Recovering Proceeds of Crime - A Comparative Study of the Nigerian and UK Legal Framework

By 

   Abbia Udofia

     September 2012 

Abstract
Corruption and terrorism have been problems in developing and developed nations alike, with modern terrorism involving increasingly sophisticated technology and methods. Anti-laundering efforts have been established in attempt to overcome the problems, but have been largely unsuccessful, even acting as a deterrent to some legitimate transactions. The following is a comparative analysis of the frameworks in the UK and Nigeria, focusing on the actions of account freezing and handling funds. The research methodology combines the examination of data and literature with primary research of human participants, targeting employees in organisations from Nigeria and the UK. Here, the primary research and primary data is pursued through the use of government legislation, bank policy, and research instrumentation targeting bank managers from the UK and Nigeria. Sampling of human participants for the primary aspect of the original research targets bank managers in Nigeria and the UK, gathering the opinions from 30 managers in each country. Five high ranking managers from each nation were targeted to complete semi-structured interviews (see section 3.5 for details on instrumentation), while the remaining 25 were targeted to complete surveys. The questionnaire results showed specific trends and demands for change within the industry, also showing how the managers have approached their environmental conditions in unique ways, while this is critical to consider in future efforts attempting to improve upon the progress of existing business models. One of the most noteworthy trends is that the UK managers have reported a diligence in development comparable to those reported in Nigeria, but these motivations are present despite the differences in threats to each country. Meanwhile, corruption is so severe in Nigeria that it has affected trends, and likely perspectives. The questionnaire results imply that Nigeria would benefit from adopting security models developed and tested, rather than relying on methods that are considered conventional in the region. Meanwhile, the interview responses support the results of the surveys, showing that the UK managers and companies are more commonly concerned with maintaining levels of security and making improvements as they are needed or in collaboration with legal developments, rather than the general improvements and demands to improve fundamental areas that have been observed in Nigeria. Following a detailed discussion considering implications and potential areas for development, a list of recommendations for research and development are provided. The success of the study is then examined within the conclusion.

Abstract 2
Chapter 1: Introduction 9
1.1 The Problem and Presentation Overview 9
1.2 Background Literature 10
1.2.1 Laundering and Anti-Laundering Efforts 10
1.2.2 General Legislation Issues 11
1.2.3 Anti-laundering Efforts in the UK 13
1.2.4 Dynamics in Nigeria 14
1.2.5 Recovering the Proceeds of Corruption 15
1.3 Aim of Presentation, Research Questions, and Objectives 15
1.4 Research Methods 16
1.4.1 Ethical Issues in the Research Validity, and Reliability 18
1.4.2 Limitations 19
1.5 Structure of Presentation 19
Chapter 2: Literature Review 20
2.1 Introduction 20
2.2 Laundering and Anti-laundering 20
2.3 Anti-laundering and crime prevention efforts in the UK 24
2.4 Laundering and Organisational Challenges in Nigeria 40
2.5 Corruption, Prevention, and Recovering Proceeds 49
2.5.1 Corruption 49
2.5.2 Prevention 56
2.6 Summary 60
Chapter 3: Research Methods 65
3.1 Introduction 65
3.2 Research Design and Direction 65
3.2.1 Research Aims 66
3.2.2 Research Questions and Hypotheses 67
3.2.3 Research Objectives 69
3.3 Sampling 69
3.4 Resources 70
3.5 Instrumentation 70
3.5.1 Survey Questionnaire Items Covered in the Research 72
3.5.2 Semi-structured Interview Questions 74
3.6 Pilot Study 74
3.7 Data Collection 75
3.8 Data Analysis 76
3.9 Limitations 76
3.10 Ethics 77
Chapter 4: Results and Analysis 78
4.1 Introduction 78
4.2 Pilot Study Results 78
4.3 Survey Results 79
4.3.1 Introduction and Background Information 79
4.3.2 Questions 1-6 82
4.3.3 Questions 7-13 98
4.3.4 Questionnaire Summary 122
4.4 Interview Results 123
4.4.1 Introduction 123
4.4.2 Nigerian Participants 123
4.4.3 UK Participants 132
4.4.4 Interview Summary 138
4.5 Summary 139
Chapter 5: Discussion and Further Implications 140
5.1 Introduction 140
5.2 Discussion and Implications 140
5.2.1 Laundering and Organisational Challenges in Nigeria 140
5.2.2 Development in the UK and Implications for UK and Nigerian Development 148
5.3 Summary 167
Chapter 6: Recommendations, Further Research, and Conclusions 169
6.1 Introduction 169
6.2 Recommendations for Practice 169
6.3 Recommendations for Further Research 170
6.4 Conclusion 171
References 174
Appendices 185
Appendix A: Survey questionnaire 185
Appendix B: Interview template 186

List of Figures
Figure 4.1: Ratings for threat levels
Figure 4.2: Ratings for corruption
Figure 4.3: Comparing steps to address threats
Figure 4.4: Changes in past and next year planned (%)
Figure 4.5: Organisational concern ratings
Figure 4.6: Strengths
Figure 4.7: Weaknesses
Figure 4.8: Improvements




Chapter 1: Introduction
1.1 The Problem and Presentation Overview
With perpetrators ranging from terrorists and drug dealers to scam artists and white-collar criminals, money laundering has remained a serious problem in financial institutions, regardless of improvements to technology and changes in legislation; those behind the illicit efforts have shown their ability to upgrade and improve their own processes in the meanwhile (Vlcek, 2008). Many have been manipulating banking procedures and regulations as they launder funds, while efforts to address and target the exploitation of procedures have been challenged by the reality that such perpetration is difficult to pinpoint; a common reaction in developed countries have been restrictions on legitimate exchanges of funds, while developing nations are generally slower in their abilities to improve security and establish better defences against laundering (Egbuiwe, 2009; Hunt, 2011). This presentation is a study of money laundering and preventative efforts, the successes of governments and financial institutions in establishing effective practices to prevent against laundering, and the potential for banking policies to further improve to better address threats and prevent security breaches. Emphasis is placed on regulations in the UK and Nigeria, conducting a comparative analysis, and with the presentation ultimately aiming at pinpointing key issues relevant to account freezing and fund handling. Such a study is important and significant for multiple reasons. First and foremost, it provides an original data set regarding a serious issue and threat affecting nations, their governments, financial institutions, other organisations, and people across the world. Additionally, there are gaps in literature regarding the regional settings targeted for the research, as few studies have been conducted on this issue for the UK alone. Meanwhile, there is next to no literature on this topic targeting Nigeria alone, and thus the study serves to address these research gaps while making recommendations, thereby facilitating further research and development. Ultimately, the comparative analysis helps to point out differences between the developed and developing nation, facilitating the more efficient and effective recommendations for multiple regions, providing unique data that can serve as a foundation for ongoing research and development.
This chapter introduces some of the important literature, theory, and concepts related to anti-laundering efforts on global and regional scales. Beyond this, it introduces the research aim, objectives, and questions of the study, providing an overview of the research methods used, as well as other fundamental aspects of the research. Section 1.5 provides an overview of the entire presentation.
1.2 Background Literature
1.2.1 Laundering and Anti-Laundering Efforts
Many analysts have recognised the problem of laundering and challenges of anti-laundering at regional and international levels, and while many have recognised the nature of the challenge and difficulty in making solutions, few have been able to recommend viable solutions to these challenges. Lavelle (2001) reported that even among the most developed banking legislation have required improvements in regulations due to laundering issues, especially with regards to terrorism. In the United States, following the World Trade Center attacks and rise of terrorist cells, legislators immediately saw a need to have an improved perspective of international monetary exchanges. Their efforts have been only so effective however, arguably damaging in some areas, and affecting legitimate business operations in other areas. With this, however, is an issue common in all countries: tightened security over all foreign transactions translates to an impedance of legitimate international business. According to Vlcik (2008), campaigning to fight terrorist financing Europe has been generally done through attempts to monitor transfers in a similar way, and this was reported to create addition problems for migrant workers, who commonly attempt to send funds home to their families through international exchanges which could be mistaken for terrorist funding. According to the author, migrant fund transfers between the European Union and third world countries are commonplace, and “measures to combat the financing of terrorism (CFT) and the related increase in anti-money laundering (AML) regulation make it increasingly expensive for migrants to share their wages with the family left behind. The result is a tension between the desire of migrant labour to send money home and the fears of insecurity against the financing of terrorism” (Vlcik, 2008).  According to ongoing research, this is something that is still relevant to date across the world, in both developed and developing countries (Delston and Walls, 2012).
1.2.2 General Legislation Issues
General legislation issues have been along the same lines as discussed in the previous section. Egbuiwe (2009) discussed an effort in the U.S. legislation that had potential for applications in other banking regulations worldwide, but the shortcomings are still evident. One of the most encompassing and influential efforts here was the Bank Secrecy Act (BSA), which required banks to take additional actions to discourage terrorist funding, but this too impacted legitimate business, and is considered undesirable in many areas. With this, currency transaction reports are required, which allow a supervisory division or law enforcement to conduct investigations, ideally promoting the exposure of illicit activities. While the effectiveness of this is debatable, it provides an example framework for other nations seeking improvement in their regulations. Following this, discussing developments against laundering on more of a global scale, Hunt (2011) assessed cyberlaundering and the potential for to restrict money laundering. The author pointed out that loopholes in the legislation of multinational organisations and banks remained even in the year of publication, with a range of theories and recommendations have been provided as possibilities in addressing the loopholes; here, Hunt (2011) pointed out that the majority of the potential solutions are considered unattractive as they would be particularly resource and time consuming. More recently, Delston and Walls (2012) examined the efforts of a Financial Action Task Force (FATF), reporting that the demand for international prevention reaches beyond tasks. Here there is still a substantial demand for additional recommendations to efficiently and effectively adjust legislation and banking regulations, but it has yet to be realised.
Other analysts have shed light on other dynamics of the problem and the nature of challenges in creating effective solutions. Ulph (2006) explained that laundering has impacted government worldwide, potentially leading to social, economic, and political consequences at both national and international levels; this reach of the problem is what is impeding progress, rather than a lack of effort to addressing purely political issues.  Discussing the problem while recommending inquiries to be examined in ongoing efforts, Sharman and Chaikin (2009) reported “the potential benefits anti-money-laundering (AML) systems can provide in fighting corruption go largely unrealised, especially in developing countries. This mismatch poses a puzzle: Why are developing countries failing to best capitalise on their expensive AML systems by using them to fight corruption?” (p. 27). The authors ultimately explained that while many launderers have diffused AML in developing countries, a lack of ownership is why the systems have had shortcomings. Aluko and Bagheri (2012) further reported on key money laundering issues in developing countries, stating “it has been apparent that development countries have been more exposed and vulnerable to its exploits, resulting in economic digression and political instability” (p. 442). Meanwhile, the launderers have been able to exploit combinations of regulation loopholes, vulnerabilities in entire systems, and the distractions due to civil or political conflicts.
1.2.3 Anti-laundering Efforts in the UK
For the most part, the conceptual approaches to addressing money laundering in the UK has been comparable to the conceptual approaches as the US, just with different legislation and political dynamics. Mansell (2005) studied AML policy in the UK, stating that much of the problem has been a lack of emphasis until the current century, while the UK’s Clause 97 made it a criminal offence to create suspicious activity reports, while this must occur through the procedures outlined by the government (unless the person can prove reasonable grounds for reporting in another fashion). Srivastava (2005) examined the changing legislation in the country, stating “the focus on anti-money laundering legislation has led to businesses potentially incurring liability in respect of underlying criminal conduct that has occurred outside Great Britain. British anti-bribery legislation was updated by the Anti-Terrorism Crime and Security Act 2001 to impose nationality-based jurisdiction” (p. 20). Goswami (2007) showed that in his year of publication, 82% of financial institutions have not seen any financial benefits from the changed legislation, while 10% had not bothered to make themselves compliant with the new regulations.  
Studying attempts to overcome laundering in the UK, Saunders and Stott (2012) reported that despite being high on the UK authorities’ agendas, the actual effectiveness of existing actions have been limited. Meanwhile the UK experts generally assert that improved harmonisation, while proposed by many others as a potentially viable solution, is in fact not the best solution to address the entirely of variables of the problem at a systematic level (recommending enforcement powers remain in member states). Simser (2013) also reported that, in the current year, an examination of the existing efforts reveal that they have fallen short of expectations and demands; the author attempted to recommend new ways to look at the systems and solution development, but the same challenges still apply.
1.2.4 Dynamics in Nigeria
As mentioned, there is a lack of studies focused on strictly Nigerian dynamics. Obuah (2010) studied general corruption and potential for such crime in Nigeria, explaining the commonplace nature of misappropriation, bribery, and embezzlement alongside money laundering. Adding to the complications has been the corruption in government, while there is an estimated 20% of the GDP that is attributed to corruption (Obuah, 2010). Nigeria was until 2002  one of the least transparent governments, and the government attempted to take some action against crimes through the creation of the Independent Corrupt Practices and Other Related Offences Commission (ICPC) in 2000 and the Economic and Financial Crimes Commission (EFCC) in 2002 to investigate and prosecute corrupt practices, economic and financial crimes. These efforts have made significant changes and reforms but further change is needed to reduce corruption such as money laundering in the nation.
The structure of the legal system in Nigeria is also to blame, while this in combination with the difference in development makes it almost entirely distinct from the UK’s system. Nigeria has four types of law working at different levels in the country, and Sharia law rules in selected states in the northern part of the country; English law, customary law, and common law divisions amid the varying Sharia law can make financial regulations and legal development difficult (Nmehielle and Obisienunwo, 2004).
1.2.5 Recovering the Proceeds of Corruption
Recovering the proceeds of corruption can be a challenging aspect of financial coordination, although legislation here appears to have had more desirable results compared to the attempts to prevent laundering through legislation. The United Nations Convention Against Corruption (UNCAC) does a great deal to contribute to corruption and anti-laundering, and will take action to recover (and properly reallocate) proceeds from corruption from organisations across the world (Carr and Goldby, 2011). In the UK, the government has attempted to make it easier for developing countries to recover assets, with some investigations made through a request to the British Central Authority; this might be ideal for Nigerian cases, while corruption and lack of development in their nation increases the chances of ineffective local attempts to recover corruption proceeds (Rider, 2007).
1.3 Aim of Presentation, Research Questions, and Objectives
The aim of the research is to assess and compare the weaknesses of banking systems and regulations in the United Kingdom and Nigeria, focusing on account freezing, fund acquisition, recovery of misappropriated funds, and recommendations for improvement. The research questions developed for this are:

Primary Research Question: “What are the strengths and weaknesses in the United Kingdom versus Nigerian regulations for monetary transfers in the financial sectors, and what are the most viable and effective ways to improve account freezing and fund handling techniques?”

Secondary Research Question: “What are the challenges and opportunities for the recommendations in literature and from financial experts?”

With this, the research objectives of the study presented are to: i) identify strengths and weaknesses in banking regulations in the UK, ii) identify the strengths and weaknesses for the same Nigerian regulations, iii) complete a comparative analysis, iv) discuss recommended solutions for improvements, emphasising account freezing and fund handling, v) discuss opportunities and challenges regarding the recommended paths to improvement, vi) present unique recommendations for on-going research and development.
1.4 Research Methods
The research methodology combines the examination of data and literature with primary research of human participants, targeting employees in organisations from Nigeria and the UK. Here, the primary research and primary data is pursued through the use of government legislation, bank policy, and research instrumentation targeting bank managers from the UK and Nigeria. Beyond this, secondary research takes place using a combination of academic studies and other information available through financial institutions and national governments, relating the findings to the literature.
The study presented is qualitative in nature, thereby assuming the inherent risk of bias in qualitative studies; this potential for bias is most relevant to questions about the recommendations for improvement, challenges, and opportunities involved in developing the regulations (Laurel, 2003; Holliday, 2007). There is less potential in any questions regarding experience or the nature of policy, or facts rather than perspective and recommendations. This qualitative study discusses the vulnerabilities and potential for bias in the responses, focusing on the relations to theory and the conceptual potentials for improvements at large and small scales alike.
The primary research efforts make use of custom instrumentation, targeting bank managers in the UK and Nigeria. Due to the distance involved, the medium of choice is the telephone. The sampling techniques are to apply a combination of ‘convenience sampling’ (or the use of the most accessible people) and inclusion criteria (Kothari, 2008). A total of 60 bank managers from large-sized businesses within the UK and Nigerian business sectors are targeted for the research, with inclusion criteria demanding that they have overseen international financial transfers (while familiar with the potential terrorism funding) for a minimum of four years. Banks from both countries are to be researched for their size, and upon confirmation that they qualify as a large business (250 or more employees), they are to be contacted regarding possible participation in an academic study. From here, the managers are to be contacted individually. The instrumentation selected for use in the study is a custom (using best practices in research methods literature and considerate of the relevant issues in financial literature) semi-structured interview template. The semi-structured instrumentation is fitting for the research purposes because it combines the flexibility and freedom to question details in an unstructured interview with the ability to use a template for each respondent (from a structured interview) (Laurel, 2003).
Prior to the full distribution of the study, the instrumentation is to be tested with a pilot study, in line with best practices in research. This serves to test the instrumentation, and the feasibility of the questions. If the questions are all deemed feasible after testing the instrumentation on two participants, then the data will be added to the research ‘bank’ for the final compilation and analysis; if any of the questions in the template are deemed in need of revision, then the participants are to be contacted to see if they are willing to provide some follow-up information. (If they are not, then another participant would have to be pursued in their place). Following this, the full scale data recording is to take place. Once this is complete, the researcher can begin their compilation, analysis, relation to literature, and any other secondary research that may need to be performed based on the uniqueness of the findings (using available data and additional literature). Here, the qualitative analysis is to be presented mostly in terms of theoretical discussion and conceptual relationships, although some charts and images are to be presented to show statistics and comparisons.
1.4.1 Ethical Issues in the Research Validity, and Reliability
Many ethical issues are relevant to this study, due to its conceptual nature and use of human participants; these ethics are relevant to several areas in the study. Aside from the general academic ethics demanded in academic research and in universities, there is the issue of confidentiality relevant to the human participants, as well as the inherent nature of bias in the qualitative study. Beyond this, there is the obligation to avoid the disruption of normal business practices. To address this, the researcher is to ensure minimal impact on business operation, and address the preferences of willing participants. Participants can be questioned for this when discussing their willingness to provide data, and the accommodations required to minimise the impact on business operations are to be observed. The researcher can address the potential for personal bias through ensuring personal objectivity at all stages, and while it may not be possible to eliminate 100% of the participants’ bias, a combination of caution and listing the potential for bias in the presentation thereby duly addresses the ethical obligations (see the discussion in Chapter 5 and the research ethics section in Chapter 3 for details) (Laurel, 2003; Holliday, 2007). Any participants willing to provide data are informed of their ability to cease participation at any time (even after starting, up to one day after the data has been recorded)  are guaranteed anonymity, and are provided with forms for them to sign regarding all relevant ethical aspects.
1.4.2 Limitations
The study is mostly limited by access and funds. A more complete study and contribution to the existing knowledge base would involve a thorough assessment of more financial institutions across more countries, and considering more aspects of government regulation, but the researcher simply does not have this kind of access, funding, or time required to complete such a study. These limitations are the reasons why the sample size and target samples were chosen, as the components were deemed feasible for an academic study of this nature (see the corresponding sections in Chapters 3 and 5 for more details on limitations).
1.5 Structure of Presentation
This presentation observes the standard five chapter dissertation format, with introductory, literature review, research methods, results and analysis, and conclusion chapters. This first introduction chapter is followed by a chapter providing an extensive comprehensive literature review, which targets the issues of laundering and anti-laundering efforts, techniques in account freezing and handling misappropriated funds, the applications in the financial sector and implications for legislation, relevant legislation and policy developments and impacts on legitimate businesses, and recommendations for implementing changes (and for restricting the potential for issues such as drug dealing or terrorist funding, while minimising impact on other areas of business). The third research methods chapter then presents the full overview of the instrumentation developed and the sampling methods used in complete detail, further providing the researcher’s initial hypotheses, and providing other details relevant to the research methods. The fourth results and analysis chapter then reveals the findings of the primary research effort, alongside their immediate implications and preliminary analysis. The final discussion and conclusion chapter discusses the results in terms of findings in literature, presenting suggestions for the existing issues, providing recommendations for ongoing research and development, and presenting the ultimate conclusions of the study.

Chapter 2: Literature Review
2.1 Introduction
Numerous studies have been created in attempt to better understand the potential to stop money laundering and to retrieve the proceeds of corruption.  Theoretical analyses and empirical studies have examined the potential for policies to be more effective in stopping crime, while analysts have continued to offer recommendations for altering policy to be more effective. As introduced in the first chapter (and shown through the following sections), most of the anti-laundering efforts (AML) have been ineffective in achieving their target goals. As such, governments and analysts have continued to pursue the potential for improvements in restricting crime without restricting the financial transactions of legitimate businessmen and account users.
2.2 Laundering and Anti-laundering
General laundering is a phenomenon as old as finance, but the rise of computer technology and its integration with banking organisations has added a new dimension to this. Now, people can more secretly manipulate bank processes, with this potential for secrecy and the exploitation of mediums translating to a higher potential for corruption. Lavelle (2001) reported that banks find reasons to help stop terrorist funding, and the efforts against terrorism in the 21st century has given rise to some of the greatest efforts to restructure bank policy associated with laundering and corruption. In the US, lobbyists have been the greatest resistance to change, while other developed nations have experienced their own versions of the commonplace resistance. At the forefront of preventative strategies have been efforts to address unregulated financial firms; terrorists such as Osama bin Laden have been alleged to have created their own as a means of organising and distributing resources for terrorist operations (Lavelle, 2001). Following the World Trade Centre attacks, there was a demand to alter legislation to determine the sources of funding for foreign deposits in native countries, but this was the beginning of legislation complications that continue through the present. Lavelle (2001) explained that much of the issue has been related to perceptions of what the government can and cannot do, for example, the author pointed out that many are concerned that opening up the privacy of banks to investigate terrorism could lead to increased tax investigations or other unnecessary scrutiny that was not permitted before. Others argue that since the policy could not have stopped the terrorist attacks, that it may be unnecessary, and more trouble than it would be worth. Meanwhile, later in 2001, Osama bin Laden got the attention of legislators and financial powers worldwide when he bragged that he exploited flaws in the Western financial system. This naturally angered policymakers, and provided more motivation to address potential corruption (Lavelle, 2001).
Later, Mansell (2005) explained that many developed world governments had been focusing on developing or improving expansive AML policies. Here anti-laundering resources and organisation had been the emphasis of on-going development, with policymakers increasingly realising that the root of the majority of the problems lie in the nature of the systems (rather than a lack of individual policy developments or enforcements).  Specifically, developers were realising how large the scope of the problem is, how far the reach of the potential offenses are, and how difficult it is to address them all in an encompassing policy that does not infringe on normal bank operations at the same time. According to Mansell (2005), “the definition of a core money laundering crime covers any offence from which a benefit is obtained. Consequently, the mandatory reporting requirements have placed huge compliance costs on the regulated sector. A perception exists that law enforcers cannot cope with the amount of information they are now receiving from an army of unpaid informants” (p. 13). Here, people became concerned that only a small fraction of reports made would lead to an actual investigation; and that only a fraction of the investigations would lead to an arrest. Feelings such as this have sparked more unique approaches to the problem, though different complications have arisen. The differences in local and international laws is another major complication that has affected the most direct approaches, as payments could be considered ‘corrupt’ under English law (for example), but permitted under a different local law where the payment is being made.
Many other researchers have provided evidence of changes and potential in relation to laundering attempts and AML efforts. In other research, Goswami (2007) explained that it is crucial to address authority organisations (i.e. the Financial Services Authority) to address potential corruption or laundering, while Egbuiwe (2009) reported on the potential for a new network to assist in the fight against laundering. Egbuiwe (2009) described the strategy behind the Bank Secrecy Act (BSA), requiring that financial institutions to take additional actions to restrict the prevalence of laundering and terrorism. Here, institutions are required to report transactions meeting predefined criteria to the Financial Enforcement Network, designed to address such cases and legislation. This improves law enforcement’s access to information if a case arises from the data, which in turn makes it easier for them to assess the need to cease the operations; it also makes it easier for law enforcement to interfere with operations. While this was assumed to be effective to a substantial degree, the resources required and the reporting demands continued to challenge effectiveness, while there is much controversy surrounding reporting methods and impacts from reports (Egbuiwe, 2009). With the improvements in computer technology has been the potential to improve the stealth or efficiency of crimes, and ‘cyberlaundering’ is a new version of crime that demands the attention of AML efforts. Cyberlaundering has become more commonly used by criminals and more commonly targeted by AML efforts, including through the actions of the United Nations, G7, Council of Europe, and more. Hunt (2011) explained that there are loopholes in cyberlaundering in developing nations, and thus the efforts to address the new potential from continuously evolving technology is a major focus in ongoing developments.
The Financial Action Task Force (FATF) has taken some of the greatest measures and dedicated some of the most effort in addressing trade-based money laundering. The FATF has established a total of 40 recommendations to improve AML measures, and most of these focus on trade based laundering. According to the authors, “estimates for the amount of money laundering through the abuse of the international trade system range from $5 billion for Colombia alone to hundreds of billions worldwide. Trade-based money laundering…has been identified as a major issue in the popular press for almost twenty years, and has received significant attention in both the US Congress and the Executive Branch since at least the late 1990s” (Delston and Walls, 2012, p. 744).
Laundering and AML has been something that has been evolving through both legislation and the nature of crime. Here both officials and criminals improve their techniques, and the end result appears to be near a balancing effect over time. Officials and analysts are not satisfied with such a trend, while true digressions are major challenges to developing and developed nations. The following section describes the evolution of these areas with more emphasis on UK trends, showing how developments have occurred (and the nature of cause and effect relationships in policy developments ) in the UK.
2.3 Anti-laundering and crime prevention efforts in the UK
The UK has experienced pressures to address AML, and while the nation is comparably as developed as the US, it has not experienced the same degree of terrorist attacks or corruption (Reynard, 2010). Meanwhile, Reynard (2010) stated that the situation is arguably easier for investigators in the United States, as they have access to tools that are not as accessible in the UK; moreover, wiretapping cannot be used as freely in the UK as it is in the US, impeding potential progress on cases or investigations. The government in the UK has given little consideration to using ‘intercepted’ evidence in criminal investigations, while plea bargaining is seen as something that has potential to more positively affect case outcomes as well. According to Reynard (2010), “this is beginning to gain credence in the UK, with the FSA’s director of enforcement Margaret Cole adopting the system in relation to market abuse cases over the last couple of years. This has resulted in a number of FSA convictions and fines” (p. 8). Meanwhile, analysts have considered the potential for the UK’s Bribery Act to take greater action to address laundering and corruption cases compared to the US, while prison sentences required by the legislation are also generally greater (maximum sentence lengths are twice as great, or five years compared to ten years). Beyond this, Reynard (2010) stated that there has been considerable apathy in the UK with regards to developing optimally effective AML and bribery policies.
Ryder (2011) inquired into many areas of crime and financial policy development in the UK, considering the costs of financial crimes, potential for corruption, extent of UK policy development, and a wide range of other relevant topics. Attempting to assess the cost of financial crime, the author reported that the FATF had found that economic and social costs of organised crime were nearly £20 billion annually, while this trend has remained relatively consistent despite preventative efforts and action (HM Treasury, 2004). Meanwhile, the Home Office (2004) reported that organised crime promotes other crime, and generally permeates every community in some way or form across the UK. The negative impacts on social and economic elements have been clear, with the economic impact of terrorism from the London bombings in 2005 having some of the greatest rippling effects in social aspects, economics, and policy making; the terrorist act occurring here alone is assumed to be responsible for a net £3 billion loss to the UK economy (HM Treasury, 2002). The Bishop Gate bombing in 1993 had only cost the country an estimated £1 billion, in comparison (HM Treasury, 2004). Ryder (2011) explained that the UK’s AML has been led by the HM treasury, while the Financial Services Authority (FSA), Joint Money Laundering Steering Group (JMLSG), and the Serious Organised Crime Agency (SOCA) have also played major influential roles in the development of AML policy. The HM treasury has placed its emphasis on three primary objectives for improving policy, focusing on engagement, effectiveness, and proportionality in its developments. Addressing effectiveness, the HM treasury assuming that the UK would continually aim to assure an effective preservation of the AML framework, hoping it will address local challenges as well as international obligations. The Proceeds of Crime Act 2002, the FSA’s efforts, the guidance of the JMLSG, and other legislation have been the primary mechanisms used in attempt to achieve these goals (Ryder, 2011). These same approaches are also used in attempt to address the standards established by the 40 recommendations put forth by the FATF, as well as the obligations created for the UK across the international community. Meanwhile, addressing proportionality, Ryder (2011) explained that “the government will continue to adopt a risk-based approach towards money laundering. This seeks to ensure that its AML measures are cost effective so that firms can adopt a flexible approach towards meeting their obligations” (p. 254). Addressing the objective of engagement, the HM Treasury facilitates communication between other authorities and firms in attempt to guarantee that the consultations taking place are used, while the feedback given from communications (regarding operations in regulated areas) is clear.
The HM Treasury attempts to address financial crimes through a wide range of measures, despite the aforementioned criticism that the UK has been more apathetic to AML developments than the US. UK legislation aims to deter money launderers through criminal punishment, to confiscate recovered proceeds, and “to the obligation on the financial services industry…and certain other sectors and professions to identify their customers and to report suspicious activities” (Ryder, 2011, p. 254). With this, the UK’s AML is generally in terms of one of three categories, money laundering criminalisation, reporting policies, and the regulation of financial institutions. The criminalisation of money laundering had been updated in 2002 and 2003, where the three main offenses addressed by the legislation and local firm policies are in terms of concealing (including misrepresenting, converting, removing, or otherwise transferring money in an illegal manner), entering into an agreement where criminal property is to be managed and controlled through a business organisation, and simply obtaining or using criminal property (Blair and Brent, 2008). Such actions are an offense regardless of the person they are committed by, regardless of their role in a regulated sector or business, while other crimes covered by the legislation are a failure for the sector or officers of the sector to disclose documentation relevant to the aforementioned offenses (as well as ‘tipping off’ criminals regarding a planned investigation). Ryder (2011) explained that the scope of the crime is great, while it is potentially possible for anyone to have benefitted from the action in some way, rather than only the person that has planned and actively coordinated the crime. The legislation creating these rules state that there is no consequence regarding the active parties or the parties that gained from the crime, and is an offense regardless of whether the crime took place before or after the legislation was passed. However, the gain by the people must flow directly from the criminal activity, with the nature of directness determined by a combination of legislation stipulations and judgment in a court of law, while this does not necessarily mean that a financial gain was made from the laundering (improvements in long-term profits or standards of living constitute direct gains) (Hudson, 2009). The accused can defend themselves if they make an authorised disclosure (through a report of suspicious activities, see previous and following sections for additional details regarding suspicious activities); this is also called an authorised disclosure. With this, an accused can be deemed innocent if they make such a disclosure, while the action they do “is in accordance with undertaking a function that relates to the enforcement of a provision under the PCA 2002” (Ryder, 2011).
The legislation governing the three main categories of AML is dynamic, but commonly argued to be in need of further improvement to address criminal activity without infringing on legitimate operations, as explained in the introduction. The second main offense, the entering into an agreement for some type of laundering (or the gain, use, or control of criminal property for someone else) requires specific criteria for a conviction. Ryder (2011) explained that a conviction can be created if the prosecuting party can prove that people became concerned “with an arrangement that they knew or suspected would make it simpler for another person to acquire, retain, use or control criminal property. Furthermore, that the person concerned also knew or suspected that the property constituted or represented benefit from criminal conduct” (p. 255). In order for people to be found guilty of violating the legislation established for this aspect of AML, the criminal property must be clearly defined and evident. Similar to the other type of offense, the person cannot be prosecuted if they make an authorised disclosure, or if they had intended to make a disclosure but had a justifiable rationale for not carrying through with it (or otherwise had legitimate reason to attempt to acquire or continue using the property regardless of the source, i.e. no knowledge of true origin). Thus, conviction requires that the funding or property obtained and handled is proven to be criminal in nature, and creating a net benefit for the business or individuals operating it; the person must be proven to have awareness of these criminal origins in addition to this. Strangely, the Terrorism Act 2000 addressed terrorist property to some extent in this earlier legislation, but it was not revisited for the more refined and detailed legislation established for the PCA 2002; the UK authorities are therefore treating illicit funds through laundering from terrorists in the same way that they would treat it from local criminals, through the conspiracy for terrorism can still potentially come as a second investigation leading to other charges (Ryder, 2011).
Examining the regulation of financial institutions in the UK in relation to AML policy, the FSA regulations control most of the policy in operations, “which has extensive rule-making powers to impose regulations on the regulated sector” (Ryder, 2011, p. 255). It was not until 2006 that the FSA decided to streamline money laundering policy, and it soon established an approached rooted in principle in a new handbook (FSA, 2006). Part of the legislation demands that firms establish and maintain systems for the firm to conduct appropriate business (FSA, 2006). With this, firms are required to take reasonable care of their policies and systems, and to ensure compliance with those systems as well as ensuring appropriate consequence or investigation for anything in violation. Firms are thereby also required to conduct assessments regularly, testing the adequacy of AML systems, and they must place a director or senior manager in charge of maintaining and supervising AML; there must also be a designated laundering reporting officer. The FSA has a large reach in terms of enforcement and investigative powers, as “it has the ability to require information from firms, to appoint investigators, to obtain the assistance of overseas financial regulators, and provide appointed investigators with additional powers” (Ryder, 2011, p. 256). It has also become a prosecuting party in certain cases, having the power to fine firms where legislation has not been observed, for general non-compliance issues, and in certain intentional violations (though courts may be required to determine the nature of intention).
Laundering criminalisation in the UK has evolved considerably in the past decades, and while many argue that it has yet to reach the desired goals of AML policy, analysts argue for the progress of development and the results of cases successfully investigating and convicting criminals (Wright, 2007; Ryder, 2011). Prior to 2006, legislation for fraud included eight statutory ‘deception’ violations. These were defined in a Theft Act, established in 1968 and revised in 1978, with the most common violation being a conspiracy to defraud. Unfortunately, however, the offenses established by the Theft Act were challenging to enforce, prompting the revisions in 1978, but even this could not solve most of the major problems originally noticed (Kiernan and Scanlan, 2003; Wright, 2007). This is another example of challenges in the UK system, while this shows that they predate the modern concerns for laundering with computers, while the modern issues show that improvements in certain techniques and firm technology (as well as national and international cooperation and coordination) do not necessarily lead to improvements for the issues. The Home Office (2002; 2004) explained that, regarding the Theft Act, it is not always evidence what offenses should be charged to the offender, and whether or not the defendants of cases had legitimate reason to act in the ways observed. These challenges prompted a re-examination of fraud law in 1998, while the Law Commission (1999) examined differences between dishonesty and deception in a formal investigation of their own; the latter concluded that while concerns for the existing legislation were generally warranted and valid in nature, they could not be sufficiently addressed through the majority of recommendations.
One of the most fundamental elements of AML in the UK is report obligation, which has impacted organisations while being the subject of much research and development across the past two decades. Unfortunately, however, this movement came to pass due to authorities noticing the gross underreported nature of fraud in the country, not even prioritised by local police. According to Ryder (2011), “even when reports are taken little is done with them. Many victims therefore, don’t report at all. So the official crime statistics display is just the tip of the iceberg and developing a strategic law enforcement response is impossible because the information to target investigations does not exist” (p. 261). Meanwhile, suspected fraud is reported to a laundering reporting officer, while ‘successful’ frauds are reported to the SOCA. Banks themselves are permitted to decide whether or not to get the police involved in their situations and cases; with this, victims of fraud (whether through checks, credit cards, or online banking) can report to the banks and institutions, as announced by the Home Office (2009) in 2007. Here, the obligation to report even allegations of fraud is important, and arguably not straight forward enough, commonly causing complications in organisations. The PCA 2002 contains the main legislation regulating fraud reporting. The law makes it an offense for a person to fail to create an SAR report when they have knowledge of even potential fraud occurring in their department, or that someone has been laundering through an organisation. Beyond this, the act requires that people of the regulated financial sector are to report their allegations as soon as ‘reasonably’ possible, as it is a criminal offense to avoid reporting without also providing a valid reason for not doing so within the time that was available to them. However, there is no legal requirement to report and attempted or unsuccessful crimes, as the PCA 2002 does not require that people who take this course of action be prosecuted for this type of neglect. In such a case, police decide whether or not an investigation will be conducted, while the Home Office advises that police should only investigate when there is reasonable cause that some crime has been committed (Home Office, 2004b; Ryder, 2011).
Other aspects of criminalisation are also covered by the PCA 2002. For instance, the law requires that members of the regulated sector create a report to the FSA within any of the following conditions: i) it becomes evident that an employee may have been guilty of fraud within one of the organisation’s customers (regardless of employer), ii) if any person (regardless of employer) is acting with some intent to commit fraud against the organisation,  iii) if irregularities are noticed with regards to accounting or other records (regardless of whether there is actual evidence of fraud), or iv) if someone suspects that one of an organisation’s employees is guilty of substantial misconduct regarding honesty related to the firm’s activities (Ryder, 2011, p. 262). According to the FSA (2008), the firm must also consider the following when deciding whether they feel the situation at hand is a significant one: i) the size of the loss in funds, or the potential loss to the company or customers (this can also include similar incidents and not necessarily one sole incident), ii) the risk of a loss of reputation to the firm, and the impact resulting from this, and iii) if the incident or a pattern of such instances are indicative internal control issues within the organisation; here, the company can properly and fully consider the range of areas relevant to the significance of matters, and the course of action to take, but this does not serve as a waiver to the obligations to report that were described above. When firms have experienced substantial financial losses due to some incident, or have experienced a significant loss to their reputations, the FSA will demand to consider the variables relevant here, and they will also consider the potential for the internal controls to be weak (as well as the potential best course of action for addressing any weaknesses). Ryder (2011) stated “the UK’s policy toward fraud has gained momentum under the previous government, a willingness shared by the new coalition administration. However, there is still scope for improvement in the initiatives that have been introduced to tackle fraud. For example, the effectiveness of the criminalisation of has been limited by the inadequacies of the Theft Acts and the common law offense, a position that has improved by the introduction of the Fraud Act” (p. 262). The author further reported that there are still remaining concerns regarding the enforcement of such crimes, by the SFO and CPS, after many high profile cases collapsed. Thus, it is too soon to determine whether the newer Fraud Act has truly successfully addressed the prosecution issues in relation to fraud. In any case, the coalition government should at least be respected for its efforts in researching and developing for a single economic crime agency; the remaining challenges in conduction and delay are caused by “the reporting of instances of suspicious fraudulent activities,” because they are “fragmented with a number of different reporting mechanisms available” (Ryder, 2011).
Terrorist financing is another area significant to the demands of AML development and improvements in financial regulations in the UK, but as mentioned, this was not addressed directly by the PCA 2002. In the same year the PCA was established, the HM Treasury created a report that stated the contribution the government had made for improvements in pinpointing the sources of funding for terrorists. Five years later, the government approached financial challenges related to crime and terrorism again, attempting to determine how the private and public sectors could join forces to deter terrorists from exploiting the existing financial system; the terrorists had been able to do this for some time, all the while the terrorists had been able to evade monitoring for much of their actions. Here, the government attempted to develop better tools that could be used by affected organisations to disrupt, freeze, and address funding used in terrorist networks. This led to some improvement, but comparable challenges and issues remained. Three years later, in 2007, the HM Treasury stated that the government was continuing to attempt to keep terrorists from using funding through banking systems, regardless of their campaign tactics, so long as they were defined as extreme and radical groups. Meanwhile the UK has attempted to improve its policies criminalising terrorist financing, following the first legislation criminalising terrorist funding in 1989; this was the Prevention of Terrorism Act, which criminalised terrorist financing. The act also permitted the government to pursue forfeiture of funds or other assets the terrorists had assumed control of (see section 2.5 for additional recovery legislation and developments). The UK has been able to stop some terrorism through such actions, especially the efforts of the Irish Republican Army. The nation’s terrorist policy was reviewed, leading the analysts to find that between 1978 and 1989, there had been many weaknesses in the legislation; only four convictions took place during this time, which contradicted with the assumed prevalence of activity over this period (Tupman, 1998; Ryder, 2011). In addition to this assessment, another analyst also argued in this case, stating that there had been no successful prosecutions related to terrorist funding in Northern Ireland in over 30 decades, while the forfeiture legislation established by the 1989 terrorism laws had never been used through the turn of the century (Bell, 2003). The Home Office advised that the scope of financing be extended to include additional areas, but this is still being debated (Ryder, 2007). The Terrorism Act of 2000 brought some changes, bringing the total potential related offenses to five in total; soliciting and receiving finances related to terrorism became a crime also, as well as the use of property (rather than funds) in terrorism. Other aspects similar to the legislation for laundering became relevant to terrorism through the legislation as well, including knowledge of fund or property use, intent, and entering into an agreement.
Despite the efforts to criminalise terrorism alongside the rest of laundering and fraud related offenses, the Terrorism Act of 2000 is asserted to have had a limited effect (Bell, 2003; Ryder, 2011). Bell (2003) reported that the main challenge for the prosecution in terrorist cases has been the proof of property or funds being thoroughly connected to terrorist activity. From 2001 and 2008, 34 people had been charged with fund raising offenses through the changes with the Terrorism Act, but only 10 of those had been convicted of some offense (Home Office, 2009). Bell (2003) thought that strategies against terrorist funding were among the most difficult to investigate or prosecute, and that it is a rare occasion to prove terrorist charges; this because it is difficult to pinpoint where an exact paper trail has been created between known terrorists combined with proving the funding was for a terrorist activity or exercise. The terrorism act does allow law enforcement agents to have additional authority in investigations, and they can access financial data or accounts as they need to complete their investigations. Asset freezing is something that has developed slowly in the UK as well, with the Anti-Terrorism Crime and Security Act of 2001 allowing terrorist funds to be immediately seized. With this, funds could be immediately frozen at the beginning of an investigation, and any account suspected to be involved in terrorist activity could be monitored without violating the previous legislation. Moreover, people were required to report accounts that were suspected of being involved in some form of terrorism. HM Treasury is now allowed to freeze foreign assets and groups if they have reasonable suspicion of a terrorist network. According to Ryder (2011), “Part 2 of the Act permits HM Treasury to freeze the assets of overseas governments or residents who have taken, or are likely to take, action to the detriment of the UK’s economy or action constituting a threat to the life or property of a national or resident of the United Kingdom. HM Treasury is allowed to make a freezing order if two statutory requirements are met” (p. 265). These requirements are that the officials must have due reason to believe that some event threatens the local economy, life of residents, or property of residents; the second is that the individuals involved in the aforementioned action must be a resident outside of the UK (or overseas government). Freezing orders prevent all people in the UK from making funds accessible to the suspected individuals, while the HM Treasury must also maintain the order to decide whether it must be put into effect across the next two years. The organisation has frozen the assets of people and organisations whom were suspected of terrorism, but as mentioned above, the number of convictions has been unexpectedly low in comparison to records of terrorist activities or cases that could not be proven (assumedly due to legislation complications). The UK continuously maintains a list of frozen accounts, with one of the most notable being the £90 million from the Taliban frozen in the early part of the century, leading to its fall (Ryder, 2007). (Since this time only £10 million has been frozen, while the organisation is thought to be much less active). The success of the legislation and the government is generally considered in terms of the amount of funds that could be located and frozen, but others argue that even high sums frozen are not an appropriate measure of success (Ryder, 2011). At the end of 2009, there were only 237 accounts with approximately £600,000 of suspected funds, but this is attributed more towards military campaigns than effective developments in legislation.
Terrorism laundering reporting requirements in financial institutions are similar to general laundering reporting requirements, but were extended by the Anti-terrorism, Crime, and Security Act 2001; this made it offense to not report disclose knowledge of offenses to the act. This demanded that three separate criteria be addressed simultaneously to constitute an offense. The first requirement is that the person is either entirely aware or reasonably suspecting that someone has violated the Terrorism Act, the second is that information became accessible to the person through traditional business operations in the sector, and the third is that the person does do nothing to present the information as soon as reasonably possible after receiving the information (Ryder, 2011).
Ryder (2011) drew numerous conclusions from his assessment of AML and related policy developments in the UK. Regarding money laundering, he stated that the United Kingdom has been fully compliant with its international obligations through the “international obligations under the Vienna and Palermo Conventions and its requirements under the Money Laundering Directives. In fact, the UK’s measures go beyond its international obligations. The criminalisation of money laundering occurred in 1986, since when the legislative frameworks have been updated and codified by the PCA 2002. The involvement of the FSA s an innovative attempt to reduce the impact of money laundering” (Ryder, 2011, p. 269). This was the first time there was a role so specific for a UK financial organisation. The FSA created an expensive and sometimes needlessly complex policy, but they have tried to reduce their obligations to AML through implementing new standards, while the new policies integrated by the FSA is deemed insufficient for dealing with organised crime laundering. The reporting requirements for the SAR have increased the burdens to administrative staff, while they have resulted in greater emphasis on record keeping, internal policy, report filing, and more. Requiring organisations to have even more reporting requirements was deemed inevitable, since the UK government has been stern when it comes to money laundering, but Ryder (2011) questioned whether filing reports will have an effect on trends; this is because of the challenges in actually convicting the accused, as the previous discussion has shown that this is even more difficult than recognising trends and making an arrest. When the HM Treasury reviewed the UK’s AML policy in 2003, it concluded that the nation has a comprehensive and effective regime to address AML, but Ryder (2011) argued that it can be criticised “because of its ambit and burden imposed on the sectors that are forced to comply with it” (p. 269). With this, no matter the effort to improve policy in the nation, it appears that AML can only be so effective when it is conducted on an international level while attempting to optimise the compatibility of legislation and general international coordination (Maylam, 2002; Rhodes and Palastrand, 2004).
Concluding with regards to fraud and terrorism funding, Ryder (2011) stated that the UK fraud policy has gained momentum since it published a review on the topic in 2006, but it also has challenges that are comparable to the challenges in improving AML legislation. The UK fraud legislation has more in common with US policy than the nation’s AML, but criminalisation is different, with considerable differences in sentence lengths. The UK has only one sole piece of legislation for fraud (the Fraud Act), criminalising different kinds of fraudulent actions while providing prosecutors with extended authority in their campaign against the crime. According to Ryder (2011), “there is no single agency that takes a lead role in tackling fraud; there are simply too many agencies who perform the same function, a position that has deteriorated by the fact that not one government department performs a similar function to the Department of Justice. For example, HM Treasury has been charged with developing and implementing the UK’s policies towards money laundering and terrorist financing, yet it has very little to do with the UK’s fraud policy” (p. 269). Meanwhile, the Home Office has been tasked with addressing organised crime issues, while taking little action to appropriately address fraud. Considering this, Ryder (2011) recommended that sole government departments be charged with addressing the full range of financial crimes, while the HM Treasury appeared to be in the best position to assume such a role (as it has experience addressing money laundering crimes as well as terrorist accounts and funding). Beyond this, it was recommended that the UK government should establish a unified agency for financial crimes, which has been addressed to some extent with the combinations of agencies that have taken place in the past years, such as the mergers of the National Criminal Intelligence Service, the National Crime Squad, and the Assets Recovery Agency with the SOCA (Ryder, 2011). The PCA 2002 requires reporting to a greater extent that had been required in the past, potentially leading to the prosecution of people whom did not inform authorities of reasonable suspicions of crimes within a reasonable amount of time. Regarding anti-terrorist legislation, this has been in place since 1989, while the UK government has fully integrated resolutions established in the UN; the government expanded the legislation in 2000 with the Terrorism Act, making the criminalisation of actions comparable to AML policy, but demanding the burden of proof of terrorist activities. All of these areas have seen improvement and increasing success in addressing issues, but the policy has been unable to reach its goals, prompting demands for further improvement that the UK government is recommended to address.
Considering the EU’s third AML directive, Bergstrom, Helgesson, and Morth (2011) assessed this, and risk management developments; here the UKs efforts and circumstances were compared with Sweden’s, revealing that the processes applied could impact democratic accountability. Their study showed that the division of labour between the banking sector and public officials is not adequately defined. Here the authors wrote “the overall goal may seem rather straightforward- to prevent money laundering and combat terrorism- but at the same time seems ambiguous regarding how particular acts of ‘terrorism’ and illicit funding’ are to be identified and counteracted” (p. 1060). With this, they considered the potential for the risk-based approach to be used as a technique to organise AML while fighting against terrorist fund distribution. An assessment of UK trends and traits showed that the country can establish goals and appropriately divided public and private figures in AML procedures. The authors asserted that public figures are accountable in the democratic system, while the private figures are not; this distinction therefore demands that the division of labour across public and private sectors, and that appropriate control systems are in place, but these can be more effectively used in enhanced AML efforts. If these are not used, there is a risk that accountability will be diluted while the potential for shifted blame increases, and this is not in line with democratic accountability. However, in EU directives and FATF recommendations, there is little prioritisation or even mention of democratic accountability. Generally, emphasis is on the legitimacy of output, and thus it is recommended that democratic accountability be given more consideration in the future. The researchers asserted that this should not be surprising, as defining AML as a security and risk-based issue, the results can be perceived as more legitimate in comparison to AML being defined as a regular crime (Bergstrom, Helgesson, and Morth).
AML in the UK has undergone many changes from a wide range of acts and legislative developments, although even the most strategic improvements in these areas are still challenged by the demands to pinpoint illicit activities. Terrorist laundering is one of the most difficult types of laundering to catch, because it requires the identification of both terrorists and terrorist activities alongside illicit funds. Fortunately, a combination of reporting laws and improved investigative legislation provides authorities with a better chance of finding and stopping criminals, but there are still complaints that some of the efforts can serve as obstacles to legitimate businesses. While there have also been complaints that the legislation has been inadequately effective, with low numbers of assets seized and people prosecuted, the known amount of activities and comparison of UK laundering compared to US laundering are thought to be low. In this sense, while the problems still seem substantial and worthy of significant attention in on-going research and development, they do not compare to the challenges in developing countries; here both legislation progress and the potential for corruption are high. The following section explains the nature of related challenges in such a country, which may be the most corrupt nation in its continent, Nigeria.
2.4 Laundering and Organisational Challenges in Nigeria
Nigeria, as a developing country with less political organisation and less organised law enforcement in comparison with the UK, has experienced a different and greater struggle with AML and corruption issues. Obuah (2010) asserted that in the nation, corruption is consistent (if not growing) in the nation, while crimes such as laundering, bribery, embezzlement, and misappropriation saturate the society. The leaders and aspiring leaders of major political organisations are generally at the greatest risk for corruption in the nation, while elected officials commonly abuse their power; approximately 20 percent of the nation’s GDP is attributed to corruption. Meanwhile, Nigeria has been near the bottom of the Corrupt Perception Index ranking of Transparency International. In 2000, Nigeria established the Independent Corrupt Practices and Other Related Offences Commission (ICPC) and the Economic and Financial Crimes Commission (EFCC) in attempt to mitigate its problems, while corruption is currently considered Nigeria’s worst problem; corruption is thought to be responsible for many problems in the nation, including obstacles to democracy and democratic elections, stunted foreign investments, debt complications, and instability in the Niger Delta and some other parts of the country (Obuah, 2010). The ICPC, until 2012, concentrated more on public system reviews and the investigation and prosecution of reported corrupt practices, while the EFCC from the onset dealt with economic and financial crimes, money laundering and proceeds of crime. For the moment, while there are many studies targeting corruption in a general sense, there are few studies that have been able to target the nature of corrupt practices, roles of anti-corruption developments, or the true extent of impact of corruption in the nation (Chukwuemerie, 2003). According to Obuah (2010), “there are a number of reasons for focusing on the scope and impact of corruption in Nigeria, and the difficulties in dealing with it. Nigeria occupies a central place in Africa as the most populous country, with an estimated population over 149 million. It is one of the continent’s richest countries and is blessed with a huge diversity of natural and human resources” (p. 18). Additionally, the country also has a range of ethnicities, and the economy has been dependent on oil exports; oil is also thought to sustain local corruption, while the permeation of corruption in Nigeria is similar to that observable in other African countries. Across the continent, corruption is thought to drain over $140 billion annually from each nation, while the existence of corruption serves to further affect the economy because it discourages investment. Moreover, corruption in the nation distorts public spending, diverts resources to richer countries, and raises the overhead costs for local businesses, while the nation is thought to exchange over $1 trillion in bribes each year (Malgwi, 2004; Obuah, 2010). National corruption is assumed to have been the cause of the collapsed republics in the 1960s and 1980s.
Efforts to fight corruption in Nigeria have ranged from legislative efforts to personal campaigns by government members, though the latter are thought to generally be for reputation or show (Obuah, 2010). Attempts to improve and expand legislation include the Banks and Other Financial Institutions Act (1991), the Financial Malpractices in Banks Act (1994), the Advance Fee Frau and Other Related Offences Act (1995), the Nigerian Corrupt Practices and Other Related Offenses Act (2000), and more (Obuah, 2010, p. 18). In 2002, the government created the Economic and Financial Crimes Commission (EFCC), serving to improve efforts in preventing, prosecuting, and investigating both financial and economic crimes in the region. Despite these efforts, those elected in powerful political positions have a better perspective and potential to work around the law, and are commonly blamed for abusing their power and giving in to corruption (Obuah, 2010). The leading corruptors in the nation are thought to be political office seekers, public officers, and officials elected into various government positions. Aluko and Bagheri (2012) studied money laundering trends in Nigeria, confirms that money laundering alone is responsible for financial and economic crimes have contributed to instability in politics and economic complications.
Nwagbara (2012) studied laundering and financial crime issues in Nigeria, attempting to isolate causes and viable strategies for reducing crime and instability, noting a major demand for ethical leadership models integrated into government and organisations. The author stated “the recent global corporate scandals, banking frauds and financial mismanagement involving high-profile institutional failures have necessitated the saliency of corporate governance and ethical leadership in the banking sector. This ugly development has intensified debates on the workability of corporate governance framework as a check on the excesses of corporations, banks and financial institutions” (Nwagbara, 2012, p. 133). Here the author claimed that Nigeria has experienced one of the worst types of scandal, with most of the blame being on the financial impropriety of local authorities and general corruption across government and leadership; this has in turn discouraged investment while damaging trust with local customers. This is why the author asserted that ethical leadership models would be of the most benefit to the region, serving to provide vision and responsibility to stakeholders, increasing the potential for legitimate operations and stability. According to Nwagbara (2012), ethical leadership would foster more ethical conduct in operations, and despite the demand for considerable restructuring and development in policy, while it would further promote more positive norms in corporations.
Nwagbara (2012) stated that in Nigeria, it is important to examine the financial sector at the microscopic level to understand the nature of cause and effect in politics and the economy, claiming that financial impropriety in the sector would be terrible for the economy, because it has such a major role in the national economy. This in turn means that improved leadership framework is needed to enhance the stability of the banking sector, thereby improving regional economics. In Nigeria, banks account for the majority of the national assets (approximately 90%), while they are also the greatest force in the local stock market (Soludo, 2009; Fadare, 2011). The nation has been known to be corrupt for decades, with numerous reports of corruption across the 1990s that have involved issues which continue to linger through the present (Babalola, 1995). After the turn of the century, Aluko (2002) state that the greatest parasite to the national society has been the issue of corruption, being so common that the majority of the citizens can be defined as corrupt in one manner or another, while the nation itself being in such a state of disorder that many social institutions have become unethical. In the 2011 corruption index, Nigeria ranked number 143 out of the total of 183 countries, thereby being one of the most corrupt; moreover, the nation has placed more efforts in combatting corruption than most other developing countries, yet it still remains one of the most corrupt. Nwagbara (2012) argued that corruption affects culture and morality in the nation alongside the impacts at a socio-political and economic level, while its support of corrupt practices within its institutions and culture is one of the largest problems. This prompted the president (Olusegun Obasanjo) to establish an anti-corruption campaign, following the 2003 effort to address the crimes through the EFCC. However, the continued efforts outside of the EFCC show how the organisation’s effectiveness has been limited (Ogundiya, 2009). Nwagbara (2010) and Ezeoha & Anyigor (2009) had asserted that the leadership structure in the nation provides some of the greatest opportunities for corruption, fostering the preservation of a culture of corruption; other criticism of the national leadership includes arguments that it is weak, compromising, broken, and even failed overall (Nwagbara, 2012). The nation has been accused of continually compromising at it handles its financial industry, while the culture of corporate governance has been accused of being poor as well (Ezeoha & Anyigor, 2009). Agaba & Emaojo (2010) explained that research had shown that Nigeria may be the single most corrupt nation in Africa, while the failure of leadership in the local banking sector is asserted to be representative of leadership issues in general in the nation (Agaba & Emaojo, 2010). According to Uche (2004), unethical political leadership has been a long-time problem in the region, while its financial industry operated unregulated for nearly 10 years following its independence from the UK. The first attempt to regulate the system was made in 1952, becoming the national banking ordinance in the nation, while six years passed beyond the Central Bank Act was passed (Fadare, 2011). Before this time, most of the oil and agriculture that comprised most of the national GDP was not properly accounted for. Later, the 1990s gave rise to many structural changes in the local banks, while there were also large increases in the amount of banks willing to assist with foreign exchange services and forms of credit. The nation soon experienced a financial ‘meltdown’, mostly attributed to leadership issues, leading the nation to forcibly develop a banking culture; Fadare (2011) argued this version of a banking culture was a ‘free for all’, and despite the changes, there were still unethical leadership practices and inadequate corporate governance throughout the industry. According to Nwagbara (2012), “as different stakeholders whose interests are represented in corporations are asking questions regarding how these funds are being managed as well as the nature of risks involved in managing their funds the veil covering unethical behaviour going on in these corporations was pierced. This led to the exposure of corporate scandal, management intrigue and unethical, visionless leadership masquerading in the Nigerian banking sector as genuine leadership” (p. 137).
Nwagbara (2012) discussed Nigeria problems and developmental attempts in further detail, stating that leadership shadow takes place when a leaders actions impact overall operation in some manner. In Nigeria, certain levels of leadership have not been living to expectation especially in the state and local governments; here, the system of leadership is stated to lack the fundamental ethical elements of charm, charisma, trust, conduct, and ethics (Takala, 2010). The increasing disorder has led to increasing investigations, which have generally confirmed the nature of the complications, but has done little to prompt viable and effective change; this is what led Nwagbara (2012) to recommend changes in leadership models that involve an increased emphasis on ethics and morality. The ethical aspects of leadership is in line with many of the conclusions of formal investigations examining the national corruption, while McConvill (2005) stated that the demand for ethical shifts parallels a demand to improve the positive nature of corporate governance, while the leadership model should be able to recognise the strengths, weaknesses, and virtues of governance; with this, it should promote the implications for improved and positive corporate governance. A similar emphasis or improvement in the system is necessary if the nation is to restore customer and investor confidence in leadership, and it is required if corporate governance is to become ethical once again. The consolidation exercise that took place in 2006 served to improve the strength in banks, improving some customer confidence, but it did little to reverse the entirety of the damage that has occurred since Nigeria had experienced corruption through prior decades (Inyang, 2009). Ogbechie & Koufopoulos (2007) argued that the institutionalisation of ethical leadership in Nigeria will aid it in its attempts to stimulate corporation performance, while it is also expected to allow it to limit the abuse of power so commonly seen in key positions.
Improving corporate governance standards is something that the nation has been faced with, and many analysts have considered, over the past decade. In the past few years, analysts have noted that the majority of banks in the nation were exhibiting textbook signs of liquidity strains; soon after, a joint inspection team was tasked with assessing banks to determine whether they were operating within ethical behaviour standards (Nwagbara, 2012). Here, it was discovered that out of the first ten banks assessed, only five were compliant with ethical standards and corporate governance demands. This forced some of the executives to be replaced. Meanwhile, aid the massive spread of corruption and unethical practices have been a widespread silence or fear to speak out against corruption. As explained in the previous section, while the UK requires that people report all knowledge of laundering or corruption (making it a punishable offense to fail to report knowledge) silence is commonplace across Nigeria. This has forced legislators to take greater action to encourage reporting or ‘whistle blowing,’ although this is a great challenge in a nation where corruption is so commonplace. According to Nwagbara (2012), “Nigeria’s Corporate Affairs Commission (CAC), Nigerian Securities and Exchange Commission (NSEC), and Corporate Affairs Commission (CAC), among other related government bodies should be in vanguard of making sure whenever a trace of potential violation is heard or suspected and it should be investigated straight away to avoid being  covered up. The institutionalisation of culture of whistle blowing should be an effort in curbing the spate of corruption and corporate governance violation. It will help in nipping potential violations in the bud” (p. 142). Considering the nation’s moral values as a whole, studies have shown that the national values have been declining across the past decades, while the monetisation of the national value system has served to stunt the developmental progress for morality in politics or finance. In the financial sector, the leaders have not shown concern for addressing public interest, while they instead focus on personal (if not outright fraudulent) improvements. An example of a major case of corruption can be illustrated by considering the former CEO of the national Union Bank, Mr. Ebong, who granted approximately $1 billion in loans to various firms and people without using collateral (a similar case is Mr. Adigwe of Afribank, who loaned nearly $900 million without security). These people effective compromised the trust of the organisations and customers, and had been motivated by the interest percentages agreed upon by the borrowers. This is why Nwagbara (2012) recommends an improved values system, and in cases such as this, it is recommended that more emphasis be placed on hard sales work and attention to detail (rather than sales without securities or fraudulent acquisitions).
Giving still further consideration to combatting laundering and fraud in the nation, and improving general financial regulations, Nwagbara (2012) also assessed visionary leadership, ethical behaviour, and intermediation with regards to the financial sector in the nation. Here the author provided a range of recommendations, asserting that the Nigerian banking system should be free from corruption while able to operate with ethical standards within visionary leadership. Discussing the potential for sustainable development through improvements in ethical behaviour, the author stated “a reinvented Nigerian banking sector sought through ethical leadership and corporate governance will bring about sustainable development. The question of sustainability deals with strategies to ensure long term business growth in the context of contributing to a nation’s present and future environmental, economic, and social needs. This process essentially resonates with integrating ethical leadership that would help drive sustainable development since it considers factors responsible for promoting societal advancement” (Nwagbara, 2012, p. 144). Claessens (2006) had recommended intermediation be used as a path towards sustainable developments in Nigeria, while Nwagbara (2012) also recommended this, as intermediation is concerned with ethical engagements with stakeholders and customers; this could serve to improve operations and reputation alike, which is needed in a nation where reputation has become a more sensitive issue. Nwagbara (2012) concluded that the Nigerian financial industry has been damaged by its own leaders, who generally violate either organisational or industrial standards as they mirror the corruption commonly evident in national politics. Since laundering, corruption, and crime are so commonplace in the nation, Nigeria has given birth to an entire culture of financial crimes and unethical practices that demands change at a systematic level. Nwagbara (2012) recommended that in order to facilitate the change demanded, ethical leadership is needed to facilitate corporate governance, while banking practices may need to be built from the ground up.
This section has shown how laundering and corruption are commonplace in Nigeria, as the developed nation has experienced problems in these areas since it gained independence from the UK. Unlike the UK, they do not have complex legislation or strict reporting requirements, and this serves to create major differences in how industry and crime are approached. Unfortunately, while it is much easier for Nigerian authorities to abuse their power, those living within the developed nation commonly give in to temptations to do so. In a country where an entire criminal and power-abusing culture has developed, this is commonly expected to be the norm, while those that would attempt to fix the situation without the full backing of a government agency may easily be discouraged by the criminals that outnumber them. This is why analysts feel that more positive change is likely to occur from a greater emphasis on adjusting policy and frameworks for ethical practices and corporate governance than other areas. The following section gives more consideration to corruption as a general concept, more common in Nigeria than in the UK, showing the nature of the challenges in dealing with the problem.
2.5 Corruption, Prevention, and Recovering Proceeds
2.5.1 Corruption
Though corruption is generally more commonplace in developing nations, it is known to plague nations and governments worldwide. According to Obuah (2010), “corruption has been define differently by various scholars and organisations,” who further reported that “corruption is a behaviour which deviates from the formal duties of a public role because of private-regarding…pecuniary or status-gain; or violates rules against the exercise of certain types of private-regarding behaviour. According to the World Bank, corruption is the abuse of public office for private gains” (p. 19). Meanwhile, the World Bank estimates that the cost of corruption across the world is near $80 billion; this figure encompasses public officials accepting bribes, extortion, soliciting for bribes, and public policies being circumvented for some form of gain (World Bank, 1997). The United Nations Development Program (UNDP) stated that corruption is a misuse of public power, public authority, or office through some form of financial crime (potentially including fraud, extortion, bribery, embezzlement, and more); Transparency International (2007) provides a similar definition, referring to corruption as illegal or inappropriate behaviour generated through the abuse of power of a person of trust, generally referring to politics and public positions. This section reviews and assesses some of the studies that have been conducted regarding corruption in the past decade, considering implications for policy and future developments to meet present demands.
Svensson (2005) studied corruption in developing nations, asking a total of eight questions in his efforts; these questions included the definition of corruption, the most corrupt countries, the common traits of corrupt countries, the extent of corruption, whether higher wages for bureaucrats can reduce corruption, whether competition can reduce corruption, why there has been few successful recent attempts to address corruption issues, and whether corruption impacts growth. Addressing the first question, the author pointed out that the most common definition for public corruption involves the misuse of public powers and funds. With this, Svensson (2005) asserted that corruption is an outcome by nature, as it is a reflection of a nation’s cultural, economic, legal, and political organisation. Thus, corruption can be a reaction to new rules, whether they are otherwise beneficial or detrimental. Corruption manifests in response to helpful rules when people are willing to bribe officials to avoid the challenges or penalties of the new rules, while corruption can manifest in response to detrimental rules when people seek bribes as a method to circumvent them. Svensson (2005) wrote “a number of parallels have been proposed for thinking about corruption. Although each of these parallels can be illuminating in certain ways, none of them capture the phenomena perfectly. As one parallel, corruption is often thought of as like a tax or a fee. Bribes, like taxes, create a wedge between the actual and privately appropriated marginal product of capital” (p. 20). With this, bribes generally involve a greater exchange of funds than with taxes, due to the nature of unpredictability and secrecy that is associated with bribe situations. Svensson (2005) pointed out that corrupt contracts are not enforceable in court.
The dynamics in corruption are rather expansive, while it can potentially play a role in many areas of national organisation, politics, or finance. Answering the question regarding the most corrupt countries, Svensson (2005) explained that it is difficult to assess corruption across nations because of the range of forms and its secretive nature. However, since the forms of corruption are still related, it reflects an underlying framework; the past decade has experienced growth in international studies targeting corruption, most commonly measuring corruption through one of three measures. The first is based on indicators developed through the work of private risk assessment businesses, while the one developed and published in the International Country Risk Guide is among the most commonly used (because of its superior coverage in both locations and time periods). This guide was designed to assess the potential that leading authorities will request additional funding, and the amount of illegal payments distributed through governmental departments. The second type of corruption measure averages figures reported, with the Corruption Perception Index being among the most popular; this was produced by Transparency International, and varies annually. Transparency International asserts that the International Country Risk Guide determines the political risk in corruption, rather than a nation’s level of corruption. Svensson (2005) stated that the variation here can range greatly, depending on how the public perceives corruption. The third type is a complementary assessment, referred to as the Control of Corruption, considering information gathered from a large number of data sets; these tend to include international indices, attempting to aggregate corruption signs in a unique manner; Svensson (2005), despite the arguments of the developers, argued that the differences across the types seem to have only marginal significance, while they are comparable effective.
As mentioned, Svensson (2005) also explored the common traits of nations with high levels of corruption, attempting to find common themes and universal characteristics. Here he noted that all of the nations with the highest levels of corruption are developing countries, while many are governed (or have recently been governed) by governments that can be defined as socialists by nature. Additionally, although there are exceptions, most of the nations are also low income nations, while the majority of nations also have closed economies. These findings led Svensson (2005) to question how intuitive connections regarding common national features in countries experiencing high levels of corruption compare with systematic research. Here the author cited institutional theories while explaining the role of economic and structural policies amid the role of the organisations; with this, the author explained that the selections of structural and economic policies have potential for institutions to affect corruption. Moreover, institutions generally evolve in accordance with a nations income level and differential needs (Svensson, 2005).  Meanwhile, the most corrupt nations worldwide were stated to be Bangladesh, Zimbabwe, Albania, Nigeria, China, Haiti, Uganda, Gabon, Iraq, Myanmar, Indonesia, Nigeria, Congo, Paraguay, Iran, Lithuania, Afghanistan, Laos, Tajikistan, Cameroon, Kenya, Turkmenistan, Congo, Somalia, North Korea, Zimbabwe, Serbia, Angola, Haiti, Libya, and Sudan. Svensson (2005) stated “yet another way in which historical traditions and colonisation might affect the extent of corruption is through the influence of religion…For example, the institutions of the Protestant church, which arose in part as an opposition to state-sponsored religion, may be more inclined to monitor abuses by state officials…politicians and public officials might be challenged less in Catholic and Muslim countries than in Protestant countries” (p. 25). Meanwhile, the nature of political and economic institutions serves to affect the extent and reach of the corruption, especially in terms of how they limit competition in politics or markets.
Khamfula (2007) moved beyond considerations of corruption and drivers to consider the manner that corruption can affect economic growth, focusing on nations that have trade strategies that differ (EP and IS nations). The author attempted to expand on previous work that had focused on influence on FDI, and suggested that additional insight can be gained through assessing how corruption can interact with trade policy to impact growth. Here, the author examined the developments in 17 nations across 10 years (1994-2004), finding that corruption is more detrimental in IS regions compared to EP. In 1997, Bardhan (1997) had asserted that corruption has had a detrimental impact on static efficiency as well as growth and investment, but further reported that there is reason to believe that corruption can potentially improve economic development and efficiency (especially considering the nature of regulations in developing nations). Khamfula (2007) explained that this is possible as “a payment of bribes by a foreign investor to get an investment license clearly diminishes the incentive to invest in the host developing country. Arguably, in the taxation system of many countries, losses can be subtracted from taxable investment income, but there is no corresponding loss offset in the case of bribes, so that the latter are particularly harmful for risk-taking in the context of innovation” (p. 1847). Meanwhile, the innovators are powerless to the actions of public officials, if they are corrupt, as new producers require government-supplied products. In related literature, Romer (1994) had found that corruption as a tax to post-profits can potentially stunt the entry of products that demand a fixed cost investment, while Mauro (1995) explained a negative impact of the corruption index on the rates of investment in growth; the latter was determined to be true even when considering the control of determinant and correction of any bias in the information. Such a negative relationship appears to apply even when national regulations are overly complex and restricting, further suggesting that corruption is commonly perceived as a way of effectively operating without the burden of inadequate regulations. Balasubramanyam et al. (1996) assessed the impact of FDI on growth, and provided a new empirical model that left room for corruption to be added; Svensson (2005) expanded on this model in his assessment, finding that the addition of corruption into the model greatly improved its descriptiveness and ability to make projections. Mo (2001) attempted to add perspective to the knowledge base on corruption, considering corruption’s role in economic growth; here, the author found that political instability resulting from corruption can potentially have the greatest impact, further finding that corruption reduces the extent of human capital or private investment shares. Svensson (2005) concluded that corruption is viewed as activity where the power of office is abused for gain in a way that violates regulations and expectations, recommending that corruption be targeted to a greater extent in pursuit of the potential benefits from the FDI it encourages (if for no other reason). The author further concluded that when the level of corruption rises, it facilitates a substantial negative impact on FDI in both EP and IS nations, but corruption in relation to local investments can lead to a positive influence in FDI for IS nations. Here changes in the growth of economy are considered to be heavily influenced by the nature of local corruption, while the impact of the interaction between FDI and corruption perception index on growth is greater for EP compared to IS nations.
Goel and Hassan (2010) assessed the impacts of corruption when it has spread across an entire economy, considering bad loans and several nations. The authors’ basic findings were that higher levels of corruption are relevant to additional bad loans, while loan defaulting occurred more slowly in faster growing economies assessed in comparison to the slower economies. Additionally, “other institutional controls, including central bank autonomy, financial underdevelopment, bank-based economies and transition nations fail to show appreciable effects on the incidence of bad loans” (Goel and Hassan, 2010, p. 458). The researchers attempted to use updated information from over 60 nations in attempt to answer their research questions, emphasising the potential for bad loans to respond to international corruption. Detailed results revealed that higher levels of corruption are related to more bad loans, while higher levels of corruption spread completely through economies appears to facilitate undesirable behaviour from borrowers, who see the potential for punishment and apprehension from defaults in a corrupt economy. This can further lead to bribes, while defaults on loans are lower in economies that grow faster, in the Euro zone, and where lending rates are higher (Goel and Hassan, 2010). According to the researchers, “other institutional controls, including central bank autonomy, financial underdevelopment, bank-based economies and transition nations fail to show appreciable effects on the incidence of bad loans. The findings are robust to an alternate corruption measure…and to potential endogeneity of corruption…From a policy perspective, policies that strengthen institutional quality by lowering corruption would pay off in terms of lowering bad loans” (Goel and Hassan, 2010, p. 460). Considering this, as countries succeed in improving their economies, they effectively reduce the risk for loan defaults. Meanwhile, higher rates of interest generally have a comparable effect, while increased autonomy for bankers does not affect performance (though European Monetary Union membership has been observed to stabilise).
This subsection has introduced corruption at a conceptual level, describing related cause and effect relationships, considering the potential for corruption in a wide range of nations worldwide, and describing the implications of empirical research targeting corruption. Overall it is evident that while corruption is more common in developing nations, it has potential in any nation, and cautious planning for the individual economic and political variables in that nation need to be considered if a nation is going to reduce the levels of corruption while improving its economy. The following section gives more consideration for the potential to eradicate or prevent corruption, considering additional empirical studies and general theoretical developments aimed at improving the theory and strategy behind preventative policy and development.
2.5.2 Prevention
As mentioned in the previous section, Svensson (2005) attempted to answer a wide range of questions related to corruption, and many of these were related to prevention. One of these questions asked why there have been so few recent successful attempts to combat corruption, leading the author to report that the majority of anticorruption efforts have been dependant on various types of financial or legal organisations (i.e. financial auditors, policy, judiciary branches, etc.) for the enforcement of policy or accountability in the public sector. Here, the author further reported that it is generally assumed that additional and improved enforcement of policy will serve to reduce the level of local corruption. However, as explained, “in many poor countries, the legal and financial institutions are weak and often corrupt themselves. In such a setting, providing more resources to enforcement institutions may not be the right solution to the problem of corruption…To date, little evidence exists that devoting additional resources to the existing legal and financial government monitoring institutions will reduce corruption” (Svensson, 2005, p. 35). With this asserted, the author pointed out that Singapore and Hong Kong are the most commonly discussed exceptions, prompting him to explore why while relating this information to the potential for developments in other affected regions. In both of the nations, developing and maintaining an anticorruption agency was proportional to decreasing corruption trends, eventually allowing them to be unique in comparison to the other nations. Hong Kong was able to create an Independent Commission Against Corruption that established their ‘guilty until proven innocent’ law and reforms that were implemented simultaneously with improvements in the national enforcement organisations. Singapore took a similar approach, increasing civil servant pay in the private sector while public officials were rotated; this strategy was designed to prevent sole officials from becoming too familiar with funding operations or clients, thereby reducing the potential for corrupt bonds to form. Moreover, the nation rewarded people who were proven to have refused bribes (generally achieved through reporting the briber to the local law enforcement). Singapore also took action to simplify its legislation, and also to publish it, while removing permits and approvals as fees were reduced (or abolished) also served to benefit the nation. Both Singapore and Hong Kong were committed to removing corruption, at least within their higher political positions, and this trait in other countries is expected to lead to greater change. Svensson (2005) stated that such commitment cannot be taken for granted in developing countries.
Further elaborating on these topics in his analysis, Svensson (2005) reported that alternative approaches to combatting corruption have been developed, but these are less commonly known and even less commonly used. One such strategy is to use private enforcement in lieu of public enforcement, using lawsuits to enforce public laws, potentially leading to more convictions and deterrence of corruption on a massive scale. This approach has limited potential, and is not easily implemented in some countries, while it has some of the same restrictions that deregulation approaches have. Another example of an alternative strategy is citizen enforcement through the providence of convenient access to public program information; this can serve to permit the citizens to request specific standards, to challenge officials regarding corruption, or to assess the quality of service. This has a potential to reduce corruption in multiple ways, while research on the topic would serve to improve the knowledge base and optimisation of strategy in this area. Svensson (2005) explained that a similar approach was taken in Uganda for some success, as awareness of underfunding in schools prompted people to monitor officials, leading to improvements in funding and operations over time (and thereby a reduction in corruption). There are different methods analysts could use to approximate the impact of accessibility to public information, but these generally involve an assessment of the target audience, while an assessment of this in the Uganda case revealed that ‘captures’ from corruption in school and government operations were observed over time following the access to public records; the central government in the nation took action to address corruption by distributing data, increasing access to relevant information, and facilitating the monitoring of fund distributions in schools across the country. This required some intervention from the government, and while it may not be possible in all nations, sufficient concern for the issue should prompt governments to take at least some minimal action to address corruption. An action as simple as spreading awareness of corruption, allowing groups in the affected to take their own preventative (or other) measures against the corruption can have a major impact on such corruption trends. Svensson (2005) stated that grassroots supervision efforts have been shown to be effective in some developing nations, increasing popularity in the meanwhile. In Brazil, for example, the local citizens have been able to use report cards in participatory budgeting, while Indian citizens have been able to access more public data or attend public hearings; preliminary data has implied that this has in fact led to a marked reduction in certain forms of corruption (Svensson, 2005). Another potential strategy in combatting corruption is delegation from the private sector; this can serve to improve monitoring processes and affect operations. A common example of this is preshipment inspections, which can serve to lower the amount of corruption in customs departments. This is because it affects monitoring capacities of the more powerful enforcers, and provides a second data set for the inventory, potentially affecting the bargaining power of the importer (Svensson, 2005). There are still other potential strategies to address corruption, generally involving access to additional information, or additional perspective regarding the actions of the potentially corrupted, while nations must seek their custom solution through their own willingness, resources, and strategy.
Considering international efforts to address corruption, the International Financial Law Review (2010) reported that more countries attempting to reduce national corruption have been entering into multinational contracts or organisations establishing greater anticorruption legislation or controls. With this, “compliance with and enforcement of the US Foreign Corrupt Practices Act (FCPA) has become more important for US and non-US companies alike, especially in the past five years. Globalised commerce and the development of global markets have induced even small companies to list themselves internationally and subjected more companies than ever to the FCPA’s restrictions” (International Financial Law Review, 2010, p. 104). This has served to improve prevention against corruption.
As mentioned, there are many potential approaches in addressing corruption prevention, and governmental intervention combined with strategic use of resources can have a major impact. This section has introduced some of these strategies, exploring strategies that have been proven effective while further considering the potential for alternative strategies to be effective in different circumstances. The following section moves to consider the potential for recovery efforts to be effective, in the event that corruption is properly served and appropriated halted.
2.5.3 Recovering Proceeds and Improving Policy
Once corruption is duly identified and checked, there is still the issue of redistributing the misappropriated funds, and this can be a great challenge to any organisation or nation. This section briefly explores this topic, considering potential for optimisation in this area as well as the potential to successfully improve policy.
Recovering proceeds can pose unique challenges to organisations, and even to entire governments. Chamberlain (2002) considered the processes in the UK which could be integrated in developing nations to find their stolen funds, and request a return, finding that the processes that are available should be optimised to improve returns. More recently, Carr and Goldby (2011) examined the efforts of the United Nations Convention Against Corruption (UNCAC) in AML and seizing corruption funds, finding that despite the challenges in locating and securing funds, there have been improvements in procedures across the past decade. There are barriers that exist in the UK and worldwide which affect asset recovery, and addressing these involves unique complications. Canhoto (2008) examined UK barriers, elaborating on the nature of challenges and complications while considering ideal paths in policy development; these were stated to be “those emerging from the nature of the application, those concerning the particular organisational circumstances and those emerging from individuals’ mental schemas” (p. 177). This researcher also found that agents attempting to improve interventions can serve as ‘gatekeepers,’ and have an effect on the net performance of the implemented solution. Concluding, the author stated that segmentation is generally perceived as a tool for consumer markets, but it is a valuable technique to use in other organisational areas; with this, they asserted that the integration of segmentation is prone to obstacles related to organisational traits, how and where it is integrated, and cognitive restrictions.
2.6 Summary
As stated, numerous studies have been created in attempt to better understand the potential to stop money laundering, and to retrieve the proceeds of corruption, but most of these studies have been unable to perceive the true extent of the problems or most effective strategy to address it. Crimes like laundering, fraud, and terrorism exist at a fluctuating but substantial rate over time, with authorities in even developed countries having limited power over the number and willpower of criminals.  A wide range of theoretical analyses and empirical studies have examined the potential for policies to be more effective in stopping crime, while analysts have continued to offer recommendations for altering policy to be more effective. The majority of the anti-laundering efforts (AML) have been ineffective in achieving their target goals. As such, governments and analysts have continued to pursue the potential for improvements in restricting crime without restricting the financial transactions of legitimate businessmen and account users. General laundering is a phenomenon as old as finance, but the rise of computer technology and its integration with banking organisations has added a new dimension to this. Now, people can more secretly manipulate bank processes, with this potential for secrecy and the exploitation of mediums translating to a higher potential for corruption.  Many other researchers have provided evidence of changes and potential in relation to laundering attempts and AML efforts. In other research, Goswami (2007) explained that it is crucial to address authority organisations (i.e. the Financial Services Authority) to address potential corruption or laundering, while Egbuiwe (2009) reported on the potential for a new network to assist in the fight against laundering.
Laundering and AML has been something that has been evolving through both legislation and the nature of crime. Here both officials and criminals improve their techniques, and the end result appears to be near a balancing effect over time. Officials and analysts are not satisfied with such a trend, while true digressions are major challenges to developing and developed nations. The following section describes the evolution of these areas with more emphasis on UK trends, showing how developments have occurred (and the nature of cause and effect relationships in policy developments) in the UK. The UK has experienced pressures to address AML, and while the nation is comparably as developed as the US, it has not experienced the same degree of terrorist attacks or corruption (Reynard, 2010). Meanwhile, Reynard (2010) stated that the situation is arguably easier for investigators in the United States, as they have access to tools that are not as accessible in the UK; moreover, wiretapping cannot be used as freely in the UK as it is in the US, impeding potential progress on cases or investigations. The government in the UK has given little consideration to using ‘intercepted’ evidence in criminal investigations, while plea bargaining is seen as something that has potential to more positively affect case outcomes as well. AML in the UK has undergone many changes from a wide range of acts and legislative developments, although even the most strategic improvements in these areas are still challenged by the demands to pinpoint illicit activities. Terrorist laundering is one of the most difficult types of laundering to catch, because it requires the identification of both terrorists and terrorist activities alongside illicit funds. Fortunately, a combination of reporting laws and improved investigative legislation provides authorities with a better chance of finding and stopping criminals, but there are still complaints that some of the efforts can serve as obstacles to legitimate businesses. While there have also been complaints that the legislation has been inadequately effective, with low numbers of assets seized and people prosecuted, the known amount of activities and comparison of UK laundering compared to US laundering are thought to be low. In this sense, while the problems still seem substantial and worthy of significant attention in on-going research and development, they do not compare to the challenges in developing countries; here both legislation progress and the potential for corruption are high. The following section explains the nature of related challenges in such a country, which may be the most corrupt nation in its continent, Nigeria.
Nigeria, as a developing country with less political organisation and less organised law enforcement in comparison with the UK, has experienced a different and greater struggle with AML and corruption issues. Obuah (2010) asserted that in the nation, corruption is consistent (if not growing) in the nation, while crimes such as laundering, bribery, embezzlement, and misappropriation saturate the society. The leaders and aspiring leaders of major political organisations are generally at the greatest risk for corruption in the nation, while elected officials commonly abuse their power; approximately 20 percent of the nation’s GDP is attributed to corruption. Meanwhile, Nigeria has been near the bottom of the Corrupt Perception Index ranking of Transparency International. In 2000 Nigeria established the Independent Corrupt Practices Commission (ICPC) and in 2002 it established the Economic and Financial Crimes Commission (EFCC) in attempt to mitigate its problems, while corruption is currently considered Nigeria’s worst problem; corruption is thought to be responsible for many problems in the nation, including obstacles to democracy and democratic elections, stunted foreign investments, debt complications, and instability. The developed nation has experienced problems in these areas since it gained independence from the UK. Unlike the UK, they do not have complex legislation or strict reporting requirements, and this serves to create major differences in how industry and crime are approached. Unfortunately, while it is much easier for Nigerian authorities to abuse their power, those living within the developed nation commonly give in to temptations to do so. In a country where an entire criminal and power-abusing culture has developed, this is commonly expected to be the norm, while those that would attempt to fix the situation without the full backing of a government agency may easily be discouraged by the criminals that outnumber them. This is why analysts feel that more positive change is likely to occur from a greater emphasis on adjusting policy and frameworks for ethical practices and corporate governance than other areas. The following section gives more consideration to corruption as a general concept, more common in Nigeria than in the UK, showing the nature of the challenges in dealing with the problem.
Though corruption is generally more commonplace in developing nations, it is known to plague nations and governments worldwide. According to Obuah (2010), “corruption has been defined differently by various scholars and organisations,” who further reported that “corruption is a behaviour which deviates from the formal duties of a public role because of private-regarding…pecuniary or status-gain; or violates rules against the exercise of certain types of private-regarding behaviour. According to the World Bank, corruption is the abuse of public office for private gains” (p. 19). Meanwhile, the World Bank estimates that the cost of corruption across the world is near $80 billion; this figure encompasses public officials accepting bribes, extortion, soliciting for bribes, and public policies being circumvented for some form of gain (World Bank, 1997). The United Nations Development Program (UNDP) stated that corruption is a misuse of public power, public authority, or office through some form of financial crime (potentially including fraud, extortion, bribery, embezzlement, and more); Transparency International (2007) provides a similar definition, referring to corruption as illegal or inappropriate behaviour generated through the abuse of power of a person of trust, generally referring to politics and public positions. As mentioned, there are many potential approaches in addressing corruption prevention, and governmental intervention combined with strategic use of resources can have a major impact. This section has introduced some of these strategies, exploring strategies that have been proven effective while further considering the potential for alternative strategies to be effective in different circumstances. The following section moves to consider the potential for recovery efforts to be effective, in the event that corruption is properly served and appropriated halted.
Chapter 3: Research Methods
3.1 Introduction
This chapter presents an overview of the research methods used for this study, including the research design and direction, research aims, research questions, research objectives, sampling, resources, instrumentation, pilot study, data collection, data analysis, limitations, ethics, limitations, ethics, and reliability and validity.  As mentioned in the introduction section, the study targets public records and empirical data collected from organisations, for a comparative analysis of Nigerian and UK policy.

3.2 Research Design and Direction
The general research design and methodology combines the examination of data and literature with primary research of human participants; it therefore uses the available relevant data as well as empirical research. With this, the study targets public records and employees in leading organisations from Nigeria and the UK, attempting to gain the participation of the largest companies possible (see following sections and Chapter 4 for details regarding the organisations that were attempted to be contacted for participation and the organisations that were actually willing to participate in this effort). Here, the primary research and primary data is pursued through facts and feedback regarding the use of government legislation, how bank policy is applied to address the problems, and what plans or issues there are in development. The research instrumentation was designed to target bank managers from the UK and Nigeria, so that their feedback could provide inside perspective to compliment the information available to the public (and also to create an original study, see section 3.5 for details). Beyond the review of literature that has examined the core concepts and analyses conducted on the subject, the ‘secondary’ research in this study is conducted using bank policies that have been published, legislation that has been created in the respective countries, and other publically available information obtained without instrumentation or participants.
This study presented is qualitative in nature, thereby assuming the inherent risk of bias in qualitative studies, but useful in exploring the conceptual and theoretical aspects that are relevant to this significant problem and case; this potential for bias from this approach to research is most relevant to questions about the recommendations for improvement, challenges, and opportunities involved in developing the regulations (Laurel, 2003; Holliday, 2007). There is less potential in any questions regarding experience or the nature of policy, or facts rather than perspective and recommendations. As mentioned, this qualitative study discusses the vulnerabilities and potential for bias in the responses, so this is considered in the discussion, and not simply ignored (allowing potential causes of bias and any implications to be considered). Beyond this, the study focuses on the relations to theory and the conceptual potentials for improvements at large and small scales, providing recommendations for further research and development as well.

3.2.1 Research Aims
Generally speaking, the aim of the research is to assess and compare the weaknesses of banking systems and regulations in the United Kingdom and Nigeria, through a standard academic approach to a comparative analysis. Here the research direction moves to focus on methods applied by banks for account freezing, fund acquisition, recovery of misappropriated funds, and recommendations for improvement. The research aims to record the most useful data and perspectives available from the respondents, combining this with literature for an informative interpretation and analysis that can potentially guide future research efforts. The research questions developed for are an extension of this research aim, serving as the foundation of the research objectives (while these in turn serve as the foundation for the instrumentation).

3.2.2 Research Questions and Hypotheses
The research questions were strategically formulated from the perceived significance of research in literature, as well as the best potential to optimise the available resources. The research questions, as presented in the introduction section, are as follows:

Primary Research Question: “What are the strengths and weaknesses in the United Kingdom versus Nigerian regulations for monetary transfers in the financial sectors, and what are the most viable and effective ways to improve account freezing and fund handling techniques?”

Secondary Research Question: “What are the challenges and opportunities for the recommendations in literature and from financial experts?”
The candidate has established hypotheses at the time of the proposal developed for the study, but these were premature without researching additional literature. Hypotheses were then established for each research question after the research for the literature review was completed, but before the results were recorded and assessed. These hypotheses are:

Primary Research Question: “What are the strengths and weaknesses in the United Kingdom versus Nigerian regulations for monetary transfers in the financial sectors, and what are the most viable and effective ways to improve account freezing and fund handling techniques?”

Hypothesis 1 (Primary hypothesis): The Nigerian government and banking systems could learn a great deal from the UK systems, but a combination of disorganisation, resource issues, and corruption in the government impede the progress. Most of the recommendations in literature are expected to be known by upper management and many analysts, but this knowledge is expected to be less commonly known across the government and banking system. Motivations for awareness and development are expected to be limited from the combination of corruption of the government and knowledge of resource and organisational challenges. It is expected that certain degrees of corruption are just expected in the nation, and that the people require some kind of assistance (from the government or otherwise) in driving progressive change in their banking systems. In the UK, it is expected that while the challenges in improvement in a general sense are lesser, their challenges in addressing the more complicated aspects are thereby the greatest overall, demanding additional research initiatives surpassing the scope of this study to gain knowledge of effective techniques and new solutions. For both countries, the most viable and effective ways to improve account freezing and fund handling techniques depend on the best methods for organising resources and processes, from which current events, policies, literature, and expert opinion have only provided clues.

Hypothesis 2 (Secondary hypothesis): The challenges and opportunities for addressing the recommendations in literature, and meeting those advised by financial experts, all stem from problems in knowledge acquisition and awareness, corruption and disorganisation, resistance to change, and available resources. Addressing these problems to the extent demanded to create the viable solutions targeted would therefore demand that the challenges be continually pursued through research and development, which will almost certain require changes in legislation or funding from an outside organisation (such as the government, the World Bank, or the United Nations).

3.2.3 Research Objectives
As mentioned, the research objectives were developed in order to provide a foundation for the research direction (particularly the research instrumentation), using the research aims and questions as their foundation. The research objectives also attempted to maximise the scope and value of the study while mindful of the limitations (i.e. available resources, time, access, etc., see limitations in section 3.9 for further details). These research objectives were strategically developed with all of this in mind, are examined throughout the data recording and analysis processes, and are revisited in the discussion. The ultimate success of the research and analysis is assessed in terms of the ability of the study to address the research objectives, ideally to their full extent (and as planned by the study), or to the highest degree possible. Considering all of this, and restating the research objectives, they are to: i) identify strengths and weaknesses in banking regulations in the UK, ii) identify the strengths and weaknesses for the same Nigerian regulations, iii) complete a comparative analysis, iv) discuss recommended solutions for improvements, emphasising account freezing and fund handling, v) discuss opportunities and challenges regarding the recommended paths to improvement, vi) present unique recommendations for on-going research and development.

3.3 Sampling
As explained in previous sections, sampling of human participants for the primary aspect of the original research targets bank managers in Nigeria and the UK, gathering the opinions from 30 managers in each country. Five high ranking managers from each nation were targeted to complete semi-structured interviews (see section 3.5 for details on instrumentation), while the remaining 25 were targeted to complete surveys. The primary methods of sampling are a combination of what is referred to as ‘convenience sampling,’ or the use of the most accessible people willing to participate in the study. As travel expenses are limited, and there is considerable distance involved in between the researcher and the range of respondents targeted in both nations, the primary mediums of communication are telephone (for the interviews, assumed to not be the desired and most convenient choice for the sampling), fax, and email (with the latter two depending on the desired choices for the respondents).

3.4 Resources
The main resources targeted for this project are enough participants for the sample, bank policies, country legislation, and literature. The researcher accesses these resources through the sampling methods described above as well as through internet research. Academic search engines such as Academic Search Premier, Business Source Premier, EBSCOHost, Google Books, and Google Scholar are used to locate the most relevant (and newest) literature, and Google is used to find the other publically available data for the banks and for the local laws that are relevant to the laundering and corruption issues.

3.5 Instrumentation
As explained in the previous sections, the instrumentation was made in two main formats: a survey questionnaire and interviews. Both of these instrumentation types are commonly used in scholarly and academic research, as they allow the most efficient and effective communication with respondents (Holliday, 2007). Survey questionnaires allow a researcher to record information from a large number of respondents in short time, and are also easy to use across long distances, making them ideal for this study as a comparative analysis of other countries. Survey questionnaires generally consist of 10 to 20 questions for this type of work, with open and closed questions in some combination; the open questions allow the respondents to provide their own answers, and while potentially slightly less convenient for them when they are not particularly passionate or concerned with the study, it allows researchers to get a better understanding of their perspective (or gain potentially unique feedback). Open questions are therefore ideal in situations where the researcher is not sure of the potential for the respondent to provide specific feedback, such as when the range of potentially influential variables is incomplete or unknown altogether (Laurel, 2003; Holliday, 2007). Closed questions, meanwhile, are often used when the researcher has a better feel for the range of possible answers and variables related to the question, or if the researcher wants to present a range of information or variables to the respondent (Kothari, 2008). The research questionnaire is therefore combining the use of open and closed questions, given the complex nature of the topic, allowing data to be recorded from respondents in known ranges of variables and in unknown areas as well. Meanwhile, considering the interviews, there are usually three categories that the researcher selects from when developing their instrumentation; these three categories are unstructured (having no template, with each respondent viewed and questioned separately), structured (having a strict format for each respondent, and with no deviations or follow-up questioning from there), and semi-structured (having a template to use for each respondent, but allowing the freedom for follow-up questioning as needed) (Holliday, 2007). There are benefits and drawbacks to each, with unstructured providing the most freedom, but also creating the most work (and with a greater potential for the researcher to lose track and miss questions and information that would be important). This study adopts the semi-structured approach, which allows the freedom of the unstructured interview and the template of the structured interview; this has the most all-around benefits for the researcher and the study, since the template can be used as it is brought to each respondent, but the researcher can ask follow up questions whenever there seems to be the potential for additional useful information relevant to the study to be recorded and integrated with the results. The instrumentation is presented below, as well as in the Appendices (the Appendices version has the full set of instructions and greetings abridged here for the purposes of presentation). Some background information was also requested for other research purposes, such as in the event of a correlation, but these areas were not targeted or prioritised in the effort (see the end portions of the instrumentation sections for details).

3.5.1 Survey Questionnaire Items Covered in the Research
1. On a scale of 1-10, how great is the threat of money laundering in your institution?____
2. On the same scale, how great is the threat of corruption, or how great is the potential for corruption to affect operations in some way?____
3. Is your organisation taking any steps to address the threats of money laundering or corruption? ____
4. If you answered yes to the above item, please describe_______________________________
5. Has your organisation taken any steps in the past year (yes/no) and do they plan to take any steps in the upcoming year (yes/no)?
6. On a scale of 1-10, how much concern do you feel the organisation has for the potential threat of laundering?_____
7. What do you think are the strengths for your organisation, in terms of protecting against laundering and corruption related actions?____________________________________________
8. What do you think are the weaknesses? ___________________________________________
9. What improvements do you think should be made regarding any of the above areas, if any?
_____________________________________________________________________________
10. Do you feel the account freezing policies are adequate?_____
11. If you answered no to the previous question, then why?______________________________
12. On a scale of 1-10, how adequate do you feel fund handling procedures are, considering the threats of crime?________________________________________________________________
13. Please provide any additional comments you feel are relevant to this research study, or you feel would be informative to any aspect of it. _________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________

Background information (please complete to provide the researcher with basic employment information which may or may not prove additionally useful through additional correlations in the study)

Approximately how long have you worked with the company?________
Approximately how many investigations have you dealt with?________
Approximately how long have you worked in any position dealing directly with anti-laundering or laundering issues for a financial service provider?________

3.5.2 Semi-structured Interview Questions

1. What kind of problems does your organisation have with money laundering, and related regulations?
2. Do you think the organisation is doing enough to address the problem?
3. What kind of work do you think is needed to improve regulations?
4. How does the potential for corruption, and the need to recover funds, affect your organisation?
5. What other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?

Background information (please complete to provide the researcher with basic employment information which may or may not prove additionally useful through additional correlations in the study)

Approximately how long have you worked with the company?________
Approximately how many investigations have you dealt with?________
Approximately how long have you worked in any position dealing directly with anti-laundering or laundering issues for a financial service provider?________

3.6 Pilot Study
As mentioned in the introduction, prior to the full distribution of the instrumentation for this study, the instrumentation is to be tested with a pilot study, in line with best practices in research. This serves to test the instrumentation with a small number of respondents, as well as the feasibility of the questions. This is a common practice in work of this type, and lets the researcher see how the respondents react to the questions; it is possible that the questions are confusing, or need to be improved to maximise the data recording or meaning of the information provided, and thus a pilot study is a desirable test in academic or scholarly research (Holliday, 2007). If, after the pilot study, the questions are all deemed feasible after testing the survey instrumentation on two participants (and the interview instrumentation on one respondent), then the data will be considered the first sets of information for the eventual complete data set, the final data compilation, and the analysis afterword (see results section for details regarding the outcome of the pilot study). In standard practice, if any of the questions in the template are deemed in need of revision, then the participants need to be contacted to see if they are willing to provide some follow-up information; if they are not, then another participant would have to be pursued in their place, then used as the beginning of the data set (Laurel, 2003; Holliday, 2007; Kothari, 2008).

3.7 Data Collection
Following the completion of the pilot study, the full scale data recording and collection take place until the researcher has reached the target number of sample participants. As mentioned, the primary mediums of communication are fax, telephone, and email; depending on the nature of the instrumentation (telephone for the interviews) and preferences of the participants (fax and email options are available for the surveys).

3.8 Data Analysis
Once the data collection is complete, researchers can begin their compilation, analysis, relation to literature, and any other secondary research that may need to be performed based on the uniqueness of the findings (using available data and additional literature) (Kothari, 2008). Here, the qualitative analysis is presented mostly in terms of theoretical discussion and conceptual relationships, although some charts and images are presented to show statistics and comparisons (see the corresponding sections in Chapter 4).

3.9 Limitations
As an academic study with little funding, this research initiative has many limitations. The study is mostly limited by access and funds, which naturally restrict the researcher from doing more travelling or questioning a greater number of more knowledgeable individuals. A more complete study and contribution to the existing knowledge base would involve a thorough assessment of more financial institutions across more countries, and this could be a greater contribution to the existing literature. However, the researcher simply does not have this kind of access, funding, or time required to complete such a study, and the study is therefore limited by this, requiring the researcher to use the custom instrumentation across the targeted sample number in order to get the most useful information; these limitations are the reasons why the sample size and target samples were chosen, as the components were deemed feasible for an academic study of this nature (see Chapters 5 for more details on limitations).

3.10 Ethics
Many ethical issues are relevant to this study, as is common in academic research or scholarly research, due to its conceptual nature and use of human participants (Laurel, 2003; Holliday, 2007). Aside from the general academic research ethics demanded in any academic research, there is the issue of confidentiality relevant to the human participants, as well as the inherent nature of bias in the qualitative study. As mentioned, beyond this, there is the obligation to avoid the disruption of normal business practices. To address this, the researcher is to ensure minimal impact on business operation, and to address the preferences of willing participants. Also as mentioned, participants can also be questioned for this when discussing their willingness to provide data, and the accommodations required to minimise the impact on business operations are to be observed. The researcher addresses the potential for personal bias through ensuring personal objectivity at all stages; and while it is assumed theoretically impossible to eliminate 100% of the participants’ biases, a combination of caution and listing the potential for bias in the presentation thereby duly addresses the ethical obligations (see the discussion in Chapter 5 and for further details). Any participants willing to provide data were informed of their ability to cease their participation at any time, even up to one day after the data recording are guaranteed anonymity, and are provided with forms for them to sign regarding all relevant ethical aspects.



Chapter 4: Results and Analysis
4.1 Introduction
This chapter presents the raw data and important relationships from the preliminary results, with more in-depth analysis that demands comparison and relation to literature provided in the discussion chapter. Pilot study results are presented before the survey and interview results are presented in separate subsections.
4.2 Pilot Study Results
The pilot study did not lead to a modification of questions, and was thus the effective beginning of the data collection and compilation; two people were surveyed and one was interviewed in this test, and since there was no miscommunication or difficulties in the respondents understanding the questions or in providing coherent answers, the instrumentation was deemed fit for the full distribution and data collection. The surveys were completed first with managers that were willing to communicate through telephone and fax, and their surveys were completed through fax. HR was contacted regarding the possible ability to speak with managers regarding the topic for an academic study, stating that the results would be confidential and would gladly be shared as an incentive, and progress was made for reaching people meeting the sample criteria through this method. The researcher did not find any problems with their ability to complete the questions or to provide relevant and complete answers (even unsupervised and with one trial), and considering this and the targeted manner of the strategically designed questionnaires, it was decided that there was no need to redesign the questions. The interview had similar outcomes. A manager willing to participate in an interview was found and then contacted, assuring the confidentiality and requesting them to state their preferred medium of choice. This manager was outside of reasonable travelling distance considering the limitations of the project, and was willing to conduct an interview via telephone. The interview went smoothly will only slightly less than the anticipated amount of information provided, and the questions were able to be answered to sufficiently complete detail. Considering this and the development of the interview questionnaire, mindful of the validity and reliability principles which were considered in the development of the research objectives as well as the instrumentation, no problems or demands to restructure the instrumentation were found.
Thus, the pilot study was successful, and was able to contribute to the full collection and compilation of information targeted through this study. Because the instrumentation was able to be kept intact with the items maintained, there were no ‘lessons learned’ as are commonly in studies where the instrumentation was remodelled based on this study; if anything, the pilot study affirms the careful consideration of the principles of reliability and validity while using the existing literature to model a questionnaire in line with qualitative research practices.
4.3 Survey Results
4.3.1 Introduction and Background Information
Unlike the instrumentation items tested through the pilot study, the survey sample quantity (along with the interview quantity) was ultimately expanded. The researcher was able to contact the number of people originally planned with a substantial amount of time remaining, and between this and the demand for statistical significance considering the lower number of people originally targeted, it was deemed safe and ideal for additional participants meeting the research criteria to be targeted and pursued with the additional time remaining. The original target quantities of 17 survey participants and three interview participants (from each country, Nigeria and the UK) were increased by substantial proportions to 25 total survey participants and five interview participants from each country, or 50 survey participants and 10 interview participants in total. This of course brings the total sample quantity to 60 for the whole effort, while being more representative of the audience considered in the study. Once these ‘round’ numbers were reached, it was believed that they would make for easier or ‘cleaner’ percentages, and that they would be (more) sufficient and representative while it would be best to not ‘push the envelope’ to attain a higher sample quantity within the limited time available for the project. Thus, the remaining time was dedicated to compilation, analysis, and report presentation rather than attempting to make the expanded sample size still more representative.
Presenting the background information first, it should be explained that there were only loose correlations between this and the nature of the results provided by people within different groups of this background information. This helps to affirm the validity and unbiased nature of the findings, but the correlations observed were not great to provide significant meaning either; implications from this are discussed along with the preliminary analysis provided here, but are not analysed in depth in a great way which is related back to literature. Most respondents seemed to prefer the email medium of communication for the survey, although some preferred fax, and a couple of respondents wished to speak over the telephone regarding the topics of research and general objectives of the project and degree program.
The first background information question requested that the respondents state how long they have worked with the company. The average time with the company was 8.5 years, with answers ranging from three to 22 years. While all of the respondents met the research criteria, this shows that most of them also had a substantial amount of experience, implying that their perspectives and responses are an asset to the study. A similar response and assurance of validity was found with the second question, which asked how many investigations the respondents have dealt with. Here, the average answer was 7.3, or just under one investigation per year (on average), with the responses ranging from two investigations for employees that had only worked with the company for a few years to over twenty or “more than I can count” from the more experienced employees that have worked with their companies for decades. This shows that the employees are experienced enough with both the policies and actual occurrences alongside the investigations to be able to contribute to such a study, and this naturally makes the value of their information and perspectives a contribution to the existing information that is present on the topic. The researcher had desired employees that were experienced in working with actual investigations, rather than ones who were simply aware of the demands and some of the relevant trends (even if they were experienced and had worked in their positions for some time), so this preferred aspect that was not fully adapted into research criteria was met, helping to ensure the quality of the data and accuracy of responses. Lastly, the final question asked how long the employees had worked in any position that dealt directly with anti-laundering or laundering issues for a financial service provider. The lowest response to this was three years, satisfying the researcher’s preferences and the inclusion criteria, while the largest number was 22 years and the average figure was 6.2 years. This shows that the general range was the same as people that have worked with the company, suggesting more company familiarity and familiarity with the concepts, but also showing a slightly lower amount of experience between working with the company and working directly with laundering. Participants were not asked to explain whether their positions that did not directly deal with laundering dealt with it indirectly, or the nature of their direct dealings (i.e. extent of ‘directness’), so this area is still treated with some reserve, precaution, and potential for bias.
The 25 respondents willing to participate in the study thus showed an average of 6.2 years of experience working with laundering, 8.3 years with their company overall, and having investigated 7.3 potential cases of laundering through some function relevant to their position. This shows that the respondents were all capable of addressing the instrumentation, even a little more prepared than the candidate had planned for this work, and tis generally helped to ensure the reliability, accuracy, and value of the data. The following subsection outlines and analyses the results to the first six questions, while the latter questions are divided into another subsection.
4.3.2 Questions 1-6
The 25 respondents from each nation willing to participate in the study thus allow this section to be more expansive than planned at earlier stages of the research, since this number is higher than the 17 planned at earlier stages of the research development. This quantity is almost 40% higher than the original quantity, and is thus believed to make the study proportionally more informative, representative, and generally valuable to the objectives of the candidate. It is believed that the convenience of email and willingness to participate in such a short survey relevant to both an important topic and academic progress is the reason that the candidate was able to make so many contacts in such a short period of time, as this is assumed to not be as probable if the questionnaires were longer, distributed by standard mail, or conducted over the telephone. This is fortunate for the student since there are commonly difficulties in attaining such high sample numbers in a study like this, entirely devoid of professional funding for the research and not providing any incentive to prospective participants to communicate aside from a possible and minimal contribution to the existing literature. The following thirteen questions present the results in terms of the Nigerian responses, the UK responses, and the total responses, discussing the implications of differences, basic relationships which can be explained without the use of literature, and generally providing a preliminary response while retaining the relationships to literature and specific expert assertions for the discussion following in Chapter 5.
Question 1
The first question asked the respondents to answer the question “on a scale of 1-10, how great is the threat of money laundering in your institution?” Here, the Nigerian people (again 25 total and 50% of the total sample) showed a much higher perspective of threat than the UK managers, but this was expected considering the development states of the nation, the organisational levels and integration of technology, and the commonly known differences in corruption and risks between the two countries considering these variables. With this, answering the question the Nigerian half of the sample rated the threat at a 6.8 on average, showing a substantially high and above-average threat that is still below a level considered to be substantial or simply on-going due to any circumstances or vulnerabilities. The range of these values spanned from 5 to 9, showing that no one considered the threat to be below average, while a considerable amount of the respondents felt that the threat of laundering was near maximum in the nation from their perspectives.  This suggests that the threat is still something that should be monitored, pursued, and addressed through policies or other measures, but there is also the potential for bias from the Nigerian managers more here than with the other questions; this is because they may not wish to reveal the nature of the threat or vulnerability for reputation reasons or the potential to encourage criminals. It is also likely that this level is slightly lower than implied from professional experts assessing the trends through peer-reviewed studies because the managers may have simply become comfortable with the operations in the company, considering this to be normal or having become more acceptable with the issues with time. Similarly, the lack of actual investigations or incidents that have not crippled the businesses may have made them more reliant on criminal pursuit and due process actions, rather than being more concerned about altering and improving the first lines of defences within the company. Meanwhile, the threat from the UK managers was rated about the same distances below the average mark from the 25 managers willing to participate in the study, or at an average of 4.2 across the sample; here the lowest value was a 3 and the highest value was a 6, generally showing that the respondents all felt that the reality of the situation was near or below average.

Figure 4.1: Ratings for threat levels

This is below but not substantially below average, suggesting that the managers feel comfortable with the technological and organisational security in place in their companies; however, this also shows that the threats are still great in the nation (or that they are at least perceived to be substantial in spite of the companies following information security best practices), because even these modern systems and elaborate developments for organisational security in the developed nation is not sufficient to bring this average value far below the average area of the scale (to a 3.5 or even 2.5, for instance). This therefore suggests that managers need to remove resistance to change and increase frequency of upgrading to alter security systems safeguarding laundering, or at least to instil a greater sense of confidence in the managers. Meanwhile, considering both portions of the sample, the average of 4.2 and 6.8 brings the average across the entirety of the sample to a 5.5. This value is considered average enough on the scale used that overall, there would not appear to be a problem greater than general criminal motivations and actions as they are perceived to take place across the world as a whole. It is also expected that there is a greater potential for bias or ‘being used to’ existing threats or being comfortable with the current systems or quantities of threats in Nigeria versus the UK; the difference between the ratings is already substantial, and considering that there is almost no motivation for the UK managers to stated their threats are marginally below average according to perception (or at least a lower motivation than the highly threated Nigerian banks), there is considerable and noteworthy potential for the difference of 2.6 to be (in reality) higher across the two samples. This is assumed to be relevant to the threat of money laundering known in both nations comparatively, and the likelihood and noteworthiness of similar scores for corruption in general would be more pronounced with the provided results being more questionable. Naturally, this cannot be assumed for any reason in work of this nature, and the presentation of results and analysis continues with the findings and discussion regarding the second question.
Question 2
The second question asked the respondents to discuss the threat of corruption in terms of operations in the organisation, taking a look at criminal activity in the financial institutions of both nations, but focusing on the general aspect of corruption (potentially and commonly leading to acts of laundering or other criminal activities). Specifically, the question asked “on the same scale, how great is the threat of corruption, or how great is the potential for corruption to affect operations in some way?” The difference, as expected, was more varied for this item compared with the previous ones, which corresponds with the actions and what is known about the different countries. This in itself reduces the probability of gross bias, but there is still some potential for both of the responses from the Nigerian candidates to be understated, because they are ‘used to’ the circumstances or otherwise. In any case, using the same scale, they provided an average response of 7.2, and regardless of being used to the environmental variables or being bias in some way, this rating is higher than the average for laundering and is generally substantially above average; the range here spanned from 6 to 10, with all participants acknowledging that the threat is above average, with a few claiming that the threat of general corruption has reached the maximum level which they perceive. This number suggests that the corruption threat is not necessarily ‘great,’ but that it is strong and persistent. Such a high value has many implications and relations to research, but considering this for preliminary analysis purposes, it should be assumed that the threat of corruption is markedly high, potentially even impacting some of the managers in the sample; if corruption is this great, as is entirely probable, than this is a potential motivator of bias and general reason for respondents in the sample to not mention or describe the true reality of the situation. Meanwhile, considering the UK managers, they provided a similarly distant response in line with the comparative differences considering the threat of laundering, averaging a value of 3.8, and with a range of responses spanning from 3 to 5 (showing no one in the nation felt that the corruption problem was above average, and with only a minority of the sample even feeling that it should be defined as average).

Figure 4.2: Ratings for corruption

This shows that the corruption in the UK is perceived as lower, considering the more elaborate and developed legal systems and greater stability of its legal systems. This is compounded by the same organisation in the banks, and media exposure of potential corrupt acts which are likely more easily exploited in the majority of cases for the nation. Comparing the differences between the responses provided by the nations, there was a difference between 3.8 and 7.2, or a 3.4 point difference; considering that this is approximately one third of the scale, the difference is substantial, while the average from both respondent groups is 5.5 again, again implying the average occurrence of both general corruption and laundering between the two nations. It is important to point out here that the general corruption was perceived as higher in the Nigerian nation and lower in the UK nation compared to laundering, suggesting that white collar crimes of laundering are more common in developed nations in the UK or developed nations with respect to corruption occurrences; meanwhile, this in turn suggests that the developing nations face a greater risk for corruption in general while laundering does not require the same variables that it requires for a successful crime in the UK. As described in the literature review and elaborated upon in the discussion chapter, there are very different environmental dynamics involved in relation to the potential for and capacity to carry out crimes in general. This is important to consider in this preliminary analysis of the reported findings, and is assumed to be responsible for the correlations in the differences in reported perspectives across the questions of a similar nature. Considering what else can be extrapolated for analysis from this question and its responses, the threat of corruption is something that is a perception more so than other concepts such as the nature of existing financial service vulnerabilities or the frequency of investigations; here there is more potential for bias and error, but the ratio of financial service precautions to potential for crimes and the potential for crimes to go unsolved or unchecked are important to consider. Corruption naturally has a better chance for success when the environmental variables allow it to continue as such while the law enforcement or legal systems also do less to stop or appropriately discourage it.
Questions 3-4
The third question allowed respondents to provide more feedback, which is useful to consider when attempting to discern details or examine individual notions in comparison to trends across sample groups. The third question asked the respondents “is your organisation taking any steps to address the threats of money laundering or corruption?” All of the respondents answered ‘yes’ to this question, bringing them to describe through the fourth question. The fact that all of the Nigerian and UK citizens answered yes to the question shows that the Nigerian managers haven’t ‘given up’ on the issues despite the frequency of corruption and challenges addressing the monetary issues, while it shows that the UK managers are still taking action to address important issues; this means that the UK managers have not fallen into a ‘false sense of security’ or become comfortable with the existing operations, and are still actively taking measures to address the issues in spite of the lesser concerns for threats or lower rates of incidence. This was not expected, but is a sign of the type of diligence and continuing development that leads to success in the companies, while observing this through the results provides an immediate foundation for recommendations for countries or organisations capable of pursing such developments with their existing resources or limitations. Here the respondents could provide short answers which could be examined in relation to their nation and the trends observable there, and the researcher could examine the trends observed across the entirety of one sample before comparing the information to the same trends in the other sample. As expected, the findings show that the Nigerians are taking more general steps to address the issues, because they have a greater need to, but the capacity and ‘size’ of the steps planned is more limited considering the organisational and resource challenges. Meanwhile, the UK has less planned and under development in these terms, but their greater potential for organisational development and coordinated resource use in their organisations suggests that their actions will continue to give them more of an advantage in terms of addressing money laundering threats.  Providing short responses to the question, 12% of the Nigerian managers stated that they have developed new training methods for the employees in the organisation, having developed new programs and had looked to the success of other companies for more effective techniques. They stated that they felt that this would provide more effective knowledge and skill capacity as well as general awareness of the issues, so this was expected to be an effective step to address both laundering and effects of corruption having the potential to impact the banks. Aside from this, 20% of the Nigerians felt that hiring additional experts would help to address the issue, but half of them stated that downsizing would be required so that this could be afforded, so the companies were debating whether or not they would carry through with the plans; here it is assumed that hiring people with more security and laundering specialities would serve to better address the needs of the organisation while safeguarding against threats, since the existing organisation and staffing is reported to be normal or modelled based on the operations of unaffected companies in spite of the additional presence of corruption and higher perceptions of vulnerability risks. If, for example, one or two laundering and corruption experts were hired into the organisation, even part time, this would allow the company to have people that are constantly addressing the demands for laundering and corruption security, reviewing literature and practices, making recommendations for employee and manager focuses regarding the issues, and other areas that would in turn lead to improved security and reduced vulnerability; this is in comparison to an existing structure without experts dedicated to catering to these needs as needed in a high-risk environment, as the managers and employees may not have the proper time to address the issues, or they might feel that they are too overwhelmed by their other duties to do anything whatsoever outside of their basic obligations and duties in their positions. In such a high risk environment, this recommendation seems to be one of the more intuitive and sensible, and is thus not surprising. The demand to downsize, however, may be troublesome as organisations may not be willing to lose the human resources it has and can afford, at least not without additional restructuring which may also be too time and resource intensive to pursue under already strained resources or operational conditions.
Aside from these 32% addressing the issues of training and hiring people specialising in the areas of corruption and money laundering, most of the remaining portions of the Nigerian sample recommended more analytical changes and planned shifts in managerial functions. These recommendations and plans seem to be less focused with a lower potential for addressing the roots of problems or core aspects of developmental objectives, but they are still appear to be carefully planned recommendations which are possible through the existing limitations and potential in the companies. For example, 24% of the managers mentioned something to the effect of altering the existing manager functions to remove less productive but time consuming aspects to include more crime-oriented procedures; this is believed to improve outcomes and reduce vulnerabilities through closer supervision and closer analysis of threats, but nonetheless demands some organisational restructuring and strategic planning which may be difficult to follow through with. Specific comments offered by individual respondents regarding this topic included having managers more involved with the computer security staff while being tasked with guiding their operations more closely (and making recommendations for changing their job functions and actions based on best practices). Similarly, a comparable amount of respondents (28%) recommended that employees in general do this, not necessarily demanding that managers of any type alter their operations or play different roles within their organisations; here these respondents stated that there were plans to better research the nature of corruption and laundering trends alongside demands for integrating best practices. This less focused step could possibly alter operations in a comparable way for comparable outcome, but being less focused, developed, and ambitious than the other steps reported, it is assumed that this less ambitious step would need to be supplemented by further action if it was to be comparably effective as the other steps recommended. Lastly, the remaining 16% of the Nigerian sample stated that their organisations were taking minimal but actual steps to address the threats of money laundering and corruption by the implementation of practice as it is deemed necessary by upper management; this lack of initiative may not be the best approach to taking steps towards reducing or addressing the existing threats, but it is important to point out that this sort of apathy towards the issues may not be due to becoming used to the complications or not having the ambition to do so; it is possible that this step is the most ambitious taken because of the restrictions imposed or the freedoms not permitted by upper management. At least some of these employees may only be free to make recommendations, rather than actually develop and implement steps as needed. Overall, considering the entirety of the Nigerian sample for this questionnaire item, it is evident that they all acknowledge the reality of the situation and demands to take active steps to address the pressing issues, but they have various limitations in their ability to do so. The most strategic recommendation is to hire additional employees specialising in the issues, but these planned steps may not be able to be actually taken without a change in funding or replacing employees that are already valued by the HR department and existing organisational structure. Second to this, the training recommendation seems to be the best rival to steps planned for UK developments, which are assumed to be the better representation of steps taken to address issues without as many resource or other limitations. Considering and comparing the responses from the UK respondents shows that the strategic approach only has some similarities, while it seems that the managers here are comparably or even more precautious in spite of the greater threats observed and reported in Nigeria.
Addressing the fourth question, the UK respondents whom unanimously answered ‘yes’ to the third question (regardless of the reduced threat in the area compared to the Nigerian counterpart of the sample) showed more signs of improvement and planned development. For example, 16% of the sample also stated there were plans to hire experts in some area of the company within the next three years, to address the dynamics in technology, but there were no signs of this being a pending issues or in demand of replacing another type of employee; the step seemed to actually be in the early stages of motion to being followed through with. This shows a similar strategy and ambition from both sets of managers, and showing that it is limitations rather than strategy, awareness, or ambition issues regarding progressive development in this specific area; this in turn serves to show that developing nations are not necessarily generally challenged by a lack of experience or motivation to improve. Another 24% of the UK sample stated that training for the existing managers and supervisors was being developed to better inform of the potential for recognising, preventing, or dealing with aspects of corruption and laundering. This 24% that stated training in these areas were being developed for implementation stated that their existing employees and general business operations were capable of addressing the issue, and it was only awareness and finer aspects of security or monitoring that needed to be addressed to handle the issue in a strategic but improved way. This represents a more strategic or at least detailed approach than the training steps reported by the Nigerian sample and this shows more of a preference for training as the step forward for the issues, at least for the people and organisations capable implementing some aspect of training (it is not known whether the resource-restricted organisations were so restricted that they are not capable of implementing their own training sessions, but it is assumed that they are not. Meanwhile, 32% of the sample reported that their organisations were taking action through improved software and technologies that were asserted to better address security threats. While it is surprising that this number is not even higher, it is common knowledge that changing technology is applied to reduce security risks in any form, and corruption and money laundering are basic examples. Software optimised to supervise transaction, safeguard systems, and alert managers or other employees of security breaches can improve operations, and the UK managers that reported actions being taken to address the demands of risk reported some aspects of these as being taken in attempt to maintain or improve existing security measures. It is not surprising that this number is higher than the number of Nigerian citizens that reported some aspect of technology, as this was only a sub-comment of the overall prioritised steps being reportedly taken to address the security issues in their region, again because of the resources. However, it is surprising that such a low number of Nigerian managers reported this at all, since it was expected that this would at least be mentioned more frequently as multiple steps listed. Overall, it is unknown whether the organisations were really generally only taking one or two steps at a time to address the issue, or if the respondents did not wish to list everything (or only listed the most important aspects that came to their minds) to save time; it is probable that the resource and organisational challenges for Nigeria and the developmental levels of UK organisations made the establishment of multiple steps planned for implementation low. The last 28% of the UK sample stated something to the effect that the organisation was taking steps to address corruption and anti-laundering through research or through partnerships with outside organisations; while outsourcing aspects of security may not be the most strategic effort, due to unfamiliarity with the organisation (and considering that outsourcing is commonly done to simply save on costs instead of for the purposes of process or organisational optimisation), contracting experts to work more closely with the businesses regarding security needs could be the best step; 14% claimed the organisation was actively planning for this type of step, while the other 14% mentioned looking into this or increasing the amount of research and efforts dedicated to updating practices.


Figure 4.3: Comparing steps to address threats: Nigeria (left) and UK (right)

A general initiative to familiarise with threats and analysis or practices is something that has been reported to be lacking in organisations, commonly relying on the efforts of upper management or the manifestation of a problem to take action, so it is both surprising and not surprising that the sample reported taking these steps; it is surprising because of the seeming breach from trends, but not surprising because organisations with experience and resources would be addressing an area commonly lacking through the appropriate steps and strategy.
Further comparing the two groups in the sample, and considering that there is no averaging for this part, it is evident that the tendency to address issues through technology and more expansive operations is something the UK continues to do despite of its lower risks regarding the subject areas. Nigerian managers and organisations do not appear to lacking in effort or knowledge, but their approaches appeared to be more limited by organisational issues and resources. It is unknown how common corruption is within these organisations, but there is the potential for this to have affected some aspects of organisational challenges and resources considering the frequency of corruption in the region. In any case, there are still plans for substantial improvements to address the issues as well as the general improvement or evolution of the businesses in line with practices and technology that are becoming increasingly global, but it appears from the responses that the rate of improvement may not be sufficient to eradicate or substantially reduce the threat nearer UK levels.        
Question 5
The fifth question asked respondents to state whether their organisation has taken any steps (regarding the same issue) for improvement in the past year, and whether they plan to take any steps in the upcoming year; this was a two part question, but simply requesting that they provide a yes or no answer to each part. Here too, there was a slight difference in UK organisations being more active in developments in spite of the greater demands present in Nigeria, implying that the capacity for corruption and laundering that improves with criminal experience and knowledge of technology is simply better countered and at a sufficient rate in a nation that has less resource and organisational challenges. Once again these results suggest that there is no easy solution for a developing nation that is so plagued by corruption issues compounding with their resource, organisational, and other issues. Reporting on the results from the Nigerian portion of the sample first again, only 64% reported that the organisation had taken steps to address the issues in the past year, 92% reported that the stated plans for change would be implemented in the upcoming year. This suggests that the issues are not handled on a quarterly or even annual basis, which is potentially the reason for the existing complications in the first place. This also shows that there are no plans for the steps to be implemented in the upcoming year for two of the managers, while the results from the first portion of the question imply that even more of the steps that are tentatively planned will not be appropriately followed through within the claimed time. Meanwhile, considering the UK respondents and their feedback to the question, 92% reported that some steps had been taken in the past year, while 100% reported plans for steps to be taken in the following year.

Figure 4.4: Changes in past and next year planned (%)

This shows that they have more plans to implement change as stated, despite the difference in threat described; this is clearly unfortunate for the Nigerian managers, as they should naturally be taking additional steps to alter their business models, procedures, and other aspects of organisational function to address the greater threat. Instead of taking greater action to address the threat, they report actually having less plans to take action or reduce their larger rates of incidents and looming threats.
Question 6
The sixth question asked the respondents to rate using a scale of 1-10 again, regarding how much effort or concern they feel the organisation is placing on the potential laundering threat; specifically they were asked “on a scale of 1-10, how much concern do you feel the organisation has for the potential threat of laundering?” This is one of the few questions which gain responses that were more equal, but again, it should be pointed out that there should be a greater concern for the potential threat of laundering in an area with higher reported rates of incidence and a greater overall corruption threat. The Nigerian managers presented ratings ranging from a 6 to a 10, but with the average rating being a 7.5. This is a rating that is surprisingly low considering the nature of the threat, as the researcher assumed that with the responses regarding incidence and also considering literature that the number would be higher. This still shows considerable concern for the laundering threat, but with the reported nature of it, an average closer to the upper limit of the range of responses was anticipated, while this seems to be required to appropriately address the threat. Meanwhile, the UK managers provided responses ranging from 4.5 to 8, showing a perspective of lesser concern despite their more frequent actions and apparent general greater involvement with developments targeting laundering and corruption. Their average response was 6.75, showing considerable concern, while it appears that their on-going developments and lower rates of incidents have played a role in the levels of concern.

Figure 4.5: Organisational concern ratings

Averaging this with the 7.5 reported from the Nigerian managers, the overall rating is 7.13. This average is nearer what was expected, aside from the numbers making the average being closer than anticipated.
4.3.3 Questions 7-13
Question 7
The seventh question asked the managers about the strengths of the organisations’ capacities to address the issues of laundering and corruption, focusing on specific actions; here the managers were asked “what do you think are the strengths for your organisation, in terms of protecting against laundering and corruption related actions?” Here the managers from Nigeria stated that they felt that strengths included constant research of incidents, dedication to improving the company, upgrading training and technology, managerial support and desire to improve organisational structure or business processes in line with the recommendations in best practices (or generally based off successes in the developed world), knowledgeable managers and hard-working employees, experience, and a few other similar and loosely related responses; the responses provided here were not of a technical nature for the most part, and this is not something that could be attributed to any lingering language barrier for the managers that still had a few steps in language learning before they were considered fully fluent in the English language. There was no mention of business models or specific technology, and no mention of processes, specific strategies, training modules, organisational designs, hiring requirements, etc. that would be expected for an organisation that has true strengths in line with literature, but this does not mean that these are not present within the organisations; the employees may have simply chosen to mention these aspects of their organisations as what they viewed as the strengths rather than explain the specific processes responsible for them. In any case, considering the percentages of individuals which wrote specific responses, this portion of the discussion considers the first choice in terms of percentages first, then mentions secondary choices (mentioning the first choice allows for division to be considered up to 100% of the sample, while a specified number of strengths was not requested and the sample members provided multiple strengths in some but not all cases). Presenting these first choices, 12% of the employees stated that they felt the greatest strength in their organisation was its capacity and diligence in constantly researching information regarding the trends in laundering and corruption. This includes statistics, investigation results, and strategies used to either stop the crimes or to investigate suspected crimes. Knowledge of this is critical, so organisations capable of familiarising themselves with on-going trends and related demands or implications for security would indeed be an asset; whether this is the best asset or strength for an organisation faced with these issues, however, is more debatable. Aside from those asserting this aspect of organisational strength, another 12% of the Nigerian sample stated that they felt that the greatest strength of their organisation was the general dedication to improve the company, with 8% stating that their organisation is always doing something for the purposes of improving, so this directly or indirectly improves their capacity to address laundering issues or to address the improvement of anti-laundering legal framework as it applies to their company. Despite the absence of technology mentioned in the other questions, 20% of the sample of Nigeria claimed their organisations were able to be relatively competitive and effective in improving technology that addresses laundering and corruption issues. Some of these managers stated that there were improvements in hardware and software to better monitor account activities and employee activities, helping to make more recordings useful to security and to provide more processing power for software tools to be used more efficiently and effectively; operating systems were reported to have been updated as recently as two years ago, and this in combination with replaced computers with faster processors were reported to be among the best organisational improvements to address the matter here. Another 24% of the sample claimed that the managerial support and desire to improve organisational structure or business processes in line with recommendations from best practices was the greatest strength; specific examples stated included remodelling investigation protocol, changing or updating manager procedures, and more discussion between managers and upper managers regarding the demands for changes or improvements, and some changes to hiring and training practices. Beyond this, 20% simply cited experience as the best organisational asset, asserting that their organisations had dealt with enough corruption and laundering to know common trends and how to save their business when it is victim to the trends, so this experience allows them to continue working without fear for the life of their businesses in the future. Since there were no reports of the specific actions taken, or at least none that could be investigated within the confines of the research here, it is unknown the extent that this experience could be used to safeguard the organisation against threats (or the extent that this is a strength). Lastly, 12% of the managers from Nigerian companies stated, as their first choice, that knowledgeable managers and hard-working employees were the greatest asset to their organisation’s efforts to combat laundering and corruption threats. Similar to the previous response, the extent by which this is a benefactor is unknown because the exact nature of the traits are unknown, but it is apparent that this portion of the managers have faith in employee abilities in spite of the reported incidents and threats. As mentioned, there were secondary responses provided by 72% of the respondents and a third strength listed by 12% of the respondents; here the same aspects were mentioned for the second and third choices with the exception of manager training and consideration of hiring outside security experts (though this is not considered to be a strength, technically speaking). Here, in the secondary choices, 24% mentioned employee and security training, 20% mentioned technology changes and expert opinions or ability for technology, 20% mentioned knowledge management, and 8% mentioned experience. For the third choice, 8% mentioned knowledgeable managers and 4% mentioned experience.  
The UK managers provided more details, suggesting their legal framework was more elaborate and refined while they were more willing to discuss details of the strengths in business operations for the purposes of the effort here. From this portion of the sample, respondents stated that they considered the strengths of their organisations to be a continually evolving managerial framework that actively integrates data from laundering cases on a routine basis, highly qualified and trained managers, the experience of the company, continually updating technology and technology use procedures as needed, emphasis on training, and emphasis on research; these were the first strengths listed while the second ones listed these and coordination with security agencies, optimising best practices, and pride in reputation. Considering the first choices in terms of percentages in this sample as well, 20% of the employees stated that the improving managerial structure or framework was responsible for the most success in the fight against laundering and corruption, and this was the greatest strength of their organisation. When research and development follows best practices this is true, and if the managerial framework is continually updated to consider security demands or other demands for changes related to security addressing the demands for safeguarding against local corruption or laundering, it is understandable and not surprising why managers would assert that this is a strength of their company. Beyond this, 12% of the sample credited their managers as the strength of the company, whether it be due to their qualifications or their training, and it is understandable that this type of experience and knowledge from people in a position of authority could be accredited to the ability of the organisations to address related complications. This is not to imply that the managers and framework would be as effective if the corruption and laundering conditions were comparable to the circumstances in Nigeria, but the lower rates of incidence combined with organisational and technological development and the asserted strengths of the company suggest that the legal framework in the UK is generally more developed and a better protectant against any existing threat to the organisations (nationally or internationally). This further suggests that the Nigerian managers (though the upper managers and stakeholders) could learn from the UK legal framework, and while resources and organisational challenges in the nation and its governmental issues may still present a challenge, the results suggest that there is still some potential for substantial improvement through this sort of attempt at development or emulation. Meanwhile, 20% of managers stated that experience was the greatest asset of the company, since many of the companies have been in business for decades while having continually improved their legal framework and technological defences against laundering cases; a few of the managers stated that experience has included research of international laundering attacks, so the organisations have learned from local and global variables while continually updating and upgrading aspects of their organisational efforts. As described in regards to the Nigerian managers and companies, it is understandable why employees would feel this way about the company’s time dealing with the organisation if they can see that it has been responsible for the individual efforts that have directly caused change; this implies that the changes witnessed by other managers may be attributed to experience if they had a greater understanding of whether the time and knowledge accrued by the company is what led to this.  Beyond these portions of the sample, 32% of the managers attributed the continuing emphasis on technology and the demands to improve technology for the success and safety of the organisations. As explained for the Nigerian sample, it is understandable why the managers would feel that this results in increased safety and reduced threat for the organisations; technology is known to be one of the greatest benefactors to security purposes such as this, so long as it has been used correctly, and the other responses imply that the UK continually considers the demands to improve its legal and organisational framework (while implementing the changes more frequently). Lastly, the final 16% of the sample listed emphasis on training and research as their first choice for the organisation’s strength, showing that the companies have placed a substantial emphasis on these techniques as the primary ways of addressing the laundering and corruption threats in their region. Like the aforementioned changes to business operations and legal framework, the organisation can benefit from this as its primary asset and line of defence. Considering secondary choices, 88% of the sample provided them, citing experience for 24% of the sample, the emphasis and continuing updating of policy and legal framework for another 24%, managerial knowledge and experience for 16%, general experience for 20%, and 4% stating awareness and research efforts. The benefits and fundamental meanings for these have already been explained throughout the section. Meanwhile, 24% of the sample provided a third answer, with 12% reporting experience as the third strength and the other 12% reporting managerial abilities and communication with upper management personnel.

Figure 4.6: Strengths (Nigeria vs. UK)

As mentioned above, one of the main differences between the first choices of the Nigerian managers with the first choices of the UK managers is that the UK managers provide more description of the legal framework and specific aspects of the business, while any differences in fluency does not seem to be responsible for this. Whether it is due to a difference in willingness to discuss details or an actual difference in efforts and development in the company is unknown, but if it is the latter, than this suggests that the emphasis on development is to blame for the current situations as much as resources. The differences in percentage selections may be due to the environmental differences, but since it also may simply be due to the differences between sample respondents and variation in general representativeness, it is unknown.
Question 8
     The eighth question then asked the respondents to provide answers in a similar manner, but considering weaknesses of the organisation they represent. Here there were similar differences between the UK and Nigeria regarding the details of legal framework and business processes considered, having identical immediate implications for this opposite concept. The Nigerian managers were quick to explain problems that were in line with the problems asserted to be relevant to the issues explained in literature, suggesting a lower potential for bias in the other questions considered and a willingness to explain organisational complications as they exist. The Nigerian managers stated that the major weaknesses regarding capacities to address corruption and laundering potential include the resource issues plaguing most companies, incomplete organisational framework, lacking organisation in business processes, a lack of awareness or training for employees working with the security issues, technology that is often below what is considered the newest standard in developed nations, and resistance to change. Examining specific percentages in the same way they were examined in the last question, 20% of the managers stated that resource issues were the main problem; here the managers stated that the economy and general free funds available for things like improving areas that were not under severe threat or recovering from a direct attack were commonly not rationalised by upper managers. Resource issues have been attributed to other complications in the company, so it is not surprising that the managers consider this to be a general weakness of many of the organisations. Addressing resource issues, however, also appears to be one of the greatest challenges, so it is difficult to determine whether this weakness is something that can easily be addressed or put into motion by the sample members or even the upper management, meaning that this weakness and its rippling effects may likely demand drastic action if it is to change in the future. Beyond this portion of the sample, 24% of the managers stated that incomplete organisational framework was the greatest weakness to addressing the threats, because there were poorly developed or no plans for things like disaster recovery from a major scam, restructuring organisation should there be a demand for this, changing business processes, or emergency management during an on-going act of corruption or laundering. Naturally, all of these areas are critical in general organisational operation as well as in addressing the stated threats, so the organisations need to consider the demands for improvement in this area; until they do it will be considered a major weakness by its own managers, and considering this it is surprising that more managers did not mention this as the first choice of weakness (for the sake of the industry in the nation this might suggest that only a minority of the organizations experience this as a problem, unless the sample is grossly unrepresentative). Organization was reported to be a complication leading to weaknesses in addressing other threats throughout the businesses though, as 20% of the sample also stated that organisation in general active business processes was a weakness; this means that the existing security protocol for active processes may be seen as incomplete, the number of people working with security (or how they are tasked with relevant security processes), and the roles of employees in standard business processes may be responsible for this perception and the results of the challenges in dealing with laundering and corruption threats. This, as with all of the answers provided by the samples, are not surprising, considering that the literature and earlier questions all point to a combination of a lack of resources and organisational detail mirroring that present in developed nations being central to most of the problems experienced in the Nigerian organisations. A lack of awareness or training for employees working with the security issues was reported by 24% of the Nigerian respondents, whom stated that general ignorance of corruption, laundering, and related IT issues was commonly responsible for most of the complications experienced in the organisations that are related to these threats. Training was considered a strength by a comparable portion of respondents while stated to be planned by others, while this shows that there are still considerable differences between demands, occurrences, and general development across companies in Nigeria. The fact that ignorance was reported as a factor leading to reduced capacity to address threats was not surprising, but it was surprising to find a different emphasis on this and the demand for training across the sample. Meanwhile, 8% of the sample reported technology being below standard as the major weakness to the organisation (listed as their first weakness), and it is common knowledge in the IT dominated world that problems with technology (whether it be through coordination, updating, or otherwise) leads to security issues. A lack of technological development or stunted development can create vulnerabilities or minimise the chance of the company dealing with a looming threat or unconventional attack, and as the following discussion shows, this weakness was selected by an even larger number of managers as their second topic when answering the question. Lastly, 4% (one respondent) stated that resistance to change was the main weakness in their organisation, implying that comfort in the existing selections and techniques coupled with a rationalisation that the existing developments have allowed the organisation to stay in business have stunted additional developments; this was another area more frequently selected as a sort of secondary weakness by respondents. Examining the secondary and third choices in more detail, 64% of respondents provided a second weakness and 24% reported a third weaknesses. In the secondary weaknesses, 32% listed technology, 20% selected resistance to change, and the remaining 12% reported organisational issues. Of the respondents that provided a third weakness, 16% reported organisational issues, and 8% reported some sort of technology and resource related issue as the weakness to properly addressing the looming laundering and corruption issues.
The UK managers provided considerably different proportions of responses, but considering the capacity for them to represent their industry, this was another answer where it seemed like the organisations were commonly faced with the same desires for development despite of the different outcomes and levels of threat relevant to their organisations. UK managers stated that the weaknesses in their organisations included prioritisation of profits, lack of manager experience in handling laundering cases, lack of emphasis on evolving practices and new literature, lack of consideration for internal suggestions, and resistance to change. A total of 24% claimed that the prioritisation of profits was considered a weakness in relation to the threats of corruption and laundering, although this does not imply that this has been a general weakness for the organisation in terms of performance. Prioritising profits means that the managers with authority have been investing time and resources in developments which either extend the existing campaigning efforts or otherwise attempt to improve internal or service processes for improved efficiency and effectiveness in operations or services (also to attract more customers) focusing on this instead of focusing on anti-laundering or anti-corruption efforts can be good for the company, but considering the reported concerns from the organisation and the fact that this was listed as a weakness, the managers apparently are not giving the areas the extent of attention, research, and development that is demanded from the circumstances. Beyond this 24%, 16% of the sample stated that the lack of manager experience in handling laundering cases was the primary weakness for their organisation. This suggests that the managers have not been threatened so much that they have had to actively deal with a situation, while the respondents feel that a combination of this and their lack of general knowledge regarding the topics has prevented them from optimal developments and attention to these critical areas. There is little that the managers can do to be more experienced in actively handling the issues, so it is uncertain what is expected of them as a vulnerability would have to be attacked in order to provide active experience, but perhaps additional training and attention to real cases would better prepare them while appeasing the employees which perceive this as a weakness. Meanwhile, 20% of the employees stated that there was a lack of emphasis on evolving practices and literature in general, relating to the previous question, but showing a general lack of consideration of literature and practice recommendations (which is usually continually evolving while presenting new demands, while it should be pointed out that this does not imply a lack of experience). Similar to the general resistance to change causes that are responsible for employees being resistant or unwilling to follow through with the implementation of changes planned, managers can become comfortable with their ways, with neither them nor the higher authorities in a company taking the time to examine the potential for new developments. A few of the managers stated that it takes an active problem or grossly outdated processes for the managers with more authority to consider the framework for change while planning the remodelling the organisation’s legal or general business framework, and not being willing to remain constantly up-to-date regarding threats and other demands to change the organisation can result in an organisation being ignorant of threats or more efficient and effective strategies for their organisation. Considering this, it is not surprising that many managers feel that this is a weakness within their organisation. Another 16% reported something similar but treated as something slightly different for the organisation, stating that there is a lack of emphasis on evolving practices in new literature in their organisation, which in turn has the same potential for affecting efforts to improve the anti-laundering and anti-corruption initiatives. A lack of considering for internal suggestions was reported by 12% of the sample, stating that people within the company had recommended ways to better address the issues or relevant policies and processes within the company, but were commonly ignored or discouraged by management. This ties in with the previous answers, but is potentially more destructive or stunting because a lack of follow-through with people pointing out potential for improvement can discourage the only people willing to stay up-to-date regarding these topics to make the appropriate recommendations. Lastly, another 12% of the sample stated that general resistance to change was responsible. Resistance to change is known to be an issue in any aspect of progressive development when the plans are developed and ready to be implemented, but is lacking the full and proper support within the organisation. This can be combated through encouragement or full awareness of the significance of the issues, but it appears that it still remains a problem in a substantial portion of the organisation (24% also listed this as their second reported weakness within their organisation). Elaborating on the secondary choices, 64% of the UK managers provided them, while 36% of the sample provided a third weakness. Aside from the 24% that listed resistance to change as the secondary weakness, 20% listed organisational problems and a lack of planning for these types of improvements (i.e. prioritisation of profit), 12% mentioned emphasis on technology for other areas (technically another form of prioritisation of profit, but with regards to capital rather than organisation), and the final 8% mentioned a lack of manager awareness regarding changing practices and changing demands for anti-laundering and anti-corruption efforts in the region). The preliminary analysis of these issues are similar to those already explained, while considering the responses comprising the 36% mentioned, 12% reported some form of resistance to change, 8% reported prioritisation in other areas (assumedly but not necessarily profit), and 16% reported a lack of structure for developing and implementing changes. The last response is somewhat unique considering that the organisation must have a proper process and set of procedures to address these issues, as ones that do not do not have a proper medium to make even recommended and accepted changes; major organisations in financial services, especially in developed nations, may wish to stick to formalities, and with processes only for developing profitable services or the efficiency of internal processes, there is a security vulnerability when there is no similar due process for considering these kinds of recommendations.


Figure 4.7: Weaknesses (Nigeria vs. UK)

Comparing the responses from the two nations, it is apparent that the UK managers more commonly reported specific organisational issues and a sort of sense of security that has led the organisations to prioritise profits instead. While these could easily be the same trends and motivations for the responses provided by the Nigerian managers, it appears that there are differences in the responses as far as limitations versus choice; the Nigerian managers provided responses that suggest more of a helplessness and lack of awareness for implementing more effective techniques at the levels of upper management despite the desires and clear demands for change, while the UK managers provided responses which imply that the organisation as a whole simply does not choose to prioritise specific changes which are known but simply not taken seriously. Considering the reduced threat in the region, these responses seem like less of a threat to business and security breaches than the responses provided by the Nigerian managers. Chapters 5 and 6 discuss additional implications for this, relations to specific findings in literature, and recommendations for change which expand beyond and elaborate upon these findings.
Question 9
The ninth question asked respondents what improvements they feel should be made regarding any of the previous questions, assuming that they felt that some improvements should be made; specifically, they were asked “what improvements do you think should be made regarding any of the above areas, if any?” Here there was also a similar contrast between the Nigerian and the UK managers. The Nigerian managers had a range of suggestions that included attempting to improve resources and processes related to resource distribution, improving software and hardware technology associated with the security and laundering issues, organisational issues, employee training, reducing resistance to change, raising job pre-requisites, hiring security experts to perform a professional examination of the anti-laundering and anti-corruption framework, and catering to the developments or expansion of security departments dedicated to anti-laundering and corruption. Everyone in the sample had a recommendation for improvement, and the majority of them (60%) had multiple recommendations. The descriptions for potential improvement were also more elaborate here than they were for the other questions, providing legitimate and detailed recommendations for change within their organisations. A lot of this demanded the cooperation of upper management and reduced resistance to change within the employees, and some even called for the assistance of the government to help fund technology implementations or assistance with improving the organisation’s capacity to deal with laundering threats (especially from terrorists, which the government may have incentive to deal with), or general corruption. As their first listing, 36% of the sample stated that their organisation should focus on acquiring more resources and improving processes for resource distribution, while four of the managers within this percentage recommended petitioning the government for assistance with funding to update their legal framework and organisational structure; here, three of the managers recommended that security experts be hired to deal with the threats of laundering and corruption, either permanently hired into the organisation or scheduled to arrive periodically for inspection (i.e. weekly, monthly, quarterly, bi-annually, etc.). Here the organisations could have assistance in emulating the models established by developed countries and safer organisations, or even to emulate the most secure organisations within their nation; looking to other nations with comparable threats that have addressed them successfully (such as nations with high rates of terrorism related laundering and nations with more government and political corruption) was recommended by one of the managers.
Beyond this, 24% recommended that the organisations improve operations by investing in hardware or software technology, similar to the recommendations that were already made or stated to be planned for implementation in the near future. It has been explained in detail how this can affect the organisations, so there is no need for further analysis. Two of the managers within this portion recommended that the government be petitioned for assistance, and another recommended that upper management be petitioned by the employees in order to persuade them to make these kinds of investments. Meanwhile, 20% of the sample recommended that general organisational issues of some type be pursued by the company, since this has been attributed to company weaknesses and vulnerabilities to corruption and laundering. The potential for this ranges from adjusting the legal framework to consider more plans and procedures to detect and handle potential laundering activities or threats alongside the same for corruption to expanding the departments to adding new types of employees (i.e. security and laundering experts). A total of 8% of the sample recommended that employee training be pursued as the primary medium of improvement for the organisations, stating that this would serve to improve the capacities of existing employees while minimising the investment required for change; it is apparent that these kinds of developments would be comparably time intensive while being less resource intensive, and considering the resource challenges commonly reported among the employees, it is actually surprising that such a small quantity of the sample recommended this as a means of improvement. Another 8% recommended a similar organisational effort, but recommended that it focus on reducing resistance to change in management and employees rather than developing their skill sets; here there is more of a reliance on upper management and their actions through planning and implementation, but assuming there is more competence and perspective at this level, prioritising resistance to change to such an extent may in fact be what an organisation needs to improve and overcome its existing challenges. Raising job prerequisites was recommended by 4% of the sample, assuming that being more strict about what types of employees come into the organisation to work with security issues would result in improved outcomes and reduced threats. Another 4% recommended a similar change in employees within the company, but instead recommended that actual security experts be hired in to work with the company, as mentioned the earlier question regarding planned changes and potential for addressing the existing threats. Lastly, 4% of the sample recommended that generally expanding security departments or areas of the organisation that are tasked with handling laundering and corruption issues be the method used to address improvements in the area.
The secondary choices listed were along the same lines as the primary, with 60% providing secondary recommendations and 8% providing a third recommendation for improvement. Since the recommendations are the same, no additional analysis is provided for these here. Listing the percentages provided by the employees, 20% recommended improvements in technology, 24% recommended improvements to organisation, and 16% recommended some changes to employees (8% training, 4% new hires related to security expertise, and 4% expanding the existing departments). The 8% providing a third recommendation for change stated that the company should improve organisation or technology responsible for safeguarding against laundering or criminal activity associated with corruption (4% each).    
The UK managers provided responses that were more focused on specific developments rather than general ones, but this was expected considering that the Nigerian managers commonly reported more general problems and limitations with their organisations in regards to the threats of security breaches and legal framework. These managers recommended a review and updating of specific anti-laundering policy (and making the recommended improvements based on this), a review of the legal framework and coordination of investigations (considering coordination between the companies, the government, and criminal investigation parties), employee and manager training, hiring more security experts to remodel organisational and legal framework, improving technology, and preparing the organisation and employees for change (reducing resistance to change). Specifically, 24% of the managers recommended a review and updating of specific anti-laundering policy, recommending that the work of upper management, stakeholders, and any experts called in to work on this would be of the greatest benefit to the organisation; here there would be a more elaborate assessment of the demands for change and any weaknesses as perceived by experts and people with more perspective, rather than relying on formal efforts established from less formal examinations and recommendations, so this seems to be an ideal recommendation for improvement.
Reviewing the legal framework and coordination of investigations while considering company-government or company-criminal investigation parties was recommended by another 24% of the UK managers; here the company could look directly into the legal framework while making updates as needed, taking a more direct approach, while examining and updating processes related to the coordination of efforts between the company and outside parties in the event some act of corruption or laundering affected the company. This approach is direct, although the previous responses implied that this was already considered to some extent on a routine basis (via annual reviews). Improving these processes and strategies could potentially result in further improvements when they are more directly targeted, however, and it is probable that at least some aspects have not been considered for updating while prioritisation has remained on more profitable aspects of operations. Coordination with the government and criminal investigation parties may require communication with them in addition to altering the policies, depending on the nature of the proposed changes, and any changes in laws or restrictions from the government would have to be considered when making these improvements. Aside from this, the policies could be altered to optimise efficiency and effectiveness, and then continually reviewed on an annual or bi-annual basis; thus, this recommendation for improvement has substantial potential to genuinely improve operations and security within the organisation. Employee and manager training was recommended by 20% of the sample, and the potential benefits of this have been assessed and stated throughout the work. This is also true for the 16% that recommended that the best improvements would come from hiring security experts to recommend changes to remodelling and legal framework. Regarding the last two choices, 8% of the UK managers recommended improving technology as the primary method of improvement, and the final 8% recommended that the organisation take action through training or some awareness initiative to reduce resistance to change.

4.8: Improvements (Nigeria vs. UK)

Comparing the results between the UK and Nigerian managers more closely, it is evident that the Nigerians have been more direct in their recommendations for addressing problems, but they have only addressed general problems with general solutions; the UK managers addressed more specific issues with more specific solutions. Here the main difference seems to be in the nature of the issues and description, and while the Nigerian managers could have provided more specific recommendations for improvement, there was no indication that they needed to provide this kind of detail for the study. Managers from both nations are aware of the problems and potential for improvement in organisations in their nations, and both have made recommendations based on this. Experiencing success is a matter of overcoming the limitations that exist with regards to these potential improvements, and this is something that is that the organisations will have to place more effort in addressing, assuming they intend to experience the benefits in the near future.
Questions 10-11
The tenth question was simply a year or no question, asking the respondents “do you feel the account freezing policies are adequate?” Here there was more disagreement from the Nigerian managers than the UK managers, which in turn prompted more of their participation in the following (eleventh) question “if you answered no to the previous question, then why?” Regarding the yes or no question, only 72% of the Nigerian managers felt that they were adequate, versus the 92% of the UK sample (or 82% of the overall sample). This was expected as the organisational issues and tendency for developing nations to be slightly ‘behind’ on policy developments, at least compared with those observable in developing nations, was relevant here. Meanwhile, the Nigerian managers had apparently not been affected by a false sense of security or become accustomed to the nature of policy, although it is possible that the number would have been even lower considering this potential. In any case, responding to the perceptions of inadequacies, the Nigerian managers stated that the reason they asserted that the account freezing policies were inadequate was because they did not have sufficient due process, and that sometimes accounts with general business activities that were not suspicious to many managers were frozen for investigation while the real criminals were able to operate while taking these precautions. This is of course unfortunate because many of the legal developments that have occurred have been designed to tighten laundering security, but the ways in which they do this can restrict innocent international funds transfer and operations. Criminals, meanwhile, can familiarise themselves with these changes, as they naturally have incentive to learn as much as they can about policy, and operate within the changes or boundaries which they discover in their research. This can be problematic, and it is no surprise that 28% of the managers in a nation which is reportedly subject to more laundering incidents and a higher rate of corruption would feel that the legal framework developments in this regard would be inadequate; considering this, it is actually surprising that the number is not substantially higher. The same is true for the UK company, as only 8% reported dissatisfaction with the policies in spite of similar complications reported from the managers in this country. It appears that the overwhelming majority of the managers are still experiencing these issues with national law, but either see no alternative solution or feel that the investigation of normal activity sort of ‘comes with the territory,’ similar to innocent people being investigated or searched by police.
Question 12
The twelfth question asked the respondents to rate their perspective of the adequacy of fund handling procedures, or specifically, “on a scale of 1-10, how adequate do you feel fund handling procedures are, considering the threats of crime?” The same trend was observed across the Nigerian and UK managers, showing a slightly greater dissatisfaction and assumed recognition of a demand for progressive change in the Nigerian companies compared to the UK companies. Here the average rating from the Nigerian managers was a 6.5, while the average rating from the UK managers was an 8.0 (making the average rating 7.25). Fund handling procedures can potentially affect both laundering and corruption vulnerabilities in a company, while the lower value presented by the Nigerian managers shows that they have less confidence in the ability of regulations and policies to counter the threats in these areas. The responses to this question suggest a need for research and development in Nigeria but not the UK, although this is not to imply that developments in the UK would not be beneficial.
Question 13
The thirteenth question simply asked respondents to provide any additional comments that respondents felt are relevant to the research study, or comments that they feel would be relevant to any aspect of the research. In this portion of the research, no percentages are provided, only the commentary as was offered by 60% of the Nigerian managers and 44% of the UK managers (however providing some comparison).
Considering the Nigerian managers, two of them mentioned that most of the problems with technology have been related to comfort and managers hesitating to invest in upgrades and make the necessary organisational changes (or training) associated with changing this technology when funds could be diverted somewhere else or the technology was simply not in need of replacement. Considering the nature of threats in the region and the common complaints regarding technology provided in the previous section, this is considered not in line with organisational objectives and demands for improvement through development. Managers acquiring a false sense of security are likely to make the risk of attack greater or generally increase vulnerability, so this should be avoided or countered (see recommendations section for additional details). Aside from the two managers reporting this, three managers stated that organisational issues would be challenging to address since the organisations were already strained by the demands for operating within the country, so that it would likely take outside assistance from the government or otherwise in order for the companies to be able to invest in any of such types of changes.
Five managers stated that the organisations would likely improve with time, and that the organisations would have likely improved if there was more investor confidence and international trade going on, but the global crisis has generally limited this reportedly to the loss of progressive development and capacity to invest within the organisations. Considering that it is unknown whether progress will increase while involving more exchanges in the organisation, it is unknown whether this method will be sufficient to fund additional improvements; it is highly probable that organisations relying on this will have to look for a sort of ‘Plan B’ to address the issues.
The remaining five managers willing to provide comments were split into two groups: three managers stating that upper management was ‘stuck’ in ‘old ways of doing things,’ one manager claiming that resistance to change at all levels was responsible for slow developments in security and elsewhere, and one manager claiming that technology could solve everything although managers in the organisation were not trusting of technology. The three managers that insisted on upper management being stuck in traditional ways of operations and conventional methods that have been recommended for change both within literature and within the organisation, but they remained confident that the old way of doing things would still be useful and ideal in present and on-going developments. One of the managers stated that they had even recommended that the organisation take a vote on the issue, but the perspectives in upper management were mostly unanimous while the opinions of the middle and lower management were considered subordinate to the opinions of the higher management for the issue. The manager that claimed that resistance to change was responsible for everything stated that both upper managers and employees throughout the organisation were accustomed to processes and generally tried to minimise change in the absence of an actual problem; here threats that cannot be directly perceived or experienced outside of researching publications or reported data appear to be next to meaningless in terms of company strategy. The last manager that reported that technology could solve all of the problems, but the company did not agree, and thus the technological plans for development that were perceived as encompassing the demands for anti-laundering and anti-corruption efforts were not implemented.
Considering the UK managers, only 10 provided comments, and five of these simply had faith in the direction provided by managers. These responses included something to the effect that the managers would be able to continually adapt to demands and recommendations from literature so long as they paid attention to the on-going recommendations for practice, or otherwise tried to maintain a competitive advantage within the industry. Three of the 10 managers commented something to the effect that future change would be, and has been, dictated by the nature of security breaches published in the news and changing legal legislation, while two of these managers were not surprised that more emphasis had not be placed in the areas of development without further change regarding their stated topics. Lastly, the two remaining managers stated that they felt that more attention would have to be called to the issue, and more awareness spread across the organisation, since the existing staff was claimed to be only partially aware of the benefits of investing in developments in the areas.
Comparing the two groups of commenters, it is evident that the UK managers are less concerned about developments amid their current threat levels, but this has not stopped them from thinking about the future and being mindful of the benefits of continuing progression. The Nigerian managers implied that their efforts would not be sufficient to do more than spread awareness, but perhaps continuing this with team efforts would slowly lead to more strategic efforts to confront needed changes in organisational and legal framework (see section 6.2 for more details regarding recommendations).
4.3.4 Questionnaire Summary
Overall the questionnaire results provided a veritable wealth of information that is useful to efforts such as this one; although the responses could have been more detailed, they show specific trends and demands for change within the industry. Moreover, they show how the respective managers have approached their environmental conditions in unique ways, while this is critical to consider in future efforts attempting to improve upon the progress of existing business models. One interesting trend is that the UK managers have reported a diligence in development comparable to the efforts and desires to improve reported in Nigeria, but these motivations are present despite the differences in threats to each country. The questionnaire results imply that Nigeria would benefit from adopting security models developed and tested, rather than relying on methods that are considered conventional in the region.
4.4 Interview Results
4.4.1 Introduction
The interview results show similar trends as the questionnaire, but with more detailed responses which therefore have unique value in a study such as this one. This section is structured similarly to the previous one, divided into sections for the Nigerian and UK citizens, then divided into additional subsections for the individual managers within these regions. As mentioned, five managers were interviewed from each region. Follow-up questioning and feedback is provided within the sections as it applied to the interview questions asked between the candidate and the respondents.
4.4.2 Nigerian Participants
Considering the distance involved between the candidate and the targeted participants in this study, the medium of telephone was preferred for all five of the Nigerian sample members. These people were thus contacted via Skype and through normal cell phones. There feedback is interpreted and presented below, providing the first portion of the secondary focus of the primary research.
First Manager
The first manager is considered a member of ‘upper management,’ although he admitted to still having a hierarchy of authority above him within financial organisation. When asked “what kind of problems does your organisation have with money laundering, and related regulations?” he responded that the organisation has done everything it can to prevent this within the organisation while eradicating it wherever possible; money laundering was reported to be one of the top priorities within the organisation’s security, and while it was not the highest breach of security or most frequent issue that required criminal investigation, it was one of the most serious and one that local authorities took the most seriously. He reported being involved in a few cases in the past few years, and stated that two of them were determined to be innocent cases of money transfer, but one of them was a legitimate case of laundering which had to be dealt with. He stated that the case ultimately led to money laundering being taken even more seriously in the organisation, but that few changes were actually implemented as far as policy or technological changes in the organisation because of it. The only real change that came from it was an improved coordination between the bank and the authorities because of the experience, so they could better deal with it next time in a more efficient way; however, the changes that were needed to better protect against it or generally protect against money laundering were not implemented. There also seemed to be no evidence of changing the agenda or rate of changes in the areas of technology, organisational structure, training, or any other area of the company as a result. The company still planned to operate as usual despite the threat and the experience of the incident.
The second interview question asked the manager “do you think the organisation is doing enough to address the problem?” Considering the responses to the previous question, it was assumed that their response to this would be no, and this in fact proved to be correct. The manager felt that some aspect of technology or at least normal business processes would be altered to tighten security, but to their disappointment and the disappointment of other managers, this did not take place. They recommended additional pressure and petitioning from supporting members, but claimed that attempting to altering a company set in its way was a ‘losing battle,’ while it was fortunate that the company still maintained reasonably profitable figures that are expected to keep it in business for years to come.
The third question asked “what kind of work do you think is needed to improve regulations?” The respondent had recommendations including technological change and hiring security experts to restructure security systems and policy, but claimed that it might be best to look at the banks legal framework and restructure it based on additional capacity for the organisation to protect against and act on assumed acts of laundering. Aside from this, they also recommended that members of middle management and those in charge of security monitoring be examined more closely for potential for training, and that the company invests more in training to cater to these needs and the potential outcomes.
The fourth question asked the respondent “how does the potential for corruption, and the need to recover funds, affect your organisation?” They stated that this is considered as the basis of security framework and some aspects of the technology used to safeguard against threats, but also stated that management commonly only considers theory and their concepts of potential damage, rather than actual cases that have manifested in theirs or in similar countries. Because of this, they stated that the demand to recover funds was the main motivator of the relevant policy, rather than the actual potential for corruption or laundering. They recommended that more emphasis be placed on this.
The fifth and final question asked the manager “what other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?” Here the manager stated that the main issue here is updating security and policies surrounding the issues, claiming that the organisation did not like to upgrade anything unless it had experienced above average profits or that it was forced to because of a problem. Even the problems that do occur can be considered normal, so the organisation was considered ‘stuck in old ways’ here as well. A follow-up question, allowed through the structure of semi-structured interviews, was thus asked of this respondent, requesting that they provide a response for “what do you think it would change for the organisation to better address the threats of corruption and laundering in your area,” to which they replying more money coming from somewhere, or new management.
Second Manager
  The second manager was also considered an upper manager that had more authority than members of middle management, but not enough to put changes regarding the subject areas directly in motion.
Responding to the first question, “what kinds of problems does your organisation have with money laundering, and related regulations,” they argued that the national regulations were not compatible with the organisation goals because of the potential for innocent actions to be reported and the potential for criminals to be too far along with their crimes to be able to be caught. When asked to elaborate on this, they stated that the regulations were developed with good intentions, but did not give as much consideration to the reality of modern crimes or the needs of the financial institution when they were created.
Addressing the second question, “do you think the organisation is doing enough to address the problem?” the manager stated that it has been doing what it can to work with outside organisations, but that it could do more internally to better safeguard against crime. The third question then asked them to follow up on this, asking “what kind of work do you think is needed to improve regulations?” to which they stated an organised meeting and planning of upper management (such as a board meeting) focusing specifically on this area and the potential of the company to gain both a competitive advantage and generally improve its security actions to become an example in the area. They stated it was unlikely that this would ever happen because of the general emphasis on profit investments and the demands of stakeholders that were also usually profit-oriented only.
The fourth question asked the manager “how does the potential for corruption, and the need to recover funds, affect your organisation?” They stated that it actually has little effect because the organisation usually only did what it needed to be compliant with the law and protect its own assets, but between the nature of the law and insurance, they stated that there is usually little incentive to make changes to policy aside from this, so the organisation is thus not very affected.
Lastly, addressing the fifth question of “what other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?” they stated that improvements could take place such as employee training, technology improvement, and better discretion of actions in relation to coordination with legal authorities, but they stated that all of this is unlikely. When asked why, they stated that compliance and doing the bare minimum will always be an issue, and even if employees could be more convinced, convincing the stakeholders to invest in additional change as well in the near future seems highly unlikely.
Third Manager
The third manager provided briefer answers that had more details in some areas. They were a member of middle management, but claimed to have more authority than most middle-level managers in their organisation or organisations like it. They stated that this was due to their responsibilities, their potential to recommend changes, and their decision-making abilities in terms of employee activities.
Answering the first question, “what kinds of problems does your organisation have with money laundering, and related regulations?” they stated that the organisation is not really having any problems but there is always room for improvement. When asked if they had any further comments regarding the issue, they stated that they did not.
Answering the second question, “do you think the organisation is doing enough to address the problem?” they stated that for the most part they are, but that not enough changes have come from some of the actual incidents and investigations that have taken place. They stated that these experiences could prompt the organisation to change some areas to be more efficient and effective with dealing with the problem, but that the members of upper management and stakeholders usually feel that the incidents are unique and do not justify altering any aspect of the operations.
Answering the third question, “what kind of work do you think is needed to improve regulations?” they stated that actual improvement of regulations despite the lower demands to make changes in these areas could involve improvements in technology, staffing extra employees, or changing policies, but they reiterated that none of this was likely to happen considering the resistance to change in upper management and the emphasis on profit that has been common across the stakeholders in the organisation.
Answering the fourth question, “how does the potential for corruption, and the need to recover funds, affect your organisation?” they stated that usually this only results in some conversation across the members of management or individual employees, and rarely results in the types of changes that the organisation needs to experience an actual change in how in addresses the issues. When asked if they have any other comments, they claimed that the organisation is usually affected only in its consideration of operations, and that even when this leads to discussion, maintaining the same aspects of operations is usually rationalised in one way or another.
Answering the fifth question, “what other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?” they stated that there does not seem to be an actual requirement for improvements, but emphasised that there is always room for improvement. Here they stated that additional training and replacing technology would likely be the most effective actions, but reiterated that these were not likely with the existing reasons for change or trends in crime.
Fourth Manager
The fourth manager defined themselves as a member of upper management, and had more of an emphasis on technology in comparison to the other managers. When asked “what kind of problems does your organisation have with money laundering, and related regulations?” they stated that the computer technology is out of date, while newer software, operating systems, and hardware would improve the organisation’s ability to see and track crimes as they occur. When asked if there were any other problems, they stated that some aspects of regulations could be changed, but stated that ‘nothing comes to mind’ regarding specific aspects of regulations or specific changes.
Addressing the second question, “do you think the organisation is doing enough to address the problem?” they stated both yes and no. They stated that yes the organisation is giving it enough attention and consideration, but agreed that it should be doing more to actually incite changes and improve these areas of management in operation as they seek to be more competitive and gain more profit. When asked if anything else came to mind regarding this question, they stated that security experts specialising in the area could provide further insight, but the managers and stakeholders would almost certainly never justify making investments in that.
Answering the third question, “what kind of work do you think is needed to improve regulations?” they stated that a formal review and restructuring would likely lead to improvements, but stated that this has not happened because management has not felt that it would be worth the investment. They stated that this would likely be the case in the future, and that something drastic would have to happen for this kind of change to be incited.
Addressing the fourth question “how does the potential for corruption, and the need to recover funds, affect your organisation?” the manager stated that even actions have no impact on the organisation most of the time, so even a scare of threats or potential usually has absolutely no impact on the organisation whatsoever. They claimed that a national scare regarding a major scam that was reported in the news as being common would probably be required for the organisation to actually change its policies from potential alone.
Answering the fifth question “what other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?” they stated that account freezing regulations did not seem to have much discrimination between criminals and common reasons for international business, so this could be researched and changed somewhat; besides this, they stated that fund recovery practices were pretty ‘straight forward’ and that money laundering policies were difficult to change because of the variables involved. They recommended improving technology to better monitor and track accounts.
Fifth Manager
The fifth and final manager was also a member of upper management, but stated that they had little control over most aspects of operations. Answering the first question, “what kind of problems does your organisation have with money laundering, and related regulations?” they stated that the organisation has more organisational problems than anything, because they are only loosely prepared for an investigation and reliant on emergency actions and the actions of outside agencies to address the issues.
Answering the second question, “do you think the organisation is doing enough to address the problem?” the manager stated that it is in that it follows through with incidents how it should, but that it could do more to prepare or protect against them. The third question then asked “what kind of work do you think is needed to improve regulations?” to which they stated that developing more and better policies to deal with protection, improving technology, and better training employees would likely be the most effective work.
Addressing the fourth question, “how does the potential for corruption, and the need to recover funds, affect your organisation?” they stated that usually it affects manager mentalities and their conversations with stakeholders, but that it rarely affects anything else. When asked what it does affect on these rare occasions, they stated that some manager treatment of operations can change, but this is usually only a short term thing and does not results in the changes of any policy. Lastly, the fifth question asking “what other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?” they stated that technology and organisation could be improved somewhat, but aside from that, the policies and actions taken by outside agencies seemed to be ‘enough’ to address the issues. When asked if the organisation saw this as doing the ‘bare minimum’ or being comfortable with policy so long as business was preserved, they stated that this is likely true because in business the emphasis and priority is usually placed on profit.
Nigerian Sample Summary
The results from the Nigerian portion of the sample confirmed their resistance to change and emphasis on profit that was reported to be commonplace in their organisations by the survey participants. The recommendations for improvement generally concurred with these results as well, suggesting a true representativeness of trends in the industry in the nation rather than random responses.
4.4.3 UK Participants
The UK participants generally offered more specific recommendations while seemingly being even more comfortable with the existing organisational policies, technology, and methods of operation. Considering the lower rates of incidents and more developed technologies and policies more commonplace in these organisations, this seemed to be more justified; similar to the survey results, many of the managers reported a similar emphasis on this area and thus a similar potential for improvement despite the differences in circumstances. The responses from the UK managers also appeared to be slightly briefer than the responses from the Nigerian managers.
First Manager
The first manager stated that they were an upper manager by definition, but considering authority, it was probably best that they were described as being somewhere between upper and middle management. Answering the first question, “what kind of problems does your organisation have with money laundering, and related regulations?” they stated that the issues would not be best described as problems. When asked what lingering issues were present, they stated that aside from the main problem of not being able to stop all laundering, the regulations were forced to become so tight in such a general way that normal customers conducting normal transactions could be perceived as just as guilty as launderers. On top of that, they added, the criminals were usually the ones that were researching the regulations so that they could ‘get around them’ undetected, so really the legislation was not all that effective in catching more criminals.
Answering the second question, “do you think the organisation is doing enough to address the problem?” the manager stated that he believed it was, depending on the definition of ‘enough.’ They claimed that the most change would come from lawmakers and policies outside of the organisation, but by this they did not mean to imply that there were not areas potentially improved in the organisation. When asked to follow up on this, they stated that main areas potentially improved having the most potential impact included technology (especially software, which usually had upgrades every year while management usually only implemented these kinds of changes every two years, except when a new version of software they were already using was released) and providing better training for employees.
Addressing the third question, “what kind of work do you think is needed to improve regulations?” they effectively provided an elaboration on the follow-up questions they answered for the previous question. Here they reiterated that technology and training would improve operations, but actions from outside the organisation would be required to address the issues of policy that they reported to be problematic (criminal avoidance of policy versus commonly providing ‘roadblocks’ for people conducting normal business).
Answering the fourth question, “how does the potential for corruption, and the need to recover funds, affect your organisation?” the manager stated that this has been the basis of the current problems they explained with making problems for normal customers and the state of existing policy, but that there were no major effects beyond this.
Answering the fifth and final question “what other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?” they simply recommended that managers be more open to potential for change and restructuring, since they were aware that best practices and literature commonly recommended slight deviations from the conventional approaches, but pointed out that stakeholder support was commonly an issue in this country as well.
Second Manager
The second manager defined themselves as being part of middle management but with extended responsibilities. They stated that, in regards to the question “what kind of problems does your organisation have with money laundering, and related regulations” that the organisation does not have any problems that are unusual or out of the ordinary; they asserted that all crime affects the organisation, and laundering or laundering regulations were not unique. Next, addressing the question of “do you think the organisation is doing enough to address the problem?” they stated that it was and has been, although they expected continuing changes in this area as well as other areas of crime. When asked to elaborate, they mentioned ATM scams and general theft.
Answering the third question, “what kind of work do you think is needed to improve regulations?” they stated that the regulations were not particularly in need of improvement, but potential work that could assist in regulation development included a collaboration of managers and outside organisations (i.e. the government) to develop an optimised set of regulations; however, they asserted that this kind of collaboration was not perceived as likely. Next, addressing the fourth question “how does the potential for corruption, and the need to recover funds, affect your organisation?” the manager stated that it has been responsible for regulations that not all people agree with, and tighter regulations than seem necessary to managers and stakeholders; however, they acknowledged that it does not seem like there is a better solution, so criminals are effectively making the innocent customers suffer because of the need to watch people more closely.
Lastly, addressing the fifth question “what other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?” they stated that the best path towards improvement is continuing research and development as needed, while there were no clear solutions to the existing complications that they are aware of.
Third Manager
The third manager defined themselves as a member of upper management, though they stated that they did not have as much authority as some of the other members of upper management. Answering the first question, “what kind of problems does your organisation have with money laundering, and related regulations?” they stated that their organisation has more problems with regulations than with laundering, and that this has translated to them commonly being disappointed with their own courses of action despite being obligated to them. Addressing the next question, “do you think the organisation is doing enough to address the problem?” they stated yes, but that the government does not be seeming to do the same; they recommended that the government take action in addressing the problem in order for the real type of progressive change to occur.
Answering the third question, “what kind of work do you think is needed to improve regulations?” the manager again stated that cooperation with the government and law makers would be needed at least as a starting point to find a solution to make it easier for international businessmen to conduct normal business while having a better method to catch actual criminals. They explained that the problem seems to be that the lawmakers do not have the perspective and knowledge of banking experience that the banking managers have, and the banking managers do not have as much perspective about what is possible with the law; they stated that collaboration to the extent seemingly demanded is not likely, but it seems to be the best path for moving forward.
Answering the fourth question, “how does the potential for corruption, and the need to recover funds, affect your organisation?” they simply stated that this has been the reason that law has been developed the way it has been, while the effects on the organisation have been obvious (affecting normal customers). They stated that the potential for corruption is not an especial concern, but there are some safeguards against this in their security policies.
Addressing the fifth question, “what other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?” the manager stated that if the previous improvements they mentioned could actually be followed through with, it would likely be the best effort to address problems. They stated that this in itself is unrealistic, so any additional improvements beyond this would be even more unrealistic.
Fourth Manager
  The fourth manager claimed they were a member of middle management with extra authority. Answering the first question, “what kind of problems does your organisation have with money laundering, and related regulations?” they stated that the organisation is generally opposed to these crimes but have not developed the most effective solutions for dealing with them. When asked the following question, “do you think the organisation is doing enough to address the problem?” they stated that it was, and it has relied on the actions of the government to make any additional progress beyond this.
Answering the third question, “what kind of work do you think is needed to improve regulations?” they recommended a closer examination of literature and incidents that have occurred since 2007, claiming that the structure for most of the developments had been changed before this time and has not been changed since in spite of implications for potential benefit. Next, answering the fourth question “how does the potential for corruption, and the need to recover funds, affect your organisation?” they stated that the potential has been the reason for the developments explained, and it does not really have an effect beyond this. Answering the last question, “what other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?” they stated that technology, training, and organisation could be approved, but this was unlikely to surpass the current emphasis without stakeholder approval, and stakeholder approval of additional investments is unlikely.
Fifth Manager
The fifth manager stated that they were considered a member of upper management, and felt generally satisfied with most of the decisions both the government and the organisation made with regards to the subject areas. Answering the first question, “what kind of problems does your organisation have with money laundering, and related regulations?” they stated that the organisation itself does not have any problems, and the crimes and regulations are a general problem everywhere. Answering the second question, “do you think the organisation is doing enough to address the problem?” they stated that is. Answering the third question, “what kind of work do you think is needed to improve regulations?” they stated that no immediate work is needed, but that the company should keep track of recommendations for change, literature, and crime statistics to make sure that it evolves how it should be.
Answering the fourth question, “how does the potential for corruption, and the need to recover funds, affect your organisation?” they stated that it is responsible for securities law and the existing policies, but that these are changed as needed and there is little ‘lingering concern’ for the issues aside from this. Lastly, addressing the fifth question “what other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?” they stated that improvements will come as needed as warranted through changing circumstances.
UK Manager Summary
The UK managers were more matter-of-fact in their responses, and more commonly considered the organisations as ‘doing what they could’ in comparison to the Nigerian managers. They also seemed to have a greater sense of overall security, and assumed that developments were occurring at a reasonable pace.

4.4.4 Interview Summary
The interviews supported the results of the surveys, showing that the UK managers and companies are more commonly concerned with maintaining levels of security and making improvements as they are needed or in collaboration with legal developments, rather than the general improvements and demands to improve fundamental areas that have been observed in Nigeria. This is assumed to contribute to the validity and reliability of the work while the samples are representative of trends in the countries.
4.5 Summary
Considering the primary research as a whole, both the surveys and interviews suggested that the managers and organisations put approximately the same amount of effort into their operations for security, anti-laundering, and any anti-corruption measures in spite of the differences in threats in the region. The focus on development and progress, however, appears to be different, with appropriate strategic focus. The Nigerian managers showed a realisation of the resource, technological, and organisational demands in their region, and revealed a general focus and path towards development that emphasise these areas. There did appear to be a slight difference in rates of improvement or plans for development, and it seemed the Nigerian organisations were on a stricter budget or were less willing to invest in the areas. Meanwhile there were some differences in opinion regarding the effects of the UK’s legal framework, as some managers stated that there is no better alternative while others were more insistent that a better solution be explored and implemented.


Chapter 5: Discussion and Further Implications
5.1 Introduction
This chapter discusses the results in greater depth, discussing additional implications alongside relations to the literature reviewed.
5.2 Discussion and Implications
5.2.1 Laundering and Organisational Challenges in Nigeria
Much of the literature has been supported by the research, while the implications of the most relevant parts are worth revisiting and uniquely relating to it through a more detailed and encompassing analysis. As mentioned, Nigeria, as a developing country with less political organisation and less organised law enforcement in comparison with the UK, has experienced a different and greater struggle with AML and corruption issues. The resource issues and technological demands were verified in the primary research, and both the emphasis on issues (being more fundamental) and the capacity to invest in developments (less frequently and less involved) was observed to be more inhibited. The managers were aware of the demands for solutions, and were aware of the methodologies used to implement them, but generally reported struggling from environmental factors, resources demanded, and organisational issues. As Obuah (2010) had asserted, in the nation, corruption is consistent or even growing while crimes such as laundering, bribery, embezzlement, and misappropriation are commonplace. The combination of literature and the results of the research suggest that managers are limited in their capacity to safeguard against and address these issues. Potentially making matters more challenging is the fact that the leaders and aspiring leaders of major political organisations are generally at the greatest risk for corruption in the nation, as this may make it difficult to detect crimes or even pass legislation which tightens security in specific areas. Nigeria has been near the bottom of the Corrupt Perception Index ranking of Transparency International, and there is no indication that it will be able to remove itself from such a position any time soon. Corruption is currently considered Nigeria’s worst problem, thought to be responsible for many problems ranging from obstacles to democracy and democratic elections, stunted foreign investments, debt complications, and instability in the Niger Delta, while it is evident from both literature and the findings of the research that financial services are affected as well (Obuah, 2010).
The scope of the problem shows the barriers financial and other institutions are up against, and considering the resource and organisational issues, it is evident why no solutions have been reached in the past decade despite the knowledge of effective techniques and access to strategic framework details. Corruption is estimated to drain over $140 billion, while the existence of corruption serves to further affect the economy because it discourages investment; this compounding impact has simply been too difficult to overcome, and there are no thorough strategic frameworks or complete solutions developed or available in literature to deal with the full range of these issues. Since corruption in the nation also distorts public spending, diverts resources to richer countries, and raises the overhead costs for local businesses, the barriers are even more evident; meanwhile, the nation is thought to exchange over $1 trillion in bribes each year, and this in combination with the assertion of organisational issues within the companies shows that developing an organisation framework to appropriately deal with the problem is a formidable challenge (Malgwi, 2004; Obuah, 2010).
Nwagbara (2010) and Ezeoha & Anyigor (2009) had stated that the leadership structure in the nation provides some of the greatest opportunities for corruption, so approaching the government and existing authority from a precautious angle may be required even when a full strategy and plan for resource utilisation or organisation is realised. The aforementioned analysts had went as far as to state that the existing conditions in the government were actually fostering the preservation of a culture of corruption, so managers have this to deal with when attempting to remodel their organisation or deal with outside legislation.  Considering the claims also included that the national is weak, compromising, broken, or even failed overall, stakeholder support or effective maintenance of a plan (including the improvements stated to be underway or recommended) appear to be unusually challenging as well (Nwagbara, 2012). Moreover, the nation has been accused of continually compromising how it handles its financial industry, but the nature of opposition in organised plans for improvement is unknown. Uche (2004) had explained that unethical political leadership has been a long-time problem in the region, while its financial industry operated unregulated for nearly 10 years following its independence from the UK. Comparing the states of development and nature of the issues between the two countries now, it is evident that the nation could benefit from mirroring aspects of legislation and operation. The independence does not appear to have benefitted the financial industry as of yet, while some may argue that it has benefitted few if any areas of the country aside from the title of independence.
Another challenge that appears to be responsible for the respondent data and the challenges facing them as they move forward is the concept of ‘leadership shadow.’ Nwagbara (2012) defined this as what takes place when a leader’s actions impact overall operation in some manner, while in the country, leadership shadow is stated to commonly result in the ‘dark leadership’ that has affected so many aspects of politics and relationships with the financial industry. The results of the study confirmed Nwagbara’s (2012) assertions that the recent events in the nation are further indicative of dark leadership; here, the system of leadership is stated to lack the fundamental ethical elements of charm, charisma, trust, conduct, and ethics, as supported by Takala (2010). All of this makes the outlook pretty bleak for the country. Meanwhile, adding to the complications and helplessness reported by the people in the study, the increasing disorder has led to increasing investigations, which have generally confirmed the nature of the complications, but have done little to prompt viable and effective change. Ogbechie & Koufopoulos (2007) had argued that the institutionalisation of ethical leadership in Nigeria will aid it in its attempts to stimulate corporation performance, while it is also expected to allow it to limit the abuse of power so commonly seen in key positions; this is supported by the managerial feedback, but actually institutionalising the framework is still an issue.
Attempting to surpass even these challenges is not something entirely new to the nation, while improving corporate governance standards is something that the nation has been faced with before, while the barriers to implementing even developed strategies has been considered. Additionally, many analysts have considered this over the past decade, while recently analysts have noted that the majority of banks in the nation have been exhibiting signs of liquidity strains. This is in line with what the managers have reported, while their seeming acceptance of the majority of circumstances is something that is the result of years of experiencing the conditions and going through investigations without organisational or political changes. Nwagbara’s (2012) report of a joint inspection team tasked with assessing banks to determine whether they were operating within ethical behaviour standards has not seemed to have had any impact, but judging from the results of the study, these kinds of assessments (or at least ones similar to them) should be continuing through the future (Nwagbara, 2012). As explained in the literature review, in this assessment it was discovered that out of the first ten banks assessed, only five were compliant with ethical standards and corporate governance demands, while the results of the survey suggest the lack of organisation and complications in the institutions translate to this being a fairly representative proportion. The investigation itself ended up being somewhat productive, and perhaps beneficial in some ways through additional efforts, since some of the executives were replaced after the study. No follow-up study was conducted to see if these executives were able to make a difference in the organisations.
Some of the efforts that have been taken to fight corruption could prove to be successful with time, or serve as a foundation for progressive developments which directly or indirectly affect the financial institution issues. Considering the existing problems and how they have remained, it is noteworthy to examine the successes and failures of past efforts attempting to address these types of issues. Efforts to fight corruption in Nigeria have ranged from legislative efforts to personal campaigns by government members, but both have had limited results. Making matters worse, the latter are thought to generally be for reputation or show, and this means that financial institutions and investors alike have not been able to benefit from these changes (Obuah, 2010). This can even lead to distrust issues. Considering the actions of the government, as listed in the literature review, the attempts to improve and expand legislation include the Banks and Other Financial Institutions Act (1991), the Financial Malpractices in Banks Act (1994), the Advance Fee Frau and Other Related Offences Act (1995), the Nigerian Corrupt Practices and Other Related Offenses Act (2000), and more (Obuah, 2010). The improvements in technology and globalisation efforts have allowed the nation to tighten security and gain assistance in key areas, but as modern literature and the feedback of the managers have shown, there have been fewer improvements in the past decade. The creation of the Economic and Financial Crimes Commission (EFCC) in 2002 served to improve efforts in preventing, prosecuting, and investigating both financial and economic crimes in the region, but this is yet another example of an effort that has not led to enough progressive change, and it appears that the government and bank managers have not been able to appropriately counter the problems through improved developments.
Considering laundering specifically, there are many angles to potentially address the issue, but bank managers and non-corrupt officials continue to seek solutions while learning from the shortcomings of the efforts that have taken place. It is uncertain whether progress is therefore slow but sure, or if the corruption is so great that it can manage to block informed and capable efforts. Aluko and Bagheri’s (2012) recent reports on money laundering trends in Nigeria, confirmed that money laundering alone is responsible for financial and economic crimes have contributed to instability in politics and economic complications, and aside from being responsible for the feedback provided in this work, it appears to be responsible for a limiting framework that has the managers seemingly helpless to initiate any sort of organised change. Nwagbara’s (2012) attempt to isolate causes and viable strategies for reducing crime and instability was similarly challenged. He agreed there is a major demand for ethical leadership models integrated into government and organisations, and pointed out current events that seem to have amplified the effects of the challenges that were already in existence in Nigeria. Global corporate scandals, bank fraud incidents, and managerial issues have impacted ethical leadership in the banking sector, so organisations may need to target these areas when attempting to address the roots of their organisational problems. Nwagbara (2012) pointed out that some of the responses from the managers may be due to increasing debate regarding legal policy relevant to financial institutions for these issues. Since Nigeria has experienced one of the worst types of scandal, with Nwagbara (2012) blaming financial impropriety of local authorities and general corruption across government and leadership, even strategic efforts to overcome the challenges could face opposition or be delayed indefinitely in spite of meeting organisational or resource requirements. Meanwhile, the discouragement of investment while damaging trust with local customers has only served to reduce the changes to acquire the resources necessary to make the kind of progress needed to fully address the target issues. Ethical leadership models were not something mentioned by any of the managers, and while it is a relatively new area in literature, it may take more research and awareness issues for this to be something more commonly pursued; Organisations may benefit from this as a professional analysis of this found that it would significantly helpful in the region, since it could serve to provide vision and responsibility to stakeholders while increasing the potential for legitimate operations and stability; an approach like this one that caters to stakeholder demands may be necessary, as stakeholder participation and hesitance was one of the most commonly reported areas of stunted growth and complications. There is potential for this approach to foster more ethical conduct in operations, and further promote more positive norms in corporations, but the organisations would still be faced with the development and implementation barriers they have faced in most other areas in need of development. Some of these complications could be potentially addressed, or at least pursued, through examining the financial sector at a microscopic level to understand the nature of cause and effect in politics and the economy. The nature of corruption and the propensity for crime is known, but examining details of the relationship with financial institution operation could be the kind of information organisations need to make progress in some areas. Both literature and the results have confirmed that some form of improved leadership framework is needed to enhance the stability of the banking sector, improving regional economics, generally reducing corruption, and restoring investor confidence.
Since the results of the survey were anonymous, the managers did not have to worry about any negative reaction following their participation in the study, but studies have shown that this is a problem when the work is not anonymous. Considering this, additional work should consider this factor and the potential for anonymous responses to be more informative and therefore beneficial. In addition to the wealth of information Nwagbara (2012) provided, considering the nation’s moral values, national values in general have been stated to be affecting developmental progress for morality in both politics and finance. More specifically, in the financial sector, leaders have not shown much concern for addressing the public’s interest while they have focused on personal improvements; the responses provided by the managers did not claim this directly, but they implied that this is a complication which has impacted the current states of development and the lingering problems.
The managers implied that the best course of action is one which is considerate of the fundamental challenges that have been asserted in literature, but they also all implied that this cannot be done while it has been attempted throughout the past. Nwagbara (2012) had acknowledged this while considering the concepts of ethical behaviours, visionary leadership, and intermediation with regards to the financial sector, the analyst determined that it may be better to address progressive development through a prioritisation of corporate governance and ethical leadership before the fundamental issues reported by the sample (giving these secondary but definite and addressed priority). Nwagbara (2012) asserted that reinventing the Nigerian banking sector demands sustainable development, while most of the immediate demands for improvement are commonly not considered in sustainable development terms (in addition to the corruption challenges). Sustainable development for the existing circumstances therefore involves an emphasis on environmental, economic, and social needs, while these are assumed to have a higher potential of being sustainable developments since they promote societal advancement in general. Both Nwagbara (2012) and Claessens (2006) had recommended intermediation, but considering the combination of resource and organisational issues alongside the past trends and corruption issues, this may not lead to the results anticipated either.
The main issue facing the financial sector and the entire country is that the Nigerian financial industry has been damaged by its own leaders, and this damage seems to stand in the way of any strategic plans which can manage to overcome the existing resource and organisational barriers. Leaders in Nigeria have been reported to commonly violate either organisational or industrial standards; while laundering, corruption, and crime are so commonplace in the nation, Nigeria has given birth to an entire culture of financial crimes and unethical practices that demands change at a systematic level. Considering this, the types of small changes recommended by the sample participants may be difficult to implement or maintain, while many of the recommendations in literature may be similarly difficult to address. Nwagbara (2012) recommended that in order to facilitate the change demanded, ethical leadership is needed to facilitate corporate governance, and banking practices may need to be built from the ground up to encompass all of this; clearly, the obvious challenge is organisation and resources amid the corrupt opposition, as even smaller scale remodelling efforts have reported to be difficult or beyond the capacity of financial organisations.
5.2.2 Development in the UK and Implications for UK and Nigerian Development
As with the previous section, there are many areas of the literature worth revisiting while considering the unique implications relevant to the research conducted for this project. This unique take on the literature supported by the results can be considered for improvement in both the UK and Nigeria, while the preliminary recommendations based on these combined aspects form the foundation for the recommendations list provided in Chapter 6. Efforts and issues regarding legal framework and improvement on the focus issues have been unique in the UK because of the reduced threat of corruption and lack of organisational and resource complications that are evident in Nigeria. However, the tightening of the legal framework has led to mixed results and mixed feelings, with many members of the sample reporting that these have created complications and undesirable results. The political framework and environmental conditions in the UK are different, as reported by both the respondents and in the literature. The UK has experienced pressures to address AML, and it has not experienced the same degree of terrorist attacks or corruption (Reynard, 2010). This may have changed the nature of the responses, if it were otherwise. Reynard (2010) had stated that wiretapping cannot be used as freely in the UK as it is in the US, impeding potential progress on cases or investigations, but neither statistics nor research results have implied that this is a serious issue in the current times. Analysts have considered the potential for the UK’s Bribery Act to take greater action to address laundering and corruption cases, and this may lead to the types of progressive changes recommended by the sample participants. Reynard (2010) had stated that there has been considerable apathy in the UK with regards to developing optimally effective AML and bribery policies, but from the sample responses, it seems like that there is actually more of an apathy (overall) in Nigeria while the UK managers seem to have a similar strive for progressive development in spite of the differing conditions. Legislation development appears to be easier in the UK, but is not without complications, or even demand for improvement for that matter. The legislation governing the three primary categories of AML is dynamic, but are commonly argued to be in need of further improvement. This is so that they can address criminal activity without infringing on legitimate operations, as explained in the introduction and as confirmed repeatedly throughout the research data.
 The second main offense as stated in the legislation, the entering into an agreement for some type of laundering requires specific criteria for a conviction, and fortunately corruption is not enough of a factor in the country to undermine this aspect of the legislation. In order for people to be found guilty of violating the legislation established for this aspect of AML, the criminal property must be clearly defined and evident, but so long as organisations track their assets in a way which can be presented to a court of law, this should not be a problem. Similar to other types of offenses, the person in question cannot be prosecuted if they make an authorised disclosure or if they intended to make a disclosure (but had a justifiable rationale for not carrying through with it; thus, conviction requires that the funding or property obtained and handled proven to be criminal in nature while establishing a net benefit for the business or individuals operating it. This is another area of the legislation which seems to be ideal for the industry, but the first action explained is commonly reported to be an inconvenience for both customers and organisations. Following the Terrorism Act 2000, which addressed terrorist property to some extent in this earlier legislation, and was revised for the PCA 2002, UK authorities are treating illicit funds through laundering from terrorists in the same way that they would treat it from local criminals; this is even in spite of the fact that conspiracy for terrorism can still potentially come as a second investigation leading to other charges (Ryder, 2011). While there is more development and organisational support than is evident in Nigeria, there are still considerable legislation complications which affect the UK organisations and managers.
Another area worth considering in this discussion is the fact that FSA regulations control most of the policy in operations, as reported by Ryder (2011). It was not until 2006 that the FSA had decided to streamline money laundering policy, and part of the legislation demands that firms establish systems for the firm to conduct appropriate business (FSA, 2006). Because of this, firms are required to take care of their policies and systems while ensuring compliance with those systems and consequence or investigation for anything in violation. This is seemingly an asset and cause for some of the manager confidence reported, and is potentially part of the framework needed for Nigeria to overcome its complications. The overall AML and FSA systems may be ideal for modelling, assuming corruption does not prevent this. The FSA has a large reach in terms of enforcement and investigative powers that would be beneficial if implemented in Nigeria the same was as it has been implemented in the UK. The FSA has become a prosecuting party with the power to fine firms where legislation has not been observed, for non-compliance issues, and in certain intentional violations; this could drastically reduce complications in Nigeria.
Laundering criminalisation in the UK has evolved considerably in the past decades, yet another area which would help Nigeria if the corruption and resource challenges could be more easily approached. Before 2006, legislation for fraud included eight statutory ‘deception’ violations defined in a Theft Act, with the most common violation being a conspiracy to defraud; such strict legislation and frequent punishment of conspiracy would be of great benefit to Nigeria if it could be implemented and maintained, but as mentioned, analysts have suggested fear of corruption impeding such large-scale developments. The Home Office (2002; 2004) explained that, regarding the Theft Act, it is not always evident what offenses should be charged to the offender, and these challenges prompted a re-examination of fraud law in 1998. Other nations could benefit from the lessons learned here, ideally avoiding the same complications and mistakes.
One of the most fundamental elements of AML in the UK which Nigeria could benefit from is report obligation. This has impacted organisations while being the subject of much research and development in the past two decades, but have not been without complications; again, the improvements here are something that Nigeria could learn from. The UK movement came to pass due to authorities noticing the gross underreported nature of fraud in the country, not even prioritised by local police, and this is surprisingly similar to the reports of Nigerian corruption. Many victims had not reported crimes assuming that police would not take them seriously, and information to target investigations is still a challenge as reported by Ryder (2011). However, Nigeria could still benefit from improvements to the UK model of suspected fraud being reported to a laundering reporting officer, with actual frauds being reported to the SOCA. Banks themselves are permitted to decide whether or not to get the police involved in their situations and cases, although this is recommended in any case where it is believed that transactions were not standard international business. Individual victims of fraud can report to the banks and institutions in the UK, and there should be mediums for this in Nigeria as well.  Here, the obligation to report even allegations of fraud is important, and if there was a way to obligate Nigerian citizens in a similar way, it would certainly be of net benefit.
Crime in general in the UK is more difficult to ‘get away’ with, but the more developed legal systems and policies have not succeeded in eradicating it. Ryder (2011) examined crime and financial policy development in the UK, considering the costs of financial crimes, potential for corruption, extent of UK policy development, and reported that the FATF had found that economic and social costs of organised crime were nearly £20 billion annually.  If costs could be saved here, through some strategy, it would theoretically then be easy to dedicate funding to further research or development for the problematic legal framework or otherwise. Ryder (2011) had further explained that the UK’s AML has been led by the HM treasury, as the Financial Services Authority (FSA), Joint Money Laundering Steering Group (JMLSG), and the Serious Organised Crime Agency (SOCA) have also been influential in the development of AML policy; if managers insisted on the modification of policy because of the impacts on normal business operations, these are organisations that could be petitioned. Similarly, these organisations could be funded to research this and relevant issues in attempt to find theoretical or structural solutions to existing legal framework or organisational operation solutions. The government in the UK has been adopting a risk based approach to laundering, and is expected to in the future; the result has been cost effectiveness, and aside from this serving as a model for Nigeria, the overall organisation it provides while retaining flexibility could be of assistance to developments in both countries.
The HM Treasury attempts to address financial crimes through a wide range of measures that have given the managers the confidence observable in the sample. Meanwhile, there has been criticism that the UK has been more apathetic to AML developments, while UK legislation aims to deter money launderers through criminal punishment, and to confiscate recovered proceeds; a similar emphasis in Nigeria would help to eradicate corruption, while it can be assumed that the lack of corruption in the UK has not impeded these kinds of legal developments. The criminalisation of money laundering was updated in 2002 and 2003; here the three main offenses addressed by the legislation were with regards to concealing (including misrepresenting, converting, removing, or otherwise transferring money in an illegal manner), entering into an agreement where criminal property is to be managed and controlled, and simply obtaining or using criminal property (Blair and Brent, 2008). There does not seem to be complaints or recommendations for improvement (in either country) regarding the definitions of crimes or punishments for these areas, so these aspects of development are not assumed to be part of the problem; however, this is not to imply that cost-effective developments in the areas would not be beneficial to the cause. Ryder (2011) explained that the scopes of the crimes are great, while it is possible for anyone to have benefitted from the action in some way. The legislation creating these rules state that there is no consequence regarding the active parties or the parties that gained from the crime, and they are offenses regardless of whether the crime took place before or after the legislation was passed. Despite this, the gain by the people must flow directly from the criminal activity in order for it to be considered a crime, with the nature of directness determined by a combination of legislation stipulations and judgment in a court of law, while this does not necessarily mean that a financial gain was made from the laundering (Hudson, 2009). This aspect of the legislation appears to be detailed and effective, despite the legislation prompting investigations into otherwise normal criminal operations.

The UK’s PCA 2002 contains the main legislation regulating fraud reporting, making it an offense for a person to fail to submit an SAR report when they have knowledge of even potential fraud or laundering. Developing the legal framework for obligations like this in Nigeria should be considered a priority and necessity. Beyond this, the PCA act requires that people of the regulated financial sector are to report their allegations as soon as ‘reasonably’ possible, but there is no legal requirement to report an attempted or unsuccessful crime (Home Office, 2004b; Ryder, 2011).
Other aspects of criminalisation covered by the PCA 2002 includes the requirement that members of the regulated sector create a report to the FSA whenever: i) it becomes evident that an employee may have been guilty of fraud within one of the organisation’s customers (regardless of employer), ii) if any person (regardless of employer) is acting with some intent to commit fraud against the organisation, iii) if irregularities are noticed with regards to accounting or other records (regardless of whether there is actual evidence of fraud), or iv) if someone suspects that one of an organisation’s employees is guilty of substantial misconduct regarding honesty related to the firm’s activities (Ryder, 2011, p. 262). This should be the basis of organisational framework in Nigeria, and even if it cannot pass the Nigerian legislation, the managers should have the authority to require that employees take appropriate action. An organised system of documentation and records could also serve to assist organisational and legislative development efforts in the future.
Both UK and Nigerian firms should consider that when firms have experienced substantial financial losses due to some incident, or have experienced a significant loss to their reputations, legislation such as the FSA will demand to consider the variables relevant here. In the case of established law in the UK, they will also consider the potential for the internal controls to be weak. As discussed in more detail in the literature review, Ryder (2011) stated “the UK’s policy toward fraud has gained momentum under the previous government…there is still scope for improvement in the initiatives that have been introduced to tackle fraud. For example, the effectiveness of the criminalisation of has been limited by the inadequacies of the Theft Acts and the common law offense, a position that has improved by the introduction of the Fraud Act” (p. 262). Thus, the Fraud Act may be a better model for developing Nigerian framework compared to the Theft Acts, but both appear to have potential to make ground for the extent of corruption in the nation and the organisational problems reported to be stemming from the issues. Ryder (2011) recommended that the coalition government should be modelled for its efforts in researching and developing for a single economic crime agency, while this could lead to more efficient and effective developments in countries like Nigeria.
Although the UK and Nigeria are both vulnerable to terrorist activities, it appears that terrorists have a greater potential to organise and operate undetected in nations like Nigeria rather than the UK. Terrorist financing is another area significant to the demands of AML development and improvements in financial regulations in the UK that could assist Nigeria. Five years after the PCA was developed, the government approached financial challenges related to crime and terrorism, attempting to determine how the private and public sectors could join forces to deter terrorists from exploiting the existing financial system; this same method could be used for terrorists and those responsible for general corruption alike in Nigeria. The UK government had attempted to develop better tools that could be used by affected organisations to disrupt, freeze, and address funding used in terrorist networks; although they had minimal success, there were reports of demands for an improved legal framework in Nigeria, and this as well as the ethical leadership recommended by other analysts appear to be the best starting points.
Other developments in the UK have led to mixed reactions evident in the results, while both the progresses and lessons learned could potentially serve as starting points or aspects of strategy developed for countries like Nigeria. The HM Treasury had stated in 2007 that the UK government was continuing to attempt to keep terrorists from using funding regardless of their campaigns as long as they were defined as extreme and radical groups; this should be considered a ‘mistake’ and not implemented by Nigeria, considering the extent of its corruption problem. The UK has attempted to improve its policies criminalising terrorist financing with the Prevention of Terrorism Act and other legislation which has criminalised terrorist financing, but these are likely only starting points for the developments needed to address major corruption. The Terrorism Act of 2000 brought changes while bringing the total potential related offenses to five in total, and other aspects similar to the legislation for laundering became relevant to terrorism through the legislation as well. It is successes like this which can benefit developing nations or nations with high frequencies of corruption.
The capacity to follow through with criminal investigations and actually find enough evidence to prosecute people is something else that developing and corrupted nations can consider; here there are some lessons they can learn from the UK. In the nation, between 2001 and 2008, 34 people had been charged with fund raising offenses through the changes with the Terrorism Act. Meanwhile, only 10 of those had been convicted of some offense, but this is considering the legislation commonly complained about in the research (treating innocent international customers as potential criminals when they are sending money for their families) (Home Office, 2009). Nigeria could adopt this framework, in whole or part, considering whether it was willing to deal with two to three times the necessary investigations if it meant a reduction of corruption and more prosecuted criminals. Bell (2003) thought that strategies against terrorist funding were among the most difficult to investigate or prosecute, because it is difficult to pinpoint where an exact paper trail has been created, but this should not mean a lack of progress for legal framework in the UK or Nigeria. The UK’s terrorism act allows law enforcement agents to have additional authority in investigations while they can access financial data or accounts as they need; additionally, asset freezing is something that has developed slowly in the UK as well, and policies here also seem to have potential for partial or whole emulation (where possible) in the corruption-plagued Nigerian government. The Anti-Terrorism Crime and Security Act of 2001 allowed terrorist funds to be immediately seized, and something similar should be implemented to stop the transfer of corruption funds. This is assumed to be much more frequent in Nigeria, so the law would have to be more encompassing, but would have the potential to involve more investigations and prosecutions (and likely more crime accompanying investigations without measures to deal with this). Funds could be immediately frozen at the beginning of an investigation while any account suspected to be involved in criminal activity could be monitored; additionally, people could be required to report accounts suspected of being involved in some form of corruption, and this could increase the amounts of investigations and prosecutions by several multiples. Freezing orders prevent all people in the UK from making funds accessible to the suspected individuals, and the HM Treasury has frozen the assets of people and organisations whom were suspected of terrorism. However, the number of convictions has been unexpectedly low in comparison to records of terrorist activities or cases that could not be proven (assumedly due to legislation complications), but the mentality ‘better safe than sorry’ seems to prevail. This mentality in Nigeria has the potential to overwhelm investigative personnel and general investigative resources, but seems to be necessary as a step towards the eradication of corruption. To further combat corruption, the Nigerian investigative framework should model the UK’s efforts in maintaining a list of frozen accounts,
The success of the legislation and the government is generally considered in terms of the amount of funds that could be located and frozen, but others argue that even high sums frozen are not an appropriate measure of success (Ryder, 2011); although this is true theoretically, the approach should not be abandoned in the absence of a superior method. As reported in the literature review, at the end of 2009, there were only 237 accounts with approximately £600,000 of suspected funds, and similar legislative if not government (i.e. military and police) actions could result in a similar decrease in terrorist and corrupt actions.
Terrorism laundering reporting requirements in financial institutions are similar to general laundering reporting requirements, and how they were extended by the Anti-terrorism, Crime, and Security Act 2001 can prove beneficial in the UK as it would for Nigeria. This specific legislation made it an offense to not report disclose knowledge of offenses to the act, and it is clear that this could go a long ways towards reducing or eradicating the corruption issues in Nigeria so long as the implementation barriers could be overcome. Meanwhile, the UK appears to be overdue for an extension of this legislation that is more considerate of investigations and current global conditions.
Ryder (2011) drew numerous other conclusions regarding and related policy developments in the UK that could be applied for the benefit of nations like Nigeria. Regarding money laundering specifically, he stated that the United Kingdom has been fully compliant with its international obligations, while the UK’s measures go beyond its international obligations. Mirroring this would be beneficial. This was the first time there was a role so specific for a UK financial organisation. The reporting requirements for the SAR have increased the burdens to administrative staff, but this should not discourage further UK developments or implementation in developing nations. Meanwhile, such developments have resulted in greater emphasis on record keeping, internal policy, report filing, and other areas that are also worth pursuit in both nations. Requiring organisations to have even more reporting requirements was deemed inevitable and seems further probably in the future, especially considering how stern the UK government has been stern when it comes to money laundering. The Nigerian government may need to petition the assistance of an international organisation in order to actually implement this kind of change, but considering the evidence and the feedback from the sample in this research, there is overwhelming evidence that this would be a worthwhile initiative.
Regarding fraud and terrorism funding, Ryder (2011) stated that the UK fraud policy has gained momentum since it published a review on the topic in 2006. Such an effort could theoretically assist Nigeria in its efforts, but the UK also has challenges that are comparable to the challenges in improving AML legislation. To remain safe while continually addressing the implementation challenges as well as the corruption challenges, Nigeria may do best by slowly implementing the legislation and legal strategies that have proven to be most successful in the UK, and slowly adjusting as needed to deal with its uniquely challenging circumstances. The UK’s fraud legislation has more in common with US policy, and Nigeria could learn from aspects of financial industry it shares with nations like this as well. Ryder (2011) had recommended that sole government departments be charged with addressing the full range of financial crimes, but this is one of the more difficult areas to integrate in Nigeria’s legal framework because of the sheer amount of corruption involved. It has been recommended that the UK government should establish a unified agency for financial crimes, such as has been instigated with the mergers of the National Criminal Intelligence Service, the National Crime Squad, and the Assets Recovery Agency with the SOCA (Ryder, 2011). Nigeria does not have these same institutions, but it seems that more collaboration is necessary if it is to use its potential to overcome corruption issues before catering to the organisational and technology issues reported by the managers in the primary research.
An assessment of UK trends and traits has shown that the country can establish goals and appropriately divided public and private figures in AML procedures (Bergstrom, Helgesson, and Morth, 2011). These experts have asserted that public figures are accountable in the democratic system, while the private figures are not. While this distinction therefore demands division of labour across public and private sectors, as well as appropriate control systems, these can be more effectively used in enhanced AML efforts. If these are not used, there is a risk that accountability will be diluted while the potential for shifted blame increases, and this is not in line with democratic accountability; this is a potential risk to Nigeria as well as the UK, and the UK can continually consider improving development in this area of its legal framework. EU directives and FATF recommendations currently have little prioritisation or even mention of democratic accountability, and this could be addressed through future efforts. Generally, on-going emphasis is currently on the legitimacy of output, and thus it is recommended that democratic accountability be given more consideration in the future.
AML in the UK has undergone many changes from a wide range of acts and legislative developments, but as the study has shown, just because there are some improvements over the Nigerian organisation and resources, it should not assume that the problems here have been solved. Most of the managers have seemed to at least acknowledge this, if not recommend changes themselves. Terrorist laundering is one of the most difficult types of laundering to catch since it requires the identification of both terrorists and terrorist activities alongside illicit funds, and the ‘better safe than sorry’ mentality has been the best solution for the UK. This can improve with strategic research and development, and be slowly implemented as possible and needed in Nigeria to slowly help to address the weaknesses and demands for improvement identified in the research and through the study conducted here. Fortunately, a combination of reporting laws and improved investigative legislation provides authorities with a better chance of finding and stopping criminals, but there are and will likely continue to be complaints that some of the efforts can serve as obstacles to legitimate businesses. While the problems still seem substantial and worthy of significant attention in on-going research and development, they do not compare to the challenges in developing countries, and thus these issues need to remain a continuing focus in on-going research and development.
The problems discussed here are commonly known to be global, but there are only few variables shared across countries, making the potential to develop a universal effective framework low. Mansell (2005) explained that many developed world governments had been focusing on developing or improving expansive AML policies, but criminals continue to counter the developments while nations struggle to implement their effective custom solution. It is important in this sense to develop innovative and creative responses to the criminalities that are technologically advanced and amoebic just as long term planning sometimes may not be adequate to address the criminal inventions and revolutions. Anti-laundering resources and organisation have been the emphasis of development while policymakers increasingly realise that the root of the majority of the problems lie in the nature of the systems, and not in a lack of individual policy developments or enforcements. This has been supported by the research. Mandatory reporting requirements have placed huge compliance costs on the regulated sector, but this should not discourage the UK from pursuing further developments or discourage nations like Nigeria from further implementation. Mansell (2005) reported that there is a common mentality that exists in the UK, that law enforcers cannot cope with the amount of information they receive, and this should be taken with especial precaution when considering the impacts of corruption. There is potential for people to become concerned that only a small number of reports could lead to an actual investigation while only a fraction of the investigations would lead to an arrest. If this is what is necessary to catch the criminals, and to end corruption in regions like Nigeria, however, it should be considered the best course of action. Differences in local and international laws is another major complication that has affected the most direct approaches; for example, payments could be considered ‘corrupt’ under English law but permitted under a different local law where the payment is being made. There was direct support of this in the research, but some of the managers supported this as the best course of action regardless of the complications. This mentality should continue, but there should be an emphasis on improving the efficiency and effectiveness of this type of legislation in both the UK and US.

Other researchers have provided evidence of changes and potential in relation to laundering attempts and AML efforts which both the UK should consider in its continuing efforts as well as Nigeria in its efforts to overcome its corruption-related problems. Goswami (2007) explained that it is crucial to address authority organisations to address potential corruption or laundering, while Egbuiwe (2009) reported on the potential for a new network to assist in the fight against laundering; the managers surveyed and others like them should bring these concepts and the others in best practices and literary findings to the attention of upper managers, facilitating the on-going familiarisation with literature alongside continuing progressive development. Egbuiwe (2009) described the strategy requiring financial institutions to take additional actions to restrict the prevalence of laundering and terrorism that can be improved in the UK and adapted in Nigeria. Institutions are required to report transactions meeting predefined criteria to the Financial Enforcement Network in the UK, which is designed to address such cases and legislation. The Nigeria Financial Intelligence Unit does this creditably well. This Unit is domiciled in the EFCC and had until recently been supplying only the EFCC with financial intelligence against suspects. Other Anti-corruption agencies are now being serviced with needed financial intelligence thereby improving their operations and activities. Meanwhile, with the improvements in computer technology having the potential to improve the stealth or efficiency of crimes, cyber laundering has become more commonly used by criminals and more commonly targeted by AML efforts, including through the actions of the United Nations, G7, Council of Europe, and more. Hunt (2011) explained that there are loopholes in cyber laundering in developing nations, and the efforts to address the new potential from continuously evolving technology is a major focus in on-going developments. In the UK, The Financial Action Task Force (FATF) has taken some of the greatest measures and dedicated some of the most effort in addressing trade-based money laundering that can be partially or wholly emulated in developing nations. The organisation has established a total of 40 recommendations to improve AML measures, and most of these focus on trade based laundering. Considering the existing conditions and complaints within the organisation regardless, it appears that more action is needed to develop these recommendations or to implement them in existing operations.
Literature and results have shown that laundering and AML have been evolving through both legislation and the nature of crimes. Both officials and criminals have attempted to improve their techniques, and the results confirmed that the end result appears to be a balancing effect over time. As mentioned in the literature review, Svensson (2005) had attempted to answer a wide range of questions related to corruption and prevention; his report that the majority of anticorruption efforts have been dependant on various types of financial or legal organisations (i.e. financial auditors, policy, judiciary branches, etc.) have implications for the enforcement of policy or accountability in the public sector. It is thus generally assumed that additional and improved enforcement of policy will serve to reduce the level of local corruption, but in cases like Nigeria, there seems to be a gradual but modest plan (through reform programmes) for overcoming corruption and corrupt officials. Svensson (2005) explained that in many poor or developing countries, the legal and financial institutions can be weak enough to corrupt themselves, so this in combination with corrupt authorities appears to require as much (if not more) effort than the normal, to address the purely resource and organisational issues. Svensson (2005) even argued that providing resources to enforcement may not even be the right direction for a solution to the problem; here he stated that there is actually little evidence that devoting additional resources to legal and financial government monitoring reduces corruption. So there are obviously unique implications for Nigeria addressing its challenges, and while some areas of development can benefit from modelling based off the UK system, it is evident that the solution to the problem in question is not this simple. Svensson’s (2005) discussions of the Singapore and Hong Kong cases reported in the literature review are not as relevant to the results, but some of the discussion and conclusions he provided still are; the reports of alternative approaches to combatting corruption developed can help to improve the Nigerian legal framework. One of these strategies is to use private enforcement in certain cases (bringing reputable and integrity-driven private law firms) in lieu of public enforcement, using lawsuits to enforce public laws, potentially leading to more convictions and deterrence of corruption on a massive scale. This may be necessary in a nation so corrupt despite of its drawbacks; this approach has limited potential, and is not easily implemented in some countries. Another example of an alternative strategy potentially useful in Nigeria is citizen enforcement through the providence of convenient access to public program information, since this can serve to permit the citizens to request specific standards, to challenge officials regarding corruption, or to assess the quality of service.
This has been ably demonstrated by the ICPC in its public anti-corruption organs like National Anti-Corruption Volunteer Corps and the National Anti-Corruption Coalition. This strategy has a potential to reduce corruption in several ways. Svensson (2005) explained that a similar approach was taken in Uganda, another corrupt country, for some success, leading to improvements in funding and operations over time (and thereby a reduction in corruption). More specifically, the central government in the nation took action to address corruption by distributing data, increasing access to relevant information, and facilitating the monitoring of fund distributions in schools across the country. This required intervention from the government, as is all but certainly needed in Nigeria, and while it may not be possible for implementation and comparable results in all nations experiencing similar complications with their legal framework, concern for the issues should at least prompt governments to take some action. Actions as simple as spreading awareness of corruption, allowing groups to take their own preventative (or other) measures against the corruption, can (potentially) have a major impact on such corruption trends, and is thus worthy of pursuing where possible. Another potential strategy in combatting corruption is delegation from the private sector, this can serve to improve monitoring processes and affect operations.
Considering international efforts to address corruption which could potentially be of benefit, the International Financial Law Review (2010) reported that more countries attempting to reduce national corruption have been entering into multinational contracts or organisations establishing greater anticorruption legislation or controls. This has improved prevention against corruption.
Although the issues of corruption seem to be too challenging to overcome in the near future, they will continually be addressed, and with this recovering proceeds and the improvement of policy will need to be considered. Once corruption is approached and addressed to some regards, there is still the issue of redistributing the misappropriated funds. Unfortunately, the high levels of corruption in the nation can challenge these efforts, and may require additional effort, but these types of strategic development should still be pursued. Recovering proceeds can pose unique challenges to organisations and entire governments. The literature has shown that despite the challenges in locating and securing funds, there have been improvements in procedures across the past decade. Canhoto (2008) had examined UK barriers, elaborating on the nature of challenges and complications while considering ideal paths in policy development; these were stated to be “those emerging from the nature of the application, those concerning the particular organisational circumstances and those emerging from individuals’ mental schemas” (p. 177). This researcher also found that agents attempting to improve interventions can serve as ‘gatekeepers,’ and have an effect on the net performance of the implemented solution. Concluding, the author stated that segmentation is generally perceived as a tool for consumer markets, but it is a valuable technique to use in other organisational areas; with this, they asserted that the integration of segmentation is prone to obstacles related to organisational traits, how and where it is integrated, and cognitive restrictions.
5.3 Summary
Much of the literature reviewed here has been supported by the research developed and carried out. Nigeria has experienced a different and greater struggle with AML and corruption issues. Certain public officials in Nigeria have been indicted and convicted for violating anti-corruption law and abusing their office. Nigeria however is slowly moving from the notorious ranks (red status) of the infamous most countries to one of the (yellow status) states of integrity and transparency. Attaining the green status of complete integrity and cleanliness is a matter of time. Though money laundering, corruption, and crime continue to be significant, giving rise to a culture of financial crimes and unethical practices that demands change at a systematic level. Considering this, the types of small changes recommended by the study participants may be difficult to implement or maintain, while many of the recommendations in literature may be similarly difficult to address. The UK’s framework and strategies proven to be successful in literature are ideal starting points for many aspects of strategy, but considering the combination of resource and organisational challenges combined with the restricting corruption factors; these are only partial solutions to the complications with the existing legal framework.


Chapter 6: Recommendations, Further Research, and Conclusions
6.1 Introduction
This briefer chapter provides a summary and overview of the recommendations for practice and research, considering the combination of the recommendations from research and development outlined throughout the discussion and additional ones only implied through it, using bullet point formats. The conclusion section then reconsiders the aims, questions, and objectives of the research, evaluating the success while discussing the limitations.
6.2 Recommendations for Practice
Recommendations for practice to improve organisations in the UK’s legal frameworks and operations include:
Increase monitoring of laundering and corruption activities
Store data and assess on an annual basis
Remain flexible and change framework for account freezing and fund handling as needed to update policy with regards to literature and criminal statistics
Pursue solutions to the international business restrictions, and present recommendations to authorities or the government as deemed informative

Recommendations for practice to improve Nigeria’s legal framework include:
Target corruption as a comparable priority as improving financial aspects of the legal framework
Use strategies proven successful in other countries as a model for the problematic areas of resources and organisation
Remain flexible and change framework for account freezing and fund handling as needed to update policy with regards to literature and criminal statistics
Present recommendations to authorities or the government as deemed informative

These recommendations are not an inclusive list, while it is expected that more specific recommendations implemented in individual organisations vary significantly based on the individual differences in organisational variables.
6.3 Recommendations for Further Research
Recommendations for further research in the UK include:
Development of legal framework that closely monitors fund handling while minimising account freezing of innocent customers
More efficient laundering detection processes and technology
Integration of security experts with ‘normal’ employees
Improving analytical and developmental framework

Recommendations for further research in Nigeria include:
Combatting corruption to make room for developments
Addressing the resource issues amid corruption
Addressing the organisational issues amid corruption
Continuing development and gaining a comparative advantage in organisations
Potential to adopt effective strategies within the unique national and organisational variables

6.4 Conclusion
Overall, the research was as successful as expected for such an academic effort, and the limitations were actually slightly lesser than expected (allowing the larger sample sizes). Considering the research question “what are the strengths and weaknesses in the United Kingdom versus Nigerian regulations for monetary transfers in the financial sectors, and what are the most viable and effective ways to improve account freezing and fund handling techniques?” corruption, resources, and organisational issues were proven to be the largest factors, while the UK’s lack of these issues are effectively its strength. The most viable and effective ways for the UK to improve appears to be to remain diligent and aware of evolving threats, practices, and technology, while Nigerian organisations seem to be in most need of basically ‘catching up’ by adopting these policies within the unique challenges of corruption. Since there does not seem to be a framework for improving legal framework and policies with the combinations of these challenges, the organisations in the nation have remained challenged for the past decade in spite of the increased awareness and technological capacity to address the organisational weaknesses. Meanwhile, regarding the second research question “what are the challenges and opportunities for the recommendations in literature and from financial experts?” the answers to this were found to be along the same lines, forming the recommendations that have been listed in this chapter and discussed directly or indirectly across the discussion chapter.
The hypotheses were proven to be correct but somewhat incomplete. For the first research question, the hypothesis was that the Nigerian government and banking systems could learn a great deal from the UK systems, but a combination of disorganisation, resource issues, and corruption in the government impede the progress. Most of the recommendations in literature are expected to be known by upper management and many analysts, but this knowledge is expected to be less commonly known across the government and banking system. Motivations for awareness and development are expected to be limited from the combination of corruption of the government and knowledge of resource and organisational challenges. It is expected that certain degrees of corruption are just expected in the nation, and that the people require some kind of assistance (from the government or otherwise) in driving progressive change in their banking systems. In the UK, it is expected that while the challenges in improvement in a general sense are lesser, their challenges in addressing the more complicated aspects are thereby the greatest overall, demanding additional research initiatives surpassing the scope of this study to gain knowledge of effective techniques and new solutions. For both countries, the most viable and effective ways to improve account freezing and fund handling techniques depend on the best methods for organising resources and processes, from which current events, policies, literature, and expert opinion have only provided clues. This was proven to be true, but the extent of corruption and active variables presented by the respondents were not predicted. Meanwhile, considering the secondary hypothesis that the challenges and opportunities for addressing the recommendations in literature, and meeting those advised by financial experts, all stem from problems in knowledge acquisition and awareness, corruption and disorganisation, resistance to change, and available resources. Addressing these problems to the extent demanded to create the viable solutions targeted would therefore demand that the challenges be continually pursued through research and development, which will almost certainly require changes in legislation or funding from an outside organisation (such as the government, the World Bank, or the United Nations). Again, the recommendations were not predicted, and neither was the extent of the corruption, but it is obvious that Nigeria needs substantial resource assistance from its governments and international bodies to overcome its corruption and infrastructure challenge.
Lastly, considering the research objectives to: i) identify strengths and weaknesses in banking regulations in the UK, ii) identify the strengths and weaknesses for the same Nigerian regulations, iii) complete a comparative analysis, iv) discuss recommended solutions for improvements, emphasising account freezing and fund handling, v) discuss opportunities and challenges regarding the recommended paths to improvement, and to vi) present unique recommendations for on-going research and development, these were all accomplished to varying extents. Objectives i), ii), iii), and v) were completed to detail, but iv and vi) were expected to be accomplished to more detail. This is thus an area that could be improved through academic research.
In summary, it is clear that Nigerian organisational challenges are complex including resource, capacity and organisational challenges, while the UK struggles to implement effective policies that do not affect legitimate business. It is clear that more research and development is desired in both regions, while Nigerian organisations may need an especially unique approach to optimise laundering and account freezing policies to fight corruption and related crimes.

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Appendices

Appendix A: Survey Questionnaire
1. On a scale of 1-10, how great is the threat of money laundering in your institution?____
2. On the same scale, how great is the threat of corruption, or how great is the potential for corruption to affect operations in some way?____
3. Is your organisation taking any steps to address the threats of money laundering or corruption? ____
4. If you answered yes to the above item, please describe_______________________________
5. Has your organisation taken any steps in the past year (yes/no) and do they plan to take any steps in the upcoming year (yes/no)?
6. On a scale of 1-10, how much concern do you feel the organisation has for the potential threat of laundering?_____
7. What do you think are the strengths for your organisation, in terms of protecting against laundering and corruption related actions?____________________________________________
8. What do you think are the weaknesses? ___________________________________________
9. What improvements do you think should be made regarding any of the above areas, if any?
_____________________________________________________________________________
10. Do you feel the account freezing policies are adequate?_____
11. If you answered no to the previous question, then why?______________________________
12. On a scale of 1-10, how adequate do you feel fund handling procedures are, considering the threats of crime?________________________________________________________________
13. Please provide any additional comments you feel are relevant to this research study, or you feel would be informative to any aspect of it. _________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________

Background information (please complete to provide the researcher with basic employment information which may or may not prove additionally useful through additional correlations in the study)

Approximately how long have you worked with the company?________
Approximately how many investigations have you dealt with?________
Approximately how long have you worked in any position dealing directly with anti-laundering or laundering issues for a financial service provider?________

Appendix B: Interview Template

1. What kind of problems does your organisation have with money laundering, and related regulations?
2. Do you think the organisation is doing enough to address the problem?
3. What kind of work do you think is needed to improve regulations?
4. How does the potential for corruption, and the need to recover funds, affect your organisation?
5. What other issues do you think require improvements related to money laundering, account freezing, or fund recovery in your organisation?

Background information (please complete to provide the researcher with basic employment information which may or may not prove additionally useful through additional correlations in the study)

Approximately how long have you worked with the company?________
Approximately how many investigations have you dealt with?________
Approximately how long have you worked in any position dealing directly with anti-laundering or laundering issues for a financial service provider?________