Nigeria is in the process of preparing for its FATF Mutual Evaluation, with an onsite visit scheduled for September 2019. Ahead of this, Nigeria published a National Risk Assessment for TF and ML (completed in 2016), which identified Designated Non-Financial Businesses and Institutions (DNFIs), of which NPOs are a subset, as being amongst those sectors most vulnerable to ML/TF. Spaces for Change, a Global NPO Coalition member, came out with a report earlier this year challenging the assessment of risk for the non-profit sector. Titled Unpacking the Official Construction of Risks and Vulnerabilities for the Third Sector in Nigeria, the report sought to dispute the official classification of NPOs as DNFIs and to tease out the nuances between vulnerability and threat, among other issues.
The report has led to increased and constructive engagement with the FIU (SCUML) and other government and NPO stakeholders, including GIABA, the FATF-Style Regional Body for West Africa.