VZCZCXYZ0000
OO RUEHWEB

DE RUEHUJA #2351/01 3641532
ZNR UUUUU ZZH
O 301532Z DEC 09
FM AMEMBASSY ABUJA
TO RUEHC/SECSTATE WASHDC IMMEDIATE 7873
INFO RUEHOS/AMCONSUL LAGOS 2585
RUEHZK/ECOWAS COLLECTIVE
RHEHNSC/NSC WASHINGTON DC
RUEBWJA/DEPT OF JUSTICE WASH DC
RUEATRS/DEPT OF TREASURY WASHDC
RUEAIIA/CIA WASHINGTON DC
RHMFIUU/FBI WASHINGTON DC
RUEKJCS/DIA WASHINGTON DC
RHMFISS/HQ USEUCOM VAIHINGEN GE
RUZEJAA/JAC MOLESWORTH RAF MOLESWORTH UK

UNCLAS ABUJA 002351 
 
 
SIPDIS 
 
STATE FOR AF/W, INL/AAE, INL/C, INR/AA, SCT, EEB; DOJ for AFMLS, 
OIA, OPDAT; TREASURY for FINCEN 
 
E.O. 12958: N/A 
TAGS: PGOV SNAR KCRM KCOR EFIN KTFN EAID ASEC NI
SUBJECT: 2009-2010 INTERNATIONAL NARCOTICS CONTROL STRATEGY REPORT 
(INCSR) NIGERIA RESPONSE 
 
REF: 114960 
 
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NIGERIA 
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¶1. (U) Nigeria remains a major drug trans-shipment point and a 
significant center for criminal financial activity. Individuals and 
criminal organizations have taken advantage of the country's 
location, porous borders, weak laws, corruption, lack of 
enforcement, and poor socioeconomic conditions to launder the 
proceeds of crime.  Proceeds from drug trafficking, illegal oil 
bunkering, bribery and embezzlement, contraband smuggling, theft, 
and financial crimes, such as bank fraud, real estate fraud, and 
identity theft constitute major sources of illicit proceeds in 
Nigeria.  Advance fee fraud, also known as "419" fraud in reference 
to the fraud section in Nigeria's criminal code, is a lucrative 
financial crime that generates hundreds of millions of illicit 
dollars annually.  Money laundering in Nigeria takes many forms, 
including:  investment in real estate; wire transfers to offshore 
banks; political party financing; deposits in foreign bank accounts; 
use of professional services, such as lawyers, accountants, and 
investment advisers; and cash smuggling.  Nigerian criminal 
enterprises are adept at devising ways to subvert international and 
domestic law enforcement efforts and evade detection. 
 
--------------- 
LEGAL FRAMEWORK 
--------------- 
 
 
¶2. (U) In December 2002, Nigeria passed an amendment to the 1995 
Money Laundering Act extending the scope of the law to cover 
proceeds from predicate offenses other than narcotics trafficking. 
In 2004, the National Assembly repealed the 1995 Money Laundering 
Act as amended and passed the Money Laundering (Prohibition) Act 
(MLPA), which applies to the proceeds of all financial crimes. 
Nigeria also passed an amendment to the 1991 Banking and Other 
Financial Institutions (BOFI) Act expanding coverage to stock 
brokerage firms and foreign currency exchange facilities, giving the 
Central Bank of Nigeria (CBN) greater power to deny bank licenses, 
and allowing the CBN to freeze suspicious accounts.  A third piece 
of legislation, the 2004 Economic and Financial Crimes Commission 
(Establishment) Act, established the Economic and Financial Crimes 
Commission (EFCC), which investigates and prosecutes money 
laundering and other financial crimes, and coordinates information 
 
sharing.  Violation of the EFCC Act carries penalties of up to life 
imprisonment.  Amendments to the EFCC Act gave the EFCC the 
authority to investigate and prosecute money laundering, expanded 
the number of EFCC board members, enabled EFCC police members to 
bear arms, and banned interim court appeals that hinder the trial 
court process.  MLPA and the EFCC Act also established the Nigerian 
Financial Intelligence Unit (NFIU), housed within the EFCC, which 
serves as the central agency for the collection, analysis, and 
dissemination of information on money laundering and terrorist 
financing. 
 
Nigeria also employs the 1995 Foreign Exchange (Monetary and 
Miscellaneous Provisions) Act.  This legislation enhanced the CBN's 
power under the BOFI to deny bank licenses and freeze suspicious 
accounts.  It also strengthened financial institutions by requiring 
more stringent monitoring of accounts, removing a minimum financial 
threshold for suspicious transactions, and lengthening the period 
for retention of records. 
 
¶3. (U) Money laundering controls apply to banks and other financial 
institutions, including stock brokerages and currency exchange 
houses, as well as designated non-financial businesses and 
professions (DNFBPs).  These institutions include dealers in 
jewelry, cars and luxury goods, chartered accountants, audit firms, 
tax consultants, clearing and settlement companies, legal 
practitioners, hotels, casinos, supermarkets and other businesses 
that the Federal Ministry of Commerce (FMC) designates as a money 
laundering risk.  The Special Control Unit Against Money Laundering 
(SCUML) under the Ministry of Commerce monitors, supervises, and 
regulates the activities of DNFBPs. 
 
¶4. (U) In May 2006, the Financial Action Task Force visited Nigeria 
to evaluate revisions made to the government's anti-money laundering 
(AML) regime.  The FATF recognized that the Government of Nigeria 
(GON) had remedied the major deficiencies in its AML regime and 
removed Nigeria from its non-cooperative countries and territories 
(NCCT) list. 
 
¶5. (U) Nigeria has criminalized money laundering and terrorism 
financing through various legal frameworks. In addition to the MLPA 
and the EFCC Act, Nigeria also adopted the following legislation: 
the Nigerian Constitution; Independent Corrupt Practices and other 
Related Offences Commission (ICPC) Act of 2000; Code of Conduct 
Bureau Act; Penal and Criminal Codes; Advanced Fee Fraud and other 
related offences Act of 2007; Federal Inland Revenue Service (FIRS) 
Act of 2007; Nigeria Extractive Industry Transparency Initiative 
(NEITI) Act of 2007; and the National Dug Law Enforcement (NDLEA) 
Act. 
 
¶6. (U) Nigeria has no bank secrecy laws that prevent the disclosure 
of client and ownership information by domestic financial services 
companies to bank regulatory and law enforcement authorities.  The 
MLPA 2004 S12 (4) prohibits banking secrecy / customer 
confidentiality as it applies to AML/CTF.  In addition, a proposed 
amendment of the MLPA 2004 contains a more comprehensive provision 
that prohibits client confidentiality and disclosure of ownership 
information by domestic and offshore financial services companies to 
bank supervisors and law enforcement authorities.  Bearer shares are 
not permitted for banks and companies in Nigeria.  All shares issued 
and allotted must be in the name of a shareholder.  Banks and other 
financial institutions are required to identify and verify the 
identity of their customers before entering into relationships with 
them, as well as update the same periodically.  This provision also 
applies to existing customers.  Records are kept for a minimum of 
five years from the date of severance of the relationship. 
 
¶7. (U) The CBN circular (BSD/13/2006) from August 2006 requires all 
financial institutions to forward Suspicious Transaction Reports 
(STRs) where the suspicious and unusual transactions include 
potential financing of terrorism to the NFIU.  Nigerian financial 
institutions periodically receive the UNSCR 1267 Sanctions 
Committee's consolidated list and have detected one case of 
terrorist financing within the banking system.  Prosecution of that 
case is currently pending. 
 
¶8. (U) Nigeria is a Party to the 1988 UN Drug Convention, the UN 
Convention against Transnational Organized Crime, the UN Convention 
for the Suppression of the Financing of Terrorism, and the UN 
Convention against Corruption. Nigeria ranked 130 out of 180 
countries in Transparency International's 2009 Corruption 
Perceptions Index, moving down from a rank of 122 in 2008. 
 
¶9. (U) The United States and Nigeria have a Mutual Legal Assistance 
Treaty (MLAT), which entered into force in January 2003.  Nigeria 
has signed memoranda of understanding with Russia, Iran, India, 
Pakistan, and Uganda to facilitate cooperation in the fight against 
narcotics trafficking and money laundering.  Nigeria has also signed 
bilateral agreements for information exchange relating to money 
laundering with South Africa, the United Kingdom, and all 
Commonwealth and Economic Community of West African States (ECOWAS) 
countries.  Nigeria is a member of GIABA, a FATF-style regional 
body. 
 
¶10. (U) The Nigerian Financial system does not allow favorable tax 
treatment or freedom from exchange control. There are no shell 
companies permitted in Nigeria. Paragraph 1.3 of the new CBN AML/CTF 
Compliance Manual 2009 states that "financial institutions are not 
permitted to keep anonymous accounts or accounts in fictitious 
names." The Security and Exchange Commission (SEC) does not license 
or regulate casinos or internet gaming sites. 
 
¶11. (U) CBN licenses off-shore banks; however, it performs 
background checks on all applicants.  Two off-shore banks operate in 
Nigeria:  Citibank Nigeria Limited and Standard Chartered Bank 
Limited.  Nominee/anonymous directors are not allowed in Nigeria or 
in Nigerian banks.  Nigeria has no separate regulatory agency for 
off-shore banks. The Central Bank of Nigeria serves as the apex 
regulatory body for all banks operating in Nigeria, whether 
 
off-shore or on-shore.  The same regulatory rules apply to both 
domestic banks and off-shore banks.  However, additional regulation 
applied to off-shore banks in line with the Basle Core Principle of 
Banking Supervision in respect of consolidated supervisions. 
 
¶12. (U) 24 Free Trade Zones (FTZs) exist in Nigeria. Eleven are 
operational and mostly belong to the Federal Government.  The FTZs 
are licensed by the Nigeria Export Processing Zones Authority 
(NEPZA), responsible for the regulation, operation and monitoring of 
FTZs activities in Nigeria.  Standardized procedures exist for FTZs, 
including a thorough registration process involving the 
identification of companies and individuals who want to use the 
zones.  Nigeria has not reported any cases of misuse of the FTZs for 
money laundering or terrorism financing. 
 
¶13. (U) The National Assembly is considering new legislation, 
including the Non-Conviction Based Asset Forfeiture Bill and the 
proposed Special Courts Bill for the speedy adjudication of economic 
and financial crimes cases.  Nigeria has incorporated FATF 
recommendations in its domestic AML/CTF laws and regulations.  The 
FATF 40 plus 9 Special recommendations are essential elements of 
Nigeria's AML/CTF strategy and implementation plans and programs. 
Nigeria is an active member of GIABA, a FATF-Style Regional Body. 
 
 
------------------------ 
LAW ENFORCEMENT AGENCIES 
------------------------ 
 
¶14. (U) Nigeria's legal framework empowers various anti-corruption 
and law enforcement agencies to deal with the challenges of money 
laundering and terrorism financing, including investigation and 
prosecution of money laundering and terrorism financing offenses. 
An apparent lack of political will to enforce the laws and 
continuous delays within the justice sector have hindered the 
progress of many prosecutions and/or investigations of perpetrators 
of these crimes, who are often politically influential. 
 
¶15. (U) The primary institutions dealing with money laundering and 
financial crimes are the Economic and Financial Crimes Commission 
(EFCC), the Nigerian Financial Intelligence Unit (NFIU), the 
Independent Corrupt Practices Commission (ICPC), and the Special 
Control Unit against Money Laundering (SCUML). Several other 
government agencies are involved in investigating financial crimes 
in Nigeria, including the Nigerian Police Force (NPF), the 
Department of State Security (DSS), and NDLEA. The EFCC is the 
coordinating agency.  All relevant agencies are adequately staffed 
and trained. 
 
---- 
EFCC 
---- 
 
¶16. (U) Since its inception in April 2004, the EFCC has held the 
mandate and the capacity to effectively investigate and prosecute 
financial crimes, including money laundering and terrorist 
financing. The EFCC also coordinates agencies' efforts in pursuing 
financial crime investigations. In its first five years of 
existence, the EFCC successfully seized over USD 5 billion in cash 
and property, and repatriated over USD 4.6 million to U.S. entities 
involving advanced fee fraud ("419") scams. About 3,301 petitions 
were received by the EFCC out of which 123 were fully investigated 
and taken to court for prosecution.  74 convictions were secured 
including the conviction and sentencing of former Governor Lucky 
Igbinedion for false declaration and money laundering. However, in 
2009, the EFCC faced significant challenges in fulfilling its 
mandate to fight financial crimes and money laundering.  The EFCC 
has not prosecuted any money laundering related case, nor secured 
any convictions in the past year. 
 
---- 
NFIU 
---- 
 
¶17. (U) The Nigerian Financial Intelligence Unit (NFIU), established 
in 2005, derives its powers from the Money Laundering (Prohibition) 
Act of 2004 and the EFCC Act. It is the central agency for the 
 
collection, analysis and dissemination of information on money 
laundering and terrorist financing.  Nigeria has an operational FIU 
with full membership status in the Egmont Group. The NFIU is 
adequately staffed and is operationally autonomous. Housed within 
the EFCC, it has its own independent budget within the EFCC's 
budget. The NFIU has a Director as the chief accounting officer. Its 
core functions are the receipt and analysis of financial disclosures 
and the dissemination of financial intelligence on money laundering 
and terrorism financing to competent authorities. It is also 
involved in AML/CTF examination and information exchange with other 
FIUs.  The NFIU is an administrative-type FIU with AML/CTF 
regulatory responsibility. Although the NFIU is a significant 
component of the EFCC, complementing the EFCC's Directorate of 
Investigations, it does not carry out its own investigations. The 
Money Laundering (Prohibition) Act, Section 6, requires STRs to be 
submitted by financial institutions and designated non-financial 
businesses and professions, and gives the NFIU the authority to 
receive them. 
 
¶18. (U) The NFIU also receives reports involving the transfer to or 
from a foreign country of funds or securities exceeding U.S. USD 
10,000 in value. All financial institutions and designated 
non-financial institutions are required by law to furnish the NFIU 
with details of these financial transactions. The NFIU has the 
responsibility to examine and supervise financial institutions for 
compliance with AML/CTF laws and regulations in conjunction with 
other regulators, including the CBN, SEC and the National Insurance 
Commission (NAICOM). The NFIU and other regulators are not 
adequately staffed and trained for this purpose. The NFIU has access 
to records or databases of other government agencies and reporting 
entities. The NFIU has formal mechanisms for sharing information 
locally with stakeholder agencies. Similarly, it has formal 
mechanisms to exchange information with international partners both 
at bilateral and multilateral platforms, using the instrumentality 
of MOUs and the Egmont Secured Web. Between January and September 
2009, the NFIU received a total of 826 Suspicious Transaction ports. 
Fifty-five of these were developed and disseminated to relevant 
competent authorities for investigation. 
 
----- 
SCUML 
----- 
 
¶19. (U) Due to Nigeria's primarily cash-based economy, 90 percent of 
money laundering activity reportedly takes place in the informal 
sector. The Special Control Unit Against Money Laundering (SCUML) is 
a special unit under the Ministry of Commerce which monitors, 
supervises, and regulates the activities of businesses and 
professions outside the formal financial sector that are thought to 
pose a money laundering risk. Oversight by the Ministry of Commerce, 
however, has reportedly not been rigorous or effective. 
Consequently, the EFCC decided to fund SCUML and second some of its 
employees to that agency in an effort to rapidly improve its 
investigative and enforcement capacity. In addition, the EFCC 
facilitated the inauguration of a Designated Non-Financial 
Institution (DNFI) Advisory Council which serves as a formal 
platform for partnership between SCUML as the regulator and the 
heads of the DNFI Self Regulatory Organizations (SROs), including 
some Civil Society Organizations (CSOs). The EFCC and SCUML have 
collaborated on efforts to strengthen the Chief Compliance Officers 
Forum, which EFCC/NFIU facilitated. 
 
----- 
NDLEA 
----- 
 
¶20. (U) While the NDLEA has the authority to handle 
narcotics-related cases, it is reported that proceeds of illicit 
traffic in narcotics and psychotropic substances is one of the 
primary sources of money laundering. However, the agency does not 
have any evidence to show that such proceeds are in any way 
connected with financing of terrorism either locally or abroad. The 
proceeds of illicit drugs in Nigeria derive largely from foreign 
criminal activity compared to domestic activities. The generated 
funds are clandestinely repatriated to Nigeria through a variety of 
schemes. The proceeds are controlled by drug trafficking syndicates 
who operate in an organized manner not necessarily as criminal 
 
gangs. Nigeria is a signatory to the World Trade Organization (WTO) 
agreements. Most of the country's trade is tariff-driven which does 
not allow for a flourishing black market of smuggled goods. However, 
one of the schemes used by drug traffickers to repatriate and 
launder their proceeds is through the importation of various 
commodities, predominantly luxury cars and other items such as 
textiles, computers, and mobile telephone units. Nigerian financial 
institutions are also reportedly used for currency transactions 
involving US dollars derived from illicit drugs. Documented evidence 
reveals that cash couriers are used for smuggling dollars into the 
country. In addition, the non-bank financial sector was also 
reportedly being used as a conduit for money laundering. 
 
 
¶21. (U) From January 1, 2009 to September 30, 2009, the NDLEA 
handled a total of 25 money laundering investigations resulting in 
16 arrests. Four of these investigations involving 6 arrested 
persons were related to the smuggling of monetary instruments 
including US dollars that were suspected to be fakes. In a fifth 
investigation,  NDLEA arrested a smuggler of a large amount of US 
dollars and the case was transferred to the EFCC since it did not 
appear to be the proceeds of illicit drug trafficking. Eight of the 
investigations were related to MLAT requests, two of which 
originated from the U.S., while the other six originated from other 
countries. NDLEA has responded to all MLAT requests. Eleven other 
investigations were found to have a drug nexus and were prosecuted. 
Only two suspects had charges vacated because their cases were found 
not to be drug-related and were released. No drug-related 
convictions were obtained but there are 18 pending cases in the 
courts. 
 
---------------- 
ASSET FORFEITURE 
---------------- 
 
¶22. (U) Nigeria has established a legal framework and regulatory 
systems for identifying, tracing, freezing, seizing, and forfeiting 
proceeds of crime. Depending on the nature of the case, the EFCC, 
NDLEA, NPF, or the ICPC would conduct the tracing, seizing, and 
freezing of assets. 
 
¶23. (U) The NDLEA Act made elaborate provisions for the forfeiture 
of a variety of assets acquired with the proceeds of illicit drugs. 
The NDLEA Act delineates procedures for seizing and forfeiting 
subject properties and enumerates the powers of the NDLEA to seize, 
freeze and confiscate proceeds of illicit drugs. Furthermore, under 
the Nigerian Money Laundering (Prohibition) Act (MPLA), assets 
connected to money laundering offences are also subject to 
forfeiture except for offences relating to the non-rendition of 
statutory returns by financial institutions and designated 
non-financial bodies and professions. These provisions cover both 
foreign and domestic assets derived from the proceeds of drugs, as 
well as instrumentalities of drug offences and the conveyance of 
real properties whose owners permit its use for drug cultivation, 
storage, and trafficking. The NDLEA Act also permits the freezing 
and subsequent forfeiture of funds, stocks, or other securities held 
in any financial institution, while the MLPA authorizes forfeiture 
of assets of corporate bodies involved in money laundering 
activities. 
 
¶24. (U) NDLEA's authority to trace, seize, investigate, and freeze 
assets and accounts held by financial institutions is subject to the 
consent of the Attorney General of the Federation before any 
accounts can be frozen. The proceeds from seizures and forfeitures 
pass to the Federal Government of Nigeria (GON), which uses a 
portion of the recovered sums to provide restitution to the victims 
of the criminal acts. The banking community cooperates with law 
enforcement to trace funds and seize or freeze bank accounts. There 
is no period of time specified before assets must be released. 
Frozen assets can be confiscated by the relevant agency handling the 
case. Nigeria does not have an asset forfeiture fund. Consequently, 
seized assets remain in the custody of the seizing agency until they 
revert to the GON. Due to lack of proper accountability, forfeited 
assets are sometimes lost or stolen. 
 
¶25. (U) The NDLEA has a separate Directorate of Assets and Financial 
Investigation (DAFI) dedicated to asset and money laundering 
 
investigations, as well as other AML/CTF enforcement activities. The 
NDLEA Act and MPLA give the agency investigative, police, and 
surveillance powers, including access to any computer 
system/database and wiretap authority. NDLEA can immediately freeze 
assets but has a difficult time in initially tracking them down. 
From January to December 2009, NDLEA reported that it seized a total 
USD 1,631,789 USD in currency and real estate. 
 
¶26. (U) The EFCC Act also provides for the forfeiture of assets and 
properties to the GON after a money laundering conviction. Foreign 
assets are subject to forfeiture by both EFCC and NDLEA. The 
properties subject to forfeiture are listed in EFCC Act and include 
any real or personal property representing the gross receipts 
obtained directly as a result of the violation of the Act, or that 
is traceable to such receipts. Any property representing the 
proceeds of an offense committed under the laws of a foreign 
country, which is punishable by a sentence of more than one year, is 
also forfeitable under EFCC Act. All means of conveyance, including 
aircraft, vehicles, or vessels used or intended to be used to 
transport or facilitate the transportation, sale, receipt, 
possession or concealment of economic or financial crimes, are 
likewise subject to forfeiture. Forfeiture is possible only as part 
of a criminal prosecution. There is no comparable law providing for 
civil forfeiture independent of a criminal prosecution, but the EFCC 
has established a committee to draft legislation to address this 
deficiency. A non-conviction based forfeiture statute is now pending 
in the National Assembly. 
 
------------------- 
TERRORISM FINANCING 
------------------- 
 
¶27. (U) Nigeria has attempted to criminalize the financing of 
terrorism through Section 15 of the EFCC Act. The EFCC has authority 
under the Act to identify, freeze, seize, and forfeit terrorist 
finance-related assets; however, implementation of the existing 
framework has revealed some practical challenges. The EFCC Act does 
not provide a comprehensive framework for criminalizing and pursuing 
the full range of terrorist financing as defined by international 
standards. The Act does not criminalize terrorist financing, nor 
does it reference terrorist financing as a predicate offense for 
money laundering. A comprehensive bill for the prevention of 
terrorism is currently before the National Assembly. If passed, it 
would be Nigeria's first autonomous anti-terrorism law. 
 
 
------------------- 
RECENT DEVELOPMENTS 
------------------- 
 
¶28. (U) In 2008, the Intergovernmental Task Force against Money 
Laundering in West Africa (GIABA) conducted, discussed and adopted 
Nigeria's mutual evaluation. According to the mutual evaluation 
report (MER), significant legal gaps still existed in Nigeria's 
AML/CTF regime. In addition, Nigerian authorities had not issued 
clear guidance to financial institutions, resulting in deficiencies 
related to customer due diligence, beneficial ownership, record 
keeping, and reporting requirements. The MER also noted that the 
NFIU's powers under the EFCC are ambiguous, and its statistics on 
suspicious transaction reports (STRs) and currency transaction 
reports (CTRs) are inconsistent. From October 2008 to September 
2009, the GON's commitment to addressing the deficiencies in its 
framework for combating financial crime and corruption was still not 
clear. However, Nigerian authorities took a few practical steps to 
consolidate some the gains of the previous years with respect to the 
implementation of Nigeria's anti-money laundering and 
counter-terrorist financing (AML/CTF) plans, programs, and 
timetable.   These steps include: 
 
(1) Amendment of the MLPA 2004 
 
¶29. (U) The MLPA 2004 was amended in July 2009 by an 
Inter-Ministerial Committee set up by the Hon. Minister of Justice 
and Attorney General of the Federation. The revised MLPA 2004 
addressed the legal weaknesses raised in Nigeria's AML/CTF MER. The 
proposed amendment bill is in the process of being transmitted to 
the National Assembly (NASS). 
 
 
(2) Anti-Terrorism Bill (ATB) 
 
¶30. (U) The ATB was sent to the NASS as an Executive Bill on October 
12, 2009 by the President. Follow-up action has been intensified by 
the Presidential Inter-Ministerial / Agency Committee on FATF to 
ensure its passage during the first quarter of 2010. 
 
(3) Constitution of Presidential Inter-    Ministerial/Agency 
Committee on FATF 
 
 
¶31. (U) This Committee was established by the President on October 
15, 2009, primarily to ensure the speedy passage of the ATB, the 
amended MLPA 2004 and the implementation of the recommendations 
contained in Nigeria's AML/CTF Mutual Evaluation Report. The 
Committee's membership was drawn from core AML/CTF institutions 
including the Presidency, Office of the Head of Service, Ministries 
of Justice, Finance, and Commerce as well as CBN, ICPC, NDLEA, SEC, 
NFIU, and EFCC. 
 
(4) Joint Capacity Building 
 
¶32. (U) Over 50 participants from stakeholder-institutions 
participated in AML/CTF Pre-Mutual Evaluation training programs 
initiated by the NFIU and supported by GIABA at the EFCC Training 
and Research Institute (TRI) in Abuja. Equally, over 200 
participants attended the annual AML/CTF Summit spearheaded by the 
NFIU in April 2009. In addition, an AML/CTF training program was 
organized for over 500 participants drawn from other financial 
institutions viz. Micro-Finance Banks, Discount Houses, and Primary 
Mortgage Institutions. There are additional joint training programs 
facilitated by other local and international stakeholders. 
Collectively, these initiatives have greatly enhanced cooperation, 
professionalism, and coordination amongst stakeholder institutions. 
 
 
(5) GIABA AML/CTF Mutual Evaluation 
 
¶33. (U) Consistent with the mutual evaluation process of GIABA, 
Nigeria successfully provided a follow-up report to GIABA 
Secretariat in May 2009. The report highlighted the progress made by 
Nigeria in the implementation of the recommendations of the 
country's AML/CTF Mutual Evaluation Report (MER) since its adoption 
in Accra, Ghana in May 2008. 
 
(6)  Inter-Agency Cooperation 
 
¶34. (U) Inter-Agency cooperation was strengthened through the 
platform of the AML/CTF Inter-Ministerial Committee and the Nigeria 
Focal Point Initiative. These platforms provided an avenue for 
collaboration and a coordinated national approach in the fight 
against money laundering and terrorism financing.  Under the 
auspices of the Inter-Ministerial Committee and Focal Point, Nigeria 
now successfully coordinates its responses to the implementation of 
the UN Security Council Resolutions on arms embargos, travel bans, 
and assets freezes with respect to Al-Qaida, Usama bin Laden, and 
the Taliban and other individuals, groups, and entities associated 
with them. 
 
(7) Regulators - Reporting Entities Relationship 
 
¶35. (U) The DNFI Advisory Council which serves as a formal platform 
for partnership between SCUML and the DNFI Self-Regulatory 
Organizations (SROs) was formally launched. Similarly, efforts were 
made to strengthen the Chief Compliance Officers Forum. 
Consequently, the DNFI Advisory Council and the Chief Compliance 
Officers Forum have helped to improve the relationship between 
regulators and the reporting entities. This, in turn, has led to 
greater AML/CTF compliance amongst reporting entities, improvement 
in the quantity and quality of CTR/STR renditions and a general 
deepening of AML/CTF culture in the country. 
 
(8) CBN AML/CTF Compliance Manual 
 
¶36.  (U) The Nigerian authorities undertook a thorough review of the 
old CBN Know Your Customer Manual and added the revisions to the 
 
CBN's AML/CTF Manual 2009. The new manual is very comprehensive, 
meets FATF requirements, and addresses many relevant issues raised 
in Nigeria's AML/CTF MER. 
 
(9) Sensitization and Awareness Creation 
 
¶37.  (U) Regulators and law enforcement agencies embarked on 
intensive AML/CTF sensitization and awareness creation during the 
period under consideration.  For instance, AML/CTF workshops were 
organized for reporting entities and stakeholders, while mass media 
campaigns were increased to reach the vast majority of the public, 
particularly through the EFCC Anti-Corruption Revolution (ANCOR) 
Program in order to enhance public/private sector participation and 
support for the GON's anti-graft program. 
 
------------- 
GOING FORWARD 
------------- 
 
¶39. (U) The GON should ensure the autonomy and independence of the 
EFCC and NFIU from political pressure. In particular, the EFCC needs 
to produce more effective results through prosecutions and 
enforcement actions in financial crimes and corruption 
investigations. The GON should also strengthen SCUML's authority to 
supervise designated non-financial businesses and professions. 
Moreover, the GON should ensure that the NPF has the capacity to 
function as an investigative partner in financial crimes cases, as 
well as work to eradicate any corruption that might exist within its 
own ranks and in other law enforcement bodies. Nigeria should 
re-invigorate its anti-corruption program and support the EFCC, as 
well as the ICPC, in their mandates to investigate and prosecute 
corrupt government officials and individuals. The GON should 
consider establishing a special court with specific jurisdiction and 
trained judges to handle financial crimes. Nigeria should enact a 
law providing for non-conviction-based forfeiture, ensure full 
implementation of its AML/CTF regime, and promote respect for the 
rule of law. Nigerian authorities should work toward a regime 
capable of thwarting money laundering and terrorist financing; and 
work toward full compliance with all relevant international 
standards, eliminating its remaining AML/CTF shortcomings. 
Authorities should work toward the passage of the comprehensive 
anti-terrorism bill in the National Assembly. Finally, the GON 
should continue to engage with the FATF, GIABA, and other 
international organizations. 
 
SANDERS