Bawo Egbakumeh: Leadership Culture, Not Regulation, Shapes Corporate Success
In today’s era of stricter regulations, cautious foreign investors, and fast-changing business risks, compliance is no longer just a back-office task, but a boardroom priority. Bawo Egbakumeh, Registrar of the Compliance Institute Nigeria, explains that strong compliance frameworks now influence valuations, partnerships, and competitiveness. She notes many corporate failures stem from weak leadership, and professionalising compliance could transform Nigeria’s business landscape. Adedayo Adejobi bring the excerpts:
Compliance is often seen by businesses as a cost centre rather than a value driver. How can Nigerian companies begin to see compliance as a strategic business advantage?
If compliance were only a cost, global investors would not be rewarding companies with strong compliance cultures with premium valuations. The reality is that compliance, when done right, is a business enabler. According to a PwC Global Economic Crime Survey, companies with mature compliance frameworks are nearly 50 percent less likely to suffer major fraud losses and experience faster recovery after regulatory shocks. In Nigeria, we are beginning to see this shift. As, we have observed, banks that invested early in Anti-Money Laundering (AML) systems, such as automated transaction monitoring and strong governance, have been better positioned to expand regionally and partner with international correspondent banks. To emphasis this, Nigerian banks responded after the 2016 global correspondent bank de-risking shock. The Banks that had invested early in AML/CFT controls preserved correspondent relationships that others lost. That wasn’t luck, it was compliance discipline paying off. So strategically, Nigerian companies must move compliance from the “back office” into enterprise decision-making, because we have seen that when compliance insights inform product design, market entry, and partnerships, it becomes a competitive differentiator, not a tick-box exercise.
From your vantage point as Registrar, what are the most common compliance failures you observe across Nigerian organisations, both public and private?
Across both public and private organisations, the most common compliance failure I observe is what I call “compliance on paper, but not in practice.” Policies exist. Frameworks exist. Committees exist. But when you scratch beneath the surface, compliance is often disconnected from day-to-day decision-making. A recurring issue is weak tone from the top. In many organisations, leadership verbally endorses compliance, but operational decisions tell a different story.
Another major failure is poor accountability and ownership. In both sectors, compliance is frequently treated as the sole responsibility of the compliance officer or unit. As, too often, business heads treat compliance as “someone else’s job,” forgetting that under the globally accepted Three Lines of Defence model, compliance is first and foremost a management responsibility. When business leaders abdicate their role, the entire defence framework collapses, leaving compliance units unfairly blamed for failures they were never designed to prevent alone. Another cross-cutting issue is capacity and skills gaps. Compliance is evolving rapidly – technology risk, data protection, ESG, and financial crimes are far more complex today than a decade ago. Yet many organisations have not invested adequately in upskilling their compliance teams.
This persistent capacity gap is precisely why the Compliance Institute Nigeria (CIN) exists. It was a core motivation behind its establishment, to deliberately build professional competence, deepen ethical standards, and strengthen compliance capacity across Nigeria’s public and private sectors.
Finally, there is the challenge of weak compliance culture. In environments where shortcuts are normalised and misconduct is quietly tolerated, even the best-designed frameworks will fail. Culture determines whether employees speak up, escalate issues, and act ethically when no one is watching.
From my vantage point at CIN, the insight is simple but uncomfortable: most compliance failures in Nigeria are not technical, they are behavioural and leadership-driven. Until organisations treat compliance as a shared responsibility, backed by leadership example, adequate resources, and professional competence, these failures will persist across both public and private sectors.
Nigeria has no shortage of laws and regulations. To what extent is the problem a weak compliance culture rather than weak regulation?
This is a question I get asked constantly. Nigeria does not lack rules – what we lack is consistent enforcement and a culture that makes compliance second nature. Nigeria’s regulatory framework is robust. We have strong laws covering banking, anti-corruption, AML/CFT, data protection, and corporate governance. The challenge lies in implementation and culture.
So, until organisations internalise compliance as a shared value rather than an external imposition, enforcement gaps will persist. Culture eats rules for breakfast. Whether in Lagos or London, the toughest part of compliance isn’t knowing the law, it’s embedding ethical decision-making into every level of the organisation. That’s where Nigeria must grow.
How does the Compliance Institute Nigeria define its role beyond certification—particularly in shaping ethical leadership and corporate governance standards?
Certification is important; it sets a professional baseline. But our work goes beyond exams. As certification is only the entry point. At CIN, our broader mandate is to shape compliance leadership, professional identity, and governance standards across Nigeria’s business ecosystem. We have been doing this through executive dialogues, board-level programmes, ethics advocacy, regulatory engagement, local and global partnerships like IFCA, ACAMS, and thought leadership.
Our position is clear and intentional compliance is not a banking sector issue alone; it is a business and governance issue that cuts across every sector, both locally and globally. Thus, one of our core responsibilities now is to embed this understanding across Nigeria’s public and private institutions. Our goal is to professionalise compliance the way accounting and law were professionalised, anchored on competence, integrity, and public trust.Ultimately, CIN exists to influence how decisions are made, not just how rules are memorised.
With rising regulatory scrutiny in sectors such as banking, fintech, oil and gas, and telecommunications, how prepared is Nigeria’s compliance workforce for today’s risk environment?
The preparedness is improving, but uneven. The banking sector is relatively mature, driven by CBN expectations and international exposure. Fintech, telecoms, and oil & gas are catching up rapidly, often after regulatory sanctions.
According to KPMG, over 60 percent of African compliance leaders report skills gaps in regulatory interpretation and risk analytics. Nigeria reflects this pattern. The workforce is growing, but capability depth must grow faster. This is why structured, continuous professional development is no longer optional; it is critical and CIN understands clearly that we have a major role to play here.
What skills gaps concern you most among compliance professionals in Nigeria, and how is CIN addressing them?
The most critical gaps are in risk-based thinking, data analytics, regulatory judgment, and board communication. Too many professionals focus on “what the rule says” rather than “what the risk means”. CIN is addressing this through redesigned curricula, scenario-based learning, ESG and technology modules, and executive-level programmes that emphasise judgment, not rote compliance. Traditional training focuses on “what the rules say.” The future requires professionals who can say: “Given this risk scenario and this regulation, here are the strategic implications.” Our aim at CIN is to close skill gaps before regulators and markets expose them.
How can strong compliance frameworks help Nigerian businesses attract foreign investment and improve their global competitiveness?
Recent trends have indicated that investors don’t just look at profits; they price governance risk. For Nigerian businesses, this matters because when an investor sees strong AML systems, transparent reporting, and ethical conduct, they see predictability, reliability, sustainability and risk mitigation, qualities that attract capital. This is why multinational partners insist on compliance audits before joint ventures. There is increasing overlap between compliance, risk management, ESG, and sustainability.
How is CIN adapting its training and advocacy to reflect this convergence?
This convergence isn’t theoretical; it’s reality. Regulators and investors increasingly expect integrated risk and ESG reporting. The IFRS Sustainability Standards and global ESG disclosures are accelerating this trend. CIN has embedded ESG, conduct risk, and sustainability into our training and advocacy. We are preparing professionals who understand that environmental failures, governance lapses, and social misconduct are compliance risks, not side issues.
What role should boards and senior executives play in driving compliance culture, rather than delegating it solely to compliance officers?
If there is one message board and senior executives must hear clearly, it is this: culture does not sit in the compliance department, it sits in the boardroom and the executive suite. Compliance officers are advisers, challengers, and guardians of standards, but they do not own culture. Leadership does.
In practical terms, boards and executives must first set unambiguous ethical expectations. This means defining what “acceptable behaviour” looks like, not just in policy documents, but in everyday business decisions. Second, they must model the behaviour they expect. Nothing undermines compliance faster than leaders who preach integrity but make exceptions for themselves or high performers.
Third, effective boards ask uncomfortable questions. They go beyond compliance reports and challenge management on emerging risks, near misses, and cultural warning signs. Silence at the board level is often interpreted as approval on the ground.
Finally, boards must resource compliance properly, with the right people, authority, and technology. Underfunded compliance functions send a powerful message that compliance is optional.
Technology is transforming compliance through RegTech, data analytics, and automation. How ready are Nigerian organisations to adopt these tools?
Nigeria is on the journey, but we are not yet where we need to be. As, readiness varies significantly by size and sector. Large financial institutions, particularly banks with international exposure, have begun investing in RegTech solutions such as advanced AML monitoring systems, data analytics, and automated regulatory reporting. These investments are often driven by regulatory expectations, cross-border obligations, and the need to maintain correspondent banking relationships.
However, when you look beyond the large institutions, a different picture emerges. Many mid-sized organisations, and even some fast-growing FinTech’s, still rely heavily on manual processes, spreadsheets, and fragmented systems. This creates blind spots, slows response times to issues such as identifying Suspicious Transactions, and increases the risk of regulatory breaches in an environment where risks, fraud, and financial crime are moving faster and becoming more complex. This brings to light clearly that automation is no longer a luxury or a future aspiration, but that it is becoming a regulatory and competitive necessity.
In short, the question is no longer whether Nigerian organisations should adopt compliance technology, but how quickly they can do so in a way that is smart, sustainable, and aligned with their risk profile.
What lessons can Nigerian businesses learn from recent corporate failures and regulatory sanctions linked to poor compliance?
After years of observing regulatory actions and corporate failures, both in Nigeria and globally, one pattern is impossible to ignore: compliance failures are rarely sudden events. They are slow, cumulative breakdowns that build quietly over time. As every major sanction tells the same story. There were early warning signs, internal audit findings that were downplayed, compliance reports that were noted but not acted upon, and controls that existed on paper but failed in practice. In many cases, leadership saw the signals but chose convenience, speed, or short-term profit over discipline. What eventually triggers regulatory action is rarely the first breach; it is the last straw after years of unresolved issues. One uncomfortable but important lesson for Nigerian businesses is that poor compliance is often tolerated because it “works” in the short term. Revenue targets are met, deals are closed, operations move faster, however time reveals that those same shortcuts accumulate risk silently.
Another critical insight is that most failures are cultural, not technical. The problem is rarely the absence of policies or frameworks. Instead, it is a culture that rationalises misconduct, discourages escalation, or treats compliance warnings as obstacles rather than safeguards.
Perhaps the most valuable lesson is this: regulators do not punish mistakes; they punish neglect. Organisations that detect issues early, escalate honestly, and take corrective action are treated very differently from those that ignore problems until they become public scandals. In the end, the message for Nigerian businesses is simple but sobering: risks ignored today become crises tomorrow. Compliance is not about avoiding punishment; it is about protecting the long-term viability of the organisation.
How can SMEs build basic but effective compliance systems without stifling growth?
When we talk to SMEs, I always say this: compliance doesn’t have to be complex or expensive to be effective. It should be risk-based and scalable. Start small, basic governance, simple controls, proper record-keeping, and clear accountability. These fundamentals go a long way, because compliance doesn’t slow growth, it actually enables it.
Looking ahead, what would success look like for the Compliance Institute Nigeria in the next five years, and how would that success impact Nigeria’s business environment?
For me, success in five years is simple to describe, but profound in impact: compliance will no longer be seen as a regulatory burden in Nigeria, but it will be recognised as a strategic business profession and a national economic asset.
At the Compliance Institute Nigeria, success means we have helped professionalise compliance across sectors, not just banking so that Nigerian organisations are benchmarked confidently against global peers. It means a strong pipeline of well-trained compliance leaders sitting at decision-making tables, influencing strategy, ethics, and risk before problems arise. The goal is to close the compliance skill gaps, build compliance capacity through local and global certifications through CIN certification pathway and our global partnerships.
When that happens, the results become visible: fewer sanctions, fewer governance failures, and a shift from reactive firefighting to preventative risk management.
