Nigeria
Overview
Nigeria’s Deep AML/CFT profile is anchored in Money Laundering (Prevention and Prohibition) Act, 2022 (Act No. 14). The statutory baseline is separated from later GIABA/FATF assessments, implementation measures and future reforms. The CBN publicly recorded a mandatory baseline for automated AML/CFT/CPF monitoring systems dated 10 March 2026 and issued separate implementation guidance dated 31 March 2026. FATF removed Nigeria in October 2025 from its jurisdictions under increased monitoring; this is a monitored-status change, not repeal of local AML requirements.
Beneficial-ownership transparency is mapped through the legal-person and arrangement requirements assessed by GIABA, together with the national AML/CFT framework. Registry access, obliged-entity CDD duties and effectiveness findings are treated as separate evidence questions.
The profile maps risk-based CDD, record keeping, suspicious-transaction reporting, FIU receipt/analysis and related reporting duties from the national instrument and GIABA implementation evidence.
Compliance Calendar2
Requirement
Suspicious Transaction Report (STR)
Authority / Report toNigeria Financial Intelligence Unit (NFIU)
Deadline / triggerRender the STR to NFIU within 24 hours in accordance with section 7 and current NFIU guidance.
Requirement
- Subject scope
- Financial institutions and designated non-financial businesses/professions subject to the Money Laundering (Prevention and Prohibition) Act 2022 and related rules.
- Trigger
- A transaction is determined to be suspicious under the statutory / NFIU reporting standard.
- Filing channel
- NFIU prescribed electronic reporting process.
Impact
- Consequences of non-compliance
- Failure to report can attract offences and administrative penalties under the 2022 Act and related legislation.
- Enforcement authority
- NFIU / relevant supervisory authority
- Operational impact
- Treat 24 hours as an external statutory deadline, not an internal investigation target; escalation must happen earlier.
Requirement
Risk-based AML/CFT controls, CDD and recordkeeping
Authority / Report toNFIU / relevant supervisor
Deadline / triggerMaintain CDD, monitoring, governance and records for the period required by the applicable law / sector rule; No single universal retention period is shown where rules differ by record type or sector.
Requirement
- Subject scope
- Financial institutions and designated non-financial businesses/professions within the applicable national AML/CFT perimeter.
- Trigger
- Continuous while carrying on covered business; enhanced measures apply when higher-risk customers, products, transactions or relationships are identified.
- Filing channel
- Internal AML programme, customer/beneficial-owner records, transaction monitoring, escalation and retained evidence; supervisory submissions apply when separately required.
Impact
- Consequences of non-compliance
- Control or recordkeeping failures can attract supervisory, administrative or criminal consequences under the applicable AML/CFT framework.
- Enforcement authority
- NFIU / relevant supervisor
- Operational impact
- Keep the firm’s control library mapped to the exact sector rule and keep evidence of CDD, monitoring, escalation and record retention.
Authorities & FIU1
FATF Assessment
Measures how fully the jurisdiction has implemented FATF’s technical requirements. It does not measure practical effectiveness.
Measures whether the AML/CFT system achieves its intended results in practice. Follow-up reports do not normally replace these ratings.
Explore 40 FATF RecommendationsSee every Technical Compliance rating and what it means.+
Explore 11 Immediate OutcomesSee how FATF rates whether the AML/CFT system works in practice.+
Regulatory Timeline41
On 31 March 2026 the Central Bank of Nigeria issued a Guidance Note responding to implementation questions following its 10 March mandatory baseline. The official CBN reform summary says the note clarifies supervisory expectations and emphasises that compliance is assessed at the financial-institution level. It is a distinct interpretive publication, not a second new statutory baseline.
The Central Bank of Nigeria describes a circular released on 10 March 2026 setting mandatory baseline standards for automated AML/CFT/CPF tools at banks, money transfer businesses, payment service providers and other covered institutions. The bank highlights capability for real-time suspicious activity detection, analysis and reporting. The public reform summary establishes the circular date but does not specify a later commencement date.
The FATF statement dated 24 October 2025 identified Nigeria among the jurisdictions no longer subject to increased monitoring, following its inclusion in February 2023. The announcement documents an international monitoring-status change; it does not abolish existing Nigeria AML/CFT controls.
FATF revised Recommendation 16 to standardise payment information and strengthen fraud/error controls in cross-border payments.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendation 1 and related interpretive material to strengthen proportionality and simplified measures under the risk-based approach.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF revised Recommendations 4, 30, 31 and 38 and related interpretive material to make asset recovery a stronger operational priority, expand tools to trace and confiscate criminal property and improve domestic and international cooperation.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗At its February 2023 Plenary FATF revised Recommendation 25 and its Interpretive Note to strengthen transparency and beneficial-ownership requirements for trusts and similar legal arrangements, complementing the 2022 strengthening of Recommendation 24 for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF added Nigeria to its jurisdictions under increased monitoring.
Money Laundering (Prevention and Prohibition) Act, 2022 (Act No. 14) is mapped as the primary national legal baseline or current reform milestone for the Deep profile.
FATF strengthened Recommendation 24 on beneficial ownership transparency for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendations 1 and 2 and their Interpretive Notes so countries and covered private-sector entities must identify, assess and mitigate risks of breaches, non-implementation or evasion of proliferation-related targeted financial sanctions.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee revised its ML/TF risk-management guidelines to add principles for information exchange and cooperation between prudential and AML/CFT supervisors in authorisation, ongoing supervision and enforcement.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted detailed implementation requirements for virtual assets and VASPs in June 2019, including the application of wire-transfer information requirements commonly described as the Travel Rule. This operationalised the virtual-asset perimeter introduced through the 2018 Recommendation 15 revision.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗In October 2018 FATF revised Recommendation 15 and added the definitions of virtual asset and virtual asset service provider, formally bringing virtual-asset activity into the global AML/CFT standards architecture. Detailed implementation requirements followed in 2019.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee issued Sound management of risks related to money laundering and financing of terrorism, superseding its 2001 CDD and 2004 consolidated KYC papers and integrating ML/TF risk management with prudential supervisory expectations.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF removed Nigeria from its on-going global AML/CFT compliance monitoring process.
FATF adopted a consolidated revised set of 40 Recommendations integrating AML, CFT and proliferation-financing safeguards.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF identified Nigeria in its on-going global AML/CFT compliance process.
The Egmont Group's official Member FIU Information register records Nigeria's FIU admission date as 2007-06-01.
Resolution 1737 imposed binding measures concerning Iran’s proliferation-sensitive nuclear activities, including an asset freeze on designated individuals and entities. Together with the DPRK regime, it forms a foundational UN counter-proliferation targeted-financial-sanctions architecture.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗Following the DPRK nuclear test, Resolution 1718 imposed binding sanctions including an asset freeze on designated persons and entities connected to the nuclear programme. It became a central UN targeted-financial-sanctions pillar for counter-proliferation financing.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗FATF de-listed Nigeria from the NCCT list on 2006-06-23.
FATF added a ninth Special Recommendation addressing cash couriers and cross-border movement of currency.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1540 requires all States to adopt and enforce laws and domestic controls to prevent non-State actors from acquiring or using weapons of mass destruction and related materials. It forms a binding global legal pillar of the proliferation-financing control environment later reflected in FATF CPF standards.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The UN General Assembly adopted the United Nations Convention against Corruption on 31 October 2003. UNCAC addresses prevention of money laundering, laundering of corruption proceeds, confiscation and a dedicated asset-recovery framework; the Convention entered into force globally on 14 December 2005.
Current UN depositary relationship to 2003 UN Convention against Corruption. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗FATF comprehensively revised its AML/CFT Recommendations, strengthening preventive measures and extending coverage.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee issued Customer due diligence for banks, setting minimum supervisory expectations for customer acceptance, identification, ongoing monitoring and risk management. It became an influential global banking KYC/CDD benchmark and was later reflected in FATF standards.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF expanded its standards to terrorist financing through eight Special Recommendations.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1373 requires all States to prevent and suppress terrorist financing, criminalise the provision or collection of funds for terrorist acts, freeze terrorist assets without delay and prohibit making funds or financial services available to terrorists and related entities.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗FATF identified Nigeria as a Non-Cooperative Country or Territory (NCCT) on 2001-06-22.
Historical official-government evidence confirms Nigeria as a GIABA member by publication of the 2000 INCSR in March 2001; the exact admission date is not established by the reviewed evidence.
The Palermo Convention was adopted on 15 November 2000 and broadened the international money-laundering framework beyond drug proceeds through criminalisation and preventive measures tied to transnational organised crime. It entered into force globally on 29 September 2003.
Current UN depositary relationship to 2000 Palermo Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗A contemporaneous U.S. government GIABA record identifies Nigeria within the exhaustive fourteen-country nominal/early membership roster associated with GIABA’s first meetings in Dakar in November 2000. The official ECOWAS 2001 Annual Report independently fixes the ministerial meeting that adopted GIABA’s statutes to 3 November 2000. Read together, the evidence fixes Nigeria’s founding-stage GIABA membership start to November 2000. Month precision is retained because the roster evidence does not establish a jurisdiction-specific signature or attendance day.
The UN General Assembly adopted the International Convention for the Suppression of the Financing of Terrorism on 9 December 1999, creating the treaty framework for criminalising terrorist financing and international cooperation. It entered into force globally on 10 April 2002.
Current UN depositary relationship to 1999 Terrorist Financing Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗Resolution 1267 imposed an assets freeze and other targeted sanctions in the Taliban context and created the Security Council committee that became the foundation of the UN 1267 sanctions architecture. It is a key global precursor to modern terrorist-financing targeted financial sanctions.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗FATF revised the Forty Recommendations to reflect evolving money-laundering methods and countermeasures.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Representatives of 13 financial intelligence units met in Brussels on 9 June 1995 and founded what became the Egmont Group. The milestone created the operational global network for FIU-to-FIU cooperation and exchange of financial intelligence.
Current profile relationship to the Egmont network. This does not imply membership in 1995; admission history is a separate LOCAL/STATUS fact.
Egmont Group · Member FIUs ↗FATF issued its original Forty Recommendations, establishing the first global AML standard framework.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The G7 established FATF in 1989 to examine and develop measures to combat money laundering. FATF became the central global standard-setting body whose recommendations are implemented through national and regional AML/CFT frameworks.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Vienna Convention was adopted on 20 December 1988 and created the first treaty-level international obligation to criminalise laundering conduct linked to drug-trafficking proceeds, alongside confiscation and international-cooperation measures. It entered into force globally on 11 November 1990.
Current UN depositary relationship to 1988 Vienna Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗The Basel Committee published a Statement of Principles for banks aimed at reducing the risk that banking institutions would be used by criminals or as channels for money laundering. This helped establish the preventive and supervisory side of AML alongside the emerging criminal-law framework.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗