Nigeria gets early Christmas present.
Father Christmas had been out and about early for Nigeria as the FATF surprises by holding off on counter-measures.
It's a long way from Lapland but Father Christmas left a wintry Paris on 20 December and headed for Lagos. Behind the reindeer, his sleigh carried the biggest present anyone could give Nigeria - a partial reprieve from the FATFs' threatened "counter-measures" which could have had a very serious effect on the economy of the country.
And others around the world should be looking under their Christmas trees, too, because the decision not to impose counter-measures has relieved financial services businesses outside Nigeria from the burden of complying with those counter-measures. In the case of Nigeria, which has considerable external trade, often in relatively small value per transaction, and has a large expatriate population this would have been a great burden especially on small professional practices.
The FATF says: "The FATF has decided, for the time being, not to apply additional counter-measures to Nigeria due to Nigeria's enactment of the "Money Laundering Act (Amendment) Act 2002" on 14 December 2002. This legislation significantly enhances the scope of Nigeria's 1995 anti-Money Laundering Law. However, deficiencies remain in Nigeria's anti-money laundering regime and Nigeria therefore remains subject to Recommendation 21."
Recommendation 21 says "Financial institutions should give special attention to business relations and transactions with persons, including companies and financial institutions, from countries which do not or insufficiently apply these Recommendations. Whenever these transactions have no apparent economic or visible lawful purpose, their background and purpose should, as far as possible, be examined, the findings established in writing, and be available to help supervisors, auditors and law enforcement agencies."