--- title: "Nigeria (NG) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/nigeria/ source_html: /jurisdictions/nigeria/index.html description: "Financial integrity intelligence for Nigeria (NG): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 02283080ad18cb78dffc83b5ebdc0e1d24b0e68d7441b40f291bc4dfb64d078f generator: "fe-fleet/md-twin@1.0" --- # Nigeria (NG) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Nigeria NG Domains covered 8 of 8 Sources 151 Role actions 8 Horizon <90d 4 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Decreasing Enablement vs enforcement: Mixed Nigeria's AML/CFT/CPF regime rests on the Money Laundering (Prohibition) Act 2011 (as amended), NFIU Act 2018, Terrorism Prevention Act, and CAMA 2020 BO framework, supervised by CBN, SEC and NAICOM with EFCC/NFIU as lead enforcement/FIU bodies. More Nigeria exited the FATF grey list in October 2025 after a February 2023-2025 action plan, but GIABA follow-up reviews still flag technical gaps, especially in free-zone beneficial ownership transparency and targeted financial sanctions for proliferation financing. Key deficiencies - Beneficial ownership registers for free-zone entities (NEPZA/OGFZA) are not publicly available and lack verification requirements - No legal framework for targeted financial sanctions (TFS) concerning proliferation financing - Low volume of stand-alone money-laundering investigations/prosecutions relative to Nigeria's risk profile; LEAs focus on predicate offences - Limited NFIU strategic analysis of terrorist-financing STRs, disproportionate to Boko Haram/ISWAP TF risk - Cybercrime/BEC/crypto-fraud scale (industrial-scale Ponzi and romance scams) outstrips supervisory and prosecutorial capacity Recent developments (18m) - FATF removed Nigeria from the 'grey list' (Jurisdictions under Increased Monitoring) at its 24 October 2025 Plenary - European Commission delisted Nigeria from the EU high-risk third-country AML list via Delegated Regulation (EU) 2026/83, adopted 4 December 2025 - UK's revised MLR 2024 definition ties HRTC status directly to live FATF lists, automatically dropping Nigeria as a UK high-risk third country following the October 2025 FATF delisting - Nigeria invited to participate under its own flag in the FATF-Style Regional Body Guest Initiative, announced at the June 2026 FATF Plenary - Nigeria enacted the Investment and Securities Act 2025, bringing crypto-assets under SEC licensing as securities and creating the SEC VASP/ARIP registration pathway - EFCC's 'Eagle Flush Operation' dismantled a 792-person crypto/romance-scam network and prosecuted 53 defendants beginning early 2025 - Former Minister of Power Saleh Mamman sentenced in absentia to 75 years for money laundering and corruption linked to hydropower project graft (May 2026) Brief ## Lead signal #### Lead Signal Nigeria's payments regulator has moved from standing-tracker monitoring to active rule-making in a way that bridges beneficial-ownership transparency with payments-market structure. A Central Bank of Nigeria circular (PSS/DIR/PUB/CIR/001/004, dated 15 June 2026) requires payment companies to disclose Ultimate Beneficial Owners as part of a wider market-structure compliance exercise due by 31 December 2026, with a related payment-data localisation obligation following on 1 January 2027. Two independent secondary legal and press analyses corroborate the circular's content and deadlines, though the Central Bank's own circular text was not directly retrieved this cycle, so the finding is rendered as probable rather than confirmed. The structural significance is that a sectoral payments regulator, rather than the corporate registry, is now the vehicle imposing a UBO-disclosure deadline on a defined population of obliged firms, layering a new compliance clock onto a beneficial-ownership landscape that already runs on three separate registers. Read full brief #### Lead Signal Nigeria's payments regulator has moved from standing-tracker monitoring to active rule-making in a way that bridges beneficial-ownership transparency with payments-market structure. A Central Bank of Nigeria circular (PSS/DIR/PUB/CIR/001/004, dated 15 June 2026) requires payment companies to disclose Ultimate Beneficial Owners as part of a wider market-structure compliance exercise due by 31 December 2026, with a related payment-data localisation obligation following on 1 January 2027. Two independent secondary legal and press analyses corroborate the circular's content and deadlines, though the Central Bank's own circular text was not directly retrieved this cycle, so the finding is rendered as probable rather than confirmed. The structural significance is that a sectoral payments regulator, rather than the corporate registry, is now the vehicle imposing a UBO-disclosure deadline on a defined population of obliged firms, layering a new compliance clock onto a beneficial-ownership landscape that already runs on three separate registers. That fragmentation is itself a standing feature rather than a new finding: Nigeria's Corporate Affairs Commission, the free-zone authority NEPZA, and the extractives-sector body NEITI each hold their own beneficial-ownership data under different institutional frameworks, and calls for harmonisation reported in mid-September 2026 remain unresolved. The payments circular does not harmonise these registers; it adds a fourth disclosure point specific to payment institutions, which raises the practical question of whether UBO data filed under the new circular will reconcile with, duplicate, or diverge from what the same corporate groups have already filed with the Corporate Affairs Commission. #### Other Developments A virtual-asset coordination structure gains institutional shape. A July 2026 Executive Order establishes a Central-Bank-chaired Virtual Asset Council intended to coordinate oversight between the Securities and Exchange Commission, which retains responsibility for securities-characterised virtual assets, and the Central Bank, which takes payment, settlement and custody oversight of non-security virtual assets. Section 79 of the Order directs the eventual designation of a single federal agency with primary responsibility for virtual-asset regulation generally. This remains an uncertain-confidence finding resting on a single secondary law-firm source; the underlying Central Bank and Securities and Exchange Commission gazette text was not retrieved this cycle, so the architecture should be read as a coordination framework taking shape rather than a settled allocation of supervisory authority. Flutterwave's acquisition of Mono widens the deposit-taking perimeter. Flutterwave's acquisition of open-banking firm Mono, announced in April 2026 and reported in trade press on 28 October 2026, delivered Flutterwave a national microfinance banking licence. That licence converts Flutterwave, for at least part of its group structure, into a deposit-taking entity, which in turn brings it within beneficial-ownership and anti-money-laundering registration duties that apply to banks rather than to payment companies alone. This is a probable-confidence finding based on trade-press reporting; no Central Bank licence-register confirmation was retrieved this cycle, so the precise scope of the newly regulated entity within the Flutterwave group is not yet independently verified. Nigeria's standing exit from increased monitoring continues to hold. Nigeria remains off the Financial Action Task Force's increased-monitoring list following its removal on 24 October 2025, a confirmed-tier finding resting on the Task Force's own publication. Nigeria's Economic and Financial Crimes Commission and Financial Intelligence Unit conducted a stocktake in the days before this cycle's window opened, explicitly framed as preparation for a 2027 mutual evaluation. No new sanctions-architecture, enabler-jurisdiction, conflict-finance or compliance-technology movement specific to Nigeria was located this cycle. #### Cross-Monitor Connections The payments circular's data-localisation limb, which requires payment-transaction data generated in Nigeria to be stored and managed within the country from 1 January 2027, sits directly on the boundary between financial-integrity oversight and data-protection regulation, since the same circular references Nigeria's data-protection statute as the applicable standard for that storage obligation. The virtual-asset coordination structure, by creating a Central-Bank/Securities-Commission joint oversight arrangement, is also a natural reference point for monitors tracking financial-innovation and digital-asset-infrastructure questions more broadly, though this brief does not itself extend into that adjacent analysis. #### Outlook The period running into 31 December 2026 and 1 January 2027 is the operative test window: payment companies face a compressed timeline to meet UBO-disclosure and market-structure requirements, followed almost immediately by the data-localisation deadline. Whether the Central Bank treats the UBO-disclosure limb as a hard compliance gate or allows a phased grace period is not yet evidenced and should be watched directly against the regulator's own published guidance as it becomes available. The virtual-asset coordination framework's progress toward naming a single lead agency under its Section 79 direction is a second marker worth tracking, since it will determine which authority becomes the primary point of contact for virtual-asset obliged entities going forward. Separately, the approach of the 2027 mutual evaluation gives the current stocktake activity a fixed external deadline against which Nigeria's post-delisting reforms will be tested, and any further stocktake or preparatory publication from the Economic and Financial Crimes Commission or Financial Intelligence Unit would be the next evidentiary marker in that trajectory. Earlier periodic briefs (5) 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Nigeria's regulatory perimeter around payments and digital assets continues to widen, with the Central Bank of Nigeria's Circular PSS/DIR/PUB/CIR/001/004 the clearest marker of this trajectory. Secondary analysis of the circular describes a package of mandatory data localisation, ultimate beneficial ownership disclosure, and enhanced systemic oversight requirements applying to payment institutions, with market-structure and UBO-disclosure compliance due by 31 December 2026 and data-localisation obligations following on 1 January 2027. The circular itself was not retrieved directly; the finding rests on two independent secondary analyses of a named primary instrument rather than on the Central Bank's own text, so the obligation is probable rather than confirmed pending sight of the primary circular. Alongside this, a Virtual Assets Coordination Executive Order reported to have taken effect from July 2026 establishes a Central Bank-chaired Virtual Asset Council intended to coordinate oversight between the Central Bank and the Securities and Exchange Commission, with a provision directing the designation of a federal agency holding primary responsibility for regulating all forms of virtual assets. This finding rests on a single secondary legal-commentary source, with the underlying gazette text not yet retrieved, and is accordingly held at an uncertain tier. #### Other Developments A beneficial-ownership disclosure duty layered onto an already fragmented register landscape. The new payment-circular disclosure requirement arrives in a context where Nigeria is reported to operate three separate beneficial-ownership transparency registers under different institutional frameworks, a structural feature of the corporate-transparency landscape that predates and continues unchanged. The circular's UBO-disclosure limb therefore adds a sector-specific duty on top of an already multi-register architecture, rather than resolving it. Commercial consolidation intersecting with the regulatory perimeter. A Nigerian payments company is reported to have secured a national microfinance banking licence through its acquisition of an open-banking startup, a transaction that sits at the intersection of commercial activity and prudential licensing. The acquisition was reported by established trade press but has not been independently confirmed against a Central Bank licence register, so the finding is treated as probable. #### Cross-Monitor Connections The payments-circular build-out and the virtual-asset coordination order both touch ground that a payments-focused monitor would track from the licensing and market-access side, while the beneficial-ownership and UBO-disclosure dimension connects most directly to work on conflict finance and extractive-industry integrity exposure, where opaque corporate ownership structures are a recurring facilitation vector. The Flutterwave-Mono transaction, read through a banking-structure lens, is also a potential input to any work tracking embedded-banking and licence-acquisition routes into regulated activity, since a licence obtained via acquisition rather than direct application changes the supervisory history attached to the resulting entity. #### Outlook The compliance deadlines attached to the payments circular — 31 December 2026 for market-structure and UBO-disclosure requirements, and 1 January 2027 for data localisation — fall due in the near term, and the industry-wide readiness picture for the UBO-disclosure limb specifically is not independently verified as. Separately, Nigeria's anti-money-laundering authorities have reportedly begun a stocktake ahead of a Financial Action Task Force mutual evaluation expected in 2027, which will test whether the reforms that supported Nigeria's removal from increased monitoring in October 2025 have been sustained in practice rather than only on paper. Confirmation of both the payments circular's primary text and the virtual-asset executive order's gazette language would materially firm up the confidence attached to each of these developments. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Nigeria's Corporate Affairs Commission (CAC) has struck off more than 500,000 entities from the national beneficial-ownership register for failing to update required information, a move reported on 8 October 2026 that represents the largest single cleanup action taken against the register since its establishment. The action is paired with a CAC call for harmonising Nigeria's three parallel beneficial-ownership registers, maintained respectively by CAC, the Nigeria Export Processing Zones Authority (NEPZA) and the Nigeria Extractive Industries Transparency Initiative (NEITI). The scale of the strike-off, applied against a backdrop of continued post-grey-list reform, signals that Nigeria's transparency authorities are treating register accuracy as an enforcement priority in its own right, not merely an administrative housekeeping exercise. A register fragmented across three independent custodians creates structural opacity even where disclosure obligations are nominally in force, since a beneficial owner can appear compliant on one register while absent from another; CAC's harmonisation call is therefore a structural signal as significant as the strike-off itself. #### Other Developments NFIU and GIABA capacity-building ahead of a mock Mutual Evaluation. Nigeria's Financial Intelligence Unit, working with the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA), trained 100 officials between 12 and 16 October 2026 in preparation for a national Mock Mutual Evaluation Exercise scheduled for November 2026. This continues the reform trajectory that saw Nigeria exit the FATF grey list on 24 October 2025 after completing a nineteen-point action plan, and positions the country ahead of its anticipated third-round FATF Mutual Evaluation. The training of Mutual Evaluation Working Groups specifically, rather than general AML staff, indicates Nigeria is preparing to defend its technical-compliance and effectiveness ratings proactively rather than reactively. Payments-circular beneficial-ownership disclosure requirement. A Central Bank of Nigeria payments-system circular (PSS/DIR/PUB/CIR/001/004) is reported to require all deposit money banks, payment service providers and other financial institutions with digital-payment footprints to disclose the ultimate beneficial ownership of significant shareholders. This obligation sits alongside the circular's data-localisation and market-structure provisions and extends beneficial-ownership transparency expectations into the financial-sector regulatory perimeter directly, complementing the CAC's corporate-registry-level enforcement. #### Cross-Monitor Connections The CBN payments circular's beneficial-ownership and data-localisation provisions connect directly to payments-sector market-structure and infrastructure developments tracked separately in the payments domain, where the same circular's data-localisation deadline and market-share caps are the subject of industry compliance planning. The circular's layering of beneficial-ownership disclosure onto payment institutions illustrates how financial-integrity and payments-regulation tracks are converging on the same instrument from different angles: one reading is a transparency requirement, the other a market-structure and operational-resilience requirement, but both originate in the same CBN text that has not yet been independently retrieved by either track. #### Outlook The next concrete marker is the November 2026 mock Mutual Evaluation Exercise, which will give an early indication of how Nigeria's post-grey-list reforms are likely to be assessed when the real third-round Mutual Evaluation follows. On beneficial ownership, the test will be whether CAC's harmonisation call for the three parallel registers produces a concrete legislative or administrative proposal, or remains an aspirational statement; a continued fragmentation across CAC, NEPZA and NEITI registers would leave a structural gap even as individual-register enforcement intensifies. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Nigeria's financial-integrity posture this cycle is defined by procedural strengthening rather than structural regime change. The Corporate Affairs Commission struck off more than 500,000 entities from Nigeria's Beneficial Ownership Register for failing to update beneficial-owner information, a mass enforcement action reported on 8 October 2026 that sits alongside CAC's continued push to harmonise three parallel beneficial-ownership registers, held respectively by CAC, the Nigeria Export Processing Zones Authority and the Nigeria Extractive Industries Transparency Initiative, into a single linked database. CAC states the current fragmentation across these three registers creates potential blind spots for illicit-flow detection, and frames the proposed unified database as a multi-year undertaking rather than a near-term fix. #### Other Developments Capacity-building ahead of the 2027 Mutual Evaluation. The Nigerian Financial Intelligence Unit trained 100 officials nearly a year after Nigeria's October 2025 FATF grey-list exit, with NFIU Chief Executive Officer Hafsat Bakari stating that Nigeria must demonstrate its AML/CFT laws and institutions deliver results, not merely exist on paper, as the country prepares for a full FATF Mutual Evaluation expected in 2027. Standing regime unchanged. Nigeria's AML/CFT architecture continues to rest on the Money Laundering (Prevention and Prohibition) Act 2022 and the Terrorism (Prevention and Prohibition) Act 2022, with the NFIU, housed within the Central Bank of Nigeria, acting as financial intelligence unit and the Economic and Financial Crimes Commission as lead enforcement agency. Nigeria was removed from the FATF grey list on 24 October 2025 after achieving Compliant or Largely Compliant status on 37 of the 40 FATF Recommendations, and that delisted status has not changed this cycle. #### Cross-Monitor Connections The Corporate Affairs Commission's beneficial-ownership enforcement and database-harmonisation push intersects directly with Nigeria's data-protection and corporate-transparency posture, a connection the advennt and data-protection monitors are better placed to develop in relation to the handling of beneficial-owner personal data across CAC, NEPZA and NEITI registers. No crypto-specific or world-payments-specific overlap was identified in this cycle's Nigeria financial-integrity signal. #### Outlook The 2027 FATF Mutual Evaluation is the clearest structural milestone on Nigeria's horizon: unlike the lighter increased-monitoring follow-up Nigeria exited in October 2025, a full mutual evaluation scrutinises institutional effectiveness as well as the legal framework on paper, and NFIU's current capacity-building activity should be read as direct preparation for that test. On beneficial ownership, CAC's proposed unified database spanning corporate, free-trade-zone and extractives registers remains a multi-year proposal without a confirmed implementation date, meaning the near-term signal to watch is less the database itself than whether CAC continues the pattern of active strike-off enforcement against non-compliant entities evidenced this cycle. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Nigeria's financial-crime architecture is being read this cycle through two converging signals: a sustained institutional effort to consolidate the gains that took Nigeria off the FATF grey list in October 2025, and a continuing structural firming of the crypto and digital-asset perimeter. The Economic and Financial Crimes Commission and the Nigerian Financial Intelligence Unit conducted a joint three-day stocktake across 29 September to 2 October 2026, reviewing the use of financial intelligence, asset recovery, money-laundering investigation and prosecution, and inter-agency cooperation, explicitly framed as preparation for Nigeria's 2027 FATF Mutual Evaluation. This is an architecture-over-incident finding: no single enforcement action drives this signal, but a coordinated institutional posture one year after delisting, confirming that Nigeria treats grey-list exit as a floor to be defended rather than a result to be banked. Alongside AML/CTF institutional readiness, the Presidential Executive Order on Virtual Assets Coordination, signed 17 July 2026, continues to reshape how Nigeria allocates regulatory authority over digital assets. The Order establishes a Virtual Asset Council chaired by the Central Bank of Nigeria, with the Securities and Exchange Commission and the Nigeria Revenue Service as vice-chairs, intended to coordinate rather than displace existing SEC and CBN mandates while directing work on a regulatory sandbox and a virtual-asset tax policy. Read together, the AML stocktake and the coordination order describe a jurisdiction actively building institutional capacity across both its conventional and its digital-asset financial-integrity perimeters. #### Other Developments National-tier fintech licensing consolidation. The Central Bank of Nigeria upgraded OPay, Moniepoint Microfinance Bank, Kuda Bank, PalmPay and Paga from regional or state licences to national microfinance-bank and fintech status, reported in late January 2026 alongside a cited NGN5 billion capital threshold for national microfinance banks. This is a commercial-activity development with financial-integrity relevance: national-tier status expands these firms' permissible footprint and correspondingly broadens the population of large-scale payment processors operating under heightened prudential thresholds. Stablecoin distribution into African commercial corridors. Busha Business, the Nigeria-domiciled business arm of Busha, partnered with Tether on 20 July 2026 to distribute USDT to African businesses. No commercial terms or deal value were disclosed. The partnership sits at the intersection of commercial activity and digital-asset integrity, extending dollar-stablecoin distribution rails through a Nigerian intermediary into a wider regional market. SEC digital-asset capital-raising consultation. The Securities and Exchange Commission's Agent Registration and Investor Protection programme had admitted eleven cumulative firms by early July 2026, while separately the SEC's proposed rules on digital and virtual asset operations, custody and markets remained under consultation. These are not treated here as a new finding beyond their coordination-order context, but they corroborate a crypto perimeter that is firming rather than static. #### Cross-Monitor Connections The Virtual Asset Council's establishment and the SEC's proposed digital-asset rules sit squarely at the boundary between financial-integrity typology and the crypto regulatory monitor: the same Executive Order that is read here as an AML/CTF-adjacent coordination mechanism is read on the crypto side as a licensing and capital-threshold development. The Busha Business-Tether partnership similarly carries a commercial-activity reading here and a stablecoin-distribution reading on the crypto side; both readings rest on the same underlying fact and should be read as complementary rather than duplicative. No conflict-finance, enabler-jurisdiction or sanctions-architecture connections were identified this cycle for Nigeria. #### Outlook The EFCC/NFIU stocktake is a leading indicator for the 2027 Mutual Evaluation cycle rather than a terminal event: continued institutional stocktaking of this kind, sustained through 2026 and into 2027, would be consistent with Nigeria defending its October 2025 delisting. On the digital-asset side, the Virtual Asset Council's coordination mandate and the SEC's proposed capital and consultation rules remain to be tested in practice; whether the Council meaningfully resolves prior SEC/CBN jurisdictional ambiguity, or merely adds a further coordination layer, is not yet resolved by the material available this cycle. Continued expansion of national-tier fintech licensing and stablecoin-distribution partnerships should be read as consistent with, rather than a departure from, the broader direction of structural consolidation described above. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Nigeria's financial-integrity posture continues to consolidate through 2026, anchored by the sustained exit from the FATF grey list. Nigeria was removed from the list at the 24 October 2025 plenary after completing a 19-point action plan, and as of the 19 June 2026 plenary it remained off the 22-jurisdiction list, with the next plenary scheduled for October 2026. This durability, rather than the delisting event itself, is this cycle's lead signal: a jurisdiction sustaining grey-list-free status across three plenaries is qualitatively different from one newly delisted, and it is being reinforced by a cluster of architecture-level measures rather than a single headline enforcement action. The Central Bank of Nigeria's 15 June 2026 circular mandating ultimate-beneficial-ownership disclosure for banks, payment service banks, mobile-money operators, switches and super-agents is the clearest structural follow-through: it closes a sector-specific transparency gap of exactly the kind FATF's prior listing had flagged, requiring continuously updated ownership records rather than a one-time disclosure. #### Other Developments Virtual asset coordination architecture advanced materially with the Presidential Executive Order on Virtual Assets Coordination, signed 17 July 2026, which establishes a Virtual Asset Council to coordinate the Securities and Exchange Commission, the Central Bank of Nigeria and other authorities' overlapping mandates over crypto activity. This is a coordination mechanism rather than a new substantive rulebook, aimed at a regulatory landscape that had previously exposed Nigerians to losses from unchecked, unregulated operators. Real-time transaction-monitoring mandate for Nigerian fintechs entered force in 2026 with an audit-backed enforcement rollout timeline, though this remains an uncertain-confidence development: a documented gap exists between the supervisory expectation of real-time AI/ML-capable monitoring and the industry's current monitoring maturity, meaning the mandate's practical enforcement bite is not yet settled. Corporate and executive prosecutions by the Economic and Financial Crimes Commission continued through 2026, with at least ten corporate entities, including Cresco Oil and Gas Ltd and Abu-Haneefa Oil and Gas Ltd, facing fraud and money-laundering prosecutions totalling several billion naira. This reflects a discernible shift toward pursuing corporate entities and executives rather than politically exposed persons alone, and the EFCC's enforcement record is credited as a contributor to the sustained FATF delisting. Data localisation for payments is a further architecture-level measure: all financial institutions must store and manage Nigeria-originated payments transaction data within Nigeria, with compliance required by 31 December 2026. While framed primarily as a payments-sector policy, it has a direct surveillance-capacity dimension for domestic AML/CFT authorities. Virtual asset service providers remain designated financial institutions under the Money Laundering (Prevention and Prohibition) Act 2022, bringing them within SCUML and EFCC AML/CFT supervision as a standing regulatory-perimeter fact, not a new development, but one that continues to matter as crypto activity in Nigeria grows. #### Cross-Monitor Connections The Virtual Asset Council and the associated SEC and CBN rule-making sit squarely at the intersection of this monitor's D5 and D7 domains and the crypto monitor's licensing and stablecoin-regime coverage; the coordination architecture established by the Executive Order does not itself constitute a licensing or classification change, but it is the governance scaffold within which the crypto monitor's licensing_and stablecoin developments are proceeding. The CBN's data-localisation and UBO-disclosure circulars overlap directly with the world-payments monitor's industry-structure coverage of the same 15 June 2026 circular, where they are read as market-structure interventions; here they are read as beneficial-ownership and surveillance-architecture measures. Both readings trace to the same underlying regulatory action and should be read as complementary rather than duplicative. #### Outlook The next FATF plenary in October 2026 is the key date to watch: a third consecutive grey-list-free plenary outcome would further cement Nigeria's delisted status as durable rather than provisional. Beyond that, the practical test for the real-time transaction-monitoring mandate and the new UBO-disclosure regime will be whether documented supervisory expectations translate into audited compliance outcomes, given the gap already flagged between mandate and industry monitoring maturity. The Virtual Asset Council's coordination of SEC and CBN crypto mandates is worth tracking for whether it produces a consolidated rulebook or remains a coordination layer atop existing separate SEC and CBN powers. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Nigeria's Bureau de Change sector became the focal point of a rare convergence between unilateral and domestic sanctions architecture this cycle. On 22 June 2026 the US Treasury's Office of Foreign Assets Control designated a Lagos-based Bureau de Change operator, three allied firms, three individuals and six entities for financing ISWAP and ISIS-linked terrorist networks. Four days earlier, on 18 June 2026, Nigeria's own Sanctions Committee, NIGSAC, had designated six individuals and three BDC companies for financing the same ISWAP threat, following an earlier April 2026 list naming forty-eight individuals and twelve entities linked to ISWAP, Ansaru and IPOB. Continue reading The near-simultaneous timing and overlapping subject matter of these two actions is analytically more significant than either designation examined alone. Sanctions-architecture analysis typically emphasises points of divergence between unilateral US listings and the autonomous or domestic listing regimes of other jurisdictions; here, the opposite pattern holds. OFAC and NIGSAC appear to be targeting the same underlying BDC-centred terrorism-financing network, and the evidence supports reading this convergence as indicative of a durable, structural vulnerability in Nigeria's Bureau de Change sector rather than an isolated incident. This finding sits alongside, and is reinforced by, a separate enabler-layer disclosure this cycle in which Nigerian banks, fintechs and microfinance institutions were found to have failed know-your-customer and customer-due-diligence controls in a scheme enabling roughly 18.1 billion naira in laundering, a portion of which was converted to crypto assets. Read together, these two findings describe a Nigerian financial system in which both licensed Bureau de Change operators and mainstream regulated institutions have each, independently, been identified as conduits for illicit value movement within the same reporting period. No divergence between US and Nigerian sanctions treatment of this specific corridor was identified in the evidence reaching this cycle. The architecture-over-incident reading is that Nigeria's BDC sector, rather than any single sanctioned entity, is the structural node requiring sustained monitoring. #### Outlook The immediate question for the coming cycle is whether the convergence between OFAC and NIGSAC designations extends to further BDC entities beyond those already named, and whether Nigerian authorities pursue asset-freezing or prosecutorial follow-through domestically to match the US unilateral action. This is an illustrative orientation for monitoring purposes, not a prediction of specific regulatory action. Judgment: No NG-specific sanctions-architecture movement located this cycle. Uncertain #### Beneficial Ownership Nigeria's beneficial-ownership picture this cycle is defined by the arrival of a new, sector-specific disclosure deadline layered on top of a structurally fragmented register environment. A Central Bank of Nigeria circular on payments-market structure, numbered PSS/DIR/PUB/CIR/001/004 and dated 15 June 2026, requires payment companies to disclose their Ultimate Beneficial Owners, with full compliance against the wider market-structure requirements due by 31 December 2026. The finding rests on two independent secondary legal and press analyses that corroborate both the content and the deadline, though the Central Bank's own circular text was not directly retrieved this cycle; the resulting confidence is probable rather than confirmed, and the obligation itself is treated as in force pending the compliance date. Continue reading This sits against a standing backdrop in which Nigeria operates three separate beneficial-ownership transparency registers under different institutional frameworks: the Corporate Affairs Commission's register for companies generally, free-zone beneficial-ownership data held by the Nigeria Export Processing Zones Authority, and extractives-sector beneficial-ownership data held by the Nigeria Extractive Industries Transparency Initiative. A call for harmonisation across these frameworks, reported in mid-September 2026, remains unresolved as of this cycle. The payments circular does not harmonise these channels; it creates a fourth distinct UBO-disclosure point specific to payment institutions, sitting alongside rather than inside the existing registers. For a payment company that is also incorporated as a company under the Corporate Affairs Commission's regime, this means two separate UBO-disclosure obligations now run on different clocks, administered by different authorities, with no indicated mechanism for reconciling the two data sets. The structural read is that beneficial-ownership transparency in Nigeria is accreting sector by sector rather than consolidating into a single register, with the payments sector now the most recent addition. This is consistent with the broader characterisation of Nigeria's beneficial-ownership architecture as institutionally fragmented, and the new circular should be read as adding a compliance deadline onto that fragmentation rather than resolving it. #### Outlook The most immediate marker to watch is whether payment companies meet the 31 December 2026 deadline for UBO disclosure and market-structure compliance, and whether the Central Bank publishes any further guidance distinguishing the UBO-disclosure limb from the broader market-structure requirements bundled into the same circular. A second marker is whether the mid-September 2026 harmonisation call gains any institutional traction before year end, given that a fourth register-equivalent disclosure channel has now been added to an already fragmented landscape. Absent confirmation of the Central Bank's own primary circular text, both the precise disclosure thresholds and any enforcement posture behind the 31 December deadline remain to be independently verified. Judgment: CBN's payments circular adds a UBO-disclosure deadline (31 Dec 2026) on top of the existing fragmented CAC/NEPZA/NEITI BO-register landscape. Probable #### Enabler Jurisdictions and Professional Facilitators The enabler-layer finding this cycle sits inside Nigeria's own regulated financial sector rather than in an offshore or professional-services facilitator network. Nigeria's Economic and Financial Crimes Commission disclosed on 22 January 2026 that a new-generation bank, six fintech companies and several microfinance banks failed to meet know-your-customer and customer-due-diligence requirements, a control failure that enabled an estimated 18.1 billion naira to be laundered, with a material portion of the proceeds converted into crypto assets. Continue reading Read through the enabler-jurisdiction lens, this finding is significant less for its monetary quantum than for what it identifies structurally: a cluster of regulated, licensed institutions, spanning traditional banking, fintech and microfinance, sharing a common control-environment weakness at the customer-onboarding and ongoing-due-diligence stage. This is the domestic analogue of the professional-facilitator or enabler-jurisdiction pattern more commonly discussed in a cross-border context; here the enabling function is performed by regulated Nigerian financial institutions rather than by foreign company-formation agents or trust-and-corporate-service providers. The crypto-conversion element of the disclosed scheme also connects this finding to Nigeria's broader digital-asset governance picture. No indication of enforcement action, penalty, or remediation timeline against the named institution types was present in the evidence reaching this cycle; the EFCC disclosure describes the control failure itself rather than its regulatory consequence. #### Outlook Whether the Central Bank of Nigeria's broader 2026 payments and fintech rulebook, including its mandatory real-time transaction-monitoring requirement, directly addresses the specific KYC and CDD lapses described in the EFCC disclosure is the key connective question for the coming cycle; the evidence reaching this cycle does not establish that link explicitly. Judgment: No NG-specific enabler-jurisdiction movement located this cycle. Uncertain #### Conflict Finance and Extractive-Industry Integrity Two developments this cycle bear on Nigeria's conflict-finance and extractive-industry integrity picture, at markedly different scales. The smaller-scale but more legally concrete development is NIGSAC's 18 June 2026 designation of six individuals and three Bureau de Change companies for financing ISWAP, following an earlier April 2026 designation of forty-eight individuals and twelve entities linked to ISWAP, Ansaru and IPOB. This domestic terrorism-finance designation activity is addressed in full in this cycle's sanctions-architecture coverage; from a conflict-finance perspective, it confirms that non-state armed groups operating in Nigeria continue to draw on domestic financial-sector channels, with the Bureau de Change sector recurring as the identified conduit. Continue reading The far larger-scale development is the Nigerian Senate's ad-hoc Committee on Crude Oil Theft interim report, which found between 200 and 300 billion dollars in unaccounted crude-oil proceeds across the 2015 to 2023 period, including an 81 billion dollar discrepancy between the Nigerian National Petroleum Corporation and the Central Bank of Nigeria specifically for 2016 to 2017. The committee's findings are explicitly tied to suspended Petroleum Industry Act oversight functions as an enabling factor, alongside Operation Delta Safe's destruction of 101 illegal refineries in the first quarter of 2026. The scale of this figure, measured in the hundreds of billions of dollars against a designation action measured in a handful of entities, illustrates the core analytical imbalance this domain exists to correct: enforcement volume and reporting attention concentrate on discrete, nameable terrorism-finance designations, while a conflict-finance and extractive-integrity gap several orders of magnitude larger receives comparatively less operational follow-through in the evidence available. No indication of asset recovery, prosecutorial referral, or structural Petroleum Industry Act reform addressing the oversight gap was present in this cycle's research; the underlying forensic-audit document was not independently retrieved, with reporting resting on secondary coverage of the committee's hearings. #### Outlook Whether the Senate committee's interim findings translate into a published forensic-audit report, a restoration of Petroleum Industry Act oversight functions, or referral for prosecution or asset recovery is the central question for the coming cycle. Judgment: No NG-specific conflict-finance movement located this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Nigeria's virtual-asset oversight architecture gained a clearer institutional shape this cycle through a July 2026 Executive Order establishing a Virtual Asset Council chaired by the Central Bank of Nigeria. The Council is designed to coordinate between two regulators with previously separate and at times unclear jurisdictional lines: the Securities and Exchange Commission, which retains responsibility for virtual assets characterised as securities, and the Central Bank, which takes on payment, settlement and custody oversight for virtual assets that are not securities. Section 79 of the Order goes further, directing the eventual designation of a single federal agency to hold primary responsibility for regulating all forms of virtual assets, which would represent a further consolidation beyond the current coordination model. Continue reading This finding carries uncertain confidence. It rests on a single secondary law-firm source, and the underlying Central Bank and Securities and Exchange Commission gazette text establishing the Council's mandate was not directly retrieved this cycle. The coordination framework should therefore be read as an architecture that has been reported into existence by informed secondary commentary, rather than one that has been verified against the Order's own primary text. Secondary-source coverage of the Council continued through this cycle's window without the emergence of any new primary instrument, suggesting the framework remains at the implementation stage rather than having produced fresh rule-making of its own. The structural significance of a coordination council, as distinct from a single enforcement action, is that it reallocates supervisory responsibility across two existing regulators rather than creating a wholly new one. That is the kind of architectural development that matters more for how virtual-asset firms experience regulatory touchpoints in Nigeria going forward than any single compliance action would, because it determines which regulator a firm answers to for which category of asset, and it sets up the eventual single-agency designation under Section 79 as the next consolidation point to watch. #### Outlook The key forward marker is whether and when the federal government acts on Section 79's direction to designate a single lead agency for virtual-asset regulation, which would mark a shift from the current dual Central-Bank/Securities-Commission coordination model to a more consolidated supervisory structure. Until primary Central Bank or Securities and Exchange Commission text on the Council's operating mandate is retrieved and verified, the practical division of labour between the two regulators, and the degree to which the Council has begun operating in practice rather than existing only on paper, remain open questions for the digital-asset sector in Nigeria. Judgment: A July 2026 Virtual Asset Coordination Executive Order formalises a CBN-chaired Virtual Asset Council coordinating SEC/CBN oversight of virtual assets; secondary-source coverage continued this cycle without a new primary instrument. Uncertain #### Compliance Technology and Active Defence The Central Bank of Nigeria issued the most significant compliance-technology and payments market-structure intervention in Nigeria's regulatory history between March and June 2026. The package includes market-concentration caps preventing any institution exceeding twenty-five percent consumer-issuing market share from simultaneously holding more than fifteen percent merchant-acquiring share, with divestiture or restructuring required by 31 December 2026; revised cash-withdrawal caps; and, most directly relevant to compliance technology, a mandatory real-time transaction-monitoring requirement carrying potential fintech liability for authorised-push-payment fraud. The hard 31 December 2026 divestiture deadline is a concrete near-term test of both industry compliance capacity and Central Bank enforcement capacity. Continue reading Running in parallel, the Nigeria Data Protection Commission entered a materially more active enforcement phase in 2026, collecting approximately 7.2 billion naira and concluding more than 240 investigations with eleven major enforcement actions in its third 2026 enforcement phase, including an April 2026 investigation into an alleged data breach at Remita Payment Services and Sterling Bank. Although data-protection enforcement sits adjacent to rather than inside the AML/CTF compliance-technology perimeter proper, the near-simultaneous emergence of a mandatory real-time transaction-monitoring regime and an actively enforcing data-protection authority together describe a Nigerian compliance-technology environment moving, in this cycle, from largely advisory posture toward binding technical and governance obligations. No evidence reaching this cycle described the specific technical standards, vendor ecosystem, or supervisory-technology tools the Central Bank's real-time monitoring mandate will require regulated institutions to adopt; this remains an open implementation question. #### Outlook The 31 December 2026 divestiture deadline and the phased rollout of mandatory real-time transaction monitoring are the two concrete dates to track into the next cycle, alongside whether the Nigeria Data Protection Commission's Remita/Sterling Bank investigation concludes with a public enforcement outcome. Judgment: No NG-specific RegTech/compliance-technology development located this cycle. Uncertain #### AML/CTF Regime Nigeria's standing AML/CTF framework, anchored in the Money Laundering (Prevention and Prohibition) Act 2022 and the Terrorism (Prevention and Prohibition) Act 2022, alongside Central Bank of Nigeria and Nigerian Financial Intelligence Unit (NFIU) guidelines, is structurally unchanged this cycle. What is active is the preparatory work ahead of Nigeria's next formal assessment. The NFIU, working with the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA), trained 100 officials between 12 and 16 October 2026 ahead of a national Mock Mutual Evaluation Exercise scheduled for November 2026. The training specifically targeted Nigeria's Mutual Evaluation Working Groups, the bodies that will coordinate Nigeria's response to the forthcoming third-round FATF Mutual Evaluation, rather than frontline compliance staff generally. This is a continuation, not a new departure: Nigeria was removed from the FATF grey list on 24 October 2025 after completing a nineteen-point action plan to strengthen its anti-money-laundering framework, and the mock-evaluation exercise is the next structured step in consolidating that exit and preparing for renewed international scrutiny. Continue reading The practical significance of a mock evaluation exercise, as distinct from a real one, is that it allows Nigeria's authorities to identify effectiveness gaps, such as weaknesses in how well AML/CTF measures function in practice rather than merely how they are written into law, before those gaps are tested by FATF assessors directly. A jurisdiction that has exited the grey list on the strength of technical-compliance reforms (the nineteen-point action plan) faces a distinct, and often harder, test on effectiveness in a full Mutual Evaluation, and the choice to run a national mock exercise ahead of time suggests Nigeria's authorities are alert to that distinction. No new designation, sanctions action or AML enforcement case specific to Nigeria was identified this cycle; the signal here is preparatory and institutional rather than punitive. A note on structural context: the standing financial-sector beneficial-ownership and data-localisation obligations under the Central Bank of Nigeria's payments circular, while formally distinct from the Money Laundering Act framework, reinforce the same broader transparency and traceability objectives that AML/CTF effectiveness assessments test for, including whether financial institutions can readily identify beneficial owners and produce transaction records on request. #### Outlook The immediate marker to watch is the outcome of the November 2026 Mock Mutual Evaluation Exercise and whether it surfaces effectiveness gaps that Nigeria's authorities act on before the actual third-round FATF Mutual Evaluation. Given the proximity of the mock exercise to the real assessment, any gaps identified are likely to shape visible policy or supervisory-practice adjustments in the months that follow, which would be the next concrete development to track in this domain. Judgment: Nigeria remains off the FATF grey list following its October 2025 removal; EFCC/NFIU's late-September stocktake continues to frame preparation for the 2027 mutual evaluation. Probable #### Commercial Activity Flutterwave's acquisition of open-banking startup Mono is this cycle's clearest commercial-activity development with a direct financial-integrity read. The acquisition was announced in April 2026 and reported in trade press on 28 October 2026 as having delivered Flutterwave a national microfinance banking licence. That licence is the significant element: it converts Flutterwave, at least with respect to the licensed entity, from a payment company into a deposit-taking institution, which carries a materially different and generally more demanding set of beneficial-ownership and anti-money-laundering registration obligations than apply to payment companies alone. Continue reading The finding is probable rather than confirmed. It rests on trade-press reporting of the Flutterwave chief executive's own account of the transaction, and no Central Bank licence-register confirmation was retrieved this cycle to independently verify the licence's scope, the specific legal entity holding it, or whether the microfinance banking licence applies across Flutterwave's wider group structure or to a narrower subsidiary. The acquisition itself is reported as completed, with the transaction amount not disclosed. Read architecturally rather than as a single transaction, this is an example of a fintech group expanding its regulatory perimeter through acquisition of a licensed or licensable entity, rather than through direct application for a banking licence. That pattern is analytically significant because it means the beneficial-ownership and anti-money-laundering obligations that attach to deposit-taking status arrive bundled with whatever beneficial-ownership and governance structure Mono carried into the deal, and the combined entity's compliance posture now depends on how well those two structures are integrated rather than on a single clean build from the licence upward. #### Outlook The principal marker to watch is independent confirmation, through the Central Bank's own licence register or public filings, of the precise entity and scope covered by the newly acquired microfinance banking licence. A second marker is whether Flutterwave's beneficial-ownership and anti-money-laundering registration obligations as a deposit-taking entity are met on the same timeline as the sector-wide UBO-disclosure deadline that the Central Bank's payments circular has set for payment companies generally, since Flutterwave now sits at the intersection of both payment-company and deposit-taking obligation sets. Judgment: Flutterwave's acquisition of Mono to secure a national microfinance banking licence newly subjects the combined entity to deposit-taking AML/BO obligations. Probable Regulatory horizon In Force Pending 31 Dec 2026 · ±quarter ### CBN payments circular market-structure/UBO-disclosure compliance deadline Full compliance with market-structure requirements, including UBO disclosure, falls due for payment institutions under Circular PSS/DIR/PUB/CIR/001/004. [Source](https://www.kietlaw.com/blog/the-central-bank-of-nigeria-payments-system-circular-market-structure-data-localisationbeneficial-ownership-amp-systemic-oversight) In Force Pending 31 Dec 2026 · ±quarter ### CBN payments market-structure divestiture deadline Institutions exceeding 25% consumer-issuing share cannot simultaneously hold more than 15% merchant-acquiring share; divestiture or restructuring required by 31 December 2026. [Source](https://www.legit.ng/business-economy/industry/1720462-cbn-unveils-tough-rules-opay-moniepoint-palmpay-deepen-financial-inclusion/) In Force Pending 2026-Q4 · ±quarter ### CBN payments circular market-structure compliance deadline Full compliance with market-structure requirements (incl. UBO disclosure) under Circular PSS/DIR/PUB/CIR/001/004 falls due. [Central Bank of Nigeria Source](https://www.kietlaw.com/blog/the-central-bank-of-nigeria-payments-system-circular-market-structure-data-localisationbeneficial-ownership-amp-systemic-oversight) Proposed 2027 · ±year ### FATF 2027 Mutual Evaluation of Nigeria Nigeria undergoes a fresh FATF mutual evaluation testing whether post-delisting reforms are sustained. [Source](https://www.tvcnews.tv/efcc-nfiu-take-stock-ahead-2027-fatf-mutual-evaluation/) Proposed 2027 · ±year ### 2027 FATF Mutual Evaluation of Nigeria A fresh mutual evaluation report will re-assess both technical compliance and effectiveness; a negative outcome could reopen grey-list exposure. [FATF / GIABA Source](https://www.premiumtimesng.com/news/top-news/913376-efcc-nfiu-prepare-for-fresh-fatf-evaluation-after-nigerias-exit-from-grey-list.html) Consultation 2027 · ±year ### FATF Mutual Evaluation of Nigeria (2027 cycle) A full FATF Mutual Evaluation assesses both technical compliance and effectiveness, replacing the lighter increased-monitoring follow-up Nigeria exited in October 2025. [FATF / GIABA Source](https://allafrica.com/stories/202609300122.html) In Force Pending 1 Jan 2027 · ±quarter ### CBN payments data-localisation deadline Payment-transaction data must be stored and managed within Nigeria, referencing the NDPA 2023 as the applicable data-protection standard. [Source](https://guardian.ng/news/cbn-payment-rules-may-raise-costs-reshape-fintech-market-says-pwc/) In Force Pending 2027-Q1 · ±quarter ### CBN payments data-localisation deadline Data-localisation duty under the same CBN circular takes full effect. [Central Bank of Nigeria Source](https://guardian.ng/news/cbn-payment-rules-may-raise-costs-reshape-fintech-market-says-pwc/) 8 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### A new Central Bank circular sets a 31 December 2026 UBO-disclosure deadline for payment companies, layered on an already fragmented beneficial-ownership register landscape. Payment institutions face a compliance gate that runs alongside, rather than through, the Corporate Affairs Commission's existing register, raising the prospect of inconsistent beneficial-ownership records across filing channels for the same corporate group. 2 evidence refs Compliance ### Payment companies must meet UBO-disclosure and market-structure requirements by 31 December 2026, with data-localisation following on 1 January 2027. Two closely sequenced deadlines under one circular create a compressed compliance window, and the underlying Central Bank circular text has not itself been independently verified, so the precise scope of disclosure obligations should be read as probable rather than settled. 1 evidence refs Legal ### A Virtual Asset Coordination Executive Order creates a Central-Bank-chaired council and directs eventual designation of a single lead virtual-asset regulator. The current dual Central-Bank/Securities-Commission coordination model is a transitional structure under Section 79, which points toward further consolidation of virtual-asset supervisory authority; the Order's own primary text has not been retrieved, so the scope of each regulator's current authority carries residual uncertainty. 1 evidence refs Board ### Flutterwave's acquisition of Mono has delivered it a national microfinance banking licence, expanding its regulated perimeter into deposit-taking obligations. A commercial acquisition has produced a material regulatory-perimeter shift, bringing beneficial-ownership and anti-money-laundering obligations that attach to deposit-taking status; the licence's precise scope within the Flutterwave group has not been independently confirmed. 1 evidence refs CTO ### A Central-Bank-chaired Virtual Asset Council is coordinating securities and non-securities virtual-asset oversight, with a single-agency designation directed for the future. Digital-asset infrastructure built for Nigeria should anticipate a possible future shift in which single regulator holds primary virtual-asset authority, though the current dual-regulator model remains the operative one pending further designation. 1 evidence refs Risk ### Nigeria's beneficial-ownership, virtual-asset and commercial-perimeter signals this cycle are all structural rather than episodic, while sanctions-list status remains stable. The combination of a new sectoral UBO-disclosure deadline, a maturing virtual-asset coordination structure, and a fintech acquisition expanding deposit-taking exposure together indicate a widening regulatory perimeter in Nigeria, even as Nigeria's standing exit from increased monitoring continues to hold. 4 evidence refs Operations ### Payment companies must prepare for UBO-disclosure and data-localisation compliance on sequential deadlines of 31 December 2026 and 1 January 2027. Operational workflows for onboarding, screening and data handling in payment institutions face two closely sequenced regulatory deadlines originating from the same circular, requiring coordinated rather than siloed preparation. 1 evidence refs Audit ### Neither the Central Bank's payments circular nor the Virtual Asset Coordination Executive Order has had its primary text independently retrieved and verified this cycle. Both of this cycle's structural findings rest on secondary legal and press commentary rather than primary regulatory text, leaving an evidentiary gap that control-testing and documentation review should treat as an open item pending primary-source confirmation. 2 evidence refs Scenario sketches ### Dual UBO-disclosure channels diverge ahead of year-end deadline An illustrative pathway worth orienting on: a payment company files Ultimate Beneficial Owner data to the Central Bank under the new payments circular ahead of the 31 December 2026 deadline, while its parallel Corporate Affairs Commission filing lists a different control structure dating from an earlier corporate restructuring. No reconciliation mechanism exists between the two channels, so the divergence is not flagged by either regulator until a later cross-check, illustrating how register fragmentation could allow inconsistent beneficial-ownership pictures to persist across sector-specific and general-purpose filings. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No NG-specific movement this cycle; NG is not a primary node in this tracker. T2 · EU AML Package / AMLA no_change Not applicable as a binding instrument for NG (non-EEA); no NG-specific movement this cycle. T3 · FATF Grey List stable Nigeria remains off the FATF grey list following its 24 October 2025 removal; EFCC/NFIU stocktake ahead of 2027 mutual evaluation. T4 · Beneficial-Ownership Register Status stable CAC continues to operate three separate BO registers; harmonisation call (mid-Sept 2026) remains unresolved; no new development this cycle. T5 · Crypto & Digital-Asset Integrity watch A July 2026 Virtual Asset Coordination Executive Order formalised a CBN-chaired Virtual Asset Council; secondary-source coverage continued without a new primary instrument this cycle. T6 · Sanctions Regime Divergence no_change No NG-specific sanctions-divergence movement located this cycle. Registers ### Enforcement actions - 22 Jun 2026 - 1 Jun 2026 - 2026-06 - 16 Sep 2026 - EFCC busted a large cybercrime/crypto-investment and romance-scam syndicate operating from a seven-storey Lagos base, arresting 792 individuals and charging 53, including cyber-terrorism, impersonation and identity-theft counts; proceeds were funnelled through a Nigerian-registered shell company's bank account and digital assets worth $222,729 were temporarily seized for forfeiture. 1 Feb 2025 - A Nigerian Federal High Court sentenced former Minister of Power Saleh Mamman in absentia to 75 years' imprisonment for money laundering and corruption linked to the Mambilla and Zungeru hydropower projects. 13 May 2026 - SEC Nigeria disclosed it is investigating 79 suspected Ponzi schemes, following estimated cumulative losses to Nigerians of roughly 1 trillion naira in crypto-linked Ponzi schemes over 25 years, including a single 1.3 trillion naira loss event ('Cybeg') in 2025, as part of its expanded ISA 2025 VASP-licensing supervisory mandate. 1 Aug 2025 - FATF conducted an on-site assessment and determined Nigeria had sustained implementation of its February 2023 action plan across BO access, risk-based supervision, ML/TF investigations and international cooperation, resulting in removal from increased monitoring. 24 Oct 2025 ### Sanctions changes - 22 Jun 2026 - The European Commission adopted Delegated Regulation (EU) 2026/83 removing Nigeria (along with Burkina Faso, Mali, Mozambique, South Africa and Tanzania) from the EU list of high-risk third countries with AML/CFT strategic deficiencies, following the FATF's October 2025 grey-list delisting. 4 Dec 2025 - Following the UK's Money Laundering Regulations 2024 amendment, which redefines 'high-risk third country' as any country named on FATF's own current lists (removing the separate Schedule 3ZA), Nigeria's UK HRTC status lapsed automatically and immediately upon FATF's October 2025 delisting, without need for a further UK statutory instrument. 24 Oct 2025 ### Regulatory horizon (register) - CBN payments market-structure divestiture deadline - CBN payments market-structure divestiture deadline - SEC proposed rules on digital/virtual asset operations, custody and markets - SEC VASP minimum-capital compliance deadline - SEC Proposed Rules on Digital and Virtual Asset Operations, Custody and Markets 2026 - 2027 FATF Mutual Evaluation of Nigeria - FATF Mutual Evaluation of Nigeria (2027 cycle) - Unified/harmonised Beneficial Ownership database (CAC proposal) - CBN payments circular market-structure compliance deadline - CBN payments data-localisation deadline - FATF 2027 Mutual Evaluation of Nigeria - CBN payments circular market-structure/UBO-disclosure compliance deadline - CBN payments data-localisation deadline - GIABA next enhanced follow-up report on Nigeria's technical compliance - Full SEC VASP licensing regime maturation under ISA 2025 - EU AML Regulation (AMLR) application affecting EU-Nigeria correspondent due diligence ### Active schemes - [HIGH] Crypto investment-fraud cash-out via offshore VASPs - [HIGH] Crude oil theft, illegal refining and bunkering networks - Free-zone beneficial-ownership opacity (NEPZA/OGFZA) - [CRITICAL] Boko Haram/ISWAP informal-economy resource mobilisation Sources - [FATF](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Nigeria Federal Ministry of Finance](https://finance.gov.ng/nigeria-exits-fatf-grey-list-a-turning-point-for-investor-confidence-economic-growth/) - [Open Government Partnership](https://www.opengovpartnership.org/members/nigeria/commitments/NG0020/) - [Daily Trust](https://dailytrust.com/lead-the-terror-finance-crackdown/) - [Vanguard News](https://www.vanguardngr.com/2026/07/security-agencies-summon-terror-financing-suspects-freeze-assets/amp/) - [Leadership (Abuja) via AllAfrica](https://allafrica.com/stories/202602090711.html) - [AllAfrica](https://allafrica.com/stories/202511060057.html) - [AllAfrica](https://allafrica.com/stories/202511060098.html) - [Web3Africa](https://web3africa.tech/africa-crypto-regulation-compliance-guide/) - [Rio Times Online](https://www.riotimesonline.com/nigeria-mdas-data-protection-officers-2026/) - [Legit.ng / EFCC briefing](https://legit.ng/business-economy/money/1693912-efcc-claims-banks-fintechs-enabled-n162bn-crypto-n187bn-scams-900000-nigerians/) - [Tech Times](https://www.techtimes.com/articles/321759/20260728/nigeria-fintech-forum-convenes-thursday-cbns-historic-rules-clock-down.htm) - [https://insights.techcabal.com/nigeria-exited-the-fatf-grey-list-now-it-wants-to-set-the-rules-for-african-fintech/](https://insights.techcabal.com/nigeria-exited-the-fatf-grey-list-now-it-wants-to-set-the-rules-for-african-fintech/) - [https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [https://arbiterz.com/cbn-orders-banks-fintechs-to-disclose-beneficial-owners-as-part-of-new-compliance-requirements](https://arbiterz.com/cbn-orders-banks-fintechs-to-disclose-beneficial-owners-as-part-of-new-compliance-requirements) - [https://economicconfidential.com/cbn-orders-banks-fintechs/](https://economicconfidential.com/cbn-orders-banks-fintechs/) - [https://www.mondaq.com/nigeria/financial-services/1823482/nigerias-financial-markets-reform-the-virtual-assets-coordination-executive-order-2026-and-secs-proposed-cross-border-trading-rules](https://www.mondaq.com/nigeria/financial-services/1823482/nigerias-financial-markets-reform-the-virtual-assets-coordination-executive-order-2026-and-secs-proposed-cross-border-trading-rules) - [https://techpoint.africa/guide/cbn-fintech-regulations/](https://techpoint.africa/guide/cbn-fintech-regulations/) - [https://prnigeria.com/2026/08/31/efcc-three-year-review/](https://prnigeria.com/2026/08/31/efcc-three-year-review/) - [https://www.templars-law.com/app/uploads/2025/12/Client-Alert_Nigeria-Commences-Enforcement-Under-Anti-Money-Laundering-Act.pdf](https://www.templars-law.com/app/uploads/2025/12/Client-Alert_Nigeria-Commences-Enforcement-Under-Anti-Money-Laundering-Act.pdf) - [https://scuml.efcc.gov.ng/efcc-to-dnfbps-ignorance-of-new-anti-money-laundering-law-not-excuse/](https://scuml.efcc.gov.ng/efcc-to-dnfbps-ignorance-of-new-anti-money-laundering-law-not-excuse/) - [https://www.licentium.io/post/virtual-and-digital-assets-in-nigeria-regulatory-perimeter-approval-status-and-market-entry-sequence](https://www.licentium.io/post/virtual-and-digital-assets-in-nigeria-regulatory-perimeter-approval-status-and-market-entry-sequence) - [https://allafrica.com/stories/202609300122.html](https://allafrica.com/stories/202609300122.html) - [https://www.premiumtimesng.com/news/top-news/913376-efcc-nfiu-prepare-for-fresh-fatf-evaluation-after-nigerias-exit-from-grey-list.html](https://www.premiumtimesng.com/news/top-news/913376-efcc-nfiu-prepare-for-fresh-fatf-evaluation-after-nigerias-exit-from-grey-list.html) - [https://gazettengr.com/cac-seeks-harmonisation-of-beneficial-ownership-registers-for-increased-transparency/](https://gazettengr.com/cac-seeks-harmonisation-of-beneficial-ownership-registers-for-increased-transparency/) - [https://www.themeridian50.com/2026/09/27/sec-proposed-rules-digital-virtual-asset-operations/](https://www.themeridian50.com/2026/09/27/sec-proposed-rules-digital-virtual-asset-operations/) - [https://nairametrics.com/2026/09/29/21-companies-fined-n30-million-each-for-operating-without-sec-licences/](https://nairametrics.com/2026/09/29/21-companies-fined-n30-million-each-for-operating-without-sec-licences/) - [https://placng.org/i/wp-content/uploads/2022/05/Money-Laundering-Prevention-and-Prohibition-Act-2022.pdf](https://placng.org/i/wp-content/uploads/2022/05/Money-Laundering-Prevention-and-Prohibition-Act-2022.pdf) - [https://www.worldstagenews.com/efcc-nfiu-prepare-for-2027-fatfs-mutual-evaluation-of-nigeria/](https://www.worldstagenews.com/efcc-nfiu-prepare-for-2027-fatfs-mutual-evaluation-of-nigeria/) - [https://businessday.ng/news/legal-business/article/presidential-executive-order-boosts-virtual-assets-regulation-in-nigeria/](https://businessday.ng/news/legal-business/article/presidential-executive-order-boosts-virtual-assets-regulation-in-nigeria/) - [https://nairametrics.com/2026/01/26/cbn-upgrades-opay-moniepoint-other-major-fintechs-mfbs-to-national-status/](https://nairametrics.com/2026/01/26/cbn-upgrades-opay-moniepoint-other-major-fintechs-mfbs-to-national-status/) - [https://allafrica.com/stories/202610150178.html](https://allafrica.com/stories/202610150178.html) - [https://businessday.ng/news/legal-business/article/cac-strikes-off-500000-entities-over-failure-to-disclose-beneficial-owners/](https://businessday.ng/news/legal-business/article/cac-strikes-off-500000-entities-over-failure-to-disclose-beneficial-owners/) - [https://www.templars-law.com/app/uploads/2025/10/Nigeria-Exits-FATF-Grey-List.pdf](https://www.templars-law.com/app/uploads/2025/10/Nigeria-Exits-FATF-Grey-List.pdf) - [https://thewillnews.com/cac-seeks-unified-ownership-database-to-close-nigerias-illicit-finance-gaps/](https://thewillnews.com/cac-seeks-unified-ownership-database-to-close-nigerias-illicit-finance-gaps/) - [https://www.kietlaw.com/blog/the-central-bank-of-nigeria-payments-system-circular-market-structure-data-localisationbeneficial-ownership-amp-systemic-oversight](https://www.kietlaw.com/blog/the-central-bank-of-nigeria-payments-system-circular-market-structure-data-localisationbeneficial-ownership-amp-systemic-oversight) - [https://innov8tiv.com/the-great-nigerian-cloud-migration-why-the-clock-is-ticking-for-banks-and-fintechs/](https://innov8tiv.com/the-great-nigerian-cloud-migration-why-the-clock-is-ticking-for-banks-and-fintechs/) - [https://authorityngr.com/2026/10/14/nfiu-giaba-train-100-experts-ahead-of-nigerias-anti-money-laundering-assessment/](https://authorityngr.com/2026/10/14/nfiu-giaba-train-100-experts-ahead-of-nigerias-anti-money-laundering-assessment/) - [https://www.knowyourcountry.com/country-aml-intelligence/country/nigeria/](https://www.knowyourcountry.com/country-aml-intelligence/country/nigeria/) - [The Guardian Nigeria](https://guardian.ng/news/cbn-payment-rules-may-raise-costs-reshape-fintech-market-says-pwc/) - [Kiet Law](https://www.kietlaw.com/blog/the-central-bank-of-nigeria-payments-system-circular-market-structure-data-localisationbeneficial-ownership-amp-systemic-oversight) - [Ogunyemi Solicitors](https://ogunyemisolicitors.org/nigeria-virtual-assets-executive-order-2026/) - [TechCabal](https://techcabal.com/2026/10/28/flutterwave-ceo-on-fintechs-and-banking/) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [allAfrica](https://allafrica.com/stories/202609170488.html) - [TVC News](https://www.tvcnews.tv/efcc-nfiu-take-stock-ahead-2027-fatf-mutual-evaluation/) - [Outcomes FATF Plenary, 17-19 June 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [Nigeria](https://www.fatf-gafi.org/en/countries/detail/Nigeria.html) - [Jurisdictions under Increased Monitoring - 13 June 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html) - [Niger](https://www.fatf-gafi.org/en/countries/detail/Niger.html) - [Jurisdictions under Increased Monitoring - 25 October 2024](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2024.html) - [Joint African Development Bank - Financial Action Task Force webinar: Exiting the FATF Grey List – Success Stories and Pathways to Sustainable Compliance](https://www.fatf-gafi.org/en/publications/Fatfgeneral/joint-AfDB-FATF-webinar.html) - [Jurisdictions under Increased Monitoring - 21 February 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Nigeria-FUR-GIABA-November-2024. ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Nigeria-FUR-GIABA-November-2024.pdf) - [Fatf-gafi](http://www.fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/GIABA-Mutual%20Evaluation%20Report%20of%20the%20Federal%20Republic%20of%20Nigeria.pdf) - [Federal Republic of Nigeria: 1st Enhanced Follow-up Report](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GIABA-Nigeria-Follow-Up-Report-2022.pdf.coredownload.inline.pdf) - [GIABA-Mutual Evaluation Report of the Federal Republic of ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/GIABA-Mutual%20Evaluation%20Report%20of%20the%20Federal%20Republic%20of%20Nigeria.pdf) - [Mutual Evaluation of Nigeria](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofnigeria.html) - [Inter Governmental Action Group against Money Laundering in West Africa (GIABA)](https://www.fatf-gafi.org/en/countries/global-network/inter-governmental-action-group-against-money-laundering-in-west.html) - [Niger's measures to combat money laundering and the financing of terrorism and proliferation](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-niger-2021.html) - [Nigeria's measures to combat money laundering and the financing of terrorism and proliferation](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mer-nigeria-2021.html) - [Plenary and Ministerial Meeting of the Intergovernmental Action Group against Money Laundering in West Africa (GIABA)](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Plenaryandministerialmeetingoftheintergovernmentalactiongroupagainstmoneylaunderinginwestafricagiaba.html) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [Anti-Money Laundering and Terrorist Financing Directive 4 - Finance](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en) - [HM Treasury Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/hm-treasury-advisory-notice-high-risk-third-countries) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [Nigeria Charges 53 in Global Crypto Scam, Cybercrime Ring | OCCRP](https://www.occrp.org/en/news/nigeria-charges-53-in-global-crypto-scam-cybercrime-ring) - [Nigerian Sentenced to Five Years Related to Fraudulent Cryptocurrency Scheme | TRM Blog](https://www.trmlabs.com/resources/blog/nigerian-sentenced-to-five-years-related-to-fraudulent-cryptocurrency-scheme) - [Binance Official Who Was Detained in Nigeria Leaves Crypto Exchange - Bloomberg](https://www.bloomberg.com/news/articles/2025-06-06/binance-official-who-was-detained-in-nigeria-leaves-crypto-exchange) - [Crypto giants moved billions linked to money launderers, drug traffickers and North Korean hackers](https://www.icij.org/investigations/coin-laundry/cryptocurrency-exchanges-binance-okx-money-laundering-crime/) - [Nigerian Court Releases Binance Executive Jailed Since February - Bloomberg](https://www.bloomberg.com/news/articles/2024-10-23/nigerian-court-releases-binance-executive-jailed-since-february) - [UK and US Binance Execs Remain Detained in Nigeria | OCCRP](https://www.occrp.org/en/news/uk-and-us-binance-execs-remain-detained-in-nigeria) - [Cybercrime Assessment – Nigeria 2025](https://www.unodc.org/conig/uploads/documents/Cybercrime_Assessment_in_Nigeria_WEB.pdf) - [Nigerian Pension Reformer Bought US and UAE Properties Before Money Laundering Conviction | OCCRP](https://www.occrp.org/en/scoop/nigerian-pension-reformer-bought-us-and-uae-properties-before-money-laundering-conviction) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [Nigeria Detains Binance Executives in Overseas Tax Crackdown](https://www.bloomberg.com/news/articles/2024-02-29/ngn-usd-nigeria-detains-binance-executives) - [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2) - [HM Treasury publish updated list of high risk third jurisdictions](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasury-publish-updated-list-of-high-risk-third-jurisdictions) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [ECSH31555 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh31555) - [Page 1 of 5 HM Treasury Advisory Notice: Changes to the FATF’s Public Lists](https://assets.publishing.service.gov.uk/media/69988878b33a4db7ff889ef3/Annex_C_-_Advisory_Notice_-_February_2026.pdf) - [High-risk third countries](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries) - [The UK Sanctions List - GOV.UK](https://www.gov.uk/government/publications/the-uk-sanctions-list) - [Enhanced due diligence: designation of high-risk countries](https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1165484/Updated_Impact_Assessment_-_HRTC_Measure_amendement_2_ECCTB_21.06.23_MIN_CLEARED.pdf) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Home | Office of Foreign Assets Control](https://ofac.treasury.gov/) - [Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions) - [OFAC Related Press Releases | Office of Foreign Assets Control](https://ofac.treasury.gov/press-releases?page=1) - [1 1. See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t). 2.](https://www.fincen.gov/system/files/2026-06/FinCEN-Alert-Fiscal-Fuel-Theft.pdf) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [SANCTIONS ADVISORY - Guidance for Shipping and ...](https://ofac.treasury.gov/media/934236/download?inline=) - [Non-Proliferation Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/non-proliferation-sanctions) - [Counter Narcotics Trafficking Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/counter-narcotics-trafficking-sanctions) - [OFAC Consolidated Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/all-faqs) - [ECSH64830 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh64830) - [S T A T U T O R Y I N S T R U M E N T S 2023 No. 1306 FINANCIAL SERVICES](https://www.legislation.gov.uk/uksi/2023/1306/pdfs/uksi_20231306_en.pdf) - [The Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) Regulations 2023](https://www.legislation.gov.uk/uksi/2023/704/made) - [The Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) (No. 3) Regulations 2022](https://www.legislation.gov.uk/uksi/2022/1183/made) - [The Money Laundering and Terrorist Financing (High-Risk ...](https://www.legislation.gov.uk/uksi/2023/704/pdfs/uksiem_20230704_en_001.pdf) - [fatf REPORT TERRORIST FINANCING IN WEST AFRICA October 2013](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/TF-in-West-Africa.pdf.coredownload.inline.pdf) - [THEMATIC COMPILATION OF RELEVANT INFORMATION SUBMITTED BY NIGERIA](https://www.unodc.org/documents/corruption/WG-Prevention/Art_14_Prevention_of_money-laundering/Nigeria.pdf) - [1 | P a g e NIGERIA’S STATEMENT DELIVERED BY CATHERINE I. UDIDA](https://www.un.org/securitycouncil/ctc/sites/www.un.org.securitycouncil.ctc/files/nigeria.pdf) - [Terrorist Financing in West Africa](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Tf-west-africa.html) - [Screening, Investigation and Rehabilitation of Boko Haram Suspects: UNODC Support to Nigeria](https://www.unodc.org/conig/en/stories/screening--investigation-and-rehabilitation-of-boko-haram-suspects_UNODC-support-to-nigeria.html) - [Counter Terrorism and the Prevention of Violent Extremism](https://www.unodc.org/conig/en/stories/counter-terrorism-and-the-prevention-of-violent-extremism.html) - [TERRORIST FINANCING IN WEST AND CENTRAL AFRICA October 2016](https://www.fatf-gafi.org/media/fatf/documents/reports/Terrorist-Financing-West-Central-Africa.pdf) - [Nigeria statement -- International Terrorism](https://www.un.org/en/ga/sixth/79/pdfs/statements/int_terrorism/02mtg_nigeria.pdf) - [Fighting Against Crude Oil Theft, Nigeria Dismantles 63 Illegal Refineries | OCCRP](https://www.occrp.org/en/news/fighting-against-crude-oil-theft-nigeria-dismantles-63-illegal-refineries) - [Nigerian Authorities Crack Down on Illegal Refining Sites | OCCRP](https://occrp.org/en/daily/18904-nigerian-authorities-crack-down-on-illegal-refining-sites) - [Nigeria’s corruption busters](https://www.unodc.org/unodc/en/frontpage/nigerias-corruption-busters.html) - [TotalEnergies implicated in repression of East Africa defenders | Global Witness](https://globalwitness.org/en/campaigns/land-and-environmental-defenders/eacop/) - [Nigeria Oil Theft, Vandalism Affecting Trans Niger Pipeline, Labor Unions Says - Bloomberg](https://www.bloomberg.com/news/articles/2022-03-23/key-nigerian-pipeline-drained-by-theft-sabotage-union-says) - [Oil theft lubricates corruption in West Africa](https://www.unodc.org/unodc/en/frontpage/2009/July/illegal-oil-trade-in-nigeria-worsens-rule-of-law-in-west-africa.html) - [Nigerian Oil Pipeline Sabotage Threatens Crude Output Revival - Bloomberg](https://www.bloomberg.com/news/articles/2025-03-19/nigerian-oil-pipeline-sabotage-threatens-crude-output-revival) - [Nigeria NNPC In Talks to Secure $2 Billion for Pipeline Upgrade - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-29/nigeria-nnpc-in-talks-to-secure-2-billion-for-pipeline-upgrade) - [ORGANIZED CRIME IN NIGERIA: A THREAT ASSESSMENT](https://www.unodc.org/conig/uploads/documents/NOCTA_Web_Version_25.09.2023.pdf) - [Nigeria’s SEC to Licence Crypto Exchanges as Adoption Surges - Bloomberg](https://www.bloomberg.com/news/articles/2024-08-20/nigeria-s-sec-to-licence-crypto-exchanges-as-adoption-surges) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Nigerian SEC’s Vision for a Trusted Crypto Ecosystem](https://www.chainalysis.com/blog/nigerian-sec-vision-trusted-crypto-ecosystem/) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Targeted Update on Implementation of the FATF Standards on Virtual Assets and](https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/2025-Targeted-Upate-VA-VASPs.pdf.coredownload.pdf) - [New FATF report highlights illicit finance risks linked to Offshore VASPs](https://www.fatf-gafi.org/en/publications/Virtualassets/Understanding-Mitigating-Risks-Offshore-VASPs.html) - [What Is a VASP? Virtual Asset Service Provider - Chainalysis](https://www.chainalysis.com/glossary/virtual-asset-service-provider/) - [Sub-Saharan Africa: Nigeria Takes #2, South Africa Grows Crypto-TradFi](https://www.chainalysis.com/blog/subsaharan-africa-crypto-adoption-2024/) - [SEC Nigeria & Chainalysis Webinar: Combating Scams with Blockchain Intelligence](https://go.chainalysis.com/SEC-Nigeria-Chainalysis-Registration-Page.html) - [Nigerian Election Officials Sentenced for Taking Bribes | OCCRP](https://www.occrp.org/en/news/nigerian-election-officials-sentenced-for-taking-bribes) - [Court Sentences Nigerian Politician to 75 Years in Jail for Graft - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-13/court-sentences-nigerian-politician-to-75-years-in-jail-for-graft) - [Nigerian National Sentenced for Orchestrating Online Romance Scam | OCCRP](https://www.occrp.org/en/news/nigerian-national-sentenced-for-orchestrating-online-romance-scam) - [Man Convicted in International Scheme that Defrauded Lawyers in the US | OCCRP](https://www.occrp.org/en/news/man-convicted-in-international-scheme-that-defrauded-lawyers-in-the-us) - [Page 1 of 217 Country Review Report of the Federal Republic of Nigeria](https://www.unodc.org/documents/treaties/UNCAC/CountryVisitFinalReports/2014_10_14_Final_Country_Report_Nigeria.pdf) - [CHIEF EMMANUEL NWUDE & 6 ORS, ID/92C/2004](https://www.unodc.org/cld/case-law-doc/moneylaunderingcrimetype/nga/2005/chief_emmanuel_nwude_6_ors_id92c2004.html) - [(NGN/USD): Nigeria Bans Naira Street Trading as Currency Takes Another Hit - Bloomberg](https://www.bloomberg.com/news/articles/2024-05-24/-ngn-usd-nigeria-bans-naira-street-trading-as-currency-takes-another-hit) - [Nigeria's measures to combat money laundering and the financing of terrorism and proliferation](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-nigeria-2021.html) - [FATF publishes new Guidance on Financial Inclusion and Anti-Money Laundering and Terrorist Financing Measures](https://www.fatf-gafi.org/en/publications/Financialinclusionandnpoissues/guidance-financial-inclusion-aml-tf-measures.html) - [GIABA (FATF-Style Regional Body) / FATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/GIABA-Mutual%20Evaluation%20Report%20of%20the%20Federal%20Republic%20of%20Nigeria.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [European Commission (DG FISMA)](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [UK Gambling Commission (relaying HM Treasury advisory notice)](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries) - [OCCRP](https://www.occrp.org/en/news/nigeria-charges-53-in-global-crypto-scam-cybercrime-ring) - [FATF](https://www.fatf-gafi.org/en/publications/Virtualassets/Understanding-Mitigating-Risks-Offshore-VASPs.html) - [Bloomberg](https://www.bloomberg.com/news/articles/2026-05-13/court-sentences-nigerian-politician-to-75-years-in-jail-for-graft) - [Chainalysis](https://www.chainalysis.com/blog/nigerian-sec-vision-trusted-crypto-ecosystem/) - [UNODC Nigeria Country Office](https://www.unodc.org/conig/uploads/documents/Cybercrime_Assessment_in_Nigeria_WEB.pdf) - [OCCRP](https://occrp.org/en/daily/18904-nigerian-authorities-crack-down-on-illegal-refining-sites) Coverage gaps fim-int-2026-08-05-G001: Primary CAC.gov.ng announcement of … fim-int-2026-08-05-G001: Primary CAC.gov.ng announcement of BO register operationalisation was not retrieved; reliance on Tier-3 press only. [resolved] fim-int-2026-08-05-G002: Primary SEC/ISA 2025 gazette text w… fim-int-2026-08-05-G002: Primary SEC/ISA 2025 gazette text was not retrieved for the VASP licensing framework; reliance on Tier-4 vendor guides only. [resolved] fim-int-2026-08-05-G003: The underlying Senate forensic-audi… fim-int-2026-08-05-G003: The underlying Senate forensic-audit document was not independently retrieved; figures rest on secondary Tier-3 reporting of the same hearing. [resolved] fim-int-2026-08-05-G004: No dedicated Tier-D (KH/LA/MX/CO) s… fim-int-2026-08-05-G004: No dedicated Tier-D (KH/LA/MX/CO) searches were run this cycle; entire collection budget was allocated to the NG dispatch. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No primary CBN circular text was directly retrieved for either the UBO-disclosure or data-localisation measures; both rest on corroborated T3 trade-press reporting. [resolved] fim-int-2026-09-28-G002: Tier D jurisdiction (KH, LA, MX, CO… fim-int-2026-09-28-G002: Tier D jurisdiction (KH, LA, MX, CO) research was not conducted this cycle because the pooled search budget was concentrated on the bound jurisdiction NG. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1, D3 and D4 coverage was thin this cycle; no NG-specific sanctions-evasion, enabler-jurisdiction or conflict-finance signal was located. [resolved] fim-int-2026-10-04-G001: Tier D jurisdictions (Cambodia, Lao… fim-int-2026-10-04-G001: Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not actively re-swept this cycle; pooled union budget was concentrated on the bound NG jurisdiction. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No D4 (conflict finance) development specific to Nigeria was identified this cycle. [resolved] fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D6'}): No D6 (compliance technology) development specific to Nigeria was identified this cycle. [resolved] fim-int-2026-10-11-G001: Tier D jurisdictions (Cambodia, Lao… fim-int-2026-10-11-G001: Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not actively searched this cycle owing to the pooled research budget being allocated to NG; absence recorded as a coverage gap rather than a no-activity finding. [resolved] fim-int-2026-10-11-G002: D2 (beneficial ownership), D3 (enab… fim-int-2026-10-11-G002: D2 (beneficial ownership), D3 (enabler jurisdictions), D4 (conflict finance) and D6 (compliance technology) were thinly covered this cycle for NG; no T1 primary sources were retrieved for these domains. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No primary FATF or NFIU document was retrieved this cycle to corroborate the NFIU training report beyond a single T4 aggregator source. [resolved] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Exact gazette/publication date of the June 2026 Executive Order creating the Virtual Asset Council was not independently retrieved; this is a crypto-adjacent FIM D5 gap. [resolved] fim-int-2026-10-25-G001: CBN's own payments circular text (P… fim-int-2026-10-25-G001: CBN's own payments circular text (PSS/DIR/PUB/CIR/001/004) was not directly retrieved this cycle; findings rest on secondary/law-firm commentary only. [resolved] fim-int-2026-10-25-G002: D1, D3, D4, D5, D6 and D8 returned … fim-int-2026-10-25-G002: D1, D3, D4, D5, D6 and D8 returned thin coverage for Nigeria this cycle; no primary sanctions, enabler-jurisdiction, conflict-finance, crypto-AML, compliance-technology or commercial-activity development was sourced. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): CBN's own primary circular text (PSS/DIR/PUB/CIR/001/004) was not directly retrieved this cycle; the two corroborating sources are both secondary legal/press commentary. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): The Virtual Asset Coordination Executive Order 2026 rests on a single T3 law-firm source; CBN/SEC primary gazette text was not retrieved this cycle. [open] fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D6'}): D1 (sanctions), D3 (enabler jurisdictions), D4 (conflict finance) and D6 (compliance technology) had no NG-specific findings this cycle; this single-JID dispatch does not cover Tier D watch jurisdictions. [open] FIM-GAP-001 (D2): Free-zone beneficial-ownership registers (… FIM-GAP-001 (D2): Free-zone beneficial-ownership registers (NBOREG for NEPZA zones, OBOREG for OGFZA oil-and-gas free zones) are not publicly available, and free-zone enterprises are not required to verify beneficial-ownership information received from beneficial owners, undermining data accuracy for a materially significant slice of Nigeria's corporate sector. FIM-GAP-002 (D1): Nigeria's 2021 Mutual Evaluation Report fo… FIM-GAP-002 (D1): Nigeria's 2021 Mutual Evaluation Report found the country lacks a legal framework for targeted financial sanctions (TFS) concerning proliferation financing, and coordination between Customs and other agencies on PF risk is limited to occasional interactions. FIM-GAP-003 (D3): Nigerian law-enforcement agencies, includi… FIM-GAP-003 (D3): Nigerian law-enforcement agencies, including the EFCC, do not prioritise stand-alone money-laundering investigations and focus primarily on predicate offences; the number of ML investigations, prosecutions and convictions remains inconsistent with the country's risk profile, and foreign-predicate-offence laundering is rarely pursued. FIM-GAP-004 (D5): UNODC's 2025 Cybercrime Assessment of Nige… FIM-GAP-004 (D5): UNODC's 2025 Cybercrime Assessment of Nigeria documents an escalating scale of cybercrime, romance and crypto-investment fraud (with INTERPOL's Africa Cyberthreat Assessment 2025 ranking Nigeria among the continent's highest-exposure jurisdictions), outstripping the current capacity of law enforcement, judiciary and financial-sector supervisors to respond at scale. ## Evidence #### Confidence-tiered claims Three-day stocktake (29 Sept-2 Oct 2026) at EFCC HQ Abuja reviewing AML/CFT progress ahead of Nigeria's 2027 FATF Mutual Evaluation. [[Source 1]](#sec-sources) Probable · 1 source Nigeria operates three separate, non-interoperable beneficial-ownership disclosure systems (CAC, NEPZA free-zone, NEITI extractive); CAC calls for harmonisation ahead of Nov 2026 Lagos conference. [[Source 1]](#sec-sources) Probable · 1 source SEC's 20 Aug 2026 Proposed Rules on Digital and Virtual Asset Operations, Custody and Markets (comment period closed 3 Sept 2026) remain under post-consultation review, not yet in force. [[Source 1]](#sec-sources) Probable · 1 source 21 companies convicted and fined ₦30 million each (plus ₦200,000/day) for operating without SEC/CBN licences under BOFIA 2020 s.57(1), 15-16 Sept 2026. [[Source 1]](#sec-sources) Probable · 1 source s.3(1) requires reporting to NFIU/CBN/SEC within one day for cross-border transfers of funds or securities exceeding US$10,000 by any person or body corporate including money service businesses. [[Source 1]](#sec-sources) Probable · 1 source EFCC and NFIU held a joint three-day stocktake (29-30 Sept and 2 Oct 2026) reviewing financial-intelligence use, asset recovery, ML investigation/prosecution and inter-agency cooperation ahead of NG's 2027 FATF Mutual Evaluation. [[Source 1]](#sec-sources) Probable · 1 source President Tinubu signed an Executive Order (17 July 2026) establishing a Virtual Asset Council chaired by CBN, with SEC and Nigeria Revenue Service as vice-chairs, coordinating rather than replacing SEC/CBN mandates and directing a regulatory sandbox and virtual-asset tax policy. [[Source 1]](#sec-sources) Probable · 1 source CBN upgraded OPay, Moniepoint MFB, Kuda Bank, PalmPay and Paga from regional/state to national microfinance-bank/fintech licences (announced late Jan 2026, e.g. NGN5bn capital threshold for national MFBs); Busha Business partnered with Tether (20 July 2026) to distribute USDT to African businesses; SEC's ARIP admitted 11 cumulative firms by early July 2026. [[Source 1]](#sec-sources) Probable · 1 source NFIU trained 100 officials nearly a year after Nigeria's October 2025 FATF grey-list exit, with CEO Hafsat Bakari stating Nigeria must demonstrate its AML/CFT laws and institutions deliver results, not merely exist on paper, ahead of the 2027 Mutual Evaluation. [[Source 1]](#sec-sources) Probable · 1 source CAC struck off more than 500,000 entities from Nigeria's Beneficial Ownership Register for failing to update beneficial-owner information. [[Source 1]](#sec-sources) Probable · 1 source Nigeria's AML/CTF regime rests on the Money Laundering (Prevention and Prohibition) Act 2022 and Terrorism (Prevention and Prohibition) Act 2022, with NFIU (housed within CBN) as FIU and EFCC as lead enforcement agency; Nigeria was removed from the FATF grey list on 24 October 2025 after achieving Compliant/Largely Compliant status on 37 of 40 FATF Recommendations. [[Source 1]](#sec-sources) Probable · 1 source All deposit money banks, PSPs and digital-payment-footprint institutions must disclose ultimate beneficial ownership of significant shareholders [[Source 1]](#sec-sources) Probable · 1 source Payment transaction data generated in Nigeria must be stored domestically from 1 January 2027, with market-share returns due 31 December 2026 [[Source 1]](#sec-sources) Probable · 1 source 100 officials trained (12-16 Oct 2026) ahead of a mock Mutual Evaluation exercise scheduled November 2026 [[Source 1]](#sec-sources) Probable · 1 source 500,000+ entities struck off Nigeria's beneficial-ownership register for failing to update required information [[Source 1]](#sec-sources) Probable · 1 source Nigeria was removed from the FATF grey list on 24 October 2025 after completing a 19-point action plan [[Source 1]](#sec-sources) Probable · 1 source 2026-12-31 [[Source 1]](#sec-sources) Probable · 1 source 2026-07-01 [[Source 1]](#sec-sources) Uncertain · 1 source True [[Source 1]](#sec-sources) Probable · 1 source CBN Circular PSS/DIR/PUB/CIR/001/004 (15 June 2026) requires payment companies to disclose Ultimate Beneficial Owners, with full market-structure compliance due 31 December 2026 and payment-data localisation due 1 January 2027. [[Source 1]](#sec-sources) Probable · 1 source A July 2026 Executive Order creates a CBN-chaired Virtual Asset Council coordinating SEC (securities-characterised virtual assets) and CBN (payment, settlement, custody of non-security virtual assets) oversight; Section 79 directs designation of a federal agency with primary virtual-asset responsibility. [[Source 1]](#sec-sources) Uncertain · 1 source Flutterwave obtained a national microfinance banking licence through its acquisition of open-banking startup Mono (announced April 2026, reported 28 Oct 2026), expanding its AML/BO registration obligations as a deposit-taking entity. [[Source 1]](#sec-sources) Probable · 1 source Nigeria remains off the FATF grey list following its 24 October 2025 removal. [[Source 1]](#sec-sources) Probable · 1 source CAC continues to operate three separate BO registers (CAC PSC register, NEPZA free-zone BO data, NEITI extractives BO data) and has called for harmonisation. [[Source 1]](#sec-sources) Probable · 1 source