Susan has been making her living from crime for over twenty years.  She provides anti-money laundering training and advice to the regulated community in the UK, Guernsey, Jersey, the Isle of Man and Gibraltar, and writes and talks on the subject at every opportunity.  As her hobby she writes historical novels—about financial crime.

I have written a few times before about the interesting stage that all countries go through as their criminals (alongside ordinary people, but I’m less interested in them) transition from cash to non-cash working patterns.  As a jurisdiction’s AML regime beds in, matures and becomes more effective, criminals find it harder and harder to get rid of their cash.  The most recent high-profile example was India – and now it is being noticed in Nigeria.  On 3 February 2017 US$9,772,800 and £74,000 was found in a fire-proof safe in a property in Kaduna (in north-west Nigeria) belonging to Andrew Yakubu, a former director of the national oil company, NNPC.  On 15 March 2017 sacks containing bundles of banknotes totalling US$155,000 were found at Kaduna airport.  And on 13 April 2017 US$43.4 million, £27,800 and 23.2 million naira [about £60,000] were recovered from a deserted Lagos apartment – a haul the local Economic and Financial Crimes Commission (EFCC) described as “humongous”.

EFCC Executive Chairman Ibrahim Magu credits the cash discoveries the whistle-blowing policy put in place by the Nigerian government in December 2016.  As part of this policy, “a whistle-blower responsible for providing the government with information that directly leads to the voluntary return of stolen or concealed funds or assets may be entitled to anywhere between 2.5-5% of amount recovered”.  Perhaps unsurprisingly, within the first three months of the policy being in place, 2,351 reports had been made.  So why have Nigerian criminals been stockpiling cash, rather than paying it into banks as they used to?

Well, in 2012 the Central Bank of Nigeria (CBN) introduced a cash-less policy, taking the view that “high cash usage enables corruption, leakages and money laundering, amongst other cash-related fraudulent activities”.  And on top of that, in February 2014 the CBN implemented the Bank Verification Number scheme.  This is a biometric identification scheme whereby every bank customer in Nigeria is required to turn up at their bank in person and have their biometric details captured and linked to a unique number that can be verified across every account they hold and every transaction they make through any Nigerian bank.  Holders of dodgy accounts used for laundering and the like have been, understandably, reluctant to turn up – which means, in effect, that their accounts are frozen.  Boo hoo.

This piece first appeared on Susan’s blog, I hate money laundering.