Crypto frontier, fragile regional defences expose Nigeria’s unfinished fight against financial crime. KEHINDE ADEGOKE unearths.
Nigeria’s removal from FATF’s grey list in October 2025 was celebrated as a hard‑won victory after nearly three years under scrutiny. Yet GIABA’s 2025 report flags two unresolved cracks: crypto assets opening a volatile new battlefield, and West Africa’s financial crime framework confronting its toughest test to date.
But the GIABA 2025 Annual Report, inaugurated this week in Dakar by Director-General Edwin Harris, tells a more complicated story — one in which Nigeria’s removal from the grey list is not a declaration of victory but a conditional parole, with two unresolved strategic deficiencies still formally on the record and a new frontier of financial crime threatening to undo hard-won progress.
TheDiggerNews.com has examined the full landscape of GIABA’s findings, FATF’s Nigeria-specific assessments, and the emerging threats documented in the regional body’s 2025 strategic work — and the picture that emerges is one that Nigeria’s financial regulators, policymakers, and citizens cannot afford to ignore.
The Grey List Exit — and What It Actually Means
Nigeria exited FATF’s increased monitoring list in October 2025 after the global body acknowledged progress and urged continued collaboration with GIABA to sustain gains in its anti‑money‑laundering and counter‑terror‑financing (AML/CFT) framework — the system designed to detect, prevent, and punish financial crimes and terrorism funding.
That language — “continue to work with GIABA to sustain improvements” — is diplomatic. What it means in practice is that Nigeria’s exit from the grey list is conditional. The FATF does not issue a clean bill of health. It issues a provisional endorsement contingent on continued progress.
Since February 2023, when Nigeria made a high‑level political commitment to work with FATF and GIABA to strengthen its anti‑money‑laundering and counter‑terror‑financing (AML/CFT) regime, the country has taken significant steps — improving risk‑based supervision of financial institutions and designated non‑financial businesses, ensuring authorities have timely access to accurate beneficial ownership data, and driving a steady rise in money‑laundering and terror‑financing investigations and prosecutions aligned with its risk profile.
Those are genuine achievements — and they deserve acknowledgement. Nigeria spent nearly three years on the grey list. Getting off it required sustained institutional effort across the NFIU, EFCC, CBN, and multiple regulatory agencies.
But Nigeria should continue to work on implementing its action plan to address its strategic deficiencies, including by enhancing the implementation of preventive measures for high-risk sectors, and proactively detecting violations of currency declaration obligations and applying appropriate sanctions.
Two deficiencies. Still unresolved. Still on the record. And both of them — high-risk sector supervision and currency declaration enforcement — are precisely the vulnerabilities that financial criminals exploit most aggressively in Nigeria’s economy.
The Two Deficiencies Nobody Is Reporting
The first unresolved deficiency — preventive measures for high-risk sectors — covers the designated non-financial businesses and professions that FATF requires to be subject to anti-money laundering obligations: lawyers, accountants, real estate professionals, car dealers, and trust and company service providers.
In Nigeria, these sectors remain among the most under-regulated in the AML/CFT framework. Real estate transactions in Lagos, Abuja, and Port Harcourt — some of the most active property markets in Africa — continue to generate significant regulatory concern. The use of property purchases to launder proceeds of corruption, oil theft, and organised crime is extensively documented in court proceedings and investigative reports. Yet the framework for monitoring, reporting, and enforcing AML obligations in the real estate sector remains incomplete.
The second unresolved deficiency — proactive detection of currency declaration violations — speaks to Nigeria’s cash economy and the cross-border movement of physical currency. FATF requires that countries proactively detect, not merely passively receive reports of, violations of currency declaration requirements at borders and ports. Nigeria’s record on this specific obligation remains insufficient in the FATF’s own assessment.
Together, these two gaps mean that the most common methods of moving dirty money through Nigeria’s economy — cash at borders and property purchases — remain less supervised than FATF standards require.
The NFIU Problem the GIABA Report Illuminates
The GIABA 2025 Annual Report’s broader findings — about financial intelligence units across West Africa — carry a direct Nigeria-specific dimension.
The Transparency International research published simultaneously this month, examining FIUs across 20 countries, including Nigeria, found that the Nigerian Financial Intelligence Unit faces structural challenges common to many African FIUs: limited direct access to beneficial ownership data, gaps in the coverage of non-financial sectors, and questions about whether proactively shared intelligence is being consistently acted upon by law enforcement and prosecution agencies.
The most striking global finding — that in some countries authorities use up to 97% of the intelligence they request from FIUs, but as little as 3% of the intelligence FIUs share proactively — is directly relevant to Nigeria. If the NFIU is sharing proactive intelligence that the EFCC, the Nigeria Police Force, and the Department of State Services are not consistently acting upon, then Nigeria’s financial intelligence architecture is operating at a fraction of its potential effectiveness.
That gap — between detection and prosecution — is precisely what kept Nigeria on the grey list for three years. And it is precisely what the two remaining FATF deficiencies are designed to address.
The Crypto Frontier — West Africa’s New Money Laundering Battleground
Perhaps the most significant finding in the GIABA Director-General’s address in Dakar was his explicit identification of crypto assets as a new avenue for criminal exploitation.
Jamaica and Nigeria have been invited by the FATF President to participate in the FATF-Style Regional Body jurisdictions’ Guest Initiative aimed at fostering inclusiveness, enhancing the cohesion of the Global Network and strengthening global capacity in the fight against illicit finance.
Nigeria’s inclusion in this initiative — alongside Jamaica — signals that FATF considers Nigeria a priority country for capacity building on emerging financial crime threats. That is a recognition of both Nigeria’s strategic importance and its ongoing vulnerabilities.
The crypto dimension is not abstract. Nigeria is the third-largest cryptocurrency market in the world by adoption. The CBEX collapse of 2025 — which cost Nigerian investors an estimated $1 billion — demonstrated the scale of financial crime risk in the digital asset space. The Southeast Asian scam farm networks that TheDiggerNews.com has previously investigated have been documented using cryptocurrency channels to move proceeds of fraud out of African markets.
GIABA’s Director-General explicitly named digital assets as creating fresh opportunities for criminal exploitation. Yet Nigeria’s regulatory framework for virtual asset service providers — despite CBN and SEC efforts — remains incomplete relative to FATF standards. The NFIU’s capacity to analyse suspicious transaction reports involving cryptocurrency transactions is still developing.
The Burkina Faso, Mali, Niger Dimension — Nigeria’s Porous Northern Borders
One of the most significant findings of the GIABA 2025 Annual Report is the decision to maintain the full membership of Burkina Faso, Mali, and Niger within GIABA despite their political crises and departures from ECOWAS.
This decision matters for Nigeria specifically. Nigeria shares extensive land borders with Niger — borders that are among the most porous in West Africa and through which terrorist financing, arms trafficking, and illicit financial flows move with documented regularity.
The Boko Haram and ISWAP financing networks that have funded insurgency in Nigeria’s Northeast for over a decade operate through cross-border financial channels that GIABA’s regional framework is designed to monitor and disrupt. If Burkina Faso, Mali, and Niger — three countries now under military juntas — had been expelled from GIABA’s framework, the regional intelligence sharing and mutual evaluation mechanisms that track those financial flows would have been severely compromised.
The decision to keep them in GIABA is therefore not merely a political gesture about institutional inclusion. It is a practical decision about whether Nigeria’s northern security perimeter remains within a functioning regional financial intelligence framework — or outside it.
GIABA’s Director-General was explicit that the decision reaffirmed the principle that the fight against financial crime must remain above politics. For Nigeria, it is also a decision about survival.
The Questions Nigeria Must Now Answer
The GIABA 2025 Annual Report’s inauguration in Dakar provides the occasion to ask questions that Nigeria’s financial regulators have not been publicly pressed to answer:
One — When will Nigeria fully resolve the two remaining FATF strategic deficiencies — high-risk sector supervision and currency declaration enforcement — and what is the specific, time-bound action plan for doing so?
Two — What is the NFIU’s current ratio of proactively shared intelligence to intelligence acted upon by law enforcement and prosecution agencies — and if that ratio reflects the global problem of proactive intelligence being ignored, what institutional mechanisms exist to close it?
Three — What is Nigeria’s specific regulatory framework for virtual asset service providers relative to FATF’s recommendations — and what is the timeline for full compliance?
Four — How is Nigeria using the FATF Guest Initiative invitation to build capacity on emerging financial crime threats — and what resources have been committed to that capacity building?
Five — What intelligence-sharing arrangements exist between Nigeria and its GIABA partners in Burkina Faso, Mali, and Niger — and are those arrangements functioning effectively despite the political disruptions in those three countries?
The Dig
Nigeria’s removal from the FATF grey list in October 2025 was a genuine achievement — the product of three years of institutional effort, political commitment, and regulatory reform that deserves to be acknowledged honestly.
But the GIABA 2025 Annual Report is not a graduation certificate. It is a progress report — one that documents genuine advances alongside persistent vulnerabilities, emerging threats alongside established ones, and a regional security environment that is growing more complex, not less.
Two deficiencies remain unresolved. Crypto assets are opening new criminal frontiers. The NFIU’s proactive intelligence may be going unacted upon. And West Africa’s three military-controlled states remain inside the financial intelligence framework only by deliberate institutional decision.
Nigeria exited the grey list. The threats that put it there have not exited Nigeria.
That is the story the GIABA 2025 Annual Report tells — and it is the story that Nigeria’s financial regulators, policymakers, and citizens need to hear clearly and completely.
TheDiggerNews.com is seeking an audience with the Nigerian Financial Intelligence Unit, the Economic and Financial Crimes Commission, the Central Bank of Nigeria, and the Securities and Exchange Commission on the questions raised in this report. Responses will be published in full upon receipt. This investigation is ongoing.
Sources: FATF, GIABA, Transparency International, News Agency of Nigeria
Kehinde Adegoke is an award-winning investigative journalist with more than 15 years of distinguished experience uncovering stories that shape public discourse. With three industry nominations across diverse beats, he has earned recognition for fearless reporting, incisive analysis, and a commitment to accountability. As Managing Editor and CEO of TheDiggerNews.com, Adegoke leads a pioneering newsroom dedicated to exposing hidden truths, amplifying marginalised voices, and setting new standards in investigative journalism.
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