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Nigeria has been added to the FATF Grey-List

Nigeria and Potential Reaction to FATF Grey-List Designation

Nigeria has been added to the FATF Grey-List alongside South Africa. This was disclosed at the end of the FATF Plenary. The second Financial Action Task Force FATF Plenary under the two-year Singapore Presidency of T. Raja Kumar held between 22-24 February 2023. What does ‘Grey-Listing’ mean for Nigeria? This article will tell you more.

What is FATF?

The Financial Action Task Force (FATF) is an intergovernmental organization that aims to combat money laundering and terrorism financing around the world. One of its key tools is the creation of lists that identify countries that are deemed to have inadequate anti-money laundering and counter-terrorism financing (AML/CFT) measures.

There are two main FATF Lists: 
  • FATF Blacklist and 
  • FATF Grey List
  1. The FATF Blacklist (also known as the “High-Risk and Non-Cooperative Jurisdictions” list) consists of countries that have serious deficiencies in their AML/CFT measures and have not made sufficient progress in addressing them. 
  2. The FATF Grey List (also known as the “Jurisdictions under Increased Monitoring” list) consists of countries that have deficiencies in their AML/CFT measures, but have committed to addressing them and are making progress in doing so. 

Nigeria is Now on FATF-Grey List

According to FATF, in February 2023, Nigeria made progress in improving its AML/CFT regime, including improving its legislative framework, assessing ML/TF/PF risks, and implementing targeted financial sanctions.

However, The FATF and FATF-style regional bodies (FSRBs) will continue to work with Nigeria and other countries in the FATF Grey-List  as they report on the progress achieved in addressing their strategic deficiencies. The FATF also calls on Nigeria and other Grey Listed Countries  to complete their action plans expeditiously and within the agreed timeframes. 

Some other countries on  the FATF Grey-List alongside Nigeria includes: Albania, Barbados, Burkina Faso, The Cayman Islands, The Democratic Republic of Congo, Gibraltar, Haiti, Jamaica, Jordan, Mali, Mozambique, Panama, Philippines, Senegal, South Africa (recently added alongside with Nigeria), South Sudan, Syria, Tanzania, Turkiye, Uganda, United Arab Emirates and Yemen.

Cambodia and Morocco were jurisdictions listed to no longer be subject to increased monitoring by the FATF. Hence, removed from the FATF Grey-List.

Negative Effects of Being Included in FATF Grey-List

A nation’s economy and image may suffer significantly if it is placed on the  FATF Grey List. Financial entities might be reluctant to work with organizations or people from the nations on the Grey List, and there might be more scrutiny and reporting requirements for transactions involving those nations.

These are some of the effects: 

  • It adversely affects a nation’s economy when other nations begin to view the country on the grey list as a risky place to engage.
  • Countries that are grey-listed also experience a hit to their tourism industries as travellers tend to steer clear of these nations.
  • It is challenging for the countries on the grey list to get extra funding from international organizations like the IMF and other borrowers.
  • Grave issues associated with greylisting, such as currency depreciation, inflation, and trade deficits, send the economy into disarray.
  • As foreign organizations downgrade the ratings of these nations, the nation’s bond market declines.
  • Grey listed countries could get boycotted on the international stage by other countries. 

3 Positive Effects of Being Included in FATF Grey-List

  1. Participation in the FATF Grey-List  could aid a nation involved in illegal activities in reforming itself.
  2. The greylist serves more as a warning to keep a nation from being included to the more stringent blacklist, where laws and fines are more harsh.
  3. Greylisting might aid a nation in righting its wrongs and reviving its struggling economy.

Potential Reaction and the Way Forward For Nigeria

Nigeria Added to FATF Grey-List: The Way Forward.
FATF Grey-Listing: The Way Forward for Nigeria

To be able to leave the FATF Grey-List, Nigeria will will work to implement its FATF action plan by: 

  1. Completing its residual Money Laundering (ML) /Terrorist Financing (TF) risk assessment.
  2. Enhancing formal and informal international cooperation in line with ML/TF risks.
  3. Improving Anti-Money Laundering (AML)/ Countering the Financing of Terrorism (CFT) risk-based supervision of Financial Institutions (FIs) and Designated Non-Financial Businesses and Professions (DNFBPs) and enhancing implementation of preventive measures for high-risk sectors.
  4. Ensuring alignment with other national strategies relevant to high-risk predicate offences
  5. Showing an increase in the Nigerian Financial Intelligence Unit (NFIU)’s dissemination of financial intelligence and the use of that information by Law Enforcement Agencies (LEAs)
  6. Showing a steady increase in ML investigations and prosecutions in accordance with ML risks.
  7. Promptly identifying currency declaration violations and enforcing appropriate sanctions.
  8. Maintaining thorough records of frozen, seized, confiscated, and disposed assets.


Overall, the FATF’s Black and Grey Lists serve as a powerful tool to encourage countries to take stronger measures to combat money laundering and terrorism financing. By identifying and publicly calling out countries that are not meeting international standards, the FATF helps to incentivize those countries to take the necessary steps to improve their AML/CFT measures and protect the integrity of the global financial system.

It is believed that Nigeria will do what is expected of it to meet up with the standards set by the Financial Action Task Force (FATF) to regain international confidence in its ability to handle matters of AML/CFT. 

At A&D Forensics, we help you implement AML/CFT policies and ensure your Web 3 business is compliant. Contact us for any of our services here

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Chioma Onyekelu is a highly skilled and accomplished professional in the field of cryptocurrency and blockchain technology. She is a Certified Cryptocurrency Investigator and Crypto Compliance Specialist, as well as a Blockchain Forensic Specialist and a teacher. She is also a public speaker and her teachings include consultations and practical solutions for African Start-ups on the best and most cost-effective way to build with compliance in mind. With a wealth of knowledge and experience in these cutting-edge technologies, she is well-equipped to navigate the complex landscape of cryptocurrency-related crimes.

In her current role as a Blockchain Forensic Specialist at A&D Forensics, Chioma is responsible for tracing and investigating cryptocurrency-related crimes, as well as training law enforcement agents and compliance officers on the latest developments and best practices in the field. In addition, she is currently pursuing a Master's degree in Blockchain and Digital Currencies at the University of Nicosia in Cyprus, further solidifying her expertise and understanding of the technology.

Chioma's dedication and passion for the field is evident in her work, and she is committed to staying at the forefront of developments in cryptocurrency and blockchain technology to provide the best possible service to her clients. Her exceptional skills in educating and consulting make her a valuable asset to the industry and an authority in the field of Blockchain and Crypto Compliance.


Adedeji is a Forensic Investigation Practitioner and CertifiedBlockchain/Cryptocurrency Forensic
Investigator (CFE, CCI, CCFI & Reactor Certified) with more than Fifteen years of experience across few banks within the Nigeria Financial Sector and educator in Corporate workplace settings, Deji is uniquely qualified and involved in forensics analysis of Financial Infractions, Cryptocurrency crimes and designing plans that works for Government, Regulators, Law enforcement.

He was appointed by SEC Nigeria as Member Virtual Asset and Fintech Regulatory framework drafting Committee, He is a member of Global Digital Finance’s KYC/AML working group in France and a member of the Industry led Thinktank that worked on and came out with FATF cryptocurrency Travel rule InterMessaging Standard for Virtual Assets (IVMS101) to help combat money laundering and terrorism financing using cryptocurrencies around the globe.

His law enforcement training efforts on new money and cybercrime have seen him train many law enforcement agents in various countries i.e Nigeria Police, Nigeria Army CyberWarfare command, Zambia Financial Intelligence Unit, Zambia Central Bank and more.
He is Chainalysis Sole Africa Investigative Partner helping law enforcement investigate criminal organizations using cryptocurrency to conceal illiccit activities across Africa, he is also a training Partner for Blockchain Intelligence Group based out of Canada.

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