Question 1

Which regulator oversees KYC and AML compliance in Nigeria?

Accepted Answer

It depends on the activity: CBN for specified banks, OFIs and payment institutions; SEC for capital-market operators and VASPs; NAICOM for insurance; PenCom for pensions; and SCUML for DNFBPs. STRs go to NFIU through the applicable channel, while threshold and sector returns may also go to SCUML or a sector regulator.

Question 2

What information is required for KYC at a CBN-supervised financial institution?

Accepted Answer

The 2023 CBN CDD Regulations list identity, address, contact, date and place of birth, nationality, occupation or public position, employer, BVN, TIN, an official identifier, relationship type, signature and PEP status, with verification from reliable independent sources. Applicability can depend on the customer and product.

Question 3

How should beneficial ownership be checked in Nigeria?

Accepted Answer

Understand the legal person's ownership and control structure, identify and verify the natural persons who ultimately own or control it, and compare declarations with reliable sources such as CAC records. The CAC PSC threshold of at least 5% is a disclosure trigger and does not replace broader control analysis.

Question 4

When must a suspicious transaction be reported in Nigeria?

Accepted Answer

File immediately once the statutory threshold is met. MLPPA section 7 requires immediate reporting and written reporting and related action within 24 hours after the suspicious transaction; TPPA section 84 requires relevant TF/PF reports within 24 hours. NFIU's FAQ describes a longer FI examination workflow but administrative guidance does not amend the Acts, so do not delay an established suspicion without current written confirmation.

Question 5

How long must CDD records be retained in Nigeria?

Accepted Answer

The CBN CDD Regulations require CBN-supervised financial institutions to keep CDD records, account files, business correspondence and analysis for at least five years after relationship termination or the occasional transaction. Another applicable law, supervisor or legal direction may require longer.

Question 6

Is Nigeria currently on the FATF grey list?

Accepted Answer

No. FATF removed Nigeria from increased monitoring on 24 October 2025. Institutions should keep country-risk data current and continue applying a documented risk-based approach rather than relying on obsolete list status.

Download the Nigeria KYC, KYB & AML checklist

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Download the Nigeria KYC, KYB & AML checklist

Get the PDF immediately

Reviewed and source-linked

Verify once. Everywhere.