AML/CFT Compliance Clinic for Non-profit Organizations (2nd edition)

AML/CFT Compliance Clinic for Non-profit Organizations (2nd edition) 5

SPACES FOR CHANGE | S4C organized the second edition of anti-money laundering (AML) and counter financing of terrorism (CFT) Compliance Clinic for non-profit organizations based in the South-South (SS) and South-East (SE) regions of Nigeria. Twenty-six administrators, executive and finance directors of 20 non-profit organizations drawn from the states in the SS and SE participated in the clinic held in Owerri, Imo State capital on Wednesday, August 19, 2020.


The clinic has been designed to enhance AML/CFT knowledge and compliance culture for non-profits in Nigeria. As a result of COVID-19, the federal and state governments are also introducing new regulations and adjusting labour guidelines in ways that change the way work used to be done. Designed to respond to these changes, the clinic aims to build the capacity of organizations to minimise regulatory disruptions that inevitably results in times of crisis.  The clinic also proceeds upon the premise that enhancing regulatory compliance in the non-profit sector forms part of a broader strategy for pushing back on governmental restrictions on the civic space.


Presentations at the clinic facilitated by the staff of SPACES FOR CHANGE and the Special Control Unit Against Money Laundering (SCUML) helped participants to understand scenarios of anti-money laundering and terrorism-financing in nonprofit organisations. They also learned how to develop and implement AML/CFT framework and checklists in the workplace which will help them deal better with regulatory and compliance authorities  such as SCUML,NFIU,FIRS,CAC etc. Very importantly, the sessions also enlightened non-profit leaders about the drivers and solutions to bank de-risking.

AML/CFT Compliance Clinic for Non-profit Organizations (2nd edition) 6

At the end of the clinic, the participants gave the following feedback:

What were the things you liked most about the clinic?

  1. What NPO’s should know about bank de-risking
  2. Understanding SCUML guidelines
  3. Its didactic nature and the deep level of explanation
  4. The stages of ML and TF and the effect on non-profit organizations
  5. The risk-based assessment of NPOs
  6. The compliance checks and tests on my organization
  7. The review on the CAMA 2020, its implications on NPOs, the exposition on our vulnerability as NPOs
  8. The expository and excellent teaching on terrorism-financing
  9. Understanding ML and TF concepts and guidelines
  10. I was exposed to everyday risk scenarios we take for granted in our offices
  11. The use of pictorial representations.

 What aspects of the training could be improved?
a. For the technical aspect of calculating the risk assessment of NPOs, I think mostly
finance staff and high profile officers of organizations should be invited

b. Giving enough time and visuals to take in all. The contents were huge.
c. The practical section could be improved in subsequent training such that a board
is used to practically illustrate the scoring patterns for clearer understanding

d. Too much information in one day. The clinic should have been held over two days.

How will this training influence your work practice?

a. We will regularly file SCUML reports
b. Increased consciousness that organizations can face risks from staff and associates
c. Always declare remaining donor funds
d. We will involve the BOD to revamp our organizational structures.
e. It will help me review my organization’s vulnerability and improve compliance to regulations
f. Inspired to be more transparent, ensure proper documentation,
compliance to legal expectations and always perform proper background
g. We will improve in the area of self-assessments of risk and the need to put in
place mechanisms to mitigate such risks.
h. Ensure that internal control measures are well in place.

i. An opportunity to revisit compliance systems in the organization with respect
to the anti-money laundering laws and regulations, and take important
decisions with the participation of the board of other stakeholders in improving
our accountability systems and compliance.
j. We will take steps to engage an officer to monitor compliance
k. Ensure the organization registers with the necessary authorities.

Private comments

a. This clinic should be regularly organized for organizations across the country.
b. More training like this is encouraged to ensure we are all aware of loopholes
and pitfalls that exist and how to avoid falling prey in a bid to perform our
c. The training is timely and should be expanded to other sectors if possible
d. This is an eye-opener for my organization, as we are now fully equipped with
knowledge and capacity to engage in subsequent matters.
e. Excellent training workshop
f. Lots of knowledge gained to improve processes and systems in our organization


Participating organizations include:

  1. Youth and Environment Advocacy Centre, Rivers State

2.       Policy Alert, Akwa-Ibom State

3.       Kebetkache Women, Rivers State

4.       Foundation for Environmental Rights Advocacy and Development  (FENRAD), Abia State

5.      African Network for Environment and Economic Justice (ANEEJ), Edo State

6.       Youth Forum for Social Change, Enugu State

7.       Coastal Youths Empowerment Foundation, Bayelsa State

8.       Ogoni Solidarity Forum, Rivers State

9.      Entrepreneurship Initiative for African Youth, Enugu State

10.    Public Enlightenment Project, Abia State

11.    Alliances for Africa, Imo State

12.    Cara Development Foundation, Imo State

13.    Development Dynamics, Imo State

14.    Open Arms Initiative, Imo State

15.    Forward Africa, Imo State

16.    Community and Youth Development Initiatives, Delta State

17.     Ambassadors for Female Youth Empowerment, Imo State

18.   Albertiqs Extra Helping Hands Foundation (AEHHF)

19.   Citizens Centre for Integrated Development and Social Rights, Imo State

20.  Special Control Unit Against Money Laundering


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