A practical, compliance-ready checklist of money laundering red flags across five categories, drawn from CBN, NFIU, and FATF guidance.
1. Document the red flag
Record the specific indicator, transaction or customer details, and the date identified. This creates the compliance audit trail.
2. Conduct enhanced due diligence
Obtain source of funds, source of wealth, and supporting documentation. Do not tip off the customer that an STR may be filed.
3. Escalate to your MLRO
All red flags must be escalated to the Money Laundering Reporting Officer for a suspicion determination.
4. File an STR if suspicion is formed
Under the ML(PP)A 2022, an STR must be filed via goAML within 24 hours. Suspicion, not certainty, is the legal test.
5. Continue monitoring
Even after filing an STR, continue to monitor the account and document subsequent activity.
AI Shield Nexus monitors every transaction channel for the red flags above, with automatic case creation and STR drafting.
What are the most common money laundering red flags in Nigeria?
Structuring of cash deposits below CTR thresholds, unusual international wire transfers, customers unwilling to provide source of funds, and transactions inconsistent with known business activity.
Are banks legally required to act on red flags?
Yes. Under the ML(PP)A 2022 and CBN AML/CFT Regulations, banks must escalate red flags to their MLRO and file STRs within 24 hours of forming suspicion.