Assessing vulnerabilities associated with religious bodies; a financial Intelligence perspective

In recent times, the concept of subjecting religious organisations to reasoning has raised concerns particularly regarding financial activities. Financial institutions, regulators and security agencies are increasingly focusing their attention on the financial activities of religious organisations as they continue to be exploited by criminals due to their high cash volumes, social trust and promises of anonymity. Religious bodies may be misused by criminals as convenient platforms to legitimise illicit proceeds of crime. In another development, members may be coerced by religious leaders to donate monies to fund their lavish lifestyle; including purchasing luxury mansions, travel expenses, luxury cars among others.

Below are some products that present financial intelligence concerns;

Offertory /Tithes/Seed sowing

These are some common methods where religious bodies unknowingly introduce illicit cash received through cash into the financial system. The high volume of cash given through offertory, tithing and sowing of seeds provide ideal cover for criminals to co-mingle illicit cash with legitimate funds from members. The issue regarding tithing often hinges on whether it is considered as a religious command or manipulative scheme by some religious leaders. An interesting dimension of this discussion is whether members who establish their faith in giving tithes even do it right. Some critics have argued that paying less than the exact percentage on income is an act of stealing. For instance, Mr A is a Christian who receives GH¢ 50,000 as monthly income, he is expected to pay GH¢ 5,000 as 10 per cent but he decides to pay GH¢ 500 to the church every month.  Mr A is being dishonest about his payment of tithe and therefore,  this act is considered as stealing. The question is, how many Christians genuinely comply with this command? There is yet another group of Christians who argue that percentages should not apply to tithing but rather encourage members with sermons like ‘the more you give, the more you receive’. These sermons have encouraged vulnerable members to donate all their incomes and later live in hardships. Religious leaders should not use manipulative words to compel members to sow seeds against their will. The act of giving should be viewed as a personal choice based on one’s belief. That notwithstanding, the act becomes questionable where religious leaders call out significant amounts in fundraising in exchange of receiving blessings which puts unnecessary pressure on members to ‘sow seeds. 

End of year harvest

Contrary to the practice by some religious bodies, end of year harvest is a time to establish one’s faith in God and to show appreciation for all the income they received throughout the year. Religious bodies call out several amounts of money of which members are expected to pay upfront or make pledges beyond their means. Sometimes, members raise their hands and make several pledges to impress religious leaders and the congregation. Some religious bodies receive significant amounts of funds from politicians during this time without identifying the source of funds.

Special offering

Special offerings, particularly those involving high-value present significant money laundering risks because they can be exploited by criminals to move illicit funds into the legitimate financial system. Special donations allow individuals to deposit significant amounts of money into the accounts of religious bodies under the guise of religious donations. Once the funds enter into the financial system, these criminals would then contact the religious leaders to issue clean cheques in the name of the religious organisation (making the tainted funds to appear clean).

Sale of items as a symbol of faith

Paraphernalia sold as symbols of faith include all kinds of oil, water, stickers of religious leaders, handkerchiefs, drinks, herbal products, soap, creams, headgear, t-shirts among others. The sale of these items has been criticised by some key persons within the religious space as a ‘scam of faith’. It is believed that comingling the sale of items with religion transforms faith into business transaction, which impacts negatively on vulnerable believers. Some of these items are even sold at exorbitant prices for the personal enrichment of religious leaders, displacing those members who are unable to afford and making those with financial muscles to have access to religious leaders. This practice suggests that one can only be blessed if he/she purchases and use these items, thereby challenging their faith of freely receiving blessings from God.

Gifts to religious leaders

Monies disguised as personal gifts or donations to religious leaders may be proceeds of crime. Religious leaders have an obligation to ask questions and to identify the sources of significant amounts or luxury items given as donations. Some criminals may use this channel to gain access to religious leaders and therefore put them at risk.

Loan facilities

Some members may have several arrangements with religious bodies to be giving out loans. Some of these loans (which may usually be in cash) are to encourage the placement of proceeds of crime through the financial system. When cash is given as loans to the religious body by criminals (also members) they end up requesting for repayments to be made in the form of cheques or other financial instruments, conveniently disguising the illicit source of funds.

Donations/anonymous transfers

Religious bodies including churches and mosques often receive donations from persons who may want to remain anonymous or persons who may want to use the accounts of religious bodies to receive huge funds from unrelated third-parties largely based on the limited oversight by financial institutions. Most of these criminals making such donations may enter into several percentage sharing agreements with these religious bodies in order to conveniently move illicit proceeds of funds without detection.

Misuse of funds and abuse of members by religious leaders

Religious leaders may be using funds intended for religious activities for their personal gains without the knowledge of the congregation. Members of religious bodies may be used to engage in the construction of religious projects or serve in the homes of religious leaders without payments under the guise of religious work (free service). This act is contrary to the provision of some doctrines which command employers to pay workers promptly, particularly focusing on the poor and needy (eg. James 5:4, Leviticus 19:13, Deuteronomy 24:14-15, Surah At-Talaq 65:6, Surah Ash-Shu’ara 26:183, Surah Al-Mutaffifin 83:1-3, dharma and rajdharma, karma, Brhaspati, Bava Metzia 110b-111b)

Anti-money laundering obligations of religious bodies

• Understand the money laundering risk in raising and use of funds.
• Identify and assess the religious body’s vulnerability to be misused by criminals.
• Know Your Members (KYM); name, residence, place of work/profession etc,
• Conduct due diligence by verifying among others; the identity cards and sources of significant donations.
• Identify donors of large donations.
• Encourage cashless payment systems to support audit trail of all donations.
• Maintain financial records of members who donate significant amounts to the religious body.
• Monitor for unusual transactions and report members suspected to be engaged in fraud and financial crimes.
• Follow and monitor the activities of politically exposed persons (politicians, their spouses, children and close associates) and report any suspicious donations.
• Show commitment in the fight against financial crime by collaborating with law enforcement agencies, competent authorities and other relevant actors.

The Writer is a Financial Crime Specialist

BY RITA YEBOAH QUAYSON

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