Nigeria’s EU High-Risk Delisting and the Importance of Sustained AML Enforcement

The European Union has removed Nigeria from its list of high-risk third countries for anti-money laundering and counter-terrorist financing, following confirmation that the country addressed deficiencies identified during the Financial Action Task Force monitoring process. The decision changes how EU-regulated entities assess Nigeria-linked financial activity, removing the automatic assumption of elevated country risk.

Nigeria’s Exit From the FATF Grey List as the Precondition for EU Delisting

Nigeria’s removal from the EU high-risk list followed its exit from the FATF grey list in October 2025, after completing a time-bound action plan under FATF’s framework for jurisdictions under increased monitoring. According to the Federal Ministry of Finance, Nigeria’s exit from the FATF grey list reflected sustained reforms across government, regulators, and financial institutions, following two years of coordinated efforts to address weaknesses in anti-money laundering and counter-terrorist financing controls.

These reforms focused on closing technical gaps and demonstrating operational impact in practice, including improvements in supervision, financial intelligence use, and coordination between competent authorities. The FATF decision confirmed that Nigeria had met the agreed conditions for removal from increased monitoring, creating the basis for subsequent changes in how international partners assessed Nigeria’s jurisdictional risk. 

What Changes With EU Delisting in Practice

Removal from the EU high-risk list has direct operational implications. While Nigeria was listed, EU-obliged entities were required to apply automatic, country-based enhanced due diligence to Nigerian-linked transactions. Delisting removes that default requirement.

In practice, this means that Nigeria-linked transactions no longer trigger enhanced due diligence solely on the basis of country risk. EU-regulated firms continue to apply enhanced controls where customer behaviour, transaction patterns, or product risk justify it, but decisions are no longer driven by jurisdiction alone.

"Delisting is a major milestone, and it raises the bar for sustained performance. Keeping lower-risk treatment depends on consistent, coordinated intelligence, effective supervision, and credible enforcement. This ensures that risks are managed early, before they escalate and become headlines."

Patricia Eromosele Director – Africa Chapter, Global Anti-Scam Alliance

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Institutional Actions That Supported Delisting

EU and FATF assessments focus on effectiveness rather than formal compliance, including whether financial intelligence is generated, shared, and used in ways that support investigation and enforcement outcomes.

A central role in this process was played by the Nigeria Financial Intelligence Unit, which has been responsible for strengthening the collection, analysis, and dissemination of financial intelligence and improving coordination across supervisory, investigative, and prosecutorial authorities.

Enforcement capability also formed part of the broader effectiveness assessment. International monitoring increasingly focuses on whether financial intelligence leads to investigation, prosecution, and disruption outcomes, including in cases involving complex and digitally facilitated financial crime such as online fraud and cross-border scam networks. In Nigeria, this has involved the work of law enforcement bodies such as the Economic and Financial Crimes Commission, operating within a wider inter-agency framework rather than as a standalone driver of reform.

What This Development Demonstrates

Nigeria’s removal from the EU high-risk list reflects a shift in how the country is assessed within international AML and counter-terrorist financing frameworks. The decision shows how progress under FATF monitoring can translate into tangible changes in regulatory treatment where reforms demonstrate effectiveness in practice.

At the same time, the delisting does not represent a permanent reclassification. EU risk assessments remain dynamic, and continued access to lower-risk treatment depends on the sustained operation of supervisory, intelligence, and enforcement mechanisms.

For regulators and market participants, the decision reduces automatic compliance friction linked to country risk, while preserving expectations around proportionate, risk-based controls. Nigeria’s position within the EU AML framework will therefore continue to be shaped by outcomes over time, rather than by milestones alone.

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About the Author

James Greening is a Digital Content Manager at the Global Anti-Scam Alliance (GASA), where he writes on cyber-enabled fraud and developments in the global fight against online scams. He previously founded Fake Website Buster, a project dedicated to identifying and raising awareness of fraudulent websites.