General Comments on the Money Laundering (Prevention and Prohibition) Bill


The Nigeria Network of NGOs (NNNGO) is pleased to provide general comments on the draft Money Laundering (Prevention and Prohibition) Bill (draft AML Bill) and how it complies with the FATF Recommendations[1]. NNNGO hereby expresses its concerns related to the burdensome provisions on non-profit organizations (NPOs) that seem contrary to international standards combating money laundering and terrorism financing and human rights conventions protecting freedom of association.


The draft AML Bill is contrary to the proportionate and targeted approach required by the revised Financial Action Task Force (FATF) standards[2] – Recommendation 8 and its Interpretative Note, and could discourage legitimate activities of NPOs.


[1] ECNL reviewed the version of the draft AML Bill available here: 


[2] Revisions made in June 2016 plenary session:


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