Trigger · Multiple cash deposits below the ₦5,000,000 CTR threshold across several branches within a short window, followed by an outbound offshore wire.
ESCALATE · risk 87
The pattern of eleven cash deposits, each deliberately below the ₦5,000,000 CTR threshold, spread across four branches over nine days, is a classic structuring signature. The declared occupation cannot plausibly generate this cash volume. Escalation for full investigation is warranted.
4 patterns · critical risk
FATF Typologies — Cash structuring below reporting thresholds
FATF Typologies — Use of offshore corporate vehicles
2 flags · 1 watchlist · PEP no
2 of 4 survived
Innocent explanation: A cash-intensive trader might keep deposits small out of habit or to match daily takings, not to evade reporting.
The amounts cluster at 92–99.8% of exactly ₦5M rather than tracking plausible daily takings, and the declared ₦1.2M monthly turnover cannot produce ₦57M in nine days. Habit does not explain the precision against the threshold.
Innocent explanation: The wire could be a legitimate supplier payment for imported electronics inventory.
No invoice, shipping, or customs documentation supports an inventory purchase, the beneficiary is a BVI holding company rather than an electronics supplier, and it appears in two prior layering cases on the internal register.
Innocent explanation: The customer may simply use whichever branch is nearest during the day.
Branch choice alone is weakly probative and is already captured by the structuring finding. It adds no independent weight and risks overstating the case.
Innocent explanation: Splitting a day’s cash into a morning and evening deposit is ordinary for a market trader.
This is consistent with legitimate trading behaviour and cannot be distinguished from the benign case. Discarded.
Net assessment · After adversarial review, the structuring and offshore-layering findings withstand the strongest innocent explanations. The multi-branch and velocity findings do not add independent weight and were downgraded. The core case for a SAR is strong: sub-threshold clustering plus an unexplained offshore disbursement, with no source of funds consistent with the customer profile.
Investigation completed in 4.8 minutes across five agents.