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Cablegate: 2009-2010 International Narcotics Control Strategy Report

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

-------
NIGERIA
-------

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In 2004, the National Assembly repealed the 1995 Money Laundering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

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