##wittingly. the cbn has, in the past four years, consolidated its efforts in the supervision of the banks, by ensuring that the banks are examined regularly. the cbn has been able to bring together all the regulators in the financial sector, through the workings of the financial services regulation coordinating committee ( frscc ), in order to ensure regulatory efficiency in the financial services sector. we discuss in section 3 below, the areas of concern for the cbn on the issue of compliance. 3. areas of concern for the cbn the cbn has been given an expanded mandate to regulate and supervise the other financial institutions. in addition to the expanded mandate are the tremendous growth of the banking sector and the new policy introduced by the cbn of universal banking. the number of banks in operation is 89 in 2003. however, the branch network has grown considerably, from 2, 220 in 1998 to 2, 984 in 2003. efforts at sanitizing the other financial institutions sub - sector started in 1997 which led to the stipulation of new minimum capital requirements ’ for community banks ( cbs ) and primary mortgage institutions ( pmis ), among other things. the areas of concern for the cbn can be discussed along the following three major dimensions : • identifying financial crime trends and patterns. • strengthening all stakeholders ’ support. • economic impact of money laundering. 3. 1 identifying financial crime trends and patterns in attempting to identify financial crime trends and patterns, effort must be geared towards monitoring the flow of funds to the banks and establishing an efficient customer identification process, with adequate record keeping rules. the cbn recently issued a manual on “ know your customer ” principles and practices. the manual emphasized the need to obtain identification evidence from private individuals, pure corporate customers and quasi corporate customers who establish business relationships with the banks. the manual indicated the vulnerability of receiving bankers / agents to money laundering. the manual was intended to serve as a further guide to the banks and other financial institutions in nigeria on the procedures to adopt for the proper identification of their customers and, therefore, getting to know their customers. additionally, the cbn restructuring / reengineering initiative ( project eagles ) has established some level of information technology that is capable of identifying the methods and patterns used to commit these crimes, particularly the advance fee fraud. when the cbn is fully automated, it will provide the unique capability to identify banking sector - wide trends and patterns associated with money laundering and other financial crimes. currently, the cbn works with the newly - introduced economic and financial crime

and regulatory activities, with a strong effort on enforcing anti - money laundering compliance by the financial sector. the cbn has, in recent times, equipped staff in the sensitive operational areas of the bank with tools that facilitate identifying and tracking the activities of money launders in the financial sector. after the september 11, 2001, attack on the world trade center, united states of america, the global efforts at surveillance increased, with the financial action task force ( fatf ) setting guidelines for identification, monitoring and tracking anti - money laundering activities. the fatf and the united states department of treasury ’ s financial crimes enforcement network ( fincen ) came up with detailed strategies for addressing the menace. these strategies are based on the belief that intensified surveillance will stop the criminals and terrorists using the organized banking services for their funding network, if the operators are vigilant and follow the guidelines established with adequate legislation to back them up. the fatf at its extraordinary, plenary meeting of 29 - 30 october, 2001, agreed to develop special guidelines for financial institutions in the detection of the techniques and mechanisms used in the finance of terrorism. the fatf has since come up with the guidelines and has visited countries with poor legal frameworks, such as nigeria. it has advised and even threatened to blacklist non - cooperating countries, including nigeria. the goal in providing these guidelines is to ensure that financial institutions do not unwittingly hide or move terrorist and criminal funds. this paper which addresses the cbn ’ s standpoint on anti - money laundering compliance, is structured into four sections, with the introduction being section 1. in section 2 we discuss the legal framework on money laundering, with emphasis on the recent amendment to the banks and other financial institutions act ( bofia ). while section 3 focuses on the areas of concern for the cbn. in section four we make some recommendations and concluding remarks. 2. the legal framework on money laundering as specified in bofia nigeria took a bold initiative in the 1980s, to enact the national drug law enforcement agency ( ndlea ) act, no. 48 of 1989. this was to set the stage in confronting the menace of money laundering on economic activities, and to comply with the vienna convention. again, in 1994, the government took another bold step to address bank failure, through checking the activities of money launderers and abuse by insiders in the banking sector, by promulgating the failed banks ( recovery of debt and financial malpractice in banks