These sanctions include the United Nations Consolidated Sanctions List, the Nigerian Sanctions List in line with the Terrorism (Prevention and Prohibition) Act 2022, and guidelines on targeted financial sanctions related to terrorism and its financing.
This was contained in a letter dated April 17, 2025 and signed by Amonia Opusunju for the Director of the Compliance Department.
The CBN directed all financial institutions to ensure strict adherence to sanctions lists maintained at both international and national levels.
According to the apex bank, financial institutions are expected to regularly update their systems to identify designated persons or entities and prevent the misuse of financial platforms to facilitate illegal transactions.
The letter read: “Financial Institutions are required to maintain a robust and dynamic sanctions compliance framework that enables them to Identify and respond promptly to updates or changes across all applicable sanctions lists; Prevent the use of their systems and platforms for transactions involving designated individuals or entities; Conduct real-time screening of customers, transactions, and beneficial owners; and File appropriate reports with the Nigerian Financial Intelligence Unit (NFIU) and notify the CBN, where necessary.”
The CBN’s directive also covers real-time screening of customers, transactions, and beneficial owners.
Institutions are to report suspicious activities to the Nigerian Financial Intelligence Unit (NFIU) and notify the apex bank where necessary, the apex bank warned.
According to the bank, non-compliance with the regulations could attract sanctions in form of enforcement actions or regulatory penalties.
It added that sanctions compliance frameworks must be periodically reviewed and aligned with prevailing laws and regulatory expectations.
The CBN advised all financial institutions to take note of the guidance and act accordingly.
“This letter serves as a regulatory reminder and all Financial Institutions are expected to ensure continued compliance with applicable laws and CBN directives,” the apex bank stated.
