It’s All ‘Fun and Games—Until They Come to Measure the Culture

Folashade Oluwasanya writes that Nigeria’s removal from the Financial Action Task Force (FATF) grey list did not happen by chance. It was the outcome of years of regulatory reforms, institutional coordination, private-sector cooperation, and a determined effort to strengthen the country’s defenses against money laundering, terrorist financing, and other illicit financial activities. Among the sectors that played a significant but often underappreciated role in this achievement is Nigeria’s gaming industry. Long viewed by international assessors as a sector vulnerable to financial crime risks, gaming operators found themselves at the center of a broader national effort to improve compliance, strengthen oversight, and align with global anti-money laundering and counter-terrorism financing standards

Nigeria’s gaming sector helped secure the country’s Financial Action Task Force (FATF) grey list exit. The grey list refers to countries identified by FATF as having strategic deficiencies in their regimes for countering money laundering, terrorist financing, and proliferation financing. By being placed on this list, a country commits to resolving these deficiencies swiftly and is subjected to increased FATF monitoring.

With a National Risk Assessment (NRA) underway and a Mutual Evaluation approaching, the question shifts from participation to proof.

Nigeria’s 2021 Mutual Evaluation Report had a lot to say about the gaming sector. None of it was flattering. GIABA — the Inter-Governmental Action Group against Money Laundering in West Africa — assessed Nigeria as non-compliant or partially compliant across several FATF

Recommendations. Designated Non-Financial Businesses and Professions (DNFBPs), including casinos, were among the sectors where the gaps were most visible. Under-supervised. Inconsistently meeting AML/CFT obligations.

Filing very few Suspicious Transaction Reports (STRs). And in many cases, not adequately verifying who was actually behind the entities they were doing business with. The report was blunt: Nigeria’s non-financial sector was a vulnerability in the country’s financial integrity architecture.

That evaluation fed directly into the 2023 grey-listing and the 19-item action plan that followed. The gaming sector had work to do. And to its credit, it engaged. The 2021 evaluation identified Nigeria’s gaps. The gaming sector was among them. The 2026 evaluation will measure what changed.

What the regulatory intervention looked like

The supervisory response between 2023 and 2025 was structured and sequenced. It did not start with enforcement. It started with evidence.

In April 2025, the Special Crime Unit Against Money Laundering (SCUML), a department under the EFCC, published a dedicated AML/CFT Sectoral Risk Assessment of the Casino Sector — a direct deliverable under Nigeria’s FATF action plan. The data was instructive. Online casinos accounted for 96 per cent of gaming sector STRs during the review period. Land-based operations accounted for four per cent — a gap that clearly pointed to where transaction monitoring and reporting culture needed strengthening.

The sector was rated medium risk, with specific vulnerabilities documented: fragmented state-level AML/CFT frameworks, weak customer due diligence, and insufficient transaction monitoring.

That evidence shaped direct engagement with the industry. SCUML and the Nigeria Financial Intelligence Unit (NFIU) partnered with the three principal gaming associations to deliver Compliance 3.0 — a substantive, operational session covering KYC obligations, currency transaction reporting thresholds of ₦5 million for individuals and ₦10 million for businesses, beneficial ownership identification of transacting entities through the Corporate Affairs Commission (CAC)  portal, and sanctions screening on NiGSAC — the Nigeria Sanctions Committee platform.

Operators were given the knowledge, the tools, and a clear statement of expectations. That work was part of what led to Nigeria’s exit from the grey list on October 24, 2025. The gaming sector contributed to a reform story that worked.

Scrutiny has not stopped

The grey list exit did not end the scrutiny. It reset the baseline. Nigeria is currently conducting an NRA — a comprehensive exercise evaluating money laundering and terrorism financing risks across the entire economy. The gaming sector is within scope. The NRA will directly inform supervisory priorities and the depth of examination high-risk sectors face going forward. It is not a formality. Its findings shape the regulatory environment operators will navigate for years.

Beyond the NRA, Nigeria’s next Mutual Evaluation is expected in 2027. Assessors do not just review legislation. They look for behavioural change in regulated entities — in STR filing trends, the quality of customer due diligence, and the consistency with which NiGSAC screening is conducted. They will look specifically at the gaming sector because the 2021 report identified it, and the 2025 risk assessment quantified its gaps. Assessors remember what they flagged. They come back to see if it was fixed. Operators who have built genuine compliance programmes since Compliance 3.0 will be visible in that data. So will those who have not.

Ongoing NRA, approaching mutual evaluation, sharper DNFBP supervision

This is not a quieter regulatory environment. It is a more demanding one. That conversation belongs at the board level. Compliance 3.0 reached compliance officers. Good. But compliance officers do not govern organisations — boards do.

AML/CFT risk is not a back-office matter. It touches how customers are onboarded, how transactions are structured, and who the business partners with. It carries personal liability at the senior management level. And it will be examined in 2027 — not assumed.

The question worth asking in any gaming boardroom is not just whether a compliance function exists. It is whether anyone around that table can actually interrogate it — read an STR filing rate and know if it is credible, spot the difference between a programme that is working and one that merely looks tidy on paper. Boards that build that literacy are not just managing regulatory risk. They are making a business decision.

Nigeria earned its grey list exit because enough people in enough institutions decided that compliance was not a checkbox — it was a commitment. Regulators mapped the evidence. Industry associations opened their doors. Operators showed up. The gaming sector was part of that decision.

The 2027 Mutual Evaluation will ask whether that commitment held, when the trainers had left, when the grey list pressure had lifted, when no one was watching. That is always when culture reveals itself.

Compliance is not a department. It is a culture.

Folasade Oluwasanya (CAMS) is an AML/CFT professional with over 15 years of experience in financial intelligence, DNFBP supervision, and regulatory compliance in Nigeria. She writes under the brand The Compliance Maven on issues of compliance governance, regulatory affairs, and financial integrity.