Implementation of COSP Resolution 10/6 on Enhancing the Use of Beneficial Ownership Information to Strengthen Asset Recovery
Nigeria: Leveraging beneficial ownership transparency for enhanced asset recovery
Context
Recognizing global challenges with illicit financial flows, Nigeria demonstrated early leadership by proactively addressing transparency gaps in corporate structures, particularly in extractive and public procurement sectors. Like many developing economies, Nigeria faced challenges with complex corporate structures obscuring ultimate beneficial ownership. Sustained pressure from civil society, international partners and Nigeria’s commitments under the EITI and OGP catalyzed comprehensive reforms toward corporate transparency.
Nigeria pioneered global efforts by launching the first public BO register for extractive companies in 2019. This register is in alignment with EITI requirements. [5] The Nigeria Extractive Industries Transparency Initiative (NEITI) oversees compliance across oil, gas and mining sectors, disclosing ownership information for 232 extractive licenses covering companies responsible for over 90 per cent of sector revenues by 2023. [6] This positioned Nigeria as a leading global pilot in sectoral BOT.
Building on EITI leadership, Nigeria achieved another milestone in 2020 with the comprehensive Companies and Allied Matters Act (CAMA 2020), establishing one of Africa’s most robust BO legal frameworks. [7] The reform created the first statutory obligation requiring corporate entities to submit adequate, accurate and up-to-date information on ultimate beneficial owners to the Corporate Affairs Commission (CAC). Complementing CAMA 2020, Nigeria enacted the Proceeds of Crime (Recovery and Management) Act 2022, strengthening Economic and Financial Crime Commission’s (EFCC) mandate and the mandate of other relevant Law Enforcement Agencies to trace and manage assets while recognizing the role of BO data in confiscation proceedings. [8] The Money Laundering (Prevention and Prohibition) Act 2022 reinforced obligations on financial institutions and designated non-financial businesses to obtain BO data, aligning reforms with FATF standards. [9]
By January 2023, the CAC’s Beneficial Ownership Register had collected comprehensive data on over 318,983 companies, representing one of Africa's most extensive databases. [10] Nigeria became the first African country to adopt the Beneficial Ownership Data Standard (BODS), which enables high-quality structured data and international interoperability. [11] The central register, through which BO data is publicly accessible through bor.cac.gov.ng, also provides authorized access to more detailed information to competent authorities including the EFCC, the Nigerian Financial Intelligence Unit (NFIU) and the Federal Inland Revenue Service (FIRS). [12]
This reform framework aligned Nigeria with FATF Recommendation 24, EITI standards and United Nations Convention against Corruption (UNCAC) commitments while establishing regional leadership. Reforms deepened inter-agency collaboration, with BO data systematically shared across CAC, EFCC, NFIU, FIRS, NEITI and other authorities, promoting operational use rather than siloed information management.
Distinctive features of Nigeria’s model
- Legal backbone: CAMA 2020 provides comprehensive statutory mandate with 5 per cent ownership threshold and foundation for Persons with Significant Control Regulations 2022. [13]
- Central register: CAC manages a national register using international standards, evolving toward broader public access with security protocols.
- Practical application: Nigeria pioneered operational use in corruption investigations, linking shell companies to officials and enabling asset recovery.
- Interagency synergy: Law enforcement, financial intelligence and tax authorities maintain systematic access, ensuring operational integration.
- Asset recovery focus: Information explicitly integrated into asset tracing, forfeiture and restitution under UNCAC Article 57.
- International leadership: Nigeria co-sponsored the December 2023 resolution 10/6 adopted by the Conference of the States Parties to UNCAC entitled “Enhancing Beneficial Ownership information to Strengthen Asset Recovery” [14] and Resolution 9/7 entitled “Enhancing the use of Beneficial Ownership information to facilitate the identification, recovery and return of proceeds of crime” in 2021.
Actions and results
Nigeria’s framework has generated substantial results. The extractive sector demonstrates strong compliance, with comprehensive filing by companies representing majority sector activity. Nigeria successfully utilized BO information to expose nominee arrangements, strengthen tax compliance and support international asset recovery. The framework includes monetary penalties under CAMA 2020, personal liability for officers and exclusion from government contracting for persistent offenders. [15]
Demonstrating transformative value, EFCC investigations successfully traced and recovered assets worth over NGN 2.2 billion (~USD 5 million) in a landmark 2016-2019 case involving multiple shell companies. Initially appearing legitimate, CAC records and BO analysis revealed ultimate control linking entities to a senior federal ministry official. Financial forensic analysis enabled comprehensive asset tracing, recovering educational institutions, hospitality facilities and manufacturing assets. The framework enabled the EFCC to obtain final forfeiture orders, and the recovered assets have been repurposed for educational and community benefit. [16]
Ongoing development and challenges
While achieving significant milestones, Nigeria continues enhancing its framework to address evolving challenges. Current priorities include strengthening verification mechanisms, as false declarations and nominee arrangements require continued vigilance. Law enforcement requires enhanced real-time access, particularly for fast-moving financial crime cases.
Cross-border asset tracing presents ongoing complexity, as officials frequently transfer funds internationally through various legal entities. Nigeria is addressing this through enhanced international cooperation and bilateral information-sharing agreements while developing technical capacity for digital integration within financial intelligence systems.
Conclusion and next steps
Nigeria’s experience demonstrates BOT as a powerful operational instrument for law enforcement, litigation and asset restitution. Through systematic inter-agency collaboration, Nigeria has successfully dismantled sophisticated corruption schemes and recovered substantial stolen assets.
Nigeria continues expanding its verification and enforcement capacity while pursuing digital integration within financial intelligence systems. The country actively promotes reciprocal international access through bilateral and multilateral frameworks. Nigeria scored 72 overall in 2024 EITI validation, with strong outcomes and impact performance (92 points), reflecting practical effectiveness. [17] Through these measures, Nigeria deepens its African leadership role while strengthening global anti-corruption contributions.
Nigeria’s experience provides a model for jurisdictions implementing effective BO frameworks delivering tangible asset recovery and corruption prevention results.
Footnotes
[5] Nigeria Extractive Industries Transparency Initiative. (2019). Available: https://bo.neiti.gov.ng.
[6] EITI. (2023). "Progress on beneficial ownership transparency in Nigeria." Available: https://eiti.org/sites/default/files/2023-05/Nigeria Beneficial ownership infographic - Nigeria 2023 pdf.pdf.
[7] Federal Republic of Nigeria. (2020). "Companies and Allied Matters Act 2020." Available: https://www.cac.gov.ng/wp-content/uploads/2020/12/CAMA-NOTE-BOOK-FULL-VERSION.pdf.
[8] Federal Republic of Nigeria. (2022). "Proceeds of Crime Act 2022." Available: https://placng.org/i/wp-content/uploads/2022/05/Proceeds-of-Crime-Recovery-and-Management-Act-2022.pdf.
[9] Federal Republic of Nigeria. (2022). "Money Laundering Act 2022." Available: https://placng.org/i/wp-content/uploads/2022/05/Money-Laundering-Prevention-and-Prohibition-Act-2022.pdf.
[10] Open Ownership. (2023). "Nigeria adopts Beneficial Ownership Data Standard." Available: https://www.openownership.org/en/news/nigeria-adopts-beneficial-ownership-data-standard-for-its-new-national-register/.
[11] Ibid.
[12] Corporate Affairs Commission. (2023). Available: https://bor.cac.gov.ng.
[13] Corporate Affairs Commission. (2022). "Persons with Significant Control Regulations 2022."
[14] UNODC. (2023). "Nigeria leads international community." Available: https://www.unodc.org/conig/en/stories/nigeria-leads-international-community-towards-enhancing-the-use-of-beneficial-ownership-information-in-support-of-stolen-asset-recovery.html.
[15] Companies and Allied Matters Act 2020, Section 120.
[16] EFCC. (2024). Internal case documentation; TVC News. (2025). "EFCC secures 4111 convictions." Available: https://www.tvcnews.tv/efcc-secures-4111-convictions-biggest-asset-recovery-in-2024/; EFCC. (2024). "Single Largest Asset Recovery." Available: https://www.efcc.gov.ng/efcc/news-and-information/news-release/10562-efcc-makes-single-largest-asset-recovery-till-date.
[17] Order Paper. (2025). "Nigeria scores high in EITI assessment." Available: https://orderpaper.ng/nigeria-scores-impressively-high-in-eiti-assessment/.