, or whose activity reveal a questionable pattern of activity.

Hinterseer (2001) argues that the principles state that money laundering is best fought at the placement stage (which is the first stage of the criminal activity); by instituting checks and disclosure requirements in order to make it difficult for criminally tainted money from entering the financial system.

The recommendation 5 of the Financial Action Task force states the measures to be taken in identifying a customer, they are as follows;

1. Identifying the customer and verifying that customer's identity using reliable, independent source documents, data or information.
2. Identifying the beneficial owner, and taking reasonable measures to verify the identity of the beneficial owner such that the financial institution is satisfied that it knows who the beneficial owner is. For legal persons and arrangements this should include financial institutions taking reasonable measures to understand the ownership and control structure of the customer.
3. Obtaining information on the purpose and intended nature of the business relationship.
4. Conducting ongoing due diligence on the business relationship and scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions being conducted are consistent with the institution's knowledge of the customer, their business and risk profile, including, where necessary, the source of funds.

Where the financial institutions are not satisfied with the information from sub - section (a - c) they reserve the right not to open an account, commence business relation or perform transaction; or they can even terminate the business relationship and consider writing a report on suspicious transaction in relation to the customer.

Therefore when we go back to the Nigeria money laundering (Prohibition) Act 2004, there are provisions for Customer Due Diligence, but they are not been carried out by the financial institutions completely. The information was contained in the report of the follow up that was carried out by the Inter - Governmental Group Action against Money Laundering in West Africa in May, 2009.

The provision relating to the Political Exposed Person in Recommendation 6 of FATF, states that before commencing a business relationship with the customer the institution must have appropriate risk management system, which will determine whether the customer is politically exposed or not. Again the branch should obtain a senior management approval before establishing a relationship with the customer and take a reasonable step to establish the sources of the funds and an ongoing monitoring of the business relationship. According to Financial Action Task Force, "Politically Exposed Persons" (PEPs) are individuals who are or have been entrusted with prominent public functions in a foreign country, for example Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials. Business relationships with family members or close associates of PEPs involve reputational risks similar to those with PEPs themselves. The definition is not intended to cover middle ranking or more junior individuals in the foregoing categories.

In relationship to the Political Exposed Person, the (2004) Money Laundering (Prohibition) Act was silence on it, until recently when the Central Bank Of Nigeria, issue a circular directing the Banks to start implementing the anti money laundering Act 2004, that such was included in directive. But the directive of Central Bank of Nigeria cannot supersede the National Assembly Act.

In recommendation 12, the customer due diligence and record-keeping requirements set out in Recommendations 5, 6, and 8 to 11 apply to designated non-financial businesses and professions in the following situations:

1. Casinos - when customers engage in financial transactions equal to or above the applicable designated threshold.
2. Real estate agents - when they are involved in transactions for their client concerning the buying and selling of real estate.
3. Dealers in precious metals and dealers in precious stones - when they engage in any cash transaction with a customer equal to or above the applicable designated threshold.
4. Lawyers, notaries, other independent legal professionals and accountants when they prepare for or carry out transactions for their client concerning the following activities:
   • Buying and selling of real estate;
   • Managing of client money, securities or other assets;
   • Management of bank, savings or securities accounts;
   • Organisation of contributions for the creation, operation or management of companies; and
   • Creation, operation or management of legal persons or arrangements, and buying and selling of business entities.

This recommendation has been partially implemented by the Nigerian Financial institutions, but not the extent of what is required.

REPORTING OF SUSPICIOUS TRANSACTION AND COMPLIANCE

The reporting of suspicious transaction in the financial institution, the bank or any institution that are engaged in form of financial activity, have become an obligatory.

In Recommendation 13 of the FATF, it states as follow;

If financial institution suspect or has a reasonable grounds to suspect that funds are proceeds of criminal activity or related to terrorist financing, it is required by law or regulation to report promptly it is suspicious the financial intelligence unit (FIU).

However, Recommendation 14 shells the financial institution from any legal action that the individual customer might take due to the disclosure of his information by the institution.

The Directors, Officers and Employees are going to be protected from Criminal and Civil liability for breach of any restriction on disclosure of information impose by the contract or by any legislative, regulatory or administrative provision, if they report their suspicious in good faith to the FIU, even if they did not know precisely what the underlying criminal was, and regardless of whether illegal activity actually occurred.

And prohibited by law from disclosing the fact that a suspicious transaction report or related information is being reported to FIU.

This recommendation has also been carried out partially by financial institutions, even though it is part of the Money Laundering (prohibition) Act 2004, and it supposed to be carried out judiciously by Banks to report all suspicious transaction.

In recommendation 15, financial institutions are required to develop programmes against money laundering and terrorist financing within the institution. These programmes should include:

1. The development of internal policies, procedures and controls, including appropriate compliance management arrangements, and adequate screening procedures to ensure high standards when hiring employees.
2. An ongoing employee training programme.
3. An audit functions to test the system.

They are being asked to train their staffs/employees in the fight against money laundering in the financial institution and to provide an internal control mechanism to check any illegal activity.

This is also in the 2004 Act on Money Laundering Regulation, but the Banks are not fully implementing it to the later. And all this contribute to the large scale of money laundering in Nigeria. There should be a reporting Officer who is supposed to work independently without interference by Banks Officials when handling any issue of suspicious transaction and such officer is to report directly to the appropriate authority, all this are not been effectively implemented. Of recent we have seen how banks CEO's have turn the bank into a personal property, a former CEO of Intercontinental Bank Plc, in Nigeria diverted the sum of 10 million pounds into his personal account in the UK.

REGULATION AND SUPERVISION

Recommendation 23 stated that, Countries should ensure that financial institutions are subject to adequate regulation and supervision and are effectively implementing the FATF Recommendations. Competent authorities should take the necessary legal or regulatory measures to prevent criminals or their associates from holding or being the beneficial owner of a significant or controlling interest or holding a management function in a financial institution.

For financial institutions subject to the Core Principles, the regulatory and supervisory measures that apply for prudential purposes and which are also relevant to money laundering, should apply in a similar manner for anti-money laundering and terrorist financing purposes.

Other financial institutions should be licensed or registered and appropriately regulated, and subject to supervision or oversight for anti-money laundering purposes, having regard to the risk of money laundering or terrorist financing in that sector. At a minimum, businesses providing a service of money or value transfer, or of money or currency changing should be licensed or registered, and subject to effective systems for monitoring and ensuring compliance with national requirements to combat money laundering and terrorist financing.

Recommendation 24 also stated that designated non-financial businesses and professions should be subject to regulatory and supervisory measures as set out below.

Countries should ensure that the other categories of designated non-financial businesses and professions are subject to effective systems for monitoring and ensuring their compliance with requirements to combat money laundering and terrorist financing. This should be performed on a risk-sensitive basis. This may be performed by a government authority or by an appropriate self-regulatory organisation, provided that such an organisation can ensure that its members comply with their obligations to combat money laundering and terrorist financing.

However, recommendation 25 state that competent authorities should establish guidelines, and provide feedback which will assist financial institutions and designated non-financial businesses and professions in applying national measures to combat money laundering and terrorist financing, and in particular, in detecting and reporting suspicious transactions.

However, there are regulatory body overseeing the activities of the financial institutions in Nigeria, but the body saddled with the responsibility of fighting Money Laundering in the country are not the regulatory agency for the banks and it makes it difficult for them to get all the reporting system they required to fight the menace. And again, they don't have much experience staffs that will detect money laundering in the banks due to it is nature, that is complicated (Okogbule, 2007).

THE UNITED NATIONS FIGHT AGAINST MONEY LAUNDERING

International concern about global problems date as far back as the League of Nations which was formed as a result of experience of the First World War (1914 - 1919), the experiment of the League of Nations in the collective security was collapsed with the outbreak of the world war two in 1939. There have been effort to address problems related to crime as far back as 1950s, the first time United Nation were committed to fight against organised crime was in 1975, during the Geneva Convention 12 September (Shehu, 2005).

The 1988 convention against illicit Traffic in Narcotic Drugs and Psychotropic Substance, which improved on both the single convention of 1961 on Narcotic Drugs, amended in 1972 with convention on Psychotropic Substances of 1971. The convention creates offences and spelt out specific sanctions and procedure for the confiscation of the crime proceed in Article 3 and 5. Article 3b(i) provides legal definition of what constitute money laundering (Shehu).

Article 5 (1-9) enjoin all member states to adopt such measure as maybe necessary to enable confiscation of the proceeds derived from offences established in Article 3. The parties are enjoined to adopt measures to identify, trace and freeze or sized the proceeds, properties or any other thing referred to under the definition in paragraph b (i) of article 3. It was based on the provision of 1988 convention, that many national laws against money laundering are derived, with modifications to suit domestic (Shehu, 2005).

Article 7 of the 2000 convention introduces additional measures aimed at enlisting the support of financial institutions and others, in preventing the use of financial systems to laundered illicit funds and for detecting and tracing of suspected funds of criminal origin. And such measures include reporting requirement for individuals and businesses that move substantial amount of cash and negotiable instruments across the borders.

Article 27 (1-3) of the convention provides for law enforcement cooperation in combating money laundering, which includes adoption of special investigation techniques, such as controlled deliveries and other forms of surveillance on the movement of the proceeds of crime or property associated with serious crime. It emphasis on the importance of exchange of information and coordination of administrative and other measures to detect the proceeds of crime, and encourage member state to enter into bilateral or multilateral agreement or arrangement on direct cooperation between their law enforcement agencies where necessary and appropriate (Shehu, 2005).

Article 28 establishes knowledge intent and purposes as elements of an offence which is similar to that of Nigerian Money Laundering (Prohibition) Act.

'Knowledge, intent or purpose required as an element of an offence established in accordance with this convention may be inferred from objective factual circumstances.'

Seeking to address the contentious issue of bank secrecy, Article 40 stated that:

'Each state party shall ensure that, in the case of domestic criminal investigations of offences established in accordance with this convention, there are appropriate mechanisms available within its domestic legal system to overcome obstacles that may arise out of the application of bank secrecy laws.'

THE WOLFSBERG PRINCIPLES

The wolfsberg principles are essentially Global anti money laundering guidelines for private banks which was drafted by some of the world largest banks in the world. The development of the principles on money laundering guidelines by the group of banks might be "surprising why should banks sit together and draft another legislation containing due diligence or as some say's know your customer principles?" (Bauer and Peter, 2002, pp 69).

Bauer and Peter (2002), there are argument for and against such initiatives but it is a positive principle by the banks sending a clear signal that they do not need dirty money. But almost everyone committing financial crimes uses the banking system; banks are usually mentioned in connection with such crime especially in true case of money laundering.

The principle is to be applied globally, which means that banks have to apply these standards in all their locations even if local law will not require such standards.

The principles include the common due diligence procedures for opening and keeping watch over accounts especially those identify as belonging to politically exposed person (PEP), who may combine corruption with drug money. The main objectives of the wolfsberg initiative are to bring leaders of private banking to cooperate in fighting money laundering 'outside competitive businesses (Shehu, 2005).

CHAPTER FIVE: THE COMPARISON BETWEEN NIGERIAN MONEY LAUNDERING AND BEST PRACTICE

CUSTOMER DUE DILIGENCE

There is no statement in the Money Laundering (Prohibition) Act 2004, which explicitly prohibits the opening or maintaining of numbered or anonymous accounts. Therefore, the requirement by Law to conduct CDD is not extended to all of the situations required by the FATF recommendations, particularly where doubts are raised as to previously obtained customer due diligence information for occasional transactions above $5,000 USD, that are not cash, when there is a suspicion of terrorist financing and for occasional transactions that are wire transfers. Again, there is no legal requirement to conduct risk assessment in order to determine the risk posed by existing customers.

The reporting requirement for occasional transactions that are wire transfer is USD 5,000, which exceeds the FATF standard of $1,000 US Dollars. There is no clear obligation to identify and take reasonable measures to verify the beneficial owner for all customers, including determining whether the customer is acting on his/her own behalf, in order to understand the ownership/control structure of the legal entity, and determine the natural persons who exercise control over the entity.

POLITICALLY EXPOSED PERSONS

However, in the Nigeria Money Laundering (Prohibition) Act 2004, did not clearly identified or define Politically Exposed Persons (PEPs) as required according to FATF standards. Again, no clear guidance that states what enhanced CDD measures banks must take for those customers or beneficial owners who become PEPs subsequent to establishing a business relationship, although the Central Bank of Nigeria, has issued a circular to banks to start implementing that as a requirement for conducting a business relations with a Politically Exposed Persons, but there is no law backing it in order to carry-out such directives.

The provision relating to the Political Exposed Person in Recommendation 6 of FATF, states that before commencing a business relationship with the customer the institution must have appropriate risk management system, which will determine whether the customer is politically exposed or not. Again the branch should obtain a senior management approval before establishing a relationship with the customer and take a reasonable step to establish the sources of the funds and an ongoing monitoring of the business relationship. According to Financial Action Task Force, "Politically Exposed Persons" (PEPs) are individuals who are or have been entrusted with prominent public functions in a foreign country, for example Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials. Business relationships with family members or close associates of PEPs involve reputational risks similar to those with PEPs themselves. The definition is not intended to cover middle ranking or more junior individuals in the foregoing categories.

CORRESPONDENT BANKING

As the international practice required, correspondent banking should be identified it has not been in Nigeria either by Law or regulation.

RECORD KEEPING

The manner of preservation of information by some banks does not meet required industry standard. There is concern that some sectors are not meeting record keeping requirements. The on-site supervision by the competent authorities is inconsistent and covers only a small percentage of the financial sector.

REPORTING

The financial institutions are obliged to report any unusual transactions to the Economic and Financials Crime Commission (EFCC), of that transaction in writing after seven days of the said transaction, it will be too late by the time the authorities knows about the said transaction. There is no any definition of unusual transaction in Nigeria Money Laundering (prohibition) Act 2004, and no consistency in guidelines issued to all reporting institutions.

The reporting of suspicious transaction in the financial institution, the bank or any institution that are engaged in form of financial activity, have become an obligatory.

In Recommendation 13 of the FATF, it states as follow;

If financial institution suspect or has a reasonable grounds to suspect that funds are proceeds of criminal activity or related to terrorist financing, it is required by law or regulation to report promptly it is suspicious the financial intelligence unit (FIU).

INTERNAL CONTROLS, COMPLIANCE AND AUDIT

In the 2004 Money Laundering (Prohibition) Act, there is no specific provision indicating that the compliance officer must have timely access to customer identification and other customer due diligence information, transaction records and other relevant information. And requirement to have screening procedures to ensure high standards when hiring all employees, no framework to establish the adequacy and appropriateness of the internal policies, lastly the compliance officers are not independent.

SHELL BANKS

However, there is no any provision in the law that prohibits the establishment or operation of shell banks in Nigeria, and no legal requirement for banks to ensure that respondent financial institutions in a foreign country do not permit their account to be used by shell banks.

However, Recommendation 14 shells the financial institution from any legal action that the individual customer might take due to the disclosure of his information by the institution.

1. The Directors, Officers and Employees are going to be protected from Criminal and Civil liability for breach of any restriction on disclosure of information impose by the contract or by any legislative, regulatory or administrative provision, if they report their suspicious in good faith to the FIU, even if they did not know precisely what the underlying criminal was, and regardless of whether illegal activity actually occurred.
2. And prohibited by law from disclosing the fact that a suspicious transaction report or related information is being reported to FIU.

REGULATION, SUPERVISION AND MONITORING

there are significant number of informal currency exchange providers in Nigeria, that are operating in the open and unregulated manner, the number of inspection specifically focused on AML/CFT is very low, and a significant number of sectors seemed to have escaped supervision of compliance with its AML/CFT obligations. Again, there is over reliance on Nigerian Financial Intelligence Unit (NFIU) for delivery of ongoing onsite AML/CFT supervisory programmes, one of the many factors that are affecting effectiveness of the AML/CFT framework.

However, according to Financial Action Task Force in Recommendation 23, states that;

Countries should ensure that financial institutions are subject to adequate regulation and supervision and are effectively implementing the FATF Recommendations. Competent authorities should take the necessary legal or regulatory measures to prevent criminals or their associates from holding or being the beneficial owner of a significant or controlling interest or holding a management function in a financial institution.

For financial institutions subject to the Core Principles, the regulatory and supervisory measures that apply for prudential purposes and which are also relevant to money laundering, should apply in a similar manner for anti-money laundering and terrorist financing purposes.

Other financial institutions should be licensed or registered and appropriately regulated, and subject to supervision or oversight for anti-money laundering purposes, having regard to the risk of money laundering or terrorist financing in that sector.

Again, in Recommendation 24 part b, it states that:

Countries should ensure that the other categories of designated non-financial businesses and professions are subject to effective systems for monitoring and ensuring their compliance with requirements to combat money laundering and terrorist financing. This should be performed on a risk-sensitive basis. This may be performed by a government authority or by an appropriate self-regulatory organisation, provided that such an organisation can ensure that its members comply with their obligations to combat money laundering and terrorist financing.

However, recommendation 25 state that competent authorities should establish guidelines, and provide feedback which will assist financial institutions and designated non-financial businesses and professions in applying national measures to combat money laundering and terrorist financing, and in particular, in detecting and reporting suspicious transactions.

CHAPTER SIX: METHODOLOGY

INTRODUCTION

This chapter deals with the method used for conducting this research work. This study aimed to Strategic Analysis of Retail Logistic in UK Industry using Tesco Plc as a case. The methodology that will be adopted in this study is the Qualitative Research Design. This method will help the researcher gather more in depth information about the topic at hand and could provide more information from other perspective which may lead to future direction of the institution

Rationale for the Research Strategy Design (Qualitative Research Design)

A research strategy as defined by Naoum (2007:37) is the method in "which the research objectives can be questioned" and based on his book he categorized the research design to be of two types: qualitative research and the quantitative research. The qualitative research is "grounded in an essential constructivist philosophical position" and is concerned with how the "complexities of the socio cultural world are experienced, interpreted and understood in a particular context and at an exact point in time" (Blomberg and Volpe, 2008). The qualitative research gives a holistic approach by examining social situation which allows the author to enter the 'world of others'.

The qualitative research focuses on descriptions and discovery, and the objectives are focused on extracting and interpreting meanings of experiences (Denzin and Lincoln, 2003, Naoum, 2007, Blomberg and Volpe, 2008).This is different from the quantitative approach which rather investigates problems based on testing a hypothesis or a theory composed of variables, usually numerically and analysed with statistical procedures, in order to determine whether the hypothesis or the theory is true (Breach 2009, Naoum 2007, Creswell 1994). Based on this information the author decided to use the qualitative methods as a form of research strategy because it most addressed the research purpose.

Quality of Qualitative Research

Qualitative research has all the problems its detractors claim. It produces new puzzles more frequently than it solves old ones. Its contributions to disciplined science are slow and tedious. The ethical risks in performing it are substantial. The cost of qualitative research in terms of time and money is very high. And it is subjective. Yet Creswell (1998) sees qualitative research sharing good company with the most rigorous quantitative research, and arguing that it should not be viewed as an easy substitute for quantitative study. The quality of qualitative work stems from a strong inquiry procedure with well-established protocols that both the researcher and reader follow. While these standards ensure that the work is trustworthy, Crabtree and Miller (1999) argued that the ultimate test of qualitative studies is that the work carries sufficient conviction to enable someone else to have the same experience as the original observer and to appreciate the truth of the account. In other words, good methods are important but what really matters is good thinking.

Place for Qualitative Research

The world is full of alternative research methodologies. According to Crabtree and Miller (1999), the best way to judge the merits of a methodology is by how well the method relates to the problem at hand. Recognizing this allows us to let go of specious distinctions between research traditions-distinctions that simply encourage conflict and disagreement. By being willing to accept alternative methodologies, we can expand the range of problems we can address because we have more ways of doing so. And by being able to deal with more problems we can generate new knowledge. Qualitative research is thus of benefit to use because it allows us to better understand phenomena embedded in situations through complex relationships.

Source of Data Collection

Such information are sourced primarily and secondarily and it involves various past literatures, journals about logistics and SCM and its effect on retail industry as relates to the analysis of Tesco company. Also included are published articles and textbooks were also studied.

The primary data will be base on Tesco data reports while secondary data to be used in this study will be obtained from various databases like emeralds, inspect which deals on issues relating to retails logistics in UK in various forms such as journals, and news papers, articles, books, reports, internet and codes of practice journals and news papers, articles, books, reports, internet and codes of practice journal, textbooks as the data collection technique from other research thesis and data from Tesco Plc. These sources will form the basis content for the literature review as secondary data is easy to locate, less expensive and could provide comparative and contextual data which may lead to unforeseen and new discoveries as Saunders et al.(2007) section 7.2 supports.

Limitations

Any author of a thesis has to be aware of the limitations and strengths of the particular research conducted and should be able to share that assessment with those reading the thesis. The circumstances of this thesis have been described earlier. They account for two limitations. The first limitation arises from the extended period for conducting this thesis research. As regards the first limitation; a thesis needs a base from which to start. This is particularly important for the literature review. This raises a difficulty: what was contemporary at the beginning, in 1997, is now superseded by subsequent academic writings. Using a document from 1997 or 1998 as a base, would appear to a reader in 2009 as rather dated. The second limitation is lack of time to conduct interviews and distribution of questionnaires. The company has continued to develop its logistics and supply chain strategy during the intervening years. The dilemma facing the author is how to address these dichotomies with credibility.

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Financial Action Task Force, Recommendation, 1

Financial Action Task Force, Recommendation, 2

Financial Action Task Force, Recommendation, 3

Financial Action Task Force, Recommendation, 5

Financial Action Task Force, Recommendation, 6

Financial Action Task Force, Recommendation, 11

Financial Action Task Force, Recommendation, 12

Financial Action Task Force, Recommendation, 13

Financial Action Task Force, Recommendation, 14

Financial Action Task Force, Recommendation, 15

Financial Action Task Force, Recommendation, 23

Financial Action Task Force, Recommendation, 24

Financial Action Task Force, Recommendation, 25