Grep · sample report

Country Risk Check — You get a sourced risk profile for one country: sanctions programs, FATF status, corruption and AML indices, political stability, payment and transfer risk, and suggested controls.

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Inputs used for this sample
Country Risk Check

Country: Nigeria

Business context (optional): Paying local suppliers in USD for raw materials

Sanctions regimes that apply to you (optional): US OFAC, EU, UK OFSI

Nigeria Country Risk Check for USD Payments to Local Suppliers: Medium Risk

Bottom line

Rating: Medium (assessment). Nigeria carries no country-wide sanctions program under the three regimes you named and has left the FATF grey list. The real risk for paying local suppliers in US dollars is legal and operational: the naira is the legal tender, a legal commentary reports that a Federal High Court refused to enforce a foreign-currency facility, and access to dollars still runs through CBN-regulated channels.

This report is a research summary and not legal advice. Controls are considerations for your compliance and legal teams.

What matters most for this context

Interpretations made

Sanctions: no Nigeria program under OFAC, the EU or the UK, so exposure is list-based

I found no Nigeria-wide or sectoral program in any of the three regimes. Status is quoted from the program indexes retrieved on 5 October 2026. Exposure arises through designated persons, so screening each supplier and owner against the lists is the working control.

Regime Program Scope Key limits Source Date
US OFAC No Nigeria program on the Sanctions Programs and Country Information index; the Nigeria-specific page URL returned 404 None found (list-based only, through the SDN List and other OFAC lists) None country-level. Name screening still applies OFAC programs index; OFAC list search tool Checked 5 Oct 2026
EU Nigeria is not in the country list of the EU Sanctions Map (Niger is) None found None country-level. Screen against the EU consolidated list EU Sanctions Map Map last updated 2 Jul 2026
UK OFSI / FCDO No Nigeria regime visible in the retrieved text of the current UK sanctions regimes collection (assessment: confirm on the OFSI consolidated list) None found None country-level Current UK sanctions regimes Collection last updated 25 Mar 2026
UN Security Council (context) Nigeria is not among the 31 regimes the Council has established None None UN Security Council sanctions Checked 5 Oct 2026

Relevance to this context: Because there is no program, paying a clean Nigerian supplier in dollars does not itself raise a sanctions bar. USD clearing does bring US jurisdiction, so a supplier that is an SDN, or 50% or more owned by one, would still be blocked (assessment, based on how OFAC lists operate). I did not run name searches on any specific counterparty; your supplier names are needed for that.

KEY TAKEAWAY: Sanctions risk is about who you pay, not where they are.

AML and corruption indicators: delisted from the FATF and EU lists, but corruption scores stay weak

Nigeria's formal AML status improved sharply in the last year. Its corruption and governance scores did not.

Indicator Status or score Edition/date Source Stale?
FATF grey list (increased monitoring) Not named on the 19 June 2026 list; Nigeria exited the grey list in October 2025 Plenary 17 to 19 June 2026 FATF increased monitoring, 19 June 2026; Nigeria Federal Ministry of Finance No
FATF black list (call for action) Not checked line by line; the call-for-action page was not fetched 19 June 2026 FATF June 2026 outcomes n/a
Latest mutual evaluation (GIABA) 2021 report (on-site visit 2019). Follow-up report: 32 Recommendations rated C/LC; Nigeria stays in enhanced follow-up on effectiveness MER 4 Nov 2021; follow-up 2023/24 FATF Nigeria follow-up page Yes (older than 12 months)
EU high-risk third countries Nigeria removed by Delegated Regulation (EU) 2026/83, adopted 4 Dec 2025 Official Journal 9 Jan 2026 EUR-Lex 2026/83 No
Basel AML Index 6.18, rank 38 in the 2025 Public Edition table (assessment: higher score means higher risk) 14th edition, 8 Dec 2025 Basel Institute ranking; Basel Institute report page No
TI Corruption Perceptions Index 26 out of 100, 142nd of 182 (140th in 2024) CPI 2025, published 10 Feb 2026 ICIR report on CPI 2025 No
World Bank WGI: Political Stability 35.1 in 2025 (33.2 in 2024), on a 0 to 100 scale Updated 25 Sep 2026 World Bank API, GOV_WGI_PV.SC No
World Bank WGI: Control of Corruption 26.5 in 2025 (25.6 in 2024) Updated 25 Sep 2026 World Bank API, GOV_WGI_CC.SC No
World Bank WGI: Rule of Law 43.0 in 2025 (42.2 in 2024) Updated 25 Sep 2026 World Bank API, GOV_WGI_RL.SC No

Interpretation (assessment): Removal from both the FATF and EU lists lowers the baseline for customer-due-diligence and bank-side friction. A CPI score of 26 and a Control of Corruption score of 26.5 still point to bribery and beneficial-ownership opacity in supplier chains, especially in procurement, customs and permits. Rule of Law (43.0) is the strongest of the three WGI measures but still below the midpoint.

KEY TAKEAWAY: The country-level AML flags are cleared, so the residual risk sits in supplier-level ownership and corruption.

Payment and political risk: dollar supplier payments face legal-tender, FX-access and enforceability risk

Ordered by your context: transfer and FX first, then banking and data, then stability.

Legal tender and USD contracts. The CBN says the Central Bank of Nigeria is the sole issuer of legal tender currency in Nigeria. A legal commentary notes that the CBN Act makes it an offence to refuse the naira and reports a Federal High Court decision that held a foreign-currency facility illegal and unenforceable. The same commentary argues the court was wrong, because legal-tender status does not by itself bar parties from agreeing a foreign-currency price. An academic paper adds that the EFCC Chairman has called domestic dollar pricing an "aberration and unlawful". The decision date and appeal status were not confirmed. My assessment is that the law is unsettled, so a dollar-priced domestic supply contract carries enforcement risk if a dispute reaches a Nigerian court.

FX availability and rates. Nigeria unified its FX windows into the NFEM in June 2023. On 5 October 2026 the official rate was about ₦1,330 per dollar, with the parallel market at ₦1,365 to ₦1,390, and another outlet put the official NAFEM print at ₦1,332. The gap is roughly 2.6% to 4.5% (derived from those figures). These are press-reported rates, not central bank data. The IMF reports that gross reserves rose to US$46 billion in 2025 from US$40 billion at end-2024, which supports dollar availability. A narrow gap suggests that paying through official channels is not heavily penalised, but that is an assessment from a single day's quotes.

Exchange restrictions and repatriation. In the June 2026 Article IV conclusion, IMF Directors called for phasing out remaining exchange restrictions, capital flow management measures and multiple currency practices as conditions permit. The CBN launched the Fourth Edition of its Foreign Exchange Manual on 15 May 2026; I could not retrieve its text, so import-payment documentation rules (such as Form M) must be confirmed against the manual. A banking guide says Nigeria was removed from the IATA blocked-funds list in December 2024, which is older than 12 months (stale) and relates to airline funds, not supplier payments. The same guide says banks still hold limited FX pools and may delay non-priority transactions. Dividend and repatriation limits were not confirmed in this run.

Payment rails and correspondent banking. The CBN unveiled Nigeria Payments System Vision 2028 on 1 June 2026. I found no source showing that Nigerian banks have lost SWIFT access. An undated SWIFT paper states that Nigeria's international banking network has not suffered de-risking; treat that as weak evidence. I found no authoritative recent report on correspondent-bank withdrawals, so this remains an open question.

Data localization. The Nigeria Data Protection Act 2023 was assented on 13 June 2023 and created the NDPC as regulator, and the GAID 2025 was issued on 20 March 2025 with cross-border transfer rules. The same secondary summary says the NDPC reiterated those rules on 24 June 2026, requiring safeguards such as adequacy decisions or contractual clauses. It describes safeguards, not a blanket local-storage rule. Sector rules for banking or telecom were not confirmed. Supplier KYC files that contain personal data will fall under the NDPA when transferred offshore: the NDPC site is the primary source to check.

Stability and conflict. As retrieved through an extraction tool (the official site blocked automated fetches, so re-confirm), the US State Department rates Nigeria Level 3, Reconsider travel, issued 12 June 2026 for crime, terrorism, unrest, kidnapping and health care, with Level 4 for Borno, Yobe, Kogi and northern Adamawa. The UK FCDO page advises against all travel to parts of Nigeria and against all but essential travel to other parts, and its map edition is Edition 11, July 2026. A conflict tracker updated 24 September 2026 describes an active, high-intensity insurgency and communal violence (a secondary source). Separately, the NCDC placed Nigeria on high alert for Ebola on 23 September 2026, after the WHO declared an outbreak in the DRC and Uganda a public health emergency of international concern on 17 May 2026. For raw-material supply, the main effect is on transport and sourcing from northern and middle-belt states (assessment).

KEY TAKEAWAY: The dominant risks are contract enforceability and FX channel access, not sanctions or AML listing.

Controls to apply

# Control Level Why
1 Screen every supplier, owner (25% or more and control persons) and bank against SDN, EU consolidated and UK OFSI lists at onboarding and on list updates Baseline List-based exposure only
2 Obtain beneficial-ownership evidence and run adverse-media and PEP checks on suppliers in procurement-heavy sectors Enhanced CPI 26 and Control of Corruption 26.5
3 Take Nigerian legal advice on whether to price in naira with USD-equivalent indexation, or in USD with explicit governing law and arbitration seat outside Nigeria Enhanced Court decision on foreign-currency facility and legal-tender provisions
4 Pay through authorised Nigerian dealer banks against invoices, with import documentation (confirm Form M or equivalent under the Fourth Edition manual) Enhanced FX rules and documentation text not retrieved
5 Pay only to accounts in the supplier's name and in the stated jurisdiction; no third-party or cash payments Baseline Fraud and AML hygiene
6 Track official and parallel rates weekly and set a gap trigger for review (for example, if the gap exceeds a level you set) Baseline Gap is currently about 2.6% to 4.5% (derived)
7 Add a payment-timing clause covering delays from FX allocation and bank processing Baseline Banks may delay non-priority FX
8 Hold a data-transfer mechanism (contractual clauses or consent basis) before sending supplier personal data offshore Baseline NDPA and GAID 2025
9 Plan site-visit and logistics security for sources in the north and middle belt Enhanced US Level 3 and Level 4 areas
10 Re-run country review after the next FATF plenary and any CBN FX circular Baseline Status can change

Open questions

Sources

Access date for all entries: 5 October 2026.