Matters Arising From Nigeria’s Removal From the FATF Grey List

EbenezER Onyeagwu

Introduction – From Compliance to Confidence

When an aircraft takes off after a long taxi on the runway, it is not the speed of the wheels that keeps it airborne – it is the alignment of thrust, lift, and balance. Nigeria’s removal from the Financial Action Task Force (FATF) grey list on 24 October 2025 evokes that same image: a nation that, after years of turbulence, finally achieved the right balance of discipline, coordination, and regulatory thrust to lift itself above international scrutiny.

For nearly two years, Nigeria remained under heightened observation – a kind of holding pattern in which every movement of its financial system was monitored, every policy examined for consistency, and every institution tested for endurance. The delisting was therefore not just a technical decision; it was a statement of regained trust. It affirmed that Nigeria’s institutions could reform, collaborate, and deliver results under global standards.

But like any pilot knows, take-off is only the beginning of the flight. The true test lies in maintaining altitude, navigating weather shifts, and landing safely at the destination. In that same spirit, the FATF delisting invites not complacency but vigilance. What lessons arise from this milestone? What risks linger beyond the applause? And what must Nigeria do to stay on course and sustain global confidence?

Background – How Nigeria Got Here

Nigeria was grey-listed by FATF in February 2023 for “strategic deficiencies” in its Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), and Counter-Proliferation Financing (CPF) regimes. Key weaknesses included inadequate supervision of financial institutions, poor transparency on beneficial ownership, limited investigations and convictions, partial implementation of financial sanctions, and weak inter-agency coordination. The listing created reputational risk, delayed cross-border transactions, and discouraged foreign investors.

The Reform Process – Institutional Collaboration and Contributions

Nigeria’s removal from the FATF grey list was achieved through a coordinated national effort anchored by the Inter-Ministerial Committee on FATF Compliance, chaired by the Federal Ministry of Justice and coordinated by the NFIU. The NFIU upgraded its goAML intelligence platform and improved inter-agency data sharing; the CBN strengthened risk-based supervision across banks and fintechs and issued VASP guidelines; the EFCC increased investigations and convictions supported by a new asset-recovery database; while the FMJ provided legislative leadership, sponsoring key amendments to the Money Laundering, Terrorism Prevention, and Proceeds of Crime Acts. Other critical agencies – including the SEC, CAC, SCUML, FIRS, NCS, and NAICOM – enhanced transparency, enforced compliance, and deepened sectoral oversight. Together, these reforms restored global confidence in Nigeria’s financial integrity architecture and demonstrated the power of institutional collaboration in driving systemic change.

Economic and Strategic Implications

Nigeria’s delisting yields broad national and regional benefits: renewed investor confidence, improved access to correspondent banking, acceleration of fintech innovation, enhanced sovereign global reputation and continental leadership in financial integrity standards.  This also has an immediate effect of reducing Nigeria sovereign risk premium and a better pricing of Nigeria risk at both the sovereign and corporate levels.

Matters Arising – Risks and Areas Requiring Vigilance

Delisting marks progress, not perfection. However, the following areas need to be seriously considered:

1.         Emerging Digital Age Risks

Emerging digital age risk remains a key area of exposure. As financial systems transition into the digital era, new vulnerabilities are rapidly surfacing at the intersection of technology and finance. The proliferation of digital assets, online payment platforms, and cross-border fintech applications has expanded both the reach and complexity of financial transactions. This is a global risk, not peculiar to Nigeria, but the difference lies in how countries design and implement their mitigation frameworks. Advanced economies have established sophisticated surveillance systems, reg-tech solutions, and cyber-resilience protocols, while many developing nations, including Nigeria, are still strengthening their capacity to respond. Without robust regulatory oversight and continuous monitoring, these innovations can easily become conduits for money laundering, cyber fraud, and terrorist financing. Artificial intelligence and blockchain, while transformative, can equally obscure beneficial ownership or automate illicit flows at unprecedented speed and scale. Nigeria must therefore adopt a proactive risk-based approach—one that balances innovation with control and ensures that regulatory frameworks evolve as fast as technology itself. Failure to do so will expose the financial system to systemic shocks capable of eroding the hard-won credibility achieved through FATF compliance.

2.         Policy Imperatives for Sustaining Compliance

To consolidate gains: institutionalise reform continuity through a permanent inter-agency council, leverage reg-tech and AI for predictive compliance, foster private-sector ownership, enhance transparency via public AML scorecards, and promote regional alignment through ECOWAS initiatives.

3.         Role of Banks and Financial Institutions Going Forward

Banks and financial institutions remain the first line of defense in safeguarding Nigeria’s post-FATF compliance gains. They must strengthen risk-based compliance systems, deepen customer due diligence, and integrate data analytics and artificial intelligence to detect suspicious activities in real time. In line with CBN’s VASP and AML/CFT guidelines, the sector must ensure transparency in beneficial ownership, tighten oversight on digital-asset transactions, and maintain robust governance that inspires confidence among correspondent banks and global partners.

Going forward, collaboration will be crucial. The financial sector should work closely with regulators, law enforcement agencies, and technology providers to establish a unified financial-integrity framework that anticipates emerging threats. By embedding ethics, accountability, and transparency into institutional culture, banks can convert compliance from a regulatory requirement into a strategic advantage that strengthens investor confidence and supports sustainable financial inclusion.

4.         Role of the Chartered Institute of Bankers of Nigeria (CIBN) and Industry Collaboration

An equally important matter arising is the coordinating role of the Chartered Institute of Bankers of Nigeria (CIBN) under the platform of Committee of Banks’ CEOs in supporting the Central Bank Nigeria (CBN) to foster an industry-wide culture of collaboration between banks, regulators, and facilitators of digital transformation such as Quros, alongside global banking technology Original Equipment Manufacturers (OEMs) and leading cybersecurity giants. CIBN can liaise with the CBN to play a catalytic role in developing common standards, shared frameworks and experience that enable the banking industry to collectively checkmate vulnerabilities in the digital environment that compromise Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) to achieve greater cost effectiveness in strengthening industry digital ecosystem resilience.

In today’s interconnected financial ecosystem, the vulnerability of one institution is the vulnerability of all. A unified ecosystem—coordinated by CIBN in partnership with the Central Bank of Nigeria, Quros, global tech OEMs, and cybersecurity leaders – will be crucial to advancing responsible digital adoption, building cyber resilience, and preserving the integrity of Nigeria’s financial system.

Conclusion – A Cautionary Triumph

Nigeria’s removal from the FATF grey list is more than a compliance victory; it is a national redemption story. It proves that discipline, coordination, and political will can restore international trust.

Yet, as every pilot knows, staying airborne requires constant calibration. The delisting should mark the beginning of deeper vigilance, not the end of scrutiny. Sustaining credibility demands that Nigeria embed compliance into the culture of governance – making transparency and integrity not just regulatory requirements but national habits.

If Nigeria continues on this path, it will stand as a continental model for financial integrity, institutional maturity, and responsible global citizenship.

•Dr. Ebenezer Onyeagwu is a distinguished banker, economist, and public speaker. He is the former Group Managing Director/Chief Executive Officer of Zenith Bank Plc, and has served on numerous boards across Africa and beyond, including the Africa Finance Corporation, FMDQ Holdings, and Mastercard Advisory Board for EMEA. He continues to contribute to Africa’s economic transformation through thought leadership, policy advocacy, and strategic advisory engagements.