WHY LEGAL DUE DILIGENCE IS THE WEAKEST LINK IN SIERRA
LEONE’S BANKING COMPLIANCE CHAIN
By Abdulai Janneh Esq. Barrister & Solicitor of the High Court of Sierra Leone | Corporate Legal
Practitioner | Banker | Business Consultant.
1. INTRODUCTION: THE HIDDEN RISKS BEHIND THE FORMS
Imagine a newly registered real estate and property development company walks into a bank in Freetown, led by a young man who introduces himself as the managing director. His documents are pristine: certificate of incorporation, tax identification, board resolution, utility bill, and two ID cards. Within seven working days, the bank opens the account. Months later, the bank is
contacted by financial intelligence officers in Ghana: the account has been used to funnel over $400,000 across borders. Digging deeper, the real owner of the company is traced to a senior government official’s brother - a politically exposed person (PEP) who deliberately hid behind proxy names to avoid detection. The bank now faces scrutiny for failing to flag the risk. We call this “the politically connected ghost owner”.