In Season Three of Compliance Training for Operators, EFCC, NFIU Highlight Increased Scrutiny on Gaming Sector

Nseobong Okon-Ekong and Iyke Bede attended a recent training in Lagos for operators in the gaming industry during which participants learned practical steps required to meet anti-money laundering  and counter-terrorism financing  standards specific to the gaming industry

To strengthen regulatory compliance within Nigeria’s gaming sector, the three major umbrella trade groups in the sector; Association of Nigerian Bookmakers (ANB), Nigeria Licensed Lottery Operators Forum and the Association for Casino and Machine Operators in Nigeria invited personnel from the Economic and Financial Crimes Commission (EFCC), through its Special Control Unit Against Money Laundering (SCUML) and the Nigerian Financial Intelligence Unit (NFIU) for a focused training session for gaming operators and other stakeholders classified as Designated Non-Financial Businesses and Professions (DNFBPs).

The session, titled ‘Training/Interactive Session on Compliance 3.0 with SCUML and NFIU’, was designed to deepen participants’ understanding of their legal obligations, the risks of non-compliance, and the practical steps required to meet anti-money laundering (AML) and counter-terrorism financing (CTF) standards specific to the gaming industry.

The training opened with a detailed presentation by ACE II Folashade Oluwasanya of SCUML, who provided a comprehensive breakdown of the 2022 Anti-Money Laundering Act. Her presentation laid out the regulatory framework within which gaming operators are expected to function, and the various tools available to help them meet these obligations. The overall goal of the instructions was to make it clear that where there are laws, there are commensurate punishment. Participants were reminded that there is increased scrutiny on the sector because it has been identified as a pliable avenue for money laundering and terrorism financing.

She highlighted that registration with SCUML remains a fundamental requirement. Operators not registered are automatically flagged during inspections, which could be onsite, offsite, or spot inspections—the last requiring no prior notification.

Oluwasanya also stressed the importance of tracking currency transactions, and cash-based transactions, which are common in the gaming environment. Operators were urged to develop strong internal control systems that include Know Your Customer (KYC) and Customer Due Diligence (CDD) processes, with particular attention to identifying both legal and beneficial owners of registered companies in Nigeria, aided by resources such as the Corporate Affairs Commission (CAC) portal. A demonstration of how this can be achieved was carried out during the training session, as participants were taken through a step-by-step procedure to unmask the real owners of any corporate entity. A beneficial owner was identified as anyone who controls shares of a company, five per cent and above. It was emphasized that a legal owner of a company can be quite different from a beneficial owner.

Operators in the gaming sector were alerted on the existence of a Targeted Financial Sanctions (TFS) list and the importance of always checking if their clients or vendors are on this record. Once identified, a gaming operator must stop dealing with them and to report to the appropriate government agency immediately. Owing to the fact that some individuals may bear the same names, participants at the training were taught how to check their unique identifiers. For instance, date of birth, place of birth, state of origin, local government area and nationality. The trainers laid emphasis on the difference between money laundering and terrorism financing. While money laundering was identified as a way of making dirty money clean, terrorism financing was described as any form of aiding or abetting terrorist operations. 

Another phrase that attracted participants’ interest was about politically exposed persons (PEPs)—for example, civil servants from the designation of Assistant Director. If persons under this category carry on, even the smallest financial transaction with a gaming industry operator, they are supposed to file a report on it to the appropriate government agency. PEPs require a heightened level of scrutiny due to their exposure to public funds and influence.

The session outlined clear steps for implementing an effective compliance structure, including establishing AML policies, appointing a compliance officer, and ongoing staff training. Particular attention was given to the requirement for operators to report Suspicious Transactions (STRs) to the NFIU.

Participants were also introduced to NIPSER, a platform used to check entities linked to terrorism financing. This tool, along with proper internal screening procedures, is intended to strengthen the industry’s defence against abuse.

Oluwasanya also noted the cash transaction thresholds that must be reported: ₦5 million for individuals and ₦10 million for businesses. These thresholds are critical in determining when reports should be filed and in identifying unusual transaction patterns.

A separate session, delivered by Mr. Dominic Offor, Head, DNFBPs Compliance of the NFIU focused on Nigeria’s standing with the Financial Action Task Force (FATF). The country remains on the grey list, though progress is being made. According to the NFIU representative, 82 of 84 recommended actions have been fulfilled, and there is optimism that Nigeria could be delisted before the end of the year.

The NFIU session also featured a case study exercise, designed to test participants’ ability to detect suspicious transactions within everyday operations. Gaming operators were encouraged to apply these insights to real-world scenarios in order to build a stronger culture of compliance within their businesses.

The training made clear that compliance is not a one-time task but a continuous responsibility. As scrutiny of DNFBPs increases, operators in the gaming sector are expected to adopt a proactive approach in identifying risks, reporting red flags, and staying up to date with regulatory expectations.

By aligning with SCUML and NFIU’s guidance, operators not only avoid penalties but also contribute to the credibility and sustainability of Nigeria’s growing gaming industry.