Financial Integrity Monitor

Nigeria NG

Sources
10
Jurisdiction profile
Largely CompliantTier BRisk: DecreasingMixed

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.

MoreNigeria 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)
Regulatory horizon
No dated horizon items this cycle. 3 items tracked without a confirmed date.
3 pending date · baseline financial-integrity-2026-07-05
Registers

Enforcement actions

  • 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

  • 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)

  • 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
  1. GIABA (FATF-Style Regional Body) / FATF
  2. FATF
  3. European Commission (DG FISMA)
  4. UK Gambling Commission (relaying HM Treasury advisory notice)
  5. OCCRP
  6. FATF
  7. Bloomberg
  8. Chainalysis
  9. UNODC Nigeria Country Office
  10. OCCRP
Coverage gaps
Free-zone beneficial-ownership registers (NBOREG for NEPZA z…
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.
Nigeria's 2021 Mutual Evaluation Report found the country la…
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.
Nigerian law-enforcement agencies, including the EFCC, do no…
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.
UNODC's 2025 Cybercrime Assessment of Nigeria documents an e…
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

No structured claims published for this jurisdiction yet.