KIGALI, RWANDA - "We don't have a limit," said Joy Ntare, the Director Financial Stability at the National Bank of Rwanda (BNR).
Ntare was answering a question by a participant on how BNR is going about the now rampant global crime of money laundering and the answer appeared to have shocked many including Daniels Ochieng the regional coordinator of the Israeli based Institute of terrorism research and response.
The brief exchange was during a two day workshop on anti-money laundering held in Kigali recently and attended by bankers, security officials and financial consultants and Ochieng had just presented a paper on terrorism and money laundering.
During the workshop where Ms Ntare gave a key note address, it emerged that unlike their counterparts in Kenya and Uganda, BNR has no limit in place as to how much cash a bank account owner can receive on their account and that it's all up to the profit minded banks to decide which transaction is suspicious and report it to BNR.
The challenge is that, during the workshop, a Kenyan presenter who's also an anti- money laundering consultant revealed his shocking experience where his Bank in Kenya advised him on a way to dodge the law when his account held more than $5000.
"Because I am a prominent and trusted client, I was advised to distribute the money by issuing five different checks to my family members who held accounts in the same Bank," revealed Ochieng to the amazement of participants.
By doing that, his bank had aided him to beat the Kenyan Central Bank law which requires Commercial Banks to report any account that accumulates $5000. But the same practice also amounted to a crime where the bank was possibly abetting a money laundering attempt by a client.
"In this day of competition, it's a risk to entirely trusting banks who do not only have an obligation to keep confidential clients' transactions but are also profit minded especially when there are big money transactions involved," said a participant.
In most banks, big money clients are accorded special treatment with special tellers and a general special relationship between such clients and the Bank's management. It's therefore going to be under very rare circumstances that a bank will report such a client's big money to the central bank especially when there's no limit required in the first place.
"To some extent, it's a risk and the bankers' association is planning to propose a limit to the central bank," said Sanjeev Anand, the Managing Director of BCR.
Once in place, the limit, if passed will be adopted by all commercial banks as a standard threshold upon which the red flag can be raised on a given transaction.
As per the current practice, the banks are operating based on the national anti-money laundering law which requires all commercial banks to formulate anti-laundering mechanisms which they then submit to the regulators including BNR and other security agencies.
All banks in Rwanda have their separate thresholds. While it's $10000 at BCR, it's $30000 at Access bank. Bank of Kigali's Lawson Naibo told this reporter that his institution follows strict guidelines as stipulated by the anti-money laundering law.
For instance, he says there are people who can't be allowed to open an account with BK as there are countries blacklisted by international bodies from where transactions will automatically be reported to the relevant authorities.
"Besides that, a journalist whose account normally gets say $300 dollars per month will raise eye brows when he receives a huge amount say $1000 from whether it's an inside or an external source," explained Naibo.
What is common among the banks we talked to is that they all conduct an anti-laundering test on a daily basis and submit those they deem suspicious to the Central Bank.
What they didn't say however is how many cases they have submitted to the regulator.
"But it's also vital to note that we don't expose our clients' transactions right left center because we have a confidentiality clause to maintain," added Naibo.
Both Kenya and Uganda have been victims of deadly terrorist attacks which have since kept the security agencies on sharp alert.






