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 (D1–D6)

Sources

Role actions

Horizon <90d

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.

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

Read full brief

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.

weekly_brief_draft · JID NG

Domain intelligence (D1–D6)

D1 Sanctions

Not covered

Sanctions is not yet covered for this jurisdiction in this report.

D2 Beneficial Ownership and Corporate Transparency

Beneficial Ownership and Corporate Transparency

In Nigeria, the directly relevant beneficial-ownership development this cycle is domestic and sector-specific: the Central Bank of Nigeria's circular dated 15 June 2026 requires banks, payment service banks, mobile-money operators, switches and super-agents to disclose ultimate beneficial owners of significant shareholders and to maintain continuously updated ownership records. This closes a transparency gap of the kind previously flagged in Nigeria's FATF listing history and is framed by the CBN as an AML-alignment measure. Corroborating this reading, Nigeria's sustained exit from the FATF grey list, confirmed off the 22-jurisdiction list as of the 19 June 2026 plenary after an October 2025 delisting, sits alongside this new BO-disclosure architecture as part of the same broader transparency-strengthening trajectory the FATF action plan required.

Globally, the EU AML Package, comprising the AML Regulation (Reg (EU) 2024/1624, directly applicable), the sixth AML Directive transposed per Member State, and the AMLA Regulation (Reg (EU) 2024/1620) establishing the Anti-Money Laundering Authority, sets the structural direction for beneficial-ownership transparency and is shifting supervision from purely national authorities toward a hybrid EU-level regime. Nigeria sits outside this EU perimeter entirely; the AMLA architecture is durable global backdrop here, not the primary subject matter for a Nigerian reading. In Nigeria, the directly relevant development is the CBN's own domestic disclosure mandate, layered onto standing VASP financial-institution designation under the Money Laundering (Prevention and Prohibition) Act 2022, which already brings virtual asset service providers within SCUML and EFCC AML/CFT supervision as beneficial-ownership-relevant reporting entities.

No primary CBN circular text was directly retrieved this cycle for the UBO-disclosure measure; the finding rests on corroborated trade-press reporting rather than the regulator's own published text, a gap that should be resolved with primary CBN documentation in a future cycle.

Outlook

The practical test for Nigeria's new UBO-disclosure regime will be whether the continuously-updated-ownership-record requirement is enforced through the CBN's supervisory examination cycle, and whether it is cross-referenced by the EFCC in future corporate-entity prosecutions of the kind already underway against firms such as Cresco Oil and Gas Ltd. Retrieval of the primary CBN circular text remains an outstanding priority for confirming the precise scope of covered entities and the compliance timeline.

D3 Enabler Jurisdictions

Not covered

Enabler Jurisdictions is not yet covered for this jurisdiction in this report.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto, Digital Assets, and Financial Innovation

Crypto, Digital Assets, and Financial Innovation

Nigeria's digital-asset regulatory architecture advanced this cycle through the Presidential Executive Order on Virtual Assets Coordination, signed by President Tinubu on 17 July 2026, which establishes a Virtual Asset Council to coordinate the overlapping mandates of the Securities and Exchange Commission, the Central Bank of Nigeria and other authorities over crypto activity. The Order is a coordination mechanism, not a new substantive licensing rulebook, and is presented as a response to a fragmented regulatory landscape that had previously exposed Nigerian residents to unchecked losses from unregulated operators.

This sits within a standing regulatory-perimeter fact directly relevant to financial-integrity supervision: virtual asset service providers are designated as financial institutions under the Money Laundering (Prevention and Prohibition) Act 2022, which brings them within the AML/CFT supervisory reach of SCUML and the EFCC. The Virtual Asset Council's coordinating role therefore operates on top of, rather than replacing, this existing AML/CFT designation.

Globally, FATF's virtual-asset standards and instruments such as MiCA provide structural backdrop for crypto-integrity regulation, but for Nigeria the directly relevant story is domestic: the Executive Order's coordination architecture, layered onto the CBN's continuing sandbox activity for VASP-track digital-asset firms, and the SEC's own rule-making trajectory in this space. The overlapping-mandate problem the Order is designed to solve is itself a financial-integrity signal: a fragmented supervisory landscape is precisely the condition in which illicit-finance risk in crypto activity tends to go undetected, so the coordination mechanism should be read as an architecture-level risk-mitigation step rather than an incident response.

Outlook

Whether the Virtual Asset Council produces a genuinely consolidated AML/CFT rulebook for virtual asset service providers, or remains a coordination layer atop the SEC's and CBN's separately-exercised powers, is the key open question for this domain. Continued monitoring of SEC rule-making activity and any CBN sandbox-track developments affecting VASPs will clarify whether Nigeria's crypto AML/CFT perimeter is converging toward a single supervisory voice.

D6 Compliance Technology and Active Defence

Compliance Technology and Active Defence

Real-time AML transaction monitoring became mandatory for Nigerian fintechs in 2026, with the Central Bank of Nigeria's mandate carrying an audit-backed enforcement rollout timeline. This represents a meaningful architecture-level shift in compliance-technology expectations: rather than relying on periodic or manual transaction review, regulated fintechs are now expected to operate continuous, real-time monitoring capability.

The finding, however, carries only uncertain confidence, and for a structural reason worth foregrounding rather than glossing over: a documented gap exists between this new supervisory expectation and the industry's current AI/ML-based monitoring maturity. A mandate that outpaces the compliance-technology capacity of the regulated population is itself an analytically significant signal, distinct from the mandate's mere existence. Enablement-as-signal reasoning applies directly here: the absence, so far, of confirmed enforcement action under this mandate may reflect either a grace period built into the rollout timeline, or a genuine capacity shortfall across the fintech sector that supervisors have not yet chosen to test through enforcement.

This compliance-technology development sits alongside, and is reinforced by, the CBN's payments-data-localisation requirement, under which Nigeria-originated payments transaction data must be stored and managed within Nigeria, with compliance required by 31 December 2026. Read together, the two measures point toward a domestic supervisory infrastructure build-out: real-time monitoring capability paired with domestically-retained transaction data creates the technical precondition for more effective domestic AML surveillance, whatever the current maturity gap.

Outlook

The audit-backed enforcement rollout timeline for the real-time monitoring mandate is the concrete date to track: whether CBN audits translate the maturity gap into enforcement action, or whether the timeline is extended, will determine whether this becomes a genuine compliance-technology uplift or a nominal requirement. The data-localisation deadline of 31 December 2026 is a second concrete date against which to test whether the domestic-data precondition for effective monitoring has actually been met.

D7 AML/CTF Regime

AML/CTF Regime

Nigeria's AML/CTF regime this cycle is defined by the durability of its FATF grey-list exit. Nigeria was removed from the list at the 24 October 2025 plenary after completing a 19-point action plan, and it remained off the 22-jurisdiction list as of the 19 June 2026 plenary, with the next plenary scheduled for October 2026. Sustaining delisted status across three consecutive plenaries is a structural signal distinct from the initial delisting event: it indicates the underlying reforms behind the action plan are being maintained rather than reversed.

The Economic and Financial Crimes Commission's enforcement activity is credited as a contributor to the sustained delisting, and its 2026 prosecution record shows continuity: at least ten corporate entities, including Cresco Oil and Gas Ltd and Abu-Haneefa Oil and Gas Ltd, are being prosecuted for fraud and money-laundering offences totalling several billion naira. This reflects a shift toward pursuing corporate entities and executives directly rather than politically exposed persons alone, a pattern consistent with maturing AML/CTF enforcement architecture rather than isolated incident response.

Virtual asset service providers remain designated as financial institutions under the Money Laundering (Prevention and Prohibition) Act 2022, placing them within SCUML and EFCC AML/CFT supervision as a standing regulatory-perimeter fact. This designation is what allows the Virtual Asset Council's coordination architecture (established by the July 2026 Executive Order) to operate within an existing AML/CFT supervisory framework rather than a regulatory vacuum. The EU AML Package (AMLR, 6AMLD, AMLA Regulation) is not directly binding on Nigeria as a non-EEA jurisdiction, and no interaction was identified this cycle.

Outlook

The October 2026 FATF plenary is the immediate date to watch: a third consecutive grey-list-free outcome would further confirm that Nigeria's 19-point action plan reforms have taken durable hold rather than representing a temporary compliance push ahead of review. Continued EFCC corporate-prosecution volume will be a useful indicator of whether enforcement intensity, credited as contributing to the original delisting, is being sustained.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon

Consultation2027-Q1 · ±half_year

SEC proposed rules on digital/virtual asset operations, custody and markets

Foreign-currency-pegged stablecoins would require SEC approval before listing or consumer holding; digital-asset issuance, custody, tokenisation and advisory activities would come under a consolidated rulebook.

Source

Adopted2027-Q2 · ±quarter

SEC VASP minimum-capital compliance deadline

Affected regulated entities must meet revised minimum-capital requirements by 30 June 2027 per SEC Circular No. 26-1 (16 Jan 2026).

Source

2 dated · 3 pending date · baseline financial-integrity-2026-07-05

Role action cards

MLRO

Nigeria's sustained FATF delisting and new CBN UBO-disclosure mandate both bear directly on suspicious-activity reporting posture.

The CBN's 15 June 2026 UBO-disclosure circular for banks, PSBs, mobile-money operators, switches and super-agents creates a new ownership-transparency data point relevant to customer due diligence, while Nigeria's sustained grey-list exit through the June 2026 FATF plenary reduces the enhanced-due-diligence trigger previously associated with Nigerian counterparties under a call-for-action or increased-monitoring designation.

2 evidence refs

Compliance

New CBN UBO-disclosure, data-localisation and real-time-monitoring mandates each carry distinct compliance-framework implications.

Compliance functions with Nigerian exposure face three concurrent obligations this cycle: UBO-disclosure record-keeping for significant shareholders, data-localisation of Nigeria-originated payments data by 31 December 2026, and mandatory real-time transaction monitoring with an audit-backed rollout timeline that outpaces documented industry monitoring maturity.

3 evidence refs

Legal

The Virtual Asset Council's coordination architecture clarifies, but does not yet resolve, overlapping SEC/CBN crypto jurisdiction in Nigeria.

The 17 July 2026 Executive Order establishes a coordinating body without displacing SEC's or CBN's existing statutory powers over virtual assets, meaning legal exposure analysis must still track both regulators' separate rule-making rather than relying on a single consolidated authority.

1 evidence refs

Board

Nigeria's sustained FATF delisting through three plenaries is a materially favourable jurisdiction-risk signal for institutional exposure decisions.

Sustained grey-list-free status since October 2025, confirmed again in June 2026, reduces reputational and correspondent-banking friction previously associated with Nigerian counterparty exposure, though this should be weighed against emerging compliance-cost increases from new CBN mandates.

1 evidence refs

CTO

Real-time AML monitoring and payments-data-localisation mandates require technical infrastructure investment ahead of 2026-2027 deadlines.

CBN's real-time transaction-monitoring mandate and the data-localisation requirement (compliance by 31 December 2026) together imply that Nigeria-facing payments infrastructure must support both domestic data residency and continuous AML/CFT monitoring capability, an area where documented industry maturity currently lags supervisory expectation.

2 evidence refs

Risk

A documented gap between real-time-monitoring mandate and industry AI/ML maturity is an emerging model-risk and compliance-gap signal.

The mandate's audit-backed enforcement timeline creates near-term exposure for firms whose transaction-monitoring technology has not kept pace with the regulatory expectation, a risk that compounds with the new UBO-disclosure and data-localisation obligations landing in the same period.

3 evidence refs

Operations

No material change for this persona this cycle.

No material change for this persona this cycle

Audit

EFCC's expanding corporate-prosecution volume and new CBN mandates both expand the evidentiary and control-testing scope for Nigerian exposure.

The EFCC's prosecution of at least ten corporate entities in 2026, alongside new UBO-disclosure and real-time-monitoring requirements, means audit trails for Nigerian counterparties now require testing against a wider set of controls than in prior cycles.

3 evidence refs

Decision lens

MLRO

Nigeria's sustained FATF delisting and new CBN UBO-disclosure mandate both bear directly on suspicious-activity reporting posture.

Compliance

New CBN UBO-disclosure, data-localisation and real-time-monitoring mandates each carry distinct compliance-framework implications.

Legal

The Virtual Asset Council's coordination architecture clarifies, but does not yet resolve, overlapping SEC/CBN crypto jurisdiction in Nigeria.

Board

Nigeria's sustained FATF delisting through three plenaries is a materially favourable jurisdiction-risk signal for institutional exposure decisions.

CTO

Real-time AML monitoring and payments-data-localisation mandates require technical infrastructure investment ahead of 2026-2027 deadlines.

Risk

A documented gap between real-time-monitoring mandate and industry AI/ML maturity is an emerging model-risk and compliance-gap signal.

Operations

No material change for this persona this cycle.

Audit

EFCC's expanding corporate-prosecution volume and new CBN mandates both expand the evidentiary and control-testing scope for Nigerian exposure.

Shared evidence: 4 refs

Scenario sketches

Illustrative: AMLA hybrid supervision and non-EEA enabler-perimeter effects

Illustrative scenario for analytical orientation only: as the EU's AMLA moves toward direct and indirect supervision of cross-border obliged entities under the AMLA Regulation, alongside the directly-applicable AMLR and per-state 6AMLD transposition, non-EEA jurisdictions such as Nigeria could see indirect effects through correspondent-banking de-risking pressure or through EU-domiciled counterparties applying stricter enhanced-due-diligence standards to Nigerian-linked beneficial-ownership structures, even though Nigeria itself sits outside the AMLA supervisory perimeter. This is architecture-over-incident framing: the shift in EU supervisory structure, not any single enforcement event, is the mechanism illustrated.

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 material change identified this cycle in Russian sanctions-evasion architecture as it pertains to or transits Nigeria.
T2 · EU AML Package / AMLA	no_change	Not applicable as a binding regime for NG (non-EEA, autonomous jurisdiction); no AMLR/6AMLD/AMLA development affects Nigeria directly this cycle.
T3 · FATF Grey List	watch	Nigeria remains off the FATF grey list (exited 24 October 2025) but EFCC/NFIU ran a joint readiness stocktake ahead of the 2027 Mutual Evaluation.
T4 · Beneficial-Ownership Register Status	watch	CAC's Beneficial Ownership Register is operational, but CAC itself now acknowledges three fragmented BO systems (CAC/NEPZA/NEITI) and is pushing harmonisation.
T5 · Crypto & Digital-Asset Integrity	watch	SEC's Proposed Rules on Digital and Virtual Asset Operations remain under post-consultation review; concurrently EFCC obtained BOFIA convictions against 21 unlicensed operators.
T6 · Sanctions Regime Divergence	no_change	No NG-specific sanctions-divergence development was identified this cycle.

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

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

Three-day stocktake (29 Sept-2 Oct 2026) at EFCC HQ Abuja reviewing AML/CFT progress ahead of Nigeria's 2027 FATF Mutual Evaluation. SRC-fim-NG-002

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. SRC-fim-NG-005

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. SRC-fim-NG-007

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. SRC-fim-NG-008

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. SRC-fim-NG-009

Probable · 1 source