Enhancing beneficial ownership data collection and use in Nigeria
Part 4: Strategic roadmap for progress
The roadmap below prioritises a small set of practical actions that can be owned, tracked, and implemented by the relevant agencies. These focus on strengthening institutional ownership, improving coordination and verification, and ensuring that BO data is used more systematically and proactively across government.
| Priority area | Key actions | Expected outcomes |
|---|---|---|
|
Maxime the use of BO data through a whole-of-government approach Proposed lead Agency: CAC Supporting Agency: NFIU |
1. Create a Cross-Agency Operational BO Working Group with named focal points from from key BO-holding and BO-using agencies such as CAC, NFIU, NRS, BPP, NUPRC, NEITI, MCO, and NEPZA to facilitate best-practice exchange, share feedback, and address shared challenges on the use of BO data. Nominated BO focal points within key partner agencies will strengthen institutional ownership and day-to-day follow-through on BO-related matters. 2. Implement Periodic Technical Coordination Meetings on a quarterly basis to synchronise register management, align inter-agency efforts, and review how BO data is being used in practice. 3. Require priority agencies (NRS, BPP, NUPRC) to adopt at least one formal internal workflow or SOP that embeds BO checks into routine tax, procurement, or licence screening. 4. To maximise existing government databases, introduce periodic risk-based screening of declared beneficial owners against the NFIU’s domestic sanctions list and other agreed risk indicators, with matches flagged for review. |
More routine and coordinated use of BO data across government; stronger inter-agency collaboration; and a more proactive, risk-oriented BO register |
|
Enhance data quality through verification and systematic feedback mechanisms Proposed lead: NFIU and CAC |
1. Deploy a Semi-Automated Discrepancy Resolution Workflow that flags conflicts when agency data contradicts information held in the CAC register, triggering structured review with human oversight. 2. Establish a formal feedback protocol for the NFIU, the NRS, and LEAs to report data-quality concerns and case-based inconsistencies to the CAC. This can be done through the Cross-Agency Operational BO Working Group. 3. Use the Cross-Agency Operational BO Working Group to map and formalise access to relevant government-held datasets, including Nigeria Immigration Service passport data, FRSC driver’s licence data, and NRS tax information, to strengthen identity verification and support more risk-based verification of BO relationships. |
Faster discrepancy detection and resolution; improved data quality; and a stronger feedback loop between BO disclosure, verification, and operational use |
|
Optimising multi-sector registers through strategic coordination Proposed lead: CAC and extractive sector regulators (NUPRC, MCO, and NEITI) |
1. Agree and use a common BO data collection form so that all agencies use the same core fields, definitions, and formats. 2. Implement API-based integration between the CAC and sector regulators, beginning with extractive sector agencies, to allow automatic comparison and reconciliation of BO records. 3. Introduce automated notifications to flag conflicting BO declarations across registers and prompt review by the relevant agency and reporting entity. |
Reduced duplication and reporting burden; improved consistency across registers; and stronger verification value from maintaining multiple sector-specific registers |
|
Build institutional capacity to sustain BO reform activities Proposed lead: CAC and NFIU |
1. Formalise the CAC’s BO coordination architecture by designating a BO focal point or establishing a cross-departmental BO working group with a clear mandate and measurable performance indicators. This approach consolidates accountability for verification protocols, discrepancy resolution, and stakeholder engagement. It ensures that existing distributed responsibilities are governed by explicit ownership, not assumed coordination. 2. Launch Continuous Capacity-Building Programme to ensure technical staff across DNFBPs and key government agencies collecting and using data remain equipped with up-to-date methodologies for ownership verification, triangulation, and discrepancy resolution. |
Clearer institutional ownership of BO reform; stronger technical capability; and more consistent implementation across the CAC and partner agencies |
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Measuring and demonstrating impact through real-world success Proposed lead: NFIU |
1. Agree on a measurable annual set of BO impact indicators across participating agencies, such as investigations supported, procurement reviews informed, tax cases strengthened, and discrepancies resolved. 2. Require agencies to submit short case examples every six months showing how BO data supported investigations, tax enforcement, procurement screening, or licensing decisions. 3. Produce an annual BO impact note jointly led by the NFIU and the CAC, summarising outcomes, lessons, and areas for improvement. This could be done in partnership with a civil society organisation. |
Stronger evidence of effectiveness; better FATF-facing documentation of BO use; and improved domestic and donor understanding of the value of Nigeria’s BO framework |
Taken together, these recommendations would not only strengthen Nigeria’s BO framework in practice, but also support the country’s compliance with FATF standards, which place increasing emphasis on effectiveness as well as technical compliance. If implemented, they would generate clearer evidence of how BO information is being verified, used, and acted upon across agencies, evidence that could be valuable during future Mutual Evaluation and follow-up processes.
However, for these technical and institutional improvements to be sustained, they must be underpinned by political will. One concrete expression of that would be a presidential executive order or ministerial regulation establishing the CAC register as the national single source of truth for BO information, confirming the CAC’s leadership role on data quality and inter-agency harmonisation, and requiring sector regulators with BO collection mandates to align with CAC standards within a defined timeframe. This would provide the legal and political foundation needed to move from fragmented implementation to a more coherent and sustainable whole-of-government system.