An Evaluation Of The Legal An Institutional Framework For Combating Money Laundering In The Nigerian Banking Sector, by Jobs Joseph

Abstract

Money laundering remains one of the major financial crimes capable of undermining the integrity and stability of the banking sector. The use of banks and other financial institutions to conceal, transfer and integrate proceeds of unlawful activities into the legitimate economy has created serious challenges for governments and financial regulators across the world. Nigeria has consequently developed a comprehensive legal and institutional framework for preventing, detecting and prosecuting money laundering. The framework includes the Money Laundering (Prevention and Prohibition) Act, 2022, the Economic and Financial Crimes Commission Act, 2004, the Nigerian Financial Intelligence Unit Act, 2018, the Banks and Other Financial Institutions Act, 2020, Central Bank of Nigeria regulations and other related legislation. These laws impose obligations on financial institutions relating to customer identification, customer due diligence, suspicious transaction reporting, record keeping and monitoring of financial transactions.

Despite the existence of these laws, money laundering continues to present significant challenges in Nigeria. The challenges include weak enforcement, institutional coordination problems, technological developments, inadequate compliance by some financial institutions, digital financial crime, shortage of specialised personnel and difficulties associated with investigating and prosecuting complex financial crimes. The emergence of fintech platforms, digital assets and increasingly sophisticated methods of identity fraud has further complicated the fight against money laundering. This article examines the legal and institutional framework for combating money laundering in the Nigerian banking sector. It considers the major laws and institutions involved, examines some of the challenges affecting their effectiveness and makes recommendations for strengthening Nigeria’s anti-money laundering regime.

Keywords: Money Laundering, Banking Sector, Anti-Money Laundering, EFCC, NFIU, CBN, Customer Due Diligence, Financial Crime.

INTRODUCTION

The banking sector plays an important role in the economic development of every country. Banks provide a platform through which individuals and businesses save money, obtain credit, make payments and conduct financial transactions. However, the same financial system can be exploited by criminals to conceal the proceeds of unlawful activities. Money laundering generally involves the process through which proceeds obtained from criminal activities are concealed or disguised in order to make them appear to have originated from legitimate sources.[1] The United Nations has estimated that money laundering globally involves sums running into approximately US$1.6 trillion annually.[2] The scale of the problem demonstrates why financial institutions have become central to international efforts to combat financial crime. Nigeria has also experienced significant challenges associated with illicit financial flows, corruption, fraud, terrorism financing, cybercrime and other forms of financial crime. These activities can generate proceeds which criminals attempt to introduce into the formal financial system. The Nigerian government has consequently enacted several laws and established various institutions to combat money laundering. The Money Laundering (Prevention and Prohibition) Act, 2022 is presently the principal legislation dealing specifically with money laundering. It operates alongside the Economic and Financial Crimes Commission Act, 2004, the Nigerian Financial Intelligence Unit Act, 2018, the Banks and Other Financial Institutions Act, 2020 and regulations issued by the Central Bank of Nigeria.[3] The introduction of the Bank Verification Number (BVN) also represents an important development in strengthening customer identification within the Nigerian banking system. The CBN introduced the BVN in 2014 as a centralised biometric identification system intended to provide customers with a unique identity across the banking industry.[4] However, technological development has also created new avenues through which criminals can exploit financial institutions. Digital banking, fintech platforms, electronic payments and digital assets have made financial transactions faster and more accessible, but they have also created new risks for money laundering. The following are some of the major legal, institutional and practical issues affecting the fight against money laundering in the Nigerian banking sector.

CONCEPT OF MONEY LAUNDERING

Money laundering is the process through which criminals attempt to conceal the origin, ownership or control of property or funds obtained from criminal activities and subsequently introduce such proceeds into the legitimate economy. The Money Laundering (Prevention and Prohibition) Act, 2022 prohibits the concealment or disguise of the origin of proceeds of unlawful activities and also prohibits the conversion, transfer, acquisition, use or possession of such proceeds in circumstances covered by the Act.[5] Money laundering is commonly explained through three principal stages.

1. Placement

Placement involves introducing proceeds of criminal activities into the financial system. For example, a person who obtains a large amount of money through fraud, corruption, kidnapping or other criminal activities may attempt to deposit the proceeds into a bank account or use the money to purchase financial instruments. The purpose at this stage is to move the proceeds away from their original criminal source and into the financial system.

2. Layering

Layering involves carrying out several transactions designed to make it difficult to identify the original source of the funds. The person may transfer money between different accounts, purchase assets, use different financial institutions or conduct international transactions. The more complicated the transactions become, the more difficult it may be for investigators to trace the proceeds to the original criminal activity.

3. Integration

Integration occurs when the proceeds are eventually introduced into the legitimate economy and appear to have been obtained from a lawful source. The criminal may, for example, invest the proceeds in property, businesses, securities or other legitimate economic activities. The three stages demonstrate why banks are particularly important in combating money laundering. Banks are often the institutions through which illicit funds enter, move through and eventually become integrated into the legitimate financial system.

EVOLUTION OF THE LEGAL FRAMEWORK FOR COMBATING MONEY LAUNDERING IN NIGERIA

Nigeria’s legal framework for combating money laundering has developed over several decades. The early framework was largely influenced by the need to prevent the laundering of proceeds derived from drug-related offences. The Money Laundering Decree No. 3 of 1995 represented one of the earliest legislative attempts to address the problem. This was followed by the Money Laundering (Prohibition) Act, 2004 and subsequently the Money Laundering (Prohibition) Act, 2011, as amended in 2012. The present principal legislation is the Money Laundering (Prevention and Prohibition) Act, 2022. The 2022 Act repealed the 2011 legislation and expanded the scope of money laundering offences and the obligations imposed on financial institutions and other reporting entities.[6] The development of the legislation demonstrates the gradual movement of Nigeria’s AML regime from a relatively narrow approach to a broader framework covering a wide range of predicate offences, financial institutions and designated non-financial businesses and professions.

LEGAL FRAMEWORK FOR COMBATING MONEY LAUNDERING IN THE NIGERIAN BANKING SECTOR

The following are some of the major laws governing the prevention and prosecution of money laundering in Nigeria.

1. Money Laundering (Prevention and Prohibition) Act, 2022

The Money Laundering (Prevention and Prohibition) Act, 2022 is the principal legislation governing money laundering in Nigeria. Section 18 prohibits money laundering and criminalises, among other things, concealing or disguising the origin of proceeds of unlawful activity, converting or transferring such proceeds and acquiring, using or possessing property known or reasonably suspected to constitute proceeds of unlawful activity.[7] A person who contravenes the relevant provision may be liable to imprisonment for a term of not less than four years and not more than fourteen years, or a fine of not less than five times the value of the proceeds of the crime, or both.[8] The Act therefore imposes serious penalties on persons who engage in money laundering.

2. Cash Transaction Restrictions

The Act also places limits on cash transactions. An individual is prohibited from making or accepting cash payments exceeding ₦5 million except through a financial institution, while the corresponding limit for a body corporate is ₦10 million.[9] The purpose of the provision is to reduce the use of large amounts of physical cash in transactions and encourage the movement of financial transactions through regulated channels where transactions can be monitored.

3. Reporting of International Transfers

The Act requires transfers to or from a foreign country involving funds or securities exceeding US$10,000 or its equivalent to be reported to the relevant authorities within one day of the transaction.[10] The report is required to contain relevant information concerning the transaction, including the amount and the names and addresses of the sender and receiver. This provision is important because international movement of funds can be used to conceal the origin of illicit proceeds and transfer them beyond the jurisdiction of Nigerian authorities.

4. Customer Due Diligence and Identification

Financial institutions are required to obtain and verify relevant information concerning their customers. Customer Due Diligence is important because financial institutions cannot effectively identify suspicious transactions without first knowing the identity and financial profile of their customers. The CBN’s AML/CFT/CPF regulatory framework requires financial institutions to identify customers and verify their identities using reliable and independently sourced documents, data or information.[11] The CBN also applies a risk-based approach to AML supervision, under which the level of scrutiny is expected to reflect the level of risk associated with particular customers and transactions.[12]

5. Suspicious Transaction Reporting

Financial institutions have a duty to monitor transactions and report suspicious transactions in accordance with the applicable law and regulations. The purpose of suspicious transaction reporting is to enable financial intelligence authorities to identify transactions that may be connected with money laundering, terrorism financing or other financial crimes. The CBN’s AML/CFT regulations require financial institutions to maintain appropriate compliance systems and report suspicious transactions to the Nigerian Financial Intelligence Unit.[13]

6 Preservation of Records

Financial institutions are required to preserve relevant transaction and customer records for at least five years after the completion of the transaction or termination of the business relationship, as applicable.[14] The importance of record keeping cannot be overstated because financial investigations frequently depend upon bank statements, transaction histories, account-opening documents and other financial records. Proper preservation of records therefore assists investigators and prosecutors in reconstructing financial transactions and establishing the movement of illicit funds.

INSTITUTIONAL FRAMEWORK FOR COMBATING MONEY LAUNDERING

The fight against money laundering in Nigeria involves several institutions. No single institution can effectively combat money laundering without cooperation with other relevant agencies.

1. Economic and Financial Crimes Commission

The Economic and Financial Crimes Commission is one of the principal institutions responsible for investigating and prosecuting economic and financial crimes in Nigeria. The EFCC Act gives the Commission powers relating to the investigation and prosecution of economic and financial crimes and the tracing, investigation and recovery of proceeds of financial crimes.[15] The Commission consequently plays an important role in investigating suspected money laundering and bringing offenders before the courts.

2. Nigerian Financial Intelligence Unit

The Nigerian Financial Intelligence Unit is responsible for receiving, analysing and disseminating financial intelligence relating to suspicious financial activities. The NFIU Act, 2018 establishes the Unit and provides it with functions relating to the collection and analysis of financial intelligence.[16] The NFIU also maintains a database of reporting institutions and exercises functions relating to account surveillance, reporting standards and risk assessment.[17] The work of the NFIU is important because financial intelligence can provide the information required by law enforcement agencies to commence or support investigations.

3. Central Bank of Nigeria

The Central Bank of Nigeria plays an important regulatory and supervisory role in relation to banks and other financial institutions under its regulatory jurisdiction. The CBN develops AML/CFT regulations and supervises financial institutions to ensure compliance with applicable requirements.[18] The CBN’s AML/CFT framework covers areas including customer due diligence, suspicious transaction reporting, record keeping, compliance functions, employee training and cooperation with competent authorities.[19] The Bank also uses a risk-based approach in supervising financial institutions for AML/CFT purposes.

4. Nigeria Police Force

The Nigeria Police Force also plays a role in combating financial crime through its general law enforcement functions. The Police may investigate criminal offences and cooperate with specialised agencies where financial crimes overlap with other criminal activities. However, the existence of several agencies involved in financial crime enforcement makes inter-agency cooperation particularly important.

CHALLENGES OF COMBATING MONEY LAUNDERING IN THE NIGERIAN BANKING SECTOR

Despite the existence of an extensive legal and institutional framework, several challenges continue to affect the effectiveness of the fight against money laundering.

The following are some of the challenges:

1. Weak Enforcement

The existence of laws does not automatically guarantee effective enforcement. Money laundering cases can involve complicated transactions, several bank accounts, different jurisdictions and sophisticated financial arrangements. Investigating and prosecuting such cases therefore requires specialised skills and resources. Where investigations are delayed or prosecutions take many years, the deterrent effect of the law may be weakened.

2. Inter-Agency Coordination

Money laundering investigations often require the cooperation of the EFCC, NFIU, CBN, Police and other relevant institutions. Poor communication or duplication of functions among agencies can result in delays and inefficient use of resources. A recent study based on a 2026 field survey reported that 69.6 per cent of respondents identified poor communication as a major barrier to inter-agency collaboration in financial crime control.[20] This demonstrates the need to strengthen institutional mechanisms for sharing information and coordinating investigations.

3. Political and Institutional Interference

The effective prosecution of financial crimes requires independence and institutional commitment. Where investigations involving politically exposed persons or individuals with substantial influence are perceived to be affected by political considerations, public confidence in the enforcement system may be weakened. The problem therefore requires strong institutional safeguards that ensure that investigations and prosecutions are conducted according to law and evidence.

4. Technological Development

The development of electronic banking and fintech has created new opportunities for criminals to move money quickly. Online account opening, electronic payments, mobile banking and digital assets can be exploited where customer identification and transaction monitoring systems are inadequate. The challenge is therefore no longer limited to traditional bank branches. Financial institutions must also monitor digital channels and emerging payment systems.

5. Digital Assets and Cryptocurrency

Digital assets create additional challenges for AML enforcement because transactions may involve multiple jurisdictions, pseudonymous addresses and platforms that operate across borders. The growth of digital assets means that regulators and law enforcement agencies require specialised technical knowledge and tools capable of tracing blockchain transactions and identifying beneficial owners. The EFCC reported in January 2026 that investigations had identified ₦162 billion in cryptocurrency transactions and ₦18.7 billion linked to investment fraud in cases involving alleged failures of due diligence by financial institutions.[21] The figures were reported by the EFCC in connection with ongoing investigations and should therefore be understood as investigative figures rather than findings of final judicial liability.

6. Challenges Associated with BVN and Identity Verification

The introduction of the BVN has strengthened customer identification in the Nigerian banking system. However, identity-based fraud can still occur where criminals exploit stolen credentials, compromised telephone numbers or weaknesses in customer onboarding processes. The CBN has continued to strengthen the BVN framework, including through the integration of BVN and NIN requirements for specified categories of accounts and wallets.[22] The effectiveness of identity verification therefore depends not only on having a unique identification number but also on ensuring that the identity attached to an account belongs to the person actually controlling the account.

7. Shortage of Skilled Personnel

Money laundering investigations require persons with specialised knowledge of accounting, banking, taxation, digital forensics, blockchain technology and financial investigation. A shortage of adequately trained personnel may affect the ability of enforcement agencies to investigate complex transactions and present evidence effectively before the courts. Continuous training and recruitment of specialised personnel are therefore necessary.

8. Judicial Delays

Money laundering cases may involve extensive documentary and electronic evidence. Where cases remain before the courts for extended periods, the recovery of assets and final determination of criminal liability may be delayed. A 2020 ICPC survey also documented substantial corruption-related payments reported within the justice sector between 2018 and 2020, with the survey recording approximately ₦9.457 billion in money reported as demanded, offered or paid in the sector.[23] The finding demonstrates the importance of strengthening judicial integrity and ensuring that financial crime cases are handled within a fair and efficient judicial process.

9. Lack of Effective Whistleblower Protection

Persons who possess information about money laundering may sometimes be reluctant to report because of fear of retaliation. An effective whistleblower protection framework can encourage the reporting of suspicious activities and provide enforcement agencies with information that may otherwise remain unavailable.

INTERNATIONAL BANKING SCANDALS AND LESSONS FOR NIGERIA

International banking scandals demonstrate that money laundering is not a problem peculiar to developing countries. For example, HSBC agreed in 2012 to pay approximately US$1.9 billion to resolve US authorities’ allegations involving AML and sanctions-control failures.[24] The Danske Bank case also demonstrated how large amounts of suspicious transactions can move through international banking systems. Investigations concerning its Estonian branch involved approximately €200 billion in potentially suspicious payments.[25] The Panama Papers disclosure in 2016 further demonstrated the difficulty of tracing beneficial ownership through offshore structures and complex corporate arrangements.[26] These cases demonstrate that sophisticated AML laws must be supported by effective compliance systems, beneficial ownership transparency, continuous monitoring and strong enforcement. Nigeria can learn from these international experiences by ensuring that regulatory compliance is not treated as a mere formal requirement.

SOCIO-ECONOMIC EFFECTS OF MONEY LAUNDERING

Money laundering does not affect only financial institutions. It has wider consequences for the Nigerian economy and society.

1. Loss of Government Revenue

Money laundering is frequently associated with predicate offences such as corruption, fraud, tax crimes and smuggling. Where proceeds of such offences are successfully concealed, government may lose revenue that could otherwise have been used for public services and development.

2. Economic Distortion

Money laundering can distort legitimate economic activities because criminals may invest illicit funds without considering ordinary commercial risks. Such investment can affect property prices, businesses and other markets and may create unfair advantages for persons using criminal proceeds.

3. Loss of Confidence in Financial Institutions

The banking sector depends heavily upon public confidence. Where financial institutions are repeatedly associated with fraudulent transactions or failures in customer due diligence, public confidence in the financial system may be affected. Banks therefore have an important responsibility to maintain effective AML systems and protect the integrity of the financial system.

4. Financing of Other Criminal Activities

The proceeds of money laundering may be connected with organised crime, fraud, kidnapping, terrorism financing, trafficking and other unlawful activities. The prevention of money laundering is therefore not merely a banking issue. It is also an important component of broader national security and crime prevention.

5. International Reputation

The effectiveness of Nigeria’s AML regime also affects its international financial relationships. Nigeria was placed under FATF increased monitoring in 2023 but subsequently completed the relevant action plan and was removed from FATF increased monitoring in October 2025.[27] Nigeria’s removal from the FATF increased-monitoring list represents progress, but it also demonstrates the importance of maintaining effective AML/CFT measures because international assessments continue to consider the effectiveness of national systems.

RECOMMENDATIONS

In order to strengthen the legal and institutional framework for combating money laundering in the Nigerian banking sector, the following recommendations are made:

1. Strengthening Enforcement

Law enforcement agencies should be provided with adequate financial, technological and human resources to investigate and prosecute money laundering cases. Specialised financial crime units should also be strengthened to handle complex banking, digital and cross-border transactions.

2. Improved Inter-Agency Cooperation

There should be an effective information-sharing mechanism linking the EFCC, NFIU, CBN, Police and other relevant agencies. A secure integrated system for sharing financial intelligence can reduce duplication of investigations and enable agencies to respond more quickly to suspicious transactions.

3. Strengthening Digital Forensic Capacity

The government should invest in modern digital forensic tools capable of analysing electronic transactions, mobile payments, cryptocurrency transactions and other forms of digital financial activity. Investigators should also receive continuous training in blockchain analysis, cybercrime investigation and digital evidence.

4. Improved Customer Due Diligence

Banks, fintech companies and other financial institutions should strictly comply with customer identification and verification requirements. Customer due diligence should not be treated as a one-time exercise. Financial institutions should continuously monitor customer activity and update customer information according to the level of risk.

5. Strengthening BVN and NIN Integration

The BVN and NIN systems should continue to be strengthened and effectively integrated in accordance with applicable CBN requirements. The objective should be to ensure that financial institutions can reliably establish the identity of persons opening and operating accounts.

6. Regulation of Fintech and Digital Assets

The rapid development of fintech and digital assets requires continuous regulatory attention. Financial technology companies should be subjected to appropriate AML requirements, including customer identification, beneficial ownership checks, transaction monitoring and suspicious transaction reporting.

7. Judicial Efficiency

Measures should be adopted to reduce unnecessary delays in financial crime cases. At the same time, expeditious determination must not compromise the constitutional rights of accused persons to fair hearing and due process.

8. Protection of Whistleblowers

Nigeria should strengthen statutory protection for persons who report information concerning money laundering and related financial crimes. Such protection should address confidentiality, retaliation and other risks associated with reporting financial crimes.

9. Continuous Review of AML Laws

The legal framework should be periodically reviewed to address new methods of money laundering.Emerging technologies such as artificial intelligence, digital assets, decentralised finance and new payment systems require regulators to continuously evaluate existing AML mechanisms.

10. Public Awareness

Banks and government institutions should increase public awareness concerning money laundering and financial fraud. Customers should be educated on the dangers of allowing other persons to use their bank accounts, sharing banking credentials and participating in suspicious financial transactions.

CONCLUSION

Money laundering remains a serious threat to the integrity of the Nigerian banking sector and the wider economy. Criminals continue to develop new methods of disguising and transferring illicit proceeds, making it necessary for the legal and institutional framework to develop alongside financial innovation. Nigeria has established a broad legal framework through the Money Laundering (Prevention and Prohibition) Act, 2022, the EFCC Act, the NFIU Act, BOFIA and CBN AML/CFT regulations. These laws impose important obligations on financial institutions and provide enforcement agencies with powers to investigate, analyse, prosecute and recover proceeds of financial crimes. The establishment of the NFIU and the supervisory role of the CBN have also strengthened the institutional structure for preventing money laundering. The EFCC remains an important enforcement institution, while other law enforcement agencies contribute to the investigation and prosecution of related offences. However, the existence of laws alone cannot eliminate money laundering. Weak enforcement, inadequate coordination, technological developments, identity-related fraud, digital assets, shortage of specialised personnel and judicial delays continue to create challenges. It is therefore submitted that the effectiveness of Nigeria’s AML regime depends upon the practical implementation of existing laws. Greater inter-agency cooperation, improved digital forensic capacity, stronger customer due diligence, effective regulation of fintech and digital assets, judicial efficiency and continuous review of the legal framework are necessary. The removal of Nigeria from the FATF increased-monitoring list in October 2025 demonstrates progress in the country’s AML/CFT framework.[28] Nevertheless, the progress must be sustained through continuous enforcement, institutional accountability and adaptation to emerging financial technologies. A strong AML regime is ultimately necessary not only to protect banks but also to protect the Nigerian economy, strengthen public confidence in financial institutions and prevent the financial system from being exploited for criminal purposes.

FOOTNOTES

[1] Central Bank of Nigeria, Anti-Money Laundering and Combating the Financing of Terrorism Regulations; see also Central Bank of Nigeria, ‘Rule Book Volume III’, discussing money laundering as the concealment of the origin and ownership of proceeds of criminal activities.

[2] United Nations, ‘Illicit Financial Flows’, estimating global money laundering at approximately US$1.6 trillion annually.

[3] Nigerian Financial Intelligence Unit, Laws and Regulations, listing the Money Laundering (Prevention and Prohibition) Act 2022, NFIU Act 2018 and related AML/CFT legislation and regulations.

[4] Central Bank of Nigeria, ‘Bank Verification Number’, explaining the introduction of the BVN in 2014 as a centralised biometric identification system for customers of Nigerian banks.

[5] Money Laundering (Prevention and Prohibition) Act, 2022, s 18(2).

[6] Money Laundering (Prevention and Prohibition) Act, 2022; the Act repealed the Money Laundering (Prohibition) Act 2011. See also National Assembly, ‘Senate Passes Bill to Amend Money Laundering Act’, 17 March 2022.

[7] Money Laundering (Prevention and Prohibition) Act, 2022, s 18(2).

[8] ibid, s 18(3).

[9] ibid, s 2(1).

[10] ibid, s 3(1). The provision requires the relevant international transfer to be reported within one day of the transaction.

[11] Central Bank of Nigeria, Anti-Money Laundering, Combating the Financing of Terrorism and Countering Proliferation Financing of Weapons of Mass Destruction in Financial Institutions Regulations, 2022, provisions on customer identification and verification.

[12] Central Bank of Nigeria, ‘Anti-Money Laundering and Counter Financing Terrorism’, explaining the CBN’s risk-based AML/CFT supervisory approach.

[13] Central Bank of Nigeria, AML/CFT/CPF Regulations, 2022, provisions concerning suspicious transaction reporting, customer due diligence, record keeping and employee training.

[14] Money Laundering (Prevention and Prohibition) Act, 2022, s 8(1).

[15] Economic and Financial Crimes Commission (Establishment) Act, 2004.

[16] Nigerian Financial Intelligence Unit Act, 2018, ss 2–4.

[17] ibid, ss 15–21.

[18] Banks and Other Financial Institutions Act, 2020; see also Central Bank of Nigeria, AML/CFT/CPF Guidelines for Licensing of Banks and Other Financial Institutions, issued pursuant to s 66 of BOFIA 2020.

[19] Central Bank of Nigeria, AML/CFT/CPF Regulations, 2022.

[20] See generally, ‘Inter-agency collaboration and the effectiveness of financial crime control in Nigeria’ (2026), reporting a field survey in which 69.6 per cent of respondents identified poor communication as a major barrier to inter-agency collaboration.

[21] Economic and Financial Crimes Commission, reported in January 2026 as identifying ₦162 billion in cryptocurrency transactions and ₦18.7 billion connected with investment fraud in ongoing investigations involving alleged due-diligence failures.

[22] Central Bank of Nigeria, ‘Bank Verification Number’, noting the December 2023 requirement concerning BVN and NIN for specified tiers of accounts and wallets.

[23] Independent Corrupt Practices and Other Related Offences Commission, Nigeria Corruption Index: Report of a Pilot Survey 2020, recording approximately ₦9.457 billion in corruptly demanded, offered and paid amounts reported by justice-sector respondents between 2018 and 2020.

[27] US Department of Justice, ‘HSBC Holdings Plc and HSBC Bank USA N.A. Admit to Anti-Money Laundering and Sanctions Violations’, 11 December 2012.

[28] European Parliament, Money Laundering Risks in the EU Banking Sector, discussing the Danske Bank Estonia case and the approximately €200 billion in transactions investigated.

[29] International Consortium of Investigative Journalists, The Panama Papers, 2016.

[27] Financial Action Task Force, ‘Jurisdictions under Increased Monitoring – 24 October 2025’, removing Nigeria from increased monitoring after the country completed its Action Plan.

[28] Financial Action Task Force, ‘Outcomes FATF Plenary, 22–24 October 2025’, confirming that Nigeria was removed from the list of jurisdictions under increased monitoring following progress in addressing identified AML/CFT/CPF deficiencies.

Author: Job Joseph, DL, LL.B(Hons), ABU Zaria