Management of Fraud In the Nigerian Commercial Banks


The review of related literature for this study met with many difficulties due to non-availability of textbooks for proper review.However, few literature consisting mainly chartered institute of Bankers of Nigerian (CIBN) journals, business and financial times, seminars, papers, classroom, handout and magazine were needed the information gathered from these sources were analyzed under the following sub-headings.


From the general observation, frauds vary widely in styles. There are non-two cases whose styles are similar except that all intentions are unintended for an action to institute fraud, there must be a dishonest intention and the action must be intended to benefit the perpetration to the detriment of another person.

There is always an element of deceit or tickery deliberately practiced in order to gain some advantages dishonestly.

Olufidipe. Fraud has been variously defined in the literature.

The Oxford Advanced learner’s Dictionary of current English defined fraud as a criminal deception use of false representation to gain unjust advantages.

Most developing countries of the world regard fraud as a criminal act. In Nigeria, it is equally recognized as a crime too this promoted the promulgation of decrees on fraud and other fraud related matters structures, namely, the failed bank  and recovery of public Decree 18 of 1994, Banks and other financial institutions Decree (BOFID) 1991, money laundering  Decree No3 of 1995, federal intelligence investigation Bureau (F11B).

According to Adekanye, fraud is an act of falsifying or altering and writing for the purpose of doing injury to another person. He continued any alteration of writing made with intention to defraud is therefore forgery.

Perry did not deviate much from that of Adekanye he added, fraud is an act on course of deception deliberately practiced to gain unlawful or unfair advantage such deception is directed to the detriment of another.

Therefore, the term fraud in it’s broadsense seems to suggest any activity that amount to unfair dealing moreso, to defraud ordinarily means to deprive of person dishonestly or something which is his or her something which is his or her something to which he is or would or mighty but for the perpetration of fraud be entitled.

Fujah sees fraud as an intent to deceive in such manner as to expose any person to lose or the risk of loss for our purpose is measured in monetary terms may be redefined as intentional mis-representation, concealment or omission of the truth for the purpose of deception or manipulation.

Here fraud is comprised of two fundamental element one is premeditation deceit and the other  is peculation of collective term for any combination of embezzlement, defalcation or mis-appropriation of fraud.

Furthermore, Kirk Patrick in his contribution said that a person who pretends to be something that he is not is a fraud, a snare, a deceptive cheat and swindler.

By extension, fraud will induce embezzlement thereafter or attempt to steal or unlawfully obtain, misuse or harm the assets of the bank. Bank administration institute records show that fraud in the commercial banks and the banks in general are not new, they are as old as the goldsmith era (origin of banking industry). In this circumstances. It is now accepted that the definition of what actually constitute fraud remains false presentation to gain unjust advantage.



Frauds in commercial banks vary widely in nature character and method of perpetration. In general it may be classified in two ways the first is on the basis of perpetration while the second is on the basic of perpetration while the second is on the basic of method used.


According to NDIC Annual Report of various issues, the classification o the basic of perpetration are further sub-divided into

  • Internal fraud
  • Mixed Fraud
  • External fraud

2.2.1a           Internal Fraud

Internal fraud is fraud committed by members of staff (insiders ). The members of staff comprised the managers, Accountants, executives Assistance, supervisors, clerks, (cashiers) typist/stenographers Technicians, messengers, Drivers, Cleaners, Ganders Securities Guards, Stewards, Temporary/Casual workers (NYSC/Industrial Attaches) and other uncategorized.

Below, table 2.1 represents categories for bank staff with the highest involvement in fraud.

 Table 2.1.

categories of staff involved in fraud.

Supervisor and manager 127 24.6
Officer, Accountants, Executives Assistants 56 10.9
Clerks (cashiers) 192 37.2
Typist, Technicians, Stenographers 34 6
Messengers, Drivers, cleaners, security 61 11.8
Temporary/casual workers (NFSC/1Ts) 6 1.2
Uncategorized Staff 40 1.8
TOTAL 316 100


From the above table, one will deduce that the highest incidences of fraud were recorded against the clerical cashiers who are unavoidably involved with raw cash.

2.2.1b                   MIXED FRAUD

Mixed fraud is fraud committed by collusion between the insider staff and the outsider customer it is the general belief that no successful fraud is perpetrated with out the aid of an insider staff. For instance in one of the outgragenuos armed robbery incident in 1986 against union bank PLC, Nnewi, the staff disposition chart recovered from one of the bandits was alleged to have been designed by a member of staff I(insider)

2.2.1c                   EXTERNAL FRAUD

External fraud related to those committed by persons not connected with the bank. A typical example was that of the armed robbery as mentioned before either during the banking hour or during specie movement (cash in transit).

Moreso, some external fraud could result through carelessness and recklessness or negligence on the part of some customers. Often times, it comes through corporate accounts in which a dishonest staff may have access to the company’s chequebook .


The  most common form of classification employed by financial institutions is on the basis of method used.

Under this approach, the list of the types of fraud methods are usually in exhaustible as new methods are devised with time fraudsters are forever devising new methods.

The most important and common types were highlighted by the bank Administration institute (2989) in fraud prevention and detection series.


2.2.1a              ADVANCED FREE FRAUD (419)

This may involve on agent approaching a bank, a company or an individual with an effort to access company or an individual with an effort to access large funds at below market rate often for long terms. The purported source of such fund is not specifically identified as the only way to have access to it is through the agent who mists receive fee or commission “in advance”. As soon as the agent collects the fee, he disappears into the air and facility never comes through. Any bank desperate for funds especially the foreign exchange can easily fall victim to this type of fraud. When the deal fails and use the fees paid in  advance is lost, these victims are not likely to the losses to the police or to the authorities.

2.2.1b                CHEQUE KITTING

Kiting is defined by the United States Controller of the currency’s policy guidelines for National Bank Directors as “a method whereby a depositor  utilized the time required for cheque to clear to obtain an authorized loan without any interest charge” The goal of the cheque kiter may be to use these uncollected funds permanently for personal use.

Competition among banks in the era of deregulation encourage banks to make funds available before actual collection customers cheques in order to attract customers especially business accounts.

2.2.1c             ACCOUNT OPENING FRAUD

This involves the deposit and subsequent cashing of fraudulent cheques. It usually starts when a person not known to the bank asks to open a transaction account such as current and saving account with false identification but unknown to the bank Sadiku.


2.2.1d              MONEY TRANSFER FRAUD

Money transfer services are means of moving funds to or from a bank to a beneficiary’s account at any banking point world wide in accordance with the any banking point world wide in accordance with the institution from the bank customers. Some common azmeans of money transfer are mail, telephone, cheque over-the counter, telegraphic, electronic process, telex and bills of exchange. Fraudulent money transfer may result from a request created solely for the purpose of committing a fraud or the alteration of a genuine funds transfer request Agada. A genuine transfer request can be altered by changing the beneficiary’s name or account number or changing the amount of the transfer.

2.2.1e                    LOAN FRAUD

Loan and other form of credit extensions to business and individual customers constitute traditional function of commercial banks. In the process of credit extension fraud may occur at any stage from the first interaction between the customers and the bank to the final payment of the loan. Loan fraud or when credit is extended to non-borrowing customer or to a borrowing customer. who has exceeded his credit ceiling. The fraudulent aspect of this class is that this is intent to conceal it from the head office (inspectorate) staff on routine check to deceive them with plausible but falsified statement document etc.

Advanced perpetrators of credit fraud is to the extent of applying credit facility approached for one customer to the credit another who is often unrelated to be first customer.

2.2.1f          CHEQUE FRAUD

The use of cheques as a means of paying for financial obligation is an essential feature of modern economy. Cheque fraud is now common involving millions of naira annually. Common types of cheques are personal, business, government travelers, certified drafts and counter cheques with each having it’s own characteristics and vulnerability or fraudulent use. The most common of  cheques fraud involves cheques that are stolen, forged, counterfeited, orated.


2.2.1g         TELEX FRAUD

Transfer of funds from one location to another can be affect through the telex. The message through often coded can be altered (decoded) to enable diversion of the funds to an account not originally intended.

2.2.1h         COMPUTER FRAUD

Computer fraud can remain undetected for long-time. It cans tale the form of corruption of the program or application packages and be even breaking into the system via a remote censor. Diskettes can be tampered with or gain access to unauthorized areas or even gives credit to  an account for which the funds were not originally intended. Computer frauds do rarely occur but when it happens, large sums of money are lost.



Many authors have analyzed in some write ups different causes of fraud in the commercial banks. However, going through their tasks, we have reasons to accept the Shongotala is the most comprehensive. He grouped the major causes of fraud usually into two classes. One he termed institutional  factors and the other environmental societal factors the institutional factors are those traceable to the internal environment of the financial institution while the environmental societal factors are those which resulted from the influence of the environment or society of the banking industry.



Apart from authors-banking chief inspectors in the industry seem to be unanimous in the identification of institutional causes of fraud as classified officials.

2.3.1b                   NUMBER OF STAFF

Where an official supervises quite a large number of staff, there is a high likelihood that fraud could go undetected (Examination Invigilation)

2.3.1c                   NATURE OF SERVICES

Fraud may be caused where document of values and liquid assets (cash) are exposed to an indiscipline staff or unauthorized persons for example. A cursory look at the classification of fraud under internal method showed that the highest number of clerks (Cashiers) about 92 representing 37-2 percent of the various issues) see table 2.1


2.3.1d                   BANKING EXPERIENCE OF STAFF

Fraud in the commercial banks occur with higher frequency among staff with little practices on the  other hand, the more the experience and knowledge of a staff less the likelihood that fraud would pass such staff undetected unless with the active support of the staff, where professionally qualified finances are involved in fraud, they are more likely to swindle large chunks of money than less qualified staff.


This could affect the morally weak as well on the morally robust staffs in various ways. Lack of  knowledge of the ways of dealing with fraudulent practices in commercial banks could affect on otherwise honest staff in apprehending and avoiding the tricks of bank fraudsters.

2.3.1f               POOR MANAGEMENT

Commercial banks with poor management, record higher incidence of all sorts of fraud then those with effective management poor management give rise to ineffective and poor control system. Indiscipline among staff and this creates an environment for fraud to flourish.

2.3.1g                   STAFF NEGLIGENCE

          In certain cases, staff negligence could give rises to the perpetration of fraud in commercial banks negligence itself is a product of several factors including poor supervising lack of technical knowledge and pressure electra.

2.3.1h              RECRUITMENT SYSTEM

Poor recruitment and selection system, where cognate experience, relevant technical knowledge competence, character and other sterling qualities are sacrificed on the alter of non performance-related factors such as connection and tribalism  constitute important facilitator of fraud in financial institution or commercial banks.


In commercial banks where security arrangement for valuable document are weak, poor and vulnerable. It is easy for fraudstars to have their way without detection.


When sophisticated accounting machines are in use and are mannered by inadequately equipped staff, errors could arise and thus lead to the production of unreliable records.

In the hands of dishonest staff. Sophisticated accounting machine could be employed to deliberately omit entries, substitute improper calculation and posting, manipulate document, substitute facilities documents and alter genuine ones. All these are different ways of perpetration fraud.

2.3.1k                   INADEQUATE INFRASTRUCTURES

Poor communication system, power failure which result in back log of unbalanced posting, congested office space etc are some factors which encourage the perpetration of fraud in commercial banks.


Management practices, when negative to the aspiration and development need of staff could result in the generality of staff being frustrated. frustration  in turns fraudulent practices in commercial banks.



This is classic example where fraud could be externally hatched and executed. Fraudwhent staff in both commercial banks and in the employment of cooperate customers could collude to take undue advantage of lapses observed in the management control systems of corporate customer.


Traditionally, it is the negligence on the part of customers that provide sample opportunities to staff or commercial banks to perpetrate frauds. Negligence by customers takes various forms consisting errors that might have been genuine but which are open to abuse, distortions and deflulcation by, unscrupulous staff both within and outside the institution in the employment of customer.


personality profile of Aromatize personal most individuals with in ordinate ambitions without qualus are prone to committing frauds. Thus kind of individual is bent on making money by hook or by crook. Such people dismiss morality as an unnecessary  prerequisite for virtuous life. To them t

he end justifies the means, they are usually unscrupulous and opportunity ‘mahamadu observed.


As for fadeyi, the value system in any society is the set of rule that prescribes what is right or wrong within that society. Where the possession of wealth determine the reputation ascribe to a person that society is bound to witness unnecessary competition for acquisition of wealth. This no doubt will lead to some people using dubious means to get rich over might. It can be argued that the main causes  of fraud in commercial banks are traceable to the general dishonesty in society where morality is thrown to the dogs. Misplacement of society values, unquestioning attitude of the society towards the sources of wealth. The rising societal expectations from staff of commercial banks and the subsequent desire by such staff to life up to such expectations are also contributory factors of fraud.



Delays in prosecution of fraud cases have a way of frustrating. The parties to the case. A frustrated party can abandon the case mid-way leading to miscarriage of justice. The delays can be  inform of :-

  • lack of specialized manpower for the investigation of fraud
  • late reporting or cases to police
  • lawyers and persecution witnesses absenting customer with the value of a forged cheque, which he has honoured. The law on the matter is clear and strike against the banker. Every act of unfair dealing whether against the bank by it’s customers or by third parties against the customers by the bank 9including it’s officers) or indeed against the bank by it’s officers etc really deserves consideration under the topic – Adekanye.


An average Nigerian banker’s attitude to his customers account is that he is obliged to repay only against his customers cheques.

This attitude has support in law for cheque is the mandate to banker’s to pay against the account to the tenor of the cheque.

Inevitably, cheques have come to acquire considerable importance in banking and indeed are taken to be the  open system to a customer’s signature.

This importance has made cheques a veritable and leading means of perpetrating fraud ways which cheques are employed to work fraud in banks.

  1. Forged cheques with forged signatures
  2. Substitution of clearing cheques with stolen cheques themselves from court.
  • include delay in the investigation and charging of cases to court and
  • frequent adjournment by the court frustrate appellant and favour the defendant. All these make fraudsters to have feeling that they are above the law and as such can get away with any act of illequality.


Although this may be considered as a most point, it is argued in some quarters that lack of effective deterrent such as hears punishment could be a factor that contributes to non abetting perpetration of fraud in commercial  banks.


Many commercial banks fail to report fraud cases to the authorities. The believe that doing so will give unnecessary negative publicity to their institutions. This attitude encourages individuals with in ordinate ambition to defraud in commercial  banks. They reason correctly that the affected institutions may not persecute them. It is even sad to note that some staff whose appointment in other commercial banks.



As the law stands at present, mere carelessness in keeping the cheque book affords no ground for the banker to refuse to recredit the account of the


Machinist or persons employed to enter credit or dept into the ledger cards of customers are also prone to the temptation of inflation t he credit balance of particular customers carrying wrong balance forward or treating a debit balance as a credit. In most cases where this is done with a criminal intent, it is not unusual for the original ledger cards to be replaced by forged ones.

According to Fogbeni, each of these enumerated forms of banks fraud would certainly fit within the scope of acts that have been stigmatized as fraudulent by the criminal code namely as stealing, forgery and fraudulent false accounting.



In the opening paragraph of this topic, certain centenary remarks were made. It is therefore imperative to link it up here to avoid its implications.

Very often, fraudstar lay their hands on cheques leaves of bank customer, forged the customers signature there on and present them for payment where the forgery goes undetected and payment affected, the customer upon discovery of the fraud in variably demand reimbursement of his accounts.

In otherworlds, he seeks to place the financial liability upon his banker’s. the law on this is that in the absence of negligence on the part of the customer that would find a stopped against him, the paying banker is bound to effect the reimbursement and this bear the loss. The banker bears the loss because it has dealt with the fraud without the customer’s knowledge and mandate this principle holds true even where the forgery was  so skillful that could not reasonable have been  detected. The only situation in which a bank will be relieved of liability is one in which the customer may be stopped from asserting that his signature has been forged or endorsed without authority. The stopped may be found upon the conduct or express representation of the customer. stopped base on conduct may arise form the failure previous payment made on an unauthorized signature (perhaps of his agent) particularly where the fact of such payment have been brought to his knowledge Adekanye.


If a banker honours a cheque in favour of a person who has fraudulently endorsed it, the position in law is that the banker has not complied with the mandate.

In otherworlds, the instruction of the customer that the bank pays a particular person is not satisfied by the payment of an unauthorized person. In consequence, the bank is liable to bear the loss by refunding the amount to the customer’s account. . However, the harshness of this common law position had been mitigated for bankers who have acted in good faith and in the ordinary course of business by the provision in section (60) of the bills of exchange Act 1958 that where a banker on whom an order cheque is drawing affects payment in good faith and in the ordinary cause of the business, it is not incumbent on the banker to show that the endorsement was made by or under the authority of the person whose endorsement it purports to be and the banker is deemed to have paid the cheque in due course although such endorsement has been forged or made without authority.

  • Liability of losses occasioned upon cashier fraud


These are cases of outright stealing ad whatever the means employed by the cashier, it is necessary to stress that it is the property of the bank that has in fact been stolen.

It is so where the means employed by the cashier is to such names or suppress tellers or vouchers because the amount in question have been received from the depositors by cashiers in the course of their employment of account of the bank the depositors regardless of the fraud are entitled to claim the full amount of their deposits whenever they so wish. Where the cashier has declare a cash shortage.

However, where he may be adjudged quality of stealing would depend upon proof of the appropriate criminal intent.

But it must be admitted that in many of the instances, the cash shortages are infect genuine. “The perhaps is what informs the banking practice that such shortage should be deducted from the cashier’s pay. Ajomo.



Where the false accounting involves the inflation of a particular customers account or the treatment of a  debit as a credit account, this again amounts to stealing of the bank money.

Invariably, the bank has to bear the loss where these have been withdraw on such account.



Fagbeni among other authors on law relating to banking maintains three district forms of crime disclosed by the nature of fraud in banks.

These are stealing, forgery and fraudulent accounting.

However, two obstacles apparently standing in the part of investigation and prosecution of these crimes. The first is the reluctance of the banks to attract the publicity, which usually attends such trials. Banks are

Quite reasonably to perceive that  there image as secure and trust-worthy financial centers will be strutted.

Of course, it must be stressed that the in circumstances of each of the type of fraud discussed in this paper, police and assist in the prosecution of the offenders. By declining to pursue such cases the banks are unwilling assisting an offender to escape punishment.

The second obstacle is the apparent in capacity of the police to handle with efficiency the investigation and prosecution of cases of bank fraud reported to it.

The remedy to this is invariably linked with the much-needed improvement in the operational facilities of the Nigerian police force. But even then, the crucial role that banks pay in the injection of money into the economy seen to fewer than score a need for the police to place bank fraud as high priority offence deserving an urgent attention.

However, one will not go so far as to support the recent calls that banks should be left to institute private prosecutions of cases of bank fraud. Criminal prosecution is the exclusive juriboliction of the state and it is believed that it would be a very dangerous precedent if a particular class within the society were given this privilege beyond that already assumed in the criminal procedure code. The door is not closed against the commercial banks instituting civil actions (be which they may redeem their loss) against offenders who have made away with their money.

Thirdly, in most cases the banks would be seeking the equitable remedy of re-situation i.e. an order of court that the benefits fraudulently returned to them time would be of essence of such civil action. This itself should be sufficient reason to confine the director public prosecution and the court of the desirability of the civil action being pursed prior to the criminal prosecution.

It is hoped that this line of action would be  more readily pursed in the future rather than for the banks to contimes in their steady reliance on insurance firms to redeem their losses through fraud. For one thing, it may prove a deterrent if fraudstar becomes aware of the risk of loosing all in addition of going to jail.


  • Effect Of Fraud on Human Resources in the Commercial Banks.

Table 2.2 below represents an extract from NDIC Annual Report various issue showing the number of bank staff involved in fraud and have lost their job from 1995-1997.

Table 2.2. Number of banks involved in fraud from 1995-1997.

Bank of staff              1995              1996           1997
Number % Number % Number %
Supervisors and managers 151 24.16 218 39.49 203 35.9
Officers, Accountant and Executives Assistants 142 22.72 96 17.39 154 27.2
Clerks and cashiers 172 27.52 145 26.27 124 21.9
Typists technician and stenographers 18 2.88 19 3.44 20 3.5
Messengers, Drivers, cleaners, security Guards and steward 123 19.68 66 11.96 57 10.1
Temporary staff 16 2.56 5 0.91 5 0.9
Uncategorical staff 3 0.48 3 0.54 3 0.5
Total 625 100.00 552 100.00 566 100.00


from the able 2.2 above, a total of 566 banks staff (various) were dismissed, retained, disengaged or had their appointment terminated because of their involvement in fraud following 1997 as against 552 in 1996 and 625 in 1995 the comparative analysis shows that greater amount per staff were involved in 1997 than in 1996 but less  were involved in 1997 than 1995.

Consequently, an informed source (NDIC Report) revealed that the amount involved per staff during the 3 years period (1995-1997) are of the total, at a glance at the above, implies that the core operations staff. Such as supervisors, officers, accountants, managers executives assistants, clerks and cashier accounted for about 84.99 percent. NDIC.


TABLE 2.3 returns of commercial banks on fraud and forgeries.

Quarter Year Average no of  banking  rendering Returns Total no of fraud cases (NM) Total amount involve (NM) Actual Expected total loss (NM) Profit of actual expected loss of amount involved %
1st 1997 44 149 2,88.97 64.92 2.25
1996 40 131 563.57 149.80 26.58
2nd 1997 34 117 275.81 42.15 15.28
1996 24 86 179.99 64.53 35.85
3rd 1997 40 99 236.40 44.03 18.63
1996 61 100 329.22 76.44 23.36
4th 1997 61 106 73.44 38.83
1996 36 180 80.31 16.90
Total 1997 471 3,590.31 224.54 6.25
1996 587 1,542.91 371.08 24.07


Table 2.3. shows the number of reporting commercial banks, the numbers of fraud  cases reported on quarterly basis. The amount involved and the actual/expected loss.

During the year 1997, the average number of reporting banks stood at 39 per quarter as against 43 in the previous year.

Similarly, the number of reported fraud cases reduced to 471 from 587 attained in 1996. On the other hand, the total amount involved in the reported cases in 1997 increased to N3,590.31 million from N1,542.91 million 1996 through the actual expected loss stood at a lower level of N224.54 million relative to N371.08 million in 1996. On the average only 6.25 percent of  the total where as for the previous year (i.e. 1996) the properties was 24.07 percent. NDIC.

After a close look and analysis of the definition and precarious nature of fraud, we have no doubt to believe the magnitude of the losses arising from bank fraud is obviously seen from the above charts.

It id appropriate to have a feeling of the extend of loss through the commercial banks in order to appreciate the  havoc the cankerworm has been wrecking on the banking industry in particular and the economy in general.

We had earlier quantified in concrete terms the amount lost in 1996 and 1997. Here the actual amount involved and actual expected loss in bank fraud should be multiplies of the reported figures in the above charts because (according to NDIC) many commercial banks were hesitant in rendering the turns due to it’s implication on their image.

Nonetheless, the sum of N6,389.96 out of which commercial banks accounted for a greater percentage (96.6% in 1997) NDIC.



Banking experts and practitioners gathered recently at the prestigious NICON HILTON HOTEL ABUJA to brainstorm on recent development on electronic banking (Sponsor) institute and computer equipment and system international company ltd.

The best for our purpose is the Novel Concept , which is fast gaining currency within the Nigerian banking system, discussed under the sub-heading information technology.

Automation facilities.

Management information  system

Program package

Problem solving techniques.



  • Information Technology

Computer is considered as the most relevant to the management of fraud among the other information technology series, telephone, radio, television etc. the large scale organization have given rise to large administrative structures in which there are large numbers of clerical workers and people with no technical and management skills collectively known as white collar workers computerization has in fact affected white collar workers as well as decision making management functions.

In addition, there has been an increase in the number of organizations involved in activities other than manufacturing.

Some of such organization for example in- power  industries contribute to the manufacturing and provide a general service. As a result of this change, some percentage of the manufacture of goods. Consequently percentage of the manufacturing continuous to general most wealth, it has also lead to society today being called past industrial society.

Again, looking at the whole of the National and international community and at the way organization are run, events highlight the fact that modern  society in which majority of the labour force will be engaged in information process and the use of the information technology. Adewunmi.



previously, the computer system made excessive use of punch card as an input medium. There were certain interest drawbacks associated with using punch cards particularly in connection with punch cards particularly in connection with laborious expensive and show processes of transcription  verification and media conversion various attempts to automate this process were made with the aim of increasing speed and reducing costs. The introduction of data transmission equipment’s, various telecommunication methods and systems were devised in order to transmit data electronically from remote sites to a central computer. Over the years, these systems have developed into superior and more. Comprehensive national  and  international networks, electronic fund transfer and automated teler machine other method of directly encoding data onto fast input media are as follows.

  1. Key to key system

This allows direct encoding from source documents into magnetic tapes.

  1. Key to disk system

This allows data entry from source documents onto disk and ultimately onto magnetic tape for input. Key to disk to system where quickly adopted for small  general-purpose work.

  1. key to diskette system

Diskette often called floppy disk was on IBM invention intended  as a punch card replacement. Diskette system allows data entry from source document onto disk and ultimately onto magnetic tape per input.

  1. Direct Capture

Data are captured at source or on machine sensible source document e.g. optical character reader (OCR), optical mark Reader (OMR), visual display Unit (VDU), magnetic ink character Reader (MICR) and computer output microfilm (COM)

In the light of  the main theme under discuss, magnetic ink character reader (MICR) system now a new development in all the commercial banks has adequately overtaken the human error encountered during cheque verification and referencing with the MICR cheque system all frauds forgeries resultant from human errors are under control by the use of computer. Oliver.


  • Management information system (MIS)

Management information system (mis) has been described as the application of technology and management techniques to produce, communicate and use information in business and general administration. Technological support is provided in from of data processing, telecommunication, office automation and some other micro processor based on equipment.

As an information system, management information system (mis) should be responsible to a variety of information.

All measurable data pertaining to the organization e.g commercial banks must be organized in a manner where it can readily be recorded, stored, processed, retrieved and communicated as required by a variety of users.

Management information system is a systematic formal assemblage of components that perform  data processing operation to;

1 meets legal and transactional data requirement.

  • provide information to management of support of planning control and decision making.
  • Provide variety of reports as required to external constituents.

The essence of management information system is to use formalized procedure to provide management with appropriate information from all relevant sources which would enable the manager to make timely and effective decision. The above goal can be realized more easily where computer technology has been adequately applied such technology includes the availability of a reliable data based on management information which can be assessed (with appropriate control) from computer terminals which also service all relevant sources of information.

These information system includes

1        Data entry and preparation devices

  • Data storage device
  • Telecommunication and equipment’s.
  • Data processing equipment to record, verify, classifying, arrange, summarize, calculate, retrieve, reproduce and communicate.
  • Terminal information device
  • Procedures, programs, methods and documentation.
  • Data manipulation models such as accounting and budgeting models linear programming, inventory models statistical techniques.
  • Decision rooms worth graphical display broads and charts.

Against these back drops, management information system(mis) is an integrated system of main machine and procedures formally or informally developed for the purpose of collecting and processing data to supply informally to aid the dancing decision making and controlling activities in an organization such as commercial banks. It is sub-system of the total organization system of the total organization system but differs from say currency accounts or bills and credit sub-system of a commercial bank in that it runs through and link all the organization decisions centers and operating units and also provides the organization necessary interface with its environment EKEKE. It is probably clear from the above definitions of a management information system(mis) that its primary objective is that of processing and supplying valuable information to wards decision making process in an organization (bank) to establish and fulfil its over all objective.



computer system is made up of the and-ware(physical computers ) and the software (coded instruction) computer soft ware refers to the collection of program designed to control and enhance the operation of the computer. Typical software system designed to solve specific user problems includes, operating language translation, bader, editor’s etc.

Common application software and payroll, order entry-invoicing accounts receivable, inventory control and billing.

In the early days of computing, a sure has to manually operate the computer machine in order to execute this programm the user would cause the programm to be loaded into the appropriate device, then the programm transmitted. In effect the user was completely in control of the system resources and this monopoly resulted in serious overhead which made the very high speed of the process appear insignificant.

Since the user has control over the component part, there may be manipulations which are thereby carried into the system.

Meanwhile, it becomes obvious that there was a need to better utilization of resources hence the idea of automatic sequencing and controlling the operations of the  various component of the system was conceived that was the beginning of the development of a suite of programs which serve as the interface between the user and the computer hardware while Chapman defined operating system as a collection of programs which control the operations with in a computer by ensuring optional allocation and usage of system resources.

At this juncture Akindodo system in order to reflect the relevance of fraud management under discussion these includes.

1    data management which include data protecting and asset control.

2    process control and inter-process communication.

  • job scheduling, including job initiation, job accounting and job control.
  • Storage management for both primary and anxitiary storage.
  • Resource management including sequencing and control.
  • Error detection, correction and recovery.

It is important to mention that there are different types of opening systems most of which are named according to the type of service offered but the most common one is the disk operating system. The aim of explaining the operating system is to enable us understand the issue of program packages, application software and data base software.



Application software according to Anderson consists of programs, which are written to sole specific user’s problem.

Typical users problem abound in almost all areas of human endearvours namely, business, engineering medicine, law, insurance, automation, integrated accounting, finance, public administration, comprising accounts receivable, accounts payable, payroll. Others include banking comprising customers’ accounts, loan management, derange house operation automated teller machine, and electronic fund transfer.

It is pertinent to mention that all these areas are sports for frauds. Computer on their own do not provide solution to problems rather the user takes advantages of the vast storage capacity incredible   speed of operation, accuracy, diligence and versatility the efficiently in plant solution he / she has designed.

This implies that before the computer can make any meaningful contribution to problem solving the nature of the problem must have been fully understood, properly designed and a solution communicated to the computer in an appropriate manner. Under the circumstance. It is not very manual or mechanical system although computer frauds do not usually occur but when it does, large sums of money are lost.



Packages are software program, pre-programmed for various types of machines. Any establishment (commercial bank) which desire to implant such package only need to purchase those suitable for its computer configuration.

Packages usually require some form of customization and initial training for the operation before the full benefits can be realized. But packages offer the benefits of fast implementation minimal maintenance cost and reduced investment. They sometimes prove too general to address the peculiar needs of some organization/bank.



A data base management software is a collection of intre-related data which are stored in such a way that they are independent of any application that used them. Database requires modern computer technology for their implementation and management. The advantages  of data base soft storage and retrial are these——————————————————————–

  • It is managed by special purpose software called data base management system (OBMS).
  • It is used to create a database.
  • It also provides centralized control of all data in the database.
  • It also reduces inconsistencies in the data integrity and corruption.
  • With data base system, duplication reduces and obsdence are minimized as very up data to data is done centrally. Anderson.



There are several approaches to problems solving. Most human activities are governed  by institution or experience. Hence problem solving is almost always approached heuristically base on human or at best on a set empirical rules.

This approach works most of the time. However, certain classes of problems are so complex that they cannot be in intinitivey visualized.

Furthermore, there may be no prevision experience to fall back on such problems can be solved through modeling.

A model is an idealized (simplified) representation of a real life system.

Some real life systems are complex because their behavior is controlled by a very large number of variable . it is only a small fraction of these variables that usually determine the behaviour of the system. Thus, the system cab be simplified by concentrating on these dominant variables. First by identifying them and then determine the inter-relationship among them.

These are various models viz. emulation, physical symbolic, iconic, analogue, geographical and mathematical.

It is appropriate to briefly mention few that are relevant to this study.



this model is a unearned (simplified) mathematical model used in deacon making.


the simulation model is an operating model or presentation of a form suitable to manipulation and study. It is also described as a symbolic and numerical abstraction of the process under study.

2.7.8(c) FINANCIAL

Financial modeling is a model constructed for the company finances, it’s resources, it’s income and it’s expenditure.

It is possible by using the model to simulate the effects of different policies.


Spread, sheet (intelligent knowledge based system (IKBS) is a more advanced integrated package which aids in such things are financial planning and statistical analysis for instance, the trend system has facilities for model building, the calculation, printing, graphical display.

It supports the decision making process by taking away the routine calculation and manipulation and also goes as far as recommending cause of action. This series of expert system (IKBS) has some characteristics, which we normally fear to be a threat to both routine administration and management function in no distant time. French.



We appreciate the efforts of the federal military government towards fraud control as represented through the sub-structure set up viz. security and exchange commission (SEC) for the capital market operations. Federal mortgage institutions (FMIS), national board of community banks (NBCB), national insurance supervisory board (NISB) for instance companies, the central bank of Nigeria (CBN) decree, national drug law enforcement agency (NDLEA) bank and other financial institution decree (BOFID). Nigeria deposits Insurance Corporation decrees (NDIC), companies and athed matters decree (NDIC), money laundering decree (ML), economic sabotage decree (ESD) failed bank and debt recovery.

Others are justice, the police, the judiciary and even the armed force NDIC.

All these are reasonable pointers to the fact that our financial system is riddled with fraud. Perhaps, the recent bank return to NDIC on fraud and forgeries in commercial banks revealed that the phenomenon has assumed an unimaginable law with this in mind, the monetary authorities (CBN, NDIC) involved the federal intelligence investigation bureau (FIIB) as well as the setting up of tribunals for example, the federal intelligence investigation bureau are empowered to.

ARREST, DETAIN, PROSECUTE, AND EVEN CONFISCATE PROPERTY of person accused of any fraudulent practices and the promulgation of decree no 18 of 1994 (failed bank and recovery of debts, financial malpractice’s) empowered to arrest, detain, prosecute and even continue to detain person (s) directly or indirectly connected to the failure or distress of any financial institution even where the person(s) secured ASSETS have been sold off by the banks.

So also, the provision of section 39 and 40 of NDIC Decree 22 of 1988 stressed the need for returns or dismissed, terminated, disengaged and retire bank staff involved in fraud related offences. Within the bank, there are internal punishment staff who has any atom of fraudulent intentions/ behaviors. Face disciplinary action viz. suspension for indefinite period with half pay, denial of year increment, bonus, demotion, inspection report.


Again, the money landing decree no 3 of 1995requires all commercial banks to disclose to the national drug law enforcement agency (NDLEA) and the CBN in the writing within 7 days any single lodgment (cash or cheque) in excess of  #500,000 for an individual and #2,000,000 for corporate body.

Furthermore, the banks and other financial institution decree (BOFID) no.25 of 1991 section 1892) stipulates penalty for the contravention of section 18(a). (c) An offence. Punishment on conviction to a fine of #100,000, or to imprisonment of a term of 3 years and forfeiture of gains and benefit to the federal government. Section 19 (PROHIBITION OF EMPLOYMENT OF CERTAIN PERSONS INTER LOCKING DIRECTORSHIP) ETC (DECREE 25).

  Section 19 (1) provides that no bank shall
  • Employ or continue the employment of any person who at any time has adjudged bankrupt or has compounded with his creditors or who is or has been convicted by a court for an offence involving fraud or dishonest or professional misconduct. BOFID.



The problem of fraud and forgeries is endemic and unavailable in the banking industry, due to a verity of reasons, for example.

  1. The very nature of banking business which involves human beings, clients, and staff of diverse background and interests in a relationship trust.
  2. The convertible ( i.e cash and near cash) nature of most bank assets.
  • Wide-network of branches some remotely locate, poorly staffed, ill-equipped and without adequate communication facilities.
  1. Widespread application of automated system which have no finger-print or handwriting evidence.
  2. Common social misconception e.g that banks fraud have limitless funds, or that bank monies are an institutional loot or body to be plundered by the able.

In  this country, commercial banks fraud has assured a frightening scale of sophisticated consequence upon the general economic depression of the last decade and the  contrinuning travails of the banking sector in the wake of government frantic policy experimentation. In section 7 (pg. 37,42) of it’s 1996 Annual Report and statement of account, the Nigeria, Deposit Insurance corporation (NDIC) already shown in the classification earlier has presented on illuminating report on cases of reported fraud in insured banks.

However, the unfortunate truth from empirical observation is that majority of commercial banks fraud are never reported to the police and NDIC inspite of the well known statutory requirements.

Some of the fraud actually passes undetected while some are criminally covered up especially where no actual or significance loss is sustained.

The common reasons for such cover up is to avoid adverse publicity, protracted police case, litigation and or black-mail.

Worse still, some of the new generation bank have been known not only to condone but actually commit and promote gross malpractices (eg kite flying and cross-firing) as a  mater of corporate deliberate business strategy.

The Nigerian banking industry has become not just a battle front with a clear-cut “firing” line between the banks and the bandits but a veritable mine-field in which some banks and their top management staff are in secret league with he enemy.

Only the increased alertness and collaboration of genuine banks together with improved supervisory measures by the CBN and NDIC will terminate such private organizations.

Commercial banks must wake up to the concern of elements in their operating environment and serious threats to their internal security arising from internal and external factors.


Internal factors are those factors that relate to their insiders or members of staff such as.

  • absence of a trough, unambiguous corporate policy committing to management to pursue the severest sanction including prosecution for acts of dishonesty.
  • Lack of clear procedural guideline or update instruction manual.
  • Poor staff of vital functions and loss of experienced personnel.
  • Low worker normal and employee frustration.
  • Staff dismissed or terminated for fraud be re-engaged in other financial institution eg mortage banks and finance houses from where they could sneak attacks on their employers.
  • Unplanned acquisition of new technologies eg computerization.



External factors relates to those factors that are not connected with the bankers such as

  • special degeneracy which promotes the get-rich-quick syndrome and workshop of materialism.
  • Exploitable defects in the legal and penal system.



In this conterest, branch is defined as a sub-ordinate division of a business, subsidiary shop, office etc. (chambers 20th century dictionary).

Branches are common features of banking corporation (especially commercial banks) their establishment being mostly dictated by market imperatives such as proximity to prime clients.

The status of bank branches with their head office is defined in the case of prince v oriental bank corporation where it was stated that ‘in principle and infant branches are agencies of one principle banking corporation or firm not with standing that they may be regarded as district for special purposes’ it is important to meter  the common rule of agency that would normally apply such that any notice served on the head office.(principle) would be deemed to apply top all its branches(the agents) allowing a reasonable time for communication.

The agency relationship however, will aid a clear understanding of the duties of branch management in fraud control.

Branch management refers both to the function of managing a branch and to the corps of personnel to whom that responsibility is entrusted. M.J. Cornor in his remarkable book ‘corporate fraud’says the scale of fraud in an organization is a reflection of the ability of its managers to manage’ the scale of fraud in a bank may result from system functions and head office weaknesses over which branch’ management may not have absolute or direct control. While Peter Drucken (in the practice of management identifies that two fold specific tasks of management as follows

  1. creating a true whole that is larger than the sum of its part, a production entity that turns out than the sum of the resources put into it. The task requires the manager to bring out and make effective whatever strength there is in this resource whatever weakness. This also requires that the manager in every one of his acts consider simultaneously the performance and result of the enterprises as a whole and the diverse activities needed to achieve synchronized performance.
  2. Harmonizing in every decision and action the requirements of immediate and range future. A holistic view of both the organization and the active management process must therefore be adopted at every level of decision making be it head office or branch level.

Branch management he continued must attain or surpass the standard of efficiency a security prescribed by head office. To do so it must only function complementarily to the head office management but take initiative in performing the five basic managerial operations.

  1. setting fraud control objectives and goals.
  2. Organizing fraud control activities and exercise.
  3. Motivating and communicating effectively.
  4. Measuring performance of teams and individuals.
  5. Developing people.

Of course, branch work is a very demanding responsibility full of unpredictable events and unanticipated frauds. Perhaps no other position in a bank carries as much risk exposure, since every account and every transaction is a potential for fraud. It has been indicated that large branch network increases a banks vulnerability to fraud especially where there is inferior quantify of staff. An empirical fact is that the massive expansion (rural banking program) of the commercial banking network in Nigeria in the last few years resulted in an unfortunate dilution of staff in key aspects of operation including 9branch management. Be that as it may, the branch ability to prevent or detect and control fraud depends essentially on the quantity of personnel assigned to it by the head office and the effectiveness of internal control in place. Internal control is defined by the American institute of certificate public accountant as ‘the plan of organization and all the co-ordinate methods and measures adopted by a business to safe guard its assets, check the accuracy and reliability of its accounting data, pro0mote operational efficiency and encourage adherence to prescribed management policies’ similarly, a second definition is offered by the institute of chartered accountants of England and Wales who refers to internal control as ‘ the whole system of controls in financial and otherwise established by management in order to carry on the business of the company in an orderly manner to safeguard its assets and secure as far as possible the accuracy and reliability of its records. Both the human resource and the internal control system in which rest the efficiency and security of the branch must be closely monitored by the branch the best measures which ensure timely detection and control of fraud may be categorized according to shongotola and ovua kporie.



Proper recruitment procedure=sreening, referees, sworn declaration, certificates, photographs permanent home address, bonds.

  1. Proper disengagement’s procedures timely notification of relevant department cancellation of right and privileges, withchraual of staff identify cards.
  2. Posting the placements.

Properly documented posting, written job description with defined authority and responsibility level job rotation.

Attendance’s logs or register

Enforced holidays and annual leave of absence training programs.



Segregation of duties

Dual custody

Movement logs and registers

Access right and restrictions

Security personnel

Franking machine

Archival system


Data validation

Prompt posting of transaction



Call over have posted entries

Signed authentication

Budgeting, standards and projections

Variance analysis

Reviews and statistics



Cash limits

Signing powers

Specialized stationer (e.g. certified cheque payment coupons)


Logs and listings

Physical checks and counts

Bincards, stock receipts notes, stock issued vouchers locks and keys

Balancing stock figures with the general ledger.



I input/output validation program

Key computer personnel (data processing manager, data administrator, programmers, system analyst, operator, librarian, data entry operators, and computer operator). The various principle and types of control are rationally applied to every aspect of branch operation as fraud antidotes and early warning system. However, it has been an accepted fact that fraud at branch level focused on the

  1. means of payment (cash-cheque, bankers payment sinter branch transfer)etc.
  2. accounts (house/ledgers, impersonal account, customer accounts)


A lot of control are also exercised over the main cash these includes dual custody of the vault and strict entry and exit procedures. Insurance limits on premises and in-transit rules for cash movements within or without limits allowable with the cashier and the staff in the hall, daily physical checks and balancing as well as agreeing the vault book with the billion officer cash control book on a daily basis daily exchange of tills books and occasional surprise check on cashiers are effective control techniques.

The use of a control register to monitor or cash lodgments checks the risk of fraudulent suppression of deposit by receiving cashier. Branch management should ensure that these controls are established and adhered to.


Bank to bank payments are usually affected with special instrument known as banker’s payment.

Similarly there are pre-printed as inter branch voucher for the settlement and transfer between branches of the same bank.

Both sets of instruments are safe custody items, which should be closely controlled even when bank. At issuance, stub or counter foil must be signed by the authorized issuing officers and retained for audit purpose. All serial numbers must be well accounted for and any lost instrument is a danger signed.



It has become a general accepted truth that the personality of the branch manager is perhaps the most important single factor in fraud prevention and control. The best internal measure would be rendered in effective if human agents deployed for their implementation were ineffective. The buck literally stops with the branch manager to see that controls are put in place, tht they are working, the violation or exceptions are promptly reported and corrective action is timely and adequate. However, in order to perform these corrective actions, the personality must posses the following qualities.

  1. Knowledgement
  2. Knowledgement ability

The branch manager must be knowledgeable enough not only to supervise but lead by example both on the job and outside the office.



On the job, he must be technically informed for only so can he succeeds in inspiriting confidence. Ability to personally check papers work and ask intelligent questions, which would discourage staff from errors and fraud attempt. It is therefore necessary that the branch manager should posses appropriate educational qualification as well as sound on the job training. He must be capable of developing himself and others. He must be receptive to new ideas and technologies (computerization)V.Okonkwo /L Okoye.





He must posses and exhibits a high level of self-discipline and sound ethical standards otherwise he can not provide the moral and leadership necessary for the prevention of fraud and abuse.

A manager who displays divided loyalty or conflict of interest or who indulge in various corrupt and unethical practices (such as bribery, extortion, kick back, and contract inflation) cannot keep his subordinates in check. ‘‘He who preaches equity must come with clean hands’’. Indeed since the position of a branch manager is a core factor to fraud detection, prevention and control, the appointment should be crucial management decision which should not be subjected to undue politics or extraneous consideration such as nepotism, favoritism etc.



The role of the federal government on the prevention and control of fraud is not only in the commercial banks but almost in all the financial institution. The government is mainly interested in ensuring a discipline society, promulgation of appropriate status, enforcement of various legal provisions.

This deduction is based on the realization that indiscipline and corruption in the society create take value systems and tend to encourage others to wants, to like the Jones’s.  in an attempt to be like the Jones, people get involved in unorthodox means of making wealth including fraudulent practices.

It is a common saying that where there is no law, there is no offence. In recognition of this, the federal government put in place relevant statutes to ensure safe and sound practice in the Nigeria financial system. They include CBN Decree, BOFIO, NDIC Decree, FMBN Decree, SEC Decree, CAM Decree, Community bank decree, and people bank decree and insurance decree.

To further, give effect to its resolve to rid the financial institutions of fraud, the government constituted the national committee on malpractice in bank and other financial institutions in 1990. The committee after deliberation recommended the promulgation of a special law on fraud and malpractice’s in banks.

What is left is to legislate appropriate so that the incidence of fraud and other malpractice’s would be curtailed in the financial system. Again the federal government puts in place necessary infrastructure that will ensure that incidence of fraud in commercial banks is abated. It is for this and many other reasons that we have the CBN, NDIC, SEC, police and judiciary.

These agencies in their own various activities have been preventing and controlling fraud. On the enforcement of the various legislation to curb fraud in the banks, we have the ministry of justice, police and the judiciary. It will suffice to add that what is required mainly from the judiciary is prompt, fair and evenly handed justice.



The subject of fraud in the commercial banks is of special concern to the monetary and supervisory authorities particularly the CBN and NDIC

These government agencies are concerned about the safety of individual institutions and the soundness of the banking system. Most especially the NDIC is specifically charged with the responsibility protection depositors.

With reference the section 32 of the NDIC decree no 22 of 1981 any incensed bank or such other financial institution which ensure its deposit with the corporation shall be required to provide fidelity bond coverage. The fidelity insurance policy covers fraud and forgeries committed by bank’s staff. The insurance policy is intended to reduce the adverse effects of insider fraud and forgeries on the banks. In this way, therefore all insured banks are expected to take up the fidelity insurance cover and renew some on annual basis. The required minimum insurance coverage for each bank has been put at15% of its paid-up capital as at the preceding year. From the beginning of 1997, it was apparent that banks were unenthusiastic about complying with this requirement especially as regards renewal of the policy. As a result of this observed apathy on the part of the banks, reminder letters were sent to them to renew the policies. In addition those banks which failed to take the policy last year (1996) were warned about the consequences of such deliberate vidation of the provisions of NDIC decree. The warning not with standing, some commercial banks especially the distressed ones did not comply with the directives during the year. and for some that complied the coverage was not adequate.

Table 2.4 commercial banks compliance with fidelity insurance requirement.

No of banks in operation No of banks that complied Percentage compliance
1996 1997 1996 1997 1996 1997
64 64 50 36 78.1 56.3


Source; bank returns (NDIC annual reports various issues). Table 2.4 reports the number of commercial banks that complied with the insurance requirement in 1997 compared to 1996.

It shows that as at the end of December 1997, only 36 insured commercial banks representing 56.3% (percent) of the insured commercial banks complied with the provision of the NDIC decree as regards fidelity insurance coverage. This was less than the level attained in 1996 when a total of 50 insured commercial banks complied with the requirement.

A further analysis of the returns shows that not all the 36 insured commercial banks that complied were adequately covered.

Table 2.5 below shows the number of commercial banks with adequate coverage during 1997 relative to 1996.

Table 2.5


No of commercial bank

That complied

No of commercial banks with adequate coverage % of total that are adequately covered
1996 1997 1996 1997 1996 1997
50 36 38 26 59.4 40.6


Source; Banks Returns (NDIC Annual report various issues).

As shown in table 2.5 above only 26 insured commercial banks representing 40.6 percent had adequate cover in 1997 as compared to 59.4 percent in 1996.

Again, when referred to section 39 and 40 of the NDIC Decree no 22 of 1988 placed on the insured banks in the country, the responsibility of the theft accruing during such months, not notifying the corporation of any staff dismissed, terminated, or advice to retire on grounds of frauds. This no doubt aimed at preventing and controlling fraud in banks.

In addition, the prudential regulations of banks by the CBN/NDIC are in the prudential guidelines for licensed banks that all banks should review their credit portfolio quarterly would help early detection of any act of frauds, forgeries, financial malpratices relating to loans and advances granted under suspicions circumstances.

The CBN/NDIC examiners supervise banks not only to ensure that they are healthy but also to prevent and detect fraud. In this respect, the agencies have powers to deal with members of banks board and management who are found to have been engaged in financial malpractice or have condoned such offenses of authoring staff NDIC.

Furthermore, it was noted that the managing director NDIC in his outing on sonny labor live on A.I.T could not satisfactionly answer questions like.

  • Why no commercials bank is free of swindle and criminal deception?
  • Why most commercial banks have not fared inspire of all insurance and effects to eliminate or abate fraud?
  • Why the banking industry has gone into a tailspin because or ravaging incidence of fraud in the industry and the erosion of confidence inspire of the NDIC. CBN’S aggressive and expensive publicity campaign?
  • Why all the statutes and infrastructures in place by the federal government to curtail fraud and malpractice in commercial banks has failed to legislate appropriately?

Thus, we can conclude the through the CBN NDIC are making a lot of impact, but a lot is still needed from them.


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