The Central Bank of Nigeria (CBN) has issued a formal reminder to all banks, payment service banks, and other financial institutions about their continuing obligations to comply with applicable sanctions regimes. These include, but are not limited to:

• The United Nations Consolidated Sanctions List

• The Nigerian Sanctions List, maintained in accordance with the Terrorism (Prevention and Prohibition) Act, 2022

• The CBN AML/CFT/CPF Regulations, 2022

• The CBN Guidelines on Targeted Financial Sanctions Related to Terrorism and Terrorism Financing, 2022

• Any other relevant regional or international sanctions lists

The CBN emphasized that financial institutions must implement and maintain a robust, dynamic sanctions compliance framework, which should be capable of:

• Identifying and responding swiftly to updates across applicable sanctions lists

• Preventing access to the financial system by or on behalf of designated persons or entities

• Conducting real-time screening of customer data, transactions, and beneficial ownership

• Filing reports with the Nigerian Financial Intelligence Unit (NFIU) and notifying the CBN, where required

Institutions are also expected to periodically review and update their compliance programmes in line with evolving legal and regulatory expectations. The CBN cautioned that failure to comply may result in enforcement actions, including monetary penalties and other regulatory consequences.

Financial institutions are strongly advised to assess and strengthen their sanctions compliance frameworks without delay.

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If you have any questions, need additional information, or guidance, please email compliance@thestructurehq.com

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