Subject transferred funds to Iyabo Logistics Ltd across 10 transactions over six days, each individually below the ₦5,000,000 CTR threshold. Combined aggregate of ₦47,200,000. Subject is PEP class 3 with overdue CDD. Structuring pattern confirmed by AML-S04 with 96% confidence.
Chukwuma O. Eze submitted 10 separate settlement payment instructions against Bills for Collection instrument BFC-2026-0019 (filtering machinery, HS 8421.39) totalling ₦47,500,000, each ranging between ₦4,250,000 and ₦4,950,000 — consistently below the ₦5,000,000 CBN trade payment reporting threshold. The pattern is consistent with TBML payment structuring on trade instruments. The named freight forwarder, Iyabo Logistics Ltd (South Africa), is absent from the CBN approved freight forwarder register. No verifiable vessel IMO appears in the document set, consistent with a phantom shipment scenario. The subject is classified PEP class 3 with a CDD review overdue by 9 days. CAC records for Iyabo Logistics show a director discrepancy against BVN-linked account holders. Combined indicators meet the threshold for STR filing to NFIU.