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Portfolio: FAFT


On March 28, 2018, over 200 participants from across the country attended the sector-wide conference themed Implementation of AML/CFT Standards for the Non-Profit Organisations, (NPOs) Sector in Nigeria. Organised by the Nigeria Network of NGOs, in collaboration with Special Control Unit on Money Laundering, the conference focused on the need for a reform of the legal framework on AML/CFT measures, strengthening of the criminal justice system and inter-agency cooperation, funding and capacity strengthening of regulatory agencies in ways that ensures ease of regulatory compliance by all sectors.



At the end of the conference, participants affirmed their commitment towards working to address critical issues faced by NPOs in relation to compliance with the law and called on SCUML to continue its good work of engaging and partnering with stakeholders in implementing a robust AML/CFT for the country


The Nigeria Network of Non- Governmental Organizations (NNNGO) in collaboration with the Special Control Unit Against Money Laundering (SCUML) organised two regional workshops themed, Effective Implementation AML/CFT Requirements in the NPO Sector in Nigeria.


The first of the workshops was held in Lagos; Vantage Hub: Mosesola House on 19th February 2018 and gathered 67 participants from across the southern region. The second workshop, organised at Den is Hotel, Abuja on 26th February, 2018 was attended by 68 participants from the northern region.


In attendance were the Directors of NFIU, Mr Francis Usani and SCUML, Mr Bamanga Bello, as well as officials from the Economic and Financial Crimes Commission (EFCC), SCUML, the Nigerian Financial Intelligence Unit (NFIU) and various Civil Society Organizations (CSOs).




The research on Nigerian laws that are, either directly or indirectly, affecting the ability of our sector to function effectively.


  1. Laws here include: The FATF recommendation 8, Money Laundering Prohibition Act 2011 (as amended), the Terrorism Prevention Act 2011 etc. This formed the basis of the project.
  2. Analysis of laws completed and is now being designed for onward submission to relevant government agencies and publication on the NNNGO website.



Sensitization on FATF and its recommendations amongst civil society


Progress made so far includes:

  1. Weekly Bulk SMS with information on FATF: FATF related bulk SMS are sent to members every Wednesday to arouse their consciousness on FATF related matters.
  2. Monthly E-newsletters focusing on FATF:

So far, we have succeeded in sending e-newsletters to members for the month of January, February, March, April, May, June and July.

  1. January newsletter focused on “Understanding the financial action taskforce”. The Financial Action Task Force (FATF) was founded in 1989 on the initiative of the group of seven (G7) summit held in Paris. This intergovernmental organization, which is also known by its French name, Groupe d’action financière (GAFI); was charged with developing policies to combat the growing trend of money laundering and combating the finance of terrorism. The FATF works to identify national-level vulnerabilities with the aim of protecting the international financial system from misuse.
  2. February newsletter focused on “Recommendation 8 and Not for Profits”. The objective of Recommendation 8 is to ensure that NGOs are not misused by terrorist organisations and, it provides measures NGOs should adopt in combating money laundering and countering terrorism within the sector.
  3. March newsletter focused on “Knowing the agencies of government in charge of money laundering”; this provided information on the global, regional and national agencies that works hand in hand in the battle against money laundering within NGOs and other organizations. Globally, we have the FATF, GIABA (intergovernmental Action Group against Money Laundering) operates regionally, SCUML (Special Control Unit against Money Laundering) operates nationally for NPOs under the watch of NFIU (Nigeria Financial Intelligence Unit).
  4. April newsletter focused on “Civil society concerns about FATF Recommendation 8”. This involves the strict adherence requirements and unbending stance on penalties on Civil Society as a result of misinterpretation of FATF recommendation 8 which is gradually stifling civil society.
  5. May newsletter focused on “Laws Guiding the Activities of Non – Profits in Nigeria”. An identified challenge within the Nigerian third sector space is that most Non Profit Organizations (NPOs) are not widely familiar with the laws that govern the sector including government institutions in charge of these laws. Being conscious of these laws and governing bodies will enable NPOs know how and where to address various issues, ranging from registration, auditing, filing annual returns, and tax payment if necessary. The main legal instrument governing NPOs in Nigeria is the Companies and Allied Matters Act (CAMA). Also governing NPOs are the Companies Income Tax Act (CITA); Taxes and Levies (Approved List for Collection) Act; Value-Added Tax Act and Value-Added Tax Amendment Act; Federal Inland Revenue Service (Establishment) Act; National Planning Commission Act; and Money Laundering Prohibition Act.
  6. June newsletter focused on the “Outcome of the Engagement Meetings with SCUML”. This was based on the main takeaways of the meetings held on the 16th of May 2017.
  7. July newsletter focused on “The Nigerian Financial Intelligence Unit (NFIU)”. It gave an overview its activities, operations and the implementation of its mandate since inception. Also, it highlighted details on the meeting we had with NFIU on the 17th of May 2017.
  8. Bi-monthly Op-ed

Three op-eds have been published for the months of February, April and June. Two were published in the PUNCH newspaper.

  1. The op-ed for February is titled “Nonprofits and Regulatory Challenges” – it primarily focused on the need to review the laws and regulations that guide non-profit organizations so that they are not subject to exploitation by terrorist organizations. Nigeria implements R8 through SCUML with directives from NFIU. The new R8 tightens its focus to organizations legitimately at risk rather than the blanket statement on all non-profits being at risk. Countries are therefore called to ensure that responses to at-risk organizations are proportionate, effective and respectful of international human rights laws.
  2. April op-ed titled “For Effective Implementation of FATF Recommendation 8”; it explained the need for countries to review the adequacy of laws and regulations that relate to nonprofit organizations which the country has identified as being vulnerable to terrorist financing abuse. Measures adopted by Nigeria to protect the nonprofit should not discourage or disrupt legitimate charitable activities. Rather, such measures should promote transparency and engender greater confidence in the sector, across the donor community and with the general public, that charitable funds and services reach intended legitimate beneficiaries.
  3. The June op-ed published on our website was titled “Understanding the Role of GIABA”. The Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) was established by the Economic Community of West African States (ECOWAS) Authority of Heads of State and Government in the year 2000. Generally, GIABA is responsible for strengthening the capacity of member states towards the prevention and control of money laundering and terrorist financing in the region. Apart from member states, GIABA grants Observer Status to African and non-African States, as well as Inter-Governmental Organizations that support its objectives and actions and which have applied for observer status.

This sensitization is as a result of the fact that not many non-profits know about recommendation 8- a regulation intended to protect the nonprofits sector from abuse through terrorist financing, developed by a global regulatory institution called the Financial Action Task Force, this regulatory body has the mandate for combating money laundering and funding of terrorism.



Formation of an informal coalition of civil society organisations interested in working on FATF related issues


  1. Quarterly meeting: Online and face-to-face meeting of coalition members.
  2. This involved drafting a coalition form, invitation of members via e-mail and drafting a concept note for the coalition.
  3. We have succeeded in conducting two online meeting and one face to face meeting.
  4. The first online meeting was held to formally welcome members to the coalition and brief them of the upcoming engagement with the NFIU and SCUML, recognising questions, suggestions and possible way forward.
  5. The second online meeting was held to brief members of the outcome of the meeting with SCUML and NFIU. Also, to explain to members how to register with SCUML without issues.
  6. The face to face meeting was held to interact with members and discuss some issues within the system and on the FATF Recommendation 8.
  7. NNNGO attended three global NPO coalition meetings.
  8. The first meeting was a Global NPO Coalition Pre-Consultative Forum Meeting. It discussed the agenda for the upcoming meeting in Vienna on FATF. Topics to be discussed includes: Global issues, Recommendation 8, training of evaluators, financial inclusion (financial measures of humanitarians worldwide).
  9. The second meeting was a recap of Vienna FATF meeting. The meeting highlighted key conversations held in London and issues surrounding the evaluation processes. It stressed the importance of government engagement with the NPO. Also, issues on how evaluators select NPOs
  10. The third meeting focused on government investigations: how to protect your organization. Nonprofits can be negatively impacted by government investigations whether they are the targets or not. Nonprofits therefore need to know their rights, how to be prepared in case of a visit from law enforcements and how to respond if it does.



5 targeted engagement meetings between NNNGO and the National Risk Assessment Secretariat, National Assembly Committee on Civil Society and other stakeholders including the media


  1. Meeting with SCUML was held on 16th May 2017

The agenda of the meeting was centred on:

  1. Monitoring compliance on AML/CFT and some aspects of the law that needs amendment
  2. To address the complaints and problems of members in registering with SCUML.
  3. Explore areas of collaboration with SCUML to strengthen CSOs.
  4. How we could monitor or improve aspect of the law
  5. FATF recommendation 8 and new interpretative note.

Key takeaways of the meeting include:

  1. The need to raise awareness and compliance with AML/CFT.
  2. The registration site is working well, we need to shrink files to 2MB to upload and follow necessary instructions. Also, a tool kit will be developed on registration and compliance and it will be assessed on SCUML website.
  3. As soon as the NRA report is out, we will be able to assess it on SCUML website
  4. SCUML is ready to work with NNNGO especially in the area of sensitization on anti-money laundering practices.


  1. Meeting with NFIU was held on 17th May

The agenda of the meeting includes:

  1. Information on NFIU report to know if they are planning to engage CSOs in risk assessment.
  2. Engaging the CSOs in evaluation
  3. Working together in new interpretative note not to shrink CSO space
  4. How to work with NFIU to participate in our workshop.

Key takeaway of the meeting includes:

  1. NRA report will be available in 2weeks; we will get the report soon.
  2. NFIU has extended a hand of partnership with NNNGO to make the civil society space more convenient, and will be available for our next workshop.
  3. We have to work around taking NPOs out from the DNFI list.

MEETING: Open Working Group on FATF Recommendation 8

MEETING:  Open Working Group on FATF Recommendation 8.

DATE: May 3, 2017.

TIME: 1:00PM; the meeting began at 1: 22PM.


CHAIRPERSON:  Executive Director, NNNGO: Oyebisi Babatunde Oluseyi

MODERATOR: Okpara Chidinma Gloria.


Oyebisi Babatunde Oluseyi – Nigeria Network of NGOs

Mrs Uche – Solace for She and Child Care Initiative.

Ediki Tega – Center for Human Capital Enterprise Development

Omoyemen Lucia Odigie – Center for Human Rights and Private Change Research.

Irene Adoroh – Support for Humanity Foundation.

Habib S. Umar – Northern Nigeria Youth Organization.


Review of the Agenda

The executive director, Nigeria Network of NGOs, Oyebisi Babatunde Oluseyi who doubled as the chairperson of the meeting read out the agenda for adoption. He then requested that comments be made. No comments were made regarding the agenda and so the meeting proceeded with introductions by attendees.


Overview of Working Group

The chairperson briefly explained the functions and the purpose of setting up the working group while noting that rather than the usual formality with which working groups are created, the one for the project was a more loosely created one.


Overview of Concept Note

The Chairperson reported that the concept note had been sent to everyone via email and thus requested for comments of participants on the concept note.


Comments on Concept Note

Mrs Uche : Solace for She and Child Initiative – Reported that she did not receive the email and thus would like it resent to allow her peruse the document before the next meeting.


Update on Engagement with Regulators

Meetings with the Special Control Unit on Money Laundering (SCUML) and the National Financial and Intelligence Unit (NFIU) have been fixed for 16th and 17th May 2017 respectively. The meetings will be based on some of the concerns of the civil society in terms of registration and the fact that their website is not fully functional. The chairperson added that attention would also be paid to some of the overzealous and overly stringent laws of these regulators. He then noted the recent publication in the Punch Newspaper which focused on concerns of the civil society. He asked for contributions as regards issues the attendees may want to be presented for discussion during the engagement meeting to be held in Abuja.

  • Mrs Uche noted that she has been encountering challenges registering with SCUML. She added that the challenges are further propounded by the fact that there are no offices where complaints could be made and so the process is very cumbersome.
  • Oyebisi Babatunde Oluseyi, the chairperson replied that the complaint had been noted and would be brought before on board as quality feedback would then be brought members of the network.


Any Other Business

  • Mrs Uche advised that the Network engage in more collaboration with International Organizations in order to provide more funding opportunities for members.
  • The chairperson noted that a lot of work and planning has been going into such collaborations and favorable outcomes would be recorded soon.
  • Mr Habib Umar asked for the Network’s position regarding the ongoing Too-Young-To-Run Bill currently at the National Assembly.
  • The chairperson replied that the Network is not strongly working on this issue as its main focus is on ensuring the protection of the civil society environment in Nigeria. He assured participants that although the Network would prefer not to deviate from its core objectives for setting up the engagement meetings to held between 16th – 18th May 2017, it would be sure to do all in its power to ensure that all is well the sector.


Closing Remarks

The chairperson raised a proposal for the close of the meeting while noting that outcomes from the engagement meetings would be communicated to participants as soon as the Coalition team

The meeting was drawn to a close at 1:43PM.


Next Meeting

The next meeting will be held on 26th May 2017 at 1:00PM via Skype.