MONEY LAUNDERING: A VIEW FROM A DEVELOPING COUNTRY

By Chibuike U Uche Department of Banking and Finance University of Nigeria Enugu Campus NigeriaNigeria

MONEY LAUNDERING: A VIEW FROM A DEVELOPING COUNTRY Introduction In recent years, there has been a rising interest in the study of money laundering.1 Unfortunately, most of the literature has focused on money laundering from the perspective of developed countries. International opinion and policies aimed at combating money laundering have also been designed based mainly on the needs of the developed countries.2 Why the reasons for this may be obvious, it is an unhealthy development. This is because money laundering is truly an international phenomenon. Money launderers are always loo ing for ways of disguising the true source of their wealth. !ome developing countries have characteristics that money launderers find attractive. Understanding the social, political and economic environment of these developing countries is therefore a vital ingredient in the war against money laundering. This paper will attempt to raise awareness of the importance of developing countries in the fight against money laundering. It will use "igeria, which promulgated a money laundering law in 1##$, as a case study. In general, the paper e%amines the whole problem of money laundering from the perspective of developing countries and indeed their financial institutions. It argues that the greatest danger to the success of international efforts to tac le money laundering is the ever
1

Money &aundering has been defined as the process by which criminals attempt to conceal the true origin and ownership of the proceeds of their criminal activity '(rage, 1##2, p.)1*+. 2 !ee Uche, 1##*, pp.22$,22-. 1

increasing disparity in the structure of the financial systems of both developed and developing countries. The greatest threat to the business of laundering is documentation. .ven after the launderers have beaten the system, their success may well be temporary. They leave a documentation trail. The story in countries with underdeveloped payments system is different. Most of the economy is underground and cash transactions are the rule rather than the e%ception. /ery little, if any, documentation trail is left. 0urthermore, the paper argues that the current economic crisis in many of the underdeveloped countries is also a cog on the wheel of the fight against money laundering. Under pressure from the IM0 and the World 1an , many of these countries have launched !tructural 2d3ustment 4rograms '!24s+. 1ecause of !24, 5overnments of many of these developing countries have inadvertently encouraged large flows of foreign capital into the country, with very little scrutiny as to its source, all in the name of deregulation. In addition, economic liberalisation brought about increased competition among financial institutions in developing countries. This in itself may be an incentive for some financial institutions in such countries to pay lip service to money laundering rules. Origins of Money Laundering Regulationsof Money Laundering Regulations Money laundering is by no means a new activity. It has e%isted as long as criminals needed to disguise the illicit origins of their funds.6 The recent burst of regulations on this sub3ect is however lin ed with the rise in drug traffic ing in the industrialised parts of the world, mainly the U!2 and Western .urope. 0or instance, it is estimated that the sale of cocaine, heroine and cannabis amount to appro%imately U!7 122 billion per year in the U!2 and .urope. $8, 98: of this amount or as much as U!7*$ billion a year could be available for laundering and investment.) There are two main reasons for the increasing concern in drug traffic ing. 0irst is the negative social and political impact of the drug problem. In a 1#*# report, the ;ommonwealth <eads of 5overnment= recalled their long,standing concern at the incidence of drug abuse and illicit traffic ing, activities which had now grown to the e%tent that they posed an actual threat to the 5overnance of some countries. They recognised that the drug problem was escalating at an alarming rate so as to represent both a serious obstacle to the processes of social and economic domestic development and a threat to the international community, to which small states are especially vulnerable.$ The second reason is the increasing recognition of the negative impact which enormous flows of illicit money can have on the financial sector. It is in this connection that the 1asle ;ommittee on 1an ing >egulation and !upervisory 4ractices asserted that= 4ublic confidence in ban s, and hence their stability, can be undermined by adverse publicity as a result of inadvertent association by ban s with criminals. In addition, ban s may lay themselves open to direct losses from fraud, either
6
)

/erwoerd, 1##$, p.v. 0inancial Tas 0orce, 1##8, !ection 2. $ ;ommonwealth <eads of 5overnment Meeting '1#*#, para $-+. 2

through negligence in screening undesirable customers or where the integrity of their own officers have been undermined, through association with criminals.In tac ling the above problems, the affected countries can do little on their own. This is so mainly because of the international nature of money laundering. 0or instance, it has been noted that= The laundering of the proceeds of crime is truly an international phenomenon. "o longer are operations limited to the country in which the illicit money is generated. ?n the contrary, the transborder movement of money is now a prominent feature of laundering operations.9 .vidence from around the world supports this view. It is, for instance, estimated that >odri@ueA 5acha laundered U!7 168 million of Medellin ;artel proceeds using *2 company and other accounts in 1- countries. 2lso, in the B4olar ;apB case, it is believed that U! 71.2 billion of cocaine proceeds was laundered for the Medellin ;artel through a complicated system of false gold and 3ewellery businesses in the United !tates. 0unds were ban ed in the United !tates, then transferred to 4anama and thence to accounts in .urope and !outh 2merica.* 0urthermore a recent analysis of the ;anadian money laundering police files revealed that over *8: had an international dimension.# The obvious way out, therefore, was through international co,operation. Multilateral agreements on money laundering have been in e%istence, at least since the beginning of the twentieth century. 1etween 1#12 and 1#92, no less than 12 multilateral drug control treaties were concluded. .fforts were then mainly directed at the regulation of the supply and movement of drugs with a view to limiting their manufacture and import to the @uantities re@uired for legitimate medical and scientific purposes.18 In 1#**, with the adoption of the United "ations ;onvention against Illicit Traffic in "arcotic (rugs and 4sychotropic !ubstances '/ienna ;onvention+, there was a fundamental change in approach. This agreement places great emphasis on trac ing down the illicit wealth of the money launderers. !uch an approach is usually defended on the following grounds= '1+ insofar as criminals act as they do for the money, the best deterrent and punishment is to confiscate their incentiveC '2+ while the higher level and more powerful criminals rarely come into contact with the illicit goods, such as drugs, from which they derive their profits, they do come into contact with the proceeds from the sale of those goods. That contact often provides a Bpaper trailB or other evidence, which constitutes the only connection with a violation of the law andC '6+ confiscating the proceeds of criminal activities is a good way to ma e law enforcement pay for itself.11 2rticle 6 of the /ienna ;onvention re@uire countries to, among others things, establish as criminal offences under its domestic law, activities such as the production, manufacture, distribution or sale of illicit drugs and the organisation, management or financing of illicit traffic ing,
;ommittee on 1an ing >egulations and !upervisory 4ractices '1#**, p.2+. Duoted in 5ilmore, 1##2, p.%. * !herman, 1##6, p.1). # 5ilmore, 1##6, p.2. 18 United "ations, 1#*9, para -. 11 "adelmann '1#*-, p.6)+.
9

when committed intentionallyC the conversion or transfer of property nowing that such property is derived from any of the above offence's+C the concealment or disguise of the true nature, source, location, disposition, movements, rights with respect to, or ownership of property, nowing that such property is derived from any of the above offence's+. 2rticle $'2+ of the /ienna ;onvention further provides that each party must enact domestic laws to enable it to identify, trace, seiAe, freeAe, and forfeit all manner of profit derived from or used in money laundering offences. It further re@uires each party to assist other parties upon re@uest to identify, trace, freeAe, seiAe or forfeit proceeds, property, instrumentality or any other thing within its territory that was used or intended to be used in money laundering offences 'article $')b+. 2nother important provision of the /ienna ;onvention is contained in article $'6+ which re@uires each party to empower its courts or other competent authorities to order that ban , financial or commercial records be made available or be seiAed in order to help trac drug offenders. 2 party cannot decline to comply with this provision on the ground of ban secrecy. There have also been other initiatives. In the main, these agreements have reinforced the principles of the /ienna ;onvention. In 1##8, for instance, the ;ouncil of .urope ;onvention on &aundering, !earch, !eiAure and ;onfiscation of the 4roceeds from ;rime was adopted. 2 notable difference between this and the 1#** /ienna ;onvention is the fact that its definition of money laundering goes far beyond drug related revenues. This approach has been defended on the grounds that= The international community, through the adoption of the 1#** ;onvention, has e%pressed its universal abhorrence of drug,related money laundering. <owever... there would seem to be little policy 3ustification for the proscription of money laundering arising from some profit,generating criminal activities and not others. (ouble standards, particularly in criminal law, are not conducive to the maintenance of the rule of law or to international co,operation, and there may be difficulties in proving that particular proceeds are attributable to particular predicate offences. In any event, drug traffic ing may not remain,or for that matter,still be the most profitable form of transborder criminal activity.12 The 0inancial 2ction Tas 0orce '02T0+16 1##8 report on money laundering, which placed great emphasis on the role of the financial system,1) also recommended the following three measures as being central to the plan against money laundering= '1+ each
12
16

Duoted in 5ilmore '1##6, p.$+. .stablished in 1#*# by the <eads of !tate or 5overnment of seven ma3or industrial nations and the 4resident of the ;ommission of the .uropean ;ommunities. Its functions include to assess the results of the ;upertino already underta en to prevent the utilisation of the ban ing system and financial institutions for the purpose of money laundering, and to consider additional preventive efforts in this field, including the adaptation of the statutory and regulatory systems to enhance multilateral legal assistance. 1) >ecommendations #,2# of the report, which treat the sub3ect of enhancement of the role of the financial system, are regarded as being of central importance Thus the <ead of the 0inancial 2ffairs division of the ?.;( once remar ed= BThe common thread underlying these recommendations is the view that financial institutions are the ey element in the detection of illicit transactions given their uni@ue function in a countryEs payment system and in the collection and transfer of financial assets. This is reflected in the heavy emphasis put on the identification of customers and beneficial owners, the availability of ade@uate record eeping systems, the necessary diligence of financial institutions in respect of unusual transactions and the development of inhouse anti,money laundering programmes 'Duoted in 5ilmore, 1##6, p.9+. )

country should, without further delay, ta e steps to fully implement the /ienna convention and proceed to ratify itC '2+ financial institutions secrecy laws should be conceived so as not to inhibit implementation of the recommendations of this group andC '6+ an effective money laundering enforcement programme should include increased multilateral co,operation and mutual legal assistance in money laundering investigations and prosecutions and e%traditions in money laundering cases where possible.1$ It is in the fulfillment of the re@uirement for "ational legislation that the "igerian 5overnment promulgated the 1##$ Money &aundering (ecree. The Nigerian Money Laundering DecreeNigerian Money Laundering Decree 2 landmar development in the fight against drug traffic ing and other types of fraud in "igeria was the promulgation, in 1##$, of the Money &aundering (ecree. Though this is an integral part of an international effort, which started mainly to curtail drug traffic ing, its adoption in "igeria is particularly notable given the reputation of the country for fraud, corruption and drug traffic ing.1- 4erhaps because of its origins, it is not surprising that the "igerian Money &aundering (ecree meets most of the recommendations of the above international initiatives, e%ceeding then in a number of cases. The ob3ectives of the Money &aundering (ecree include, among others, to ensure that a documentary trail is left in all money laundering transactions through ban s and to forge a closer lin between ban s and the "ational (rug &aw enforcement 2gency '"(&.2+ all with the aim of preventing and trac ing down money launderers. The decree, for instance, limits the amount of cash transactions, in the country, to "$88,888.88 in the case of an individual and "2,888,888.88 in the case of a corporate body.19 Transactions above these limits shall be disclosed to the "(&.2, in writing, within 9 days.1* 2lso, the "(&.2 may, in order to identify and locate narcotic drugs and psychotropic substances, proceeds, property, ob3ects or other things related to the commission of a money laundering offence= 'a+ place any ban account and account comparable to a ban account under surveillanceC 'b+ place under surveillance or tap any telephone lineC 'c+ have access to any computer systemC and 'd+ obtain communication or any authentic instrument or private contract, together with all ban , financial and commercial record, when the account, telephone line, or computer system is used or may be used by any person suspected of performing or ta ing part in a transaction involving the proceeds, property or things or when the instrument, contract or record concern or may concern the transaction.1# 2dditionally, any transfer, to or from a foreign country, of funds or securities of a sum greater than 718,888 or its e@uivalent shall be reported to the ;entral 1an of "igeria ';1"+.28 .ven casinos are now re@uired to verify the identities of all gamblers who buy, bring into or e%change chips or to ens, by re@uiring gamblers to present authentic documents bearing their names and addresses. 2lso, casinos are re@uired to record all the above transactions in chronological orders indicating the nature and amount involved in
1$ 1-

02T0, 1##8, section iii 'a+. Uche, 1##*, p.228.

!ection 1. !ection 18. 1# !ection 12 28 !ection 2. "ote that the decree is not specific as to which party is supposed to ma e the report to ;1".
19 1*

each transaction and each gamblerEs name and address.21 ?ther provisions of the decree include a mechanism for registering and regulating businesses that carry out over the counter e%change transactionsC22 a re@uirement for financial institutions to verify its customers identity before opening up an account for, issuing a passport to, entering into a fiduciary transaction with, renting a safe deposit bo% to or establishing any other business relationship with the customerC26 a re@uirement that all records created in complying with the decree are to be preserved for a period of at least ten yearsC2) procedures for arousing money laundering awareness among the employees of financial institutions.2$ 0inally, ban ing secrecy cannot be invo ed as an ob3ection to any of the above measures.2- Military style tribunals established under the !pecial Tribunal 'Miscellaneous ?ffence+ (ecree 1#*), as amended try offences under this decree. 2lso penalties for offences under the decree are severe and wide ranging including long 3ail sentences, heavy fines and forfeiture of assets. (espite stringent regulations, it will be erroneous to e%pect the volume of the money laundering in the country to ta e a dive 3ust because a decree has been promulgated. Whatever good intentions the 5overnment may have, the fight against laundering, in a developing country li e "igeria, will be a difficult one for several reasons, both structural and otherwise. Problems of combating money launderingof combating money laundering The poor ban ing habit among "igerians29 remains the greatest asset to money launderers and thus a predicament to an effective money laundering policy in the country. Though the Money &aundering (ecree prohibits cash transactions above "$88,888 and "2,888,888 for individuals and companies respectively and re@uires the reporting of ban ing transactions above these limits to the "(&.2, the practicality of such regulations are doubtful especially in the cash and carry economy prevalent in many developing countries including "igeria. !uch regulations no doubt can be effective in countries with advanced financial systems where large cash transactions are unnecessary and thus naturally raise suspicion. The same cannot be said of "igeria where large cash transactions though unsafe, are not uncommon. !everal factors have contributed to the above situation. The vast siAe of the country has slowed the development of a ban ing habit. This is especially so given the underdeveloped nature of the countryEs infrastructure especially the communication system. 5iven the limited number of ban branches and the total absence of ban ing facilities in many places, ban ing contact is impossible for a large section of the population and a great number of financial transactions are still carried on outside the ban ing system.2* 2 second reason for the
!ection ). !ection 6. 26 !ection $. 2) !ection 9. 2$ !ection #. 2!ection 12. BThe phrase Eban ing habitE is an omnibus one, covering not only economic psychology with respect to ban s but also the ob3ective economic facts and practices of people with regard to the use of ban ing facilities and their asset,holding patterns. Whatever meaning is attached to the Eban ing habitE, "igeria is a country which is only beginning to ac@uire the ban ing habit to any mar ed e%tent 'Teriba, 1#*-, p.-#+.
21 22 2*

29

Ibid, p.96. -

e%tensive cash and carry nature of the "igerian economy is the widespread distrust, by the populace, in the ban ing system. !uch distrust dates bac to the pre,independence days. 0or instance, between 1#$6 and 1#$), 19 of the 21 indigenous ban s, then in e%istence, collapsed. With no deposit insurance scheme in place and no rescue operation attempted by the colonial monetary authorities, many indegenes had their savings wiped out. 2# There is currently, also, a ban ing crisis going on in "igeria. In 1##*, for instance, 2ban s had their licences revo ed. Though there is a deposit insurance scheme in place, it pays only a ma%imum of "$8,888 per depositor. .ven at that depositors usually have a hard time getting their money. this is in part due to "(I; bureaucracy. 2 third reason for the total lac of trust in the ban ing system is the high incidence of fraud in the entire "igeria system including ban s.68 Unfortunately, despite the good intentions of the 5overnment, it has been difficult to chec this fraud mainly because of the inefficient system of crime investigation and law enforcement in the country.61 >ather than fight for 3ustice with the legal machinery prescribed by law, many people rightly choose to do cash and carry business thus reducing the chances of misunderstanding. There is a widespread belief that the ever,growing sophistication of financial mar ets and institutions will continue to create avenues for money launderers to prosper.62 True= but that is not the main danger. The ever,increasing disparity in the structure of the financial systems of both developed and developing countries will continue to be a valuable asset to money launderers. The greatest threat to the business of laundering is documentation. .ven after the launderers have beaten the system, their success may well be temporary. They live a documentation trail. The story in countries with underdeveloped payments system is different. Most of the economy is underground and cash transactions are the rule rather than the e%ception. /ery little if any documentation trail is left. The current economic crisis in "igeria is also a cog on the wheel of the fight against money laundering. 0aced with declining oil fortunes, and after several years of import control regulations and import licensing, the 1abangida 2dministration, under pressure from the International Monetary 0und and the World 1an , launched the !tructural 2d3ustment 4rogramme '!24+ in Fuly 1#*-. It was designed to achieve
2#

!ee Uche '1##9+ for a detailed e%position of the events that led to the mass failure of indigenous ban s.
68

!ee, for instance, Uche '1##-, p.)6*+.

61

!ummarising the 0ederal 5overnment commissioned report on the ways of reforming and reorganising the ;entral 1an of "igeria, the committee chairman, 4ius ? igbo, claimed that the committee was Bfrightened by the countless number of B)1#B cases around the G;entralH ban and often involving the name of the ban and amounting to scores of billions of dollars. These cases are fully documented and reported to the police. The fault, we are constrained to say, is not so much with the ban as with the system of crime investigation and law enforcement in which the ban finds itselfB '"ewswatch '?ctober 2) 1##), p.62+. The full report is yet to be released by the 5overnment.
62

BThe sophistication of money laundering methods increasingly matches the sophistication of modern financial mar ets, so it is sensible to assume 'as is shown in an increasing number of cases of money laundering+ that non, ban financial institutions can be used as much...GasH ban s, that sophisticated products are becoming as attractive as cash to the money laundered, and that second and third tier mar ets which are currently in early stages of development are as useful to money launderers as the more traditional financial mar ets. f derivatives and hedge funds are not late twentieth century e@uivalents of the eighteenth century !outh !ea 1ubble, law enforcement officers and prosecutors will need specialists in these fields to help guide them through the money movement '<ill, 1##$, p.16+. 9

balance of payment viability by altering and restructuring the production and consumption patterns of the economy, eliminating price distortions, reducing the heavy dependence on consumer goods imports and crude oil e%ports, enhancing the non oil e%port base, rationalise the role of the public sector, accelerate the growth potential of the private sector and achieve sustainable growth.66 To achieve the above ob3ectives, the main strategies of the programme were the adoption of a mar et determined e%change rate for the "aira, reductions in price and administrative controls, more reliance on mar et forces as a ma3or determinant of economic activity and the deregulation of e%ternal trade and payments arrangements. In the bid to achieve the above policy ob3ectives and boost its foreign e%change income, 5overnment inadvertently encouraged large flows of foreign capital into the country with very little scrutiny as to its source all in the name of deregulation. 0urthermore, 5overnment delay in introducing regulation has no doubt made the tas of ridding the economy of money laundering more daunting. 5overnment indecision on how to deal with local fraudstars has, in the past, encouraged fraud. Ta e for instance the infamous advance fee fraud scam. The ingenious design of the scam no doubt led to initial 5overnment reluctance to tac le the problem head,on. In the design of this scam, fraudstars capitalise on the reputation of the country as the most corrupt country in the world, where anything is possible, to dupe foreigners. Most of the "igerian fraud letters, which have turned up in $1 countries all have the same theme= E(ear !ir or Madam, I am a thief who has stolen a lot of money from the 5overnment and I would li e your help to get it out of "igeria.E6) !uch monies are usually non, e%istent. The reward for would be victims are usually a mouth,watering percentage of the stolen money. Those who fall for this bait are then duped in various ways ranging from re@uest for advance payments to help bribe officials in &agos to clearing their ban accounts with signed letter headed paper of the companyIperson deceitfully obtained by the scamstars. The fact that most victims of the B)1#B scam are themselves accomplices to fraud ma e it difficult for them to report their e%periences to the police. 1oth the authorities and the general populace were, at least at the beginning, unsympathetic to their woes. 2s the .conomist noted= "igerians have little sympathy for victims of the scam.... !ome rec on greedy and gullible foreigners are fair game. More persuasively, a recent paper by a deputy governor of the central ban argued that victims should be prosecuted= they, after all, are would,be scamstars themselves, who hoped to 3oin in fraud on the public purse.6$ !uch official assertions, no doubt, encouraged fraudstars some of who began to see themselves as the blac manEs >obin <ood getting repayment from whitemen for slavery and colonialism.666

;1", 1##$, p.).

6)

The Times, 1#I1I#-.

6$

The .conomist, 9th Fanuary 1##$, p.)*.

6-

1oth the 5overnment and the populace completely misconceived the point. There are also domestic problems when homegrown criminals are not e%plicitly discouraged. There is no doubt that the initial victims of the "igerian criminal scams were foreigners. With massive international education and publicity on the ways and means of these "igerian fraudstars, however, most foreigners are now wiser. The attention of these fraudstars is increasingly being turned to the home front with disastrous conse@uences for both business and social relationships. 0urthermore, as recently noted by &amberto (ini, money &aundering leads to the consolidation of the economic power of the power of criminal organisations enabling them to penetrate the legitimate economy.69 This could have disastrous conse@uences for the economy especially when one considers the fact that money launderers generally do not loo for the highest rate of return on the money they launder but for the place or the investment that most easily allows the recycling of the criminally or illegally obtained money even when this re@uires accepting a lower rate of return.6* Ta e for instance a drug baron who decides to launder his ill,gotten wealth by importing goods into "igeria. <is eagerness to get bac his money may lead to his undercutting the legitimate dealers in his chosen area of trade by perhaps selling below the cost price. This will, no doubt, have undesirable conse@uences on the legitimate dealers in that area of trade. 0urthermore, funds from such illegal activities could be used to destabilise the !tate. It has thus been noted that= illicit traffic generates large financial profits and wealth enabling transnational criminal organisations to penetrate, contaminate and corrupt the structures of government, legitimate commercial and financial business, and society at all its levels.6# 4erhaps the 5overnment change of tactics may have been influenced, to some e%tent, by the above possibilities. Conclusion (espite the efforts by the "igerian 5overnment to combat money laundering, it is clear that they can only achieve limited success. The current economic conditions have made it difficult for the 5overnment to effectively police money laundering. .conomic downturn, withdrawal of subsidies and e%ternally influenced economic liberaliAation policies, encourage the 5overnment of developing countries to embrace laundered money or at least turn a blind eye on it. 2nother negative conse@uence of the economic downturn is corruption The prevailing harsh economic environment have greatly reduced the resistance of the law enforcement agents to corrupt practices. The underdeveloped nature of the infrastructure and financial system in these developing countries also does not help matters. 2ll these limit the ability of law enforcement
69

Ibid. Duoted in 5ilmore, 1##$, p.2$. TanAi, 1##-, p.-. United "ations '1#**, p.1+. #

6*

6#

agencies to combat money laundering. We must not see this as a problem for the developing countries. Indeed it is more of a problem for the developed countries. 0or one thing, most of the laundered money originates from developed countries.)8 The increasing disparity in the financial systems and law enforcement infrastructure between developing and developed countries will continue to encourage the diversion of laundered money to developing countries. 2ddressing this structural imbalance is therefore essential in the fight against money laundering. This, in my opinion, is the main challenge for all involved in combating money laundering.

)8

The main source of laundered money in developing countries,stolen national wealth, is outside the 3urisdiction of the /ienna convention. 18

REFERENCES ;entral 1an of "igeria, Annual Reports '/arious+. ;entral 1an of "igeria, "o. #$I86, 1##$+. ;ommuni@uJ at the ;ommonwealth <eads of 5overnment Meeting held at Kuala &umpur, Malaysia 1*,2) ?ctober 1#*#, reproduced in 5ilmore,W.;. 'ed+, !nternational Efforts to Combat oney "aundering ';ambridge= 5rotius 4ublications &imited, 1##2+. onetary policy in Nigeria ';1" 1riefs, >esearch (epartment !eries

;ommittee on 1an ing >egulations and !upervisory 4ractices '1an for International !ettlements, #revention of Criminal Use of the Banking $ystem for the #urpose of oney "aundering '1asle, (ecember 1#**+. (rage,F., E;ountering Money &aunderingE, Bank of England %uarterly Bulletin '"ovember 1##2, pp.)1*,)2-+. .conomist '/arious+ 0inancial 2ction Tas 0orce on Money &aundering >eport of - 0ebruary 1##8, reproduced in 5ilmore,W.;. 'ed+, !nternational Efforts to Combat oney "aundering ';ambridge= 5rotius 4ublications &imited, 1##2+. 5ilmore,W.;., EIntroductionE in 5ilmore,W.;. 'ed+, !nternational Efforts to Combat "aundering ';ambridge= 5rotius 4ublications &imited, 1##2+. 5ilmore,W.;., EMoney &aundering= The International 2spectE in MacDueen,<.&. 'ed+ "aundering '.dinburgh= University 4ress, 1##6+. 5ilmore,W,;,. Dirty oney& 'he Evolution of oney "aundering Counter '!trasbourg= ;ouncil of .urope 4ublishing and (ocumentation !ervice, 1##$+. oney oney

easures

11

5overnment of "igeria, Advance Fee Fraud and other Fraud Related (ffences Decree )**+ '2bu3a, 5overnment 4rinters+. 5overnment of "igeria, oney "aundering Decree )**+ '2bu3a, 5overnment 4rinters+.

<erbst,F., Is "igeria a /iable !tateL, 'he ,ashington %uarterly '!pring 1##-, pp.1$1,192+. <ill,;., EMoney &aundering MethodologyE in 4arlour,>. 'ed+ !nternational -uide to oney

"aundering "a. and #ractice '&ondon= 1uttersworths and ;o. 4ublishers &td, 1##$+. International Maritime 1ureau, Nigeria& 'raders at Risk '1##), !pecial >eport+. &evi,M., E>egulating Money &aundering= The (eath of 1an !ecrecy in the UKE, 'he British /ournal of Criminology '!pring 1##1, pp.18#,12$+. "adelmann,..2., EUnlaundering (irty Money 2broad= U.!. 0oreign 4olicy and 0inancial !ecrecy FurisdictionsE, 'he University of *1+. "ewspapers '/arious+. "ewswatch '/arious+. !herman,T., EInternational .fforts to ;ombat Money &aundering= The >ole of the 0inancial 2ction Tas 0orceE in MacDueen,<.&. 'ed+ 1##6+. TanAi,/., EMoney &aundering and the International 0inancial !ystemE, !nternational Fund ,orking #aper 'W4I#-I$$, May 1##-+. onetary oney "aundering '.dinburgh= University 4ress, iami !nter0American "a. Revie. '0all 1#**, pp.66

12

Teriba,?. EThe (evelopment of the 1an ing <abit in "igeriaE in ?ye3ide,2. and !oyode,2. 'eds+ Commercial Banking in Nigeria 'Ibadan= Unibadan 4ublishing ;onsultants, 1#*-+. Uche,;.U., The "igerian 0ailed 1an s (ecree= 2 ;riti@ue, /ournal of !nternational Banking "a. '?ctober 1##-, pp. )6-,))1+. Uche,;.U., 1an ing E!candalE in a 1ritish West 2frican ;olony= The 4olitics of the 2frican ;ontinental 1an ;risis, Financial 1istory Revie. '1##9, pp. $1,-*+. Uche, ;.U., The 2doption of a Money &aundering &aw in "igeria, Fournal of Money &aundering ;ontrol 'Fanuary 1##*, pp.228,22*+. United "ations, E1#*9 United "ations International ;onference on (rug 2buse and Illicit"ations, E1#*9 United "ations International ;onference on (rug 2buse and Illicit Traffic ing= ;omprehensive ?utline of 0uture 2ctivities in (rug 2buse ;ontrolE reproduced in 5ilmore,W.;. 'ed+, !nternational Efforts to Combat 4ublications &imited, 1##2+. United "ations, EUnited "ations ;onvention 2gainst Illicit Traffic in "arcotic (rugs and 4sychotropic !ubstances 2dopted in /ienna on 1# (ecember 1#**E reproduced in 5ilmore,W.;. 'ed+, !nternational Efforts to Combat 4ublications &imited, 1##2+. /erwoerd,&.<., EIntroductionE in 4arlour,>. 'ed+ !nternational -uide to and #ractice '&ondon= 1uttersworths and ;o. 4ublishers &td, 1##$+. oney "aundering "a. oney "aundering ';ambridge= 5rotius oney "aundering ';ambridge= 5rotius

16