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NIRA Summary

This document discusses Nigeria's national risk assessment of money laundering, terrorist financing, and proliferation financing risks. It provides an overview of the process for conducting Nigeria's 2022 national risk assessment, including establishing a taskforce to gather and analyze data, validate risks, and draft a report. Key risk assessments are outlined covering terrorism financing, money laundering, proliferation financing, and specific areas like legal entities and the extractive industries. The document concludes with next steps around prioritizing the highest risks and ensuring coordinated mitigation efforts across law enforcement, policy authorities, supervisors, and regulated entities.

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Kawtar Mo
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106 views13 pages

NIRA Summary

This document discusses Nigeria's national risk assessment of money laundering, terrorist financing, and proliferation financing risks. It provides an overview of the process for conducting Nigeria's 2022 national risk assessment, including establishing a taskforce to gather and analyze data, validate risks, and draft a report. Key risk assessments are outlined covering terrorism financing, money laundering, proliferation financing, and specific areas like legal entities and the extractive industries. The document concludes with next steps around prioritizing the highest risks and ensuring coordinated mitigation efforts across law enforcement, policy authorities, supervisors, and regulated entities.

Uploaded by

Kawtar Mo
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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2022 National AML/CFT/CPF Inherent

Risk Assessment
• Nigeria’s 1st National Risk Assessment published in 2016
• 2nd Round AML/CFT Mutual Evaluation of Nigeria in
2019 and Report (MER) published in 2021
• MER noted deficiencies in Nigeria’s understanding of risk
Background and application of counter-measures
• Priority Action includes updating the National Risk
Assessment and the AML/CFT National Strategy
• Risk Understanding and the Risk Based Approach are
fundamental elements of National AML/CFT frameworks
FATF and the Risk Based Approach

•Risks are composed of threats,


vulnerabilities, their likelihood and
Implement • Assess on an ongoing
consequences basis the effectiveness of
•Ensure inclusive approaches to risk •Tailor law enforcement and supervisory
assessment, covering public and private measures (particularly assignment of the risk-based measures
sector resources) to the identified risks
•Ensure broad awareness of the threats and •Prioritise the higher risks and apply
• Update the risk
vulnerabilities enhanced measures assessment on a periodic
•Understand risks at multiple levels: national, •Apply simplified measures where the risk is
sector-wide and institutional (entity-level) lower
basis
•Allow exemptions where there is a
demonstrated and documented low level of
risk

Understand Assess
The FATF has published guidance on risk-based approaches: https://www.fatf-
gafi.org/documents/riskbasedapproach/?hf=10&b=0&s=desc(fatf_releasedate)
Dec 2021
NIRA May – Aug Aug-Sep 2022
Taskforce 2022 Report
Constituted Report review and
with 13 drafting update
Workstreams

Jan 2022 May 2022


Oct 2022
2022 NIRA Training of
NIRA
Data
Validation
Approval of
NIRA by IMC
Taskforce Workshop

Jan-Mar 2022 Mar 2022


Data Pilot
gathering and Validation
analysis Workshop
Terrorism Financing Risk Assessment
• Capacity of terrorist groups
• Global reach of terrorist
Scope groups
• Estimated amount of funds
raised

• Very High Threat from


Islamic State (West Africa)
Key Threats
• High Level of Threat from 4
other groups

• Banking Sector (current


accounts associated with
Key BDCs and agency banking)
Vulnerabilities • DNFBPs (gold dealers)
• Bureau De Change
• Use of NPOs
Money Laundering Risk Assessment
• Capacity of criminal
actors
Scope
• Extent of criminal
activity
• Estimated amount of
criminal proceeds

• Bribery and Corruption


• Traffic in illicit
Key Threats
substances
• Fraud

• Banking Sector
Key (particularly agent
Vulnerabilities banking)
• Real Estate Sector
Proliferation Financing Risk Assessment
• Scope of PF state actors
• Scope of PF actors
Scope
• Scale of proliferation
activity

• High level of Threat from


State Actors (DPRK and
Key Threats Iran)
• Medium Level of Threat
from Non-State Actors

• Banking Sector
(correspondent banking)
Key • OFIs/DNFBPs (lack of PF
Vulnerabilities risk assessment)
• VASPs Sector
• Capital Market
Legal Persons and Legal Arrangements Risk Assessment

• Mainland Legal Persons


• Private Companies Limited - (High Risk)
• Business Names (High Risk)
• Free Trade Zones (FTZs) – Foreign Legal Persons
• Branches of Foreign Legal Persons in FTZ (under the supervision
of the Nigeria Export Processing Zones Authority) - (High Risk)
• Legal Persons operating in the Oil and Gas Export Free Trade
Zone (under the supervision of the Oil and Gas Free Zones
Thematic Authority) – High Risk
Risk • Legal Arrangements – (High Risk)

Assessments Extractive Industries Risk Assessment

• Corruption, tax evasion, illegal mining, smuggling are


amongst the predicate crimes evident in this sector.
• The banking sector serves as conduit for illicit proceeds
out of the extractive sector. Legal entities and the real
estate sector aid in obscuring the source of illicit proceeds
and integrating same into the licit economy.
NIRA – What Next?
Judiciary
Prioritise the adjudication of
high risk predicate offences by
issuing practice guidelines
Issue sentencing guidelines to
ensure the application of
proportionate and dissuasive
sanctions for the most serious
crimes Proceeds of Crime
Pursue confiscation of the
proceeds of serious crimes as a
priority
Collect data on number of
investigations/prosecutions/co
nvictions/recoveries by risk
Law Enforcement area

Prioritise investigation of the


highest risk offences
Allocate resources
(human/financial) to the
highest risk areas
NIRA – What Next?

Policy Authorities
Provide resources targeted at
the highest priority risks
Issue policy guidance on
prioritization of mitigations
against the highest risk areas
Ensure coordination of actions Supervisors
by competent authorities
Carry out sectoral risk
assessments and review
mitigations
Share risk assessments with
all regulated entities
Regulated Entities Issue risk-based guidance to
regulated entities
Carry out institutional risk
assessment based on NIRA
Develop risk based
mitigations
Provide risk assessments
and mitigations with
supervisor
Very High

NIRA – Priority Threat Areas High

Medium

ML Threats TF Threats
Bribery and corruption Islamic State (West Africa Province)
Drug trafficking Boko Haram (JAS)
Fraud Indigenous People of Biafra (IPOB)
Participation in organized crime Yan Bindiga and Yan Ta’ada
Trafficking in persons
Kidnapping PF Threats

Environmental crime Democratic Peoples Republic of Korea

Smuggling Islamic Republic of Iran

Tax crime Non-State Actors


Very High

NIRA – Priority Vulnerabilities High

Medium

ML Threats Legal Persons


Banking sector Private limited companies
Real estate sector Business names
Dealers in precious metals and stones Branches of foreign legal persons in free zones
Trust and company service providers Legal persons operating in oil and gas-free zones
Trafficking in persons Legal arrangements
Casinos and lotteries
Download the NIRA Reports Via:

https://www.nfiu.gov.ng/Home/NiraReports

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