Since 2013, non-profit organizations (NPOs) operating in Nigeria have been designated as obliged reporting entities under various national anti-money laundering and countering financing of terrorism (AML/CFT) programs and regimes. SPACES FOR CHANGE has led advocacy pushing back on governmental restrictions on civil society either framed around countering terrorism and protecting national security or resulting from the perception of NPOs as conduits for money-laundering or the financing of terrorism. S4C’s 2019 research report, Unpacking the Official Construction of Risks and Vulnerabilities for the Third Sector in Nigeria, challenged the official classification of NPOs as designated non-financial institutions (DFNIs). It also interrogated the evidential basis for tagging DNFIs—of which NPOs are a subset—amongst those sectors most vulnerable to money laundering (ML) and terrorist financing (TF).
After years of sustained research activism and constructive engagements with authorities campaigning relentlessly against this designation, Nigeria repealed the Money Laundering (Prohibition) Act, NO. 11, 2011 on the 12th of May 2022, and replaced it with another legislation, called the Money Laundering (Prevention and Prohibition) Act, 2022. The new law removed NPOs from the list of DFNIs, extricating non-profit entities from the litany of reporting and regulatory burdens that obstruct their legitimate charitable operations. This policy brief explains the subsisting compliance requirements applicable to non-profits under the new law, the obligations NPOs have been excused from and addresses concerns that have been raised in the non-profit community in Nigeria regarding a possible re-inclusion in the future.