Filing Institution: Zenith Bank Plc (pilot) · Prepared by: Omnivig Investigation System · Status: Draft, pending compliance officer review
The subject is Adebayo Ogundimu, an individual account holder (account 3081447792), onboarded on 19 November 2024 . The declared occupation is independent electronics trader operating in Computer Village, Ikeja, with a declared monthly turnover of ₦1,200,000 . The source-of-funds record on file does not document any activity capable of generating the cash volume described below .
Between 2 April 2025 and 10 April 2025, the account received eleven cash deposits totalling ₦53,460,000 . Each individual deposit fell between ₦4,600,000 and ₦4,990,000, remaining below the ₦5,000,000 Currency Transaction Report threshold . On 11 April 2025 the account transmitted an outbound wire of ₦3,500,000 to Palmworth Ventures Ltd, an entity registered in the British Virgin Islands .
The deposits display a clustering pattern immediately beneath the reporting threshold, including a single deposit of ₦4,990,000 representing 99.8% of the ₦5,000,000 threshold . The deposits were placed across four separate branches (Ikeja, Surulere, Yaba, and Lekki) , a dispersion pattern that reduces the likelihood of single-branch scrutiny. The declared monthly turnover of ₦1,200,000 cannot account for ₦53,460,000 deposited within nine days . Two days after the deposit series concluded, the aggregated funds were partially transmitted offshore to a British Virgin Islands entity .
The conduct is consistent with structuring (smurfing) as described in FATF typologies concerning cash deposits below reporting thresholds . The subsequent offshore transfer is consistent with layering through an offshore corporate vehicle . The beneficiary entity matches Omnivig's internal offshore shell register at 0.72 confidence and has appeared in two prior unrelated cases .
Two candidate findings raised during analysis, multi-branch dispersion considered in isolation and same-day deposit velocity, were reviewed adversarially and are not relied upon as independent grounds for this report. They are recorded here for completeness only .