Nigeria's AML/CFT framework has undergone significant reform in a short period. The Money Laundering (Prevention and Prohibition) Act 2022, the CBN Customer Due Diligence Regulations 2023, and the SCUML Regulations 2024 have collectively raised the bar for financial institutions, capital market operators, and designated non-financial businesses and professions operating in the country. The result is a framework that is both comprehensive and genuinely complex to navigate, particularly for businesses that operate across more than one regulated category.
This checklist maps core obligations under Nigeria's AML/CFT legislation to the Sumsub solutions that support them, broken down by sector where requirements differ. It's built for compliance and legal teams who need to understand what's required and what constitutes good implementation.
What's inside:
- KYC and KYB obligations for individuals and legal entities across all three regulatory frameworks, including beneficial ownership identification and representative verification requirements
- Identity verification standards under the AML/CFT and CBN CDD Regulations, including document-based verification, database checks, and Sumsub's Non-Doc solution (independently audited by FINTRAIL for the Nigerian market)
- Sector-specific EDD requirements, including source of funds, PEP screening, and the additional obligations that apply to SEC registrants and iGaming operators
- Transaction monitoring and STR obligations, including the 24-hour reporting window for capital market operators and the currency transaction thresholds applicable to DNFBPs under SCUML
- Travel Rule requirements for businesses engaged in virtual asset transfers
- AML Screening obligations across all three sectors, covering UN sanctions lists, the Nigeria Sanctions List, PEP databases, and adverse media
- A product mapping table showing Sumsub coverage across financial institutions, SEC registrants including digital assets, and iGaming operators regulated under SCUML
