typologies Of Money Laundering From Illicit Trafficking In Drugs And Psychotropic Substances In Nigeria

July 2023 UNITY AND FAITH PEACE AND PROGRESS TYPOLOGIES OF MONEY LAUNDERING FROM ILLICIT TRAFFICKING IN NARCOTICS AND PSYCHOTROPIC SUBSTANCES IN NIGERIA UNDER INVESTIGATION SEALED BY NDLE A LAGOS COMMAND 6/6/23 OF NIGERIA 1000 N50 5870 00 #20 UGENIA BOF1494 50 20 10 5

A publication of the Nigerian Financial Intelligence Unit AN FINANCIAL INTELLIGEN UN NFIU INTEGRITY & DILIGENCE The Nigerian Financial Intelligence Unit (NFIU) is the central national agency responsible for the receipt of disclosures from reporting organisations, the analysis of these disclosures and the production of intelligence for dissemination to competent authorities. The NFIU is an autonomous unit, domiciled within the Central Bank of Nigeria and the central coordinating body for the country's Anti-Money Laundering, Counter-Terrorist Financing and Counter- Proliferation Financing (AML/CFT/CPF) framework. No reproduction or translation of this publication may be made without prior written permission. Applications for such permissions, for all or part of this publication, should be made to The Director/Chief Executive Officer, Nigerian Financial Intelligence Unit 12, Ibrahim Taiwo Street, Aso Villa Abuja, Nigeria 1, Monrovia Street, Block 3, Wuse II, Abuja, Nigeria (e-mail: info@nfiu.gov.ng) © 2023 NFIU. All rights reserved.

TABLE OF CONTENTS ACKNOWLEDGEMENTS 3 LIST OF ACRONYMS 4 CHAPTER 1: INTRODUCTION 6

1. 1 Objective of the Report... 9

2. 2 Methodology/ Scope/Limitation 10 CHAPTER 2: CONCEPTUAL FRAMEWORK FOR ILLICIT TRAFFICKING IN NARCOTIC DRUGS AND PSYCHOTROPIC SUBSTANCES 11

3. 1. Definition of Narcotic Drugs... 11
4. 2. Definition of Psychotropic Substances. 11 CHAPTER 3: NIGERIA'S LEGAL AND INSTITUTIONAL FRAMEWORK FOR COMBATTING ILLEGAL TRAFFICKING OF NARCOTICS AND PSYCHOTROPIC SUBSTANCES. 12 CHAPTER 4: SUMMARY OF REPORTS ON ILLIICT TRAFFICKING IN DRUGS & PSYCHOTROPIC SUBSTANCES 17

5. 1 The 2023 World Drug Report 17

6. 2 THE UNODC 2023 Global Cocaine Report 19

7. 3 FATF (2022), Money Laundering from Fentanyl and Synthetic Opioids 20

8. 4 THE 2022 National Inherent Risk Assessment of MONEY LAUNDERING IN NIGERIA ...... 21

9. 5 Drug Trafficking in Nigeria: Its Causes and Effects on the Citizens (2022): Nigeria and Drug Cartel Links Close to the Summit of Power .. 22

10. 6 Trends in Illicit Drug Trafficking in Nigeria Highlighting the Imperative of Raising the Red Flag (2019). 23

11. 7 The UNODC 2018 Survey on Drug use in Nigeria 23

12. 8 Drug Trafficking and the Threat to Nigeria's National Security (2016). 24

13. 9 Illicit Drug Trafficking In Nigeria: Obstacle To National Development And Security ....... 24 CHAPTER 5 ANALYSIS OF QUESTIONNAIRE RESPONSES. 26 CHAPTER 6: MONEY LAUNDERING TYPOLOGIES AND CASE STUDIES OF ILLICIT TRAFFICKING IN NARCOTIC DRUGS ANS PSYCHOTROPIC SUBSTANCES IN NIGERIA 31

14. 1 Typology1: Laundering The Proceeds Of Illicit Trafficking In Drugs Through The Real Estate Sector.. 31

15. 2 Typology 2: Use Of Auto Dealership.. 33 1 Page

16. 3 Typology 3: Use Of The Capital Market Sector. 36

17. 4 Typology 4: Use Of Bank Products.. 38

18. 5 Other Emerging Typologies In Laundering Proceeds From Illicit Drugs Trafficking 42

19. 6 Illicit Drugs Trafficking Related Suspicious Transaction Reports Filed By Banks To The NFIU 43

20. 7 Jurisdictions of Concern.. 46

21. 8 Trends Associated with Illicit Drug Trafficking 47

22. 9 Vulnerable Sectors Susceptible to Money Laundering through Illicit Trafficking in Drugs Activities 48

23. 10 Emerging Trends of Money Laundering Techniques Associated with Illicit Trafficking in Drugs.... 48

24. 11 Types of Drugs According to Estimated Proceeds of Crime seized and destroyed between 2021 and 2023 by the NDLEA 49

25. 12 Drug Trafficking Heat Map in Nigeria 50 CHAPTER 7: CONTEMPORARY ISSUE ON DRUG TRAFFICKING IN NIGERIA 55 CHAPTER 8: VULNERABILITIES AND CHALLENGES IN THE FIGHT AGAINST ILLICIT DRUG TRAFFICKING IN NIGERIA 58 CHAPTER 9: CONCLUSION AND RECOMMENDATION 61

26. 1 Conclusion 61

27. 2 Recommendation 61 2 Page

ACKNOWLEDGEMENTS We extend our sincere appreciation to the following esteemed agencies, whose contributions have been instrumental in the completion of this report on money laundering typologies through illicit trafficking in drugs and psychotropic substances in Nigeria: 28. Economic and Financial Crimes Commission (EFCC) 29. Federal Ministry of Justice (FMoJ) 30. International Police Organisation – National Central Bureau (INTERPOL – NCB) 31. National Drug Law Enforcement Agency (NDLEA) 32. National Agency for Food & Drug Administration & Control (NAFDAC) 33. Nigeria Customs Service (NCS) 34. Nigeria Immigration Service (NIS) This report represents a collaborative effort marked by diligence, expertise, and unwavering commitment to a critical issue that affects our nation. The importance of this endeavour cannot be overemphasized, as it provides a comprehensive understanding of money laundering typologies through illicit drugs trafficking, particularly in light of the high-risk findings from Nigeria's national risk assessment with respect to the predicate crime. This study is a crucial source of information in a world where the dynamics of money laundering are ever evolving. It provides reporting entities and competent authorities the knowledge required to successfully detect and combat money laundering respectively. Once again, we extend our heartfelt gratitude to these agencies for their invaluable contributions to this endeavour. Together, we stand prepared to face the challenges ahead and secure the integrity of our financial systems. Finally, we would like to express our gratitude to all of the Nigerian Financial Intelligence Unit (NFIU) team members whose persistent work and commitment made this study possible. We appreciate their efforts to this project and their excellent dedication to professionalism and quality. Thank you all for your support and contributions to this report on money laundering typologies through illicit trafficking in drugs & psychotropic substances in Nigeria. Modibbo R. HammanTukur Director/CEO Nigerian Financial Intelligence Unit 3 Page

LIST OF ACRONYMS ADSU Anti-Drug and Smuggling Unit AIDS Acquired Immunodeficiency Syndrome AML Anti Money Laundering ATS Amphetamine-Type Stimulants BDC Bureau De-Change CBN Central Bank of Nigeria CDD Customer Due Diligence CFT Counter Financing of Terrorism CMOS Capital Market Operators CPF Counter Proliferation Financing DNFBPS Designated Non-Financial Businesses and Professions DOGI Directorate of General Investigation DSS Department of State Services EFCC Economic and Financial Crimes Commission FARC Colombia's Revolutionary Armed Forces FATF Financial Action Task Force FinCEN Financial Crimes Enforcement Network Fls Financial Institutions FMoJ Federal Ministry of Justice GOA Government Accountability Office HIV Human Immunodeficiency Virus INCB International Narcotics Control Board INCSR International Narcotics Control Strategy Report INTERPOL-NCB International Police Organisation – National Central Bureau ITD Illicit Trafficking in Drugs KYC Know Your Customer MDMA Methylenedioxymethamphetamine MLPPA Money Laundering (Prevention and Prohibition) Act 2022 NAFDAC National Agency for Food and Drug Administration and Control NAICOM National Insurance Commission NCS Nigeria Customs Service NDLEA National Drug Law Enforcement Agency NFIU Nigerian Financial Intelligence Unit NIRA National Inherent Risk Assessment NIS Nigeria Immigration Service NPF Nigeria Police Force NPS New Psychoactive Substances NSA National Security Agency 4 Page

OFC Offshore Finance Centre PCMD Proceeds of Crime Management Directorate POS Point of Sale PSPS Payment Service Providers SAR Suspicious Activity Reports SCUML Special Control Unit against Money Laundering SEC Securities and Exchange Commission STRs Suspicious Transaction Reports ΤΡΡΑ Terrorism (Prevention and Prohibition) Act 2022 UNDOC United Nations Office on Drugs and Crime USD United States Dollar WHO World Health Organization 5 Page

CHAPTER 1: INTRODUCTION Globally, the use of illicit drugs remains an issue of great concern. Research indicates that in the past 12 months, one in every 17 individuals aged 15-64 has used drugs, with an estimated 296 million users in 2021. The number has increased by 23 percent from 2011, mainly due to population growth. Among the drugs used, cannabis is the most widely-used with an estimated 219 million users globally. While men constitute the majority of cannabis users, women account for 42 percent of users in North America¹. Additionally, in 2021, an estimated 36 million people used amphetamines, 22 million used cocaine, and 20 million used "ecstasy"-type substances. Female users are prevalent in amphetamine-type stimulants and non-medical use of pharmaceuticals, while men dominate opiates and cocaine use. Opioids continue to cause the most severe drug-related harm, including fatal overdoses. An estimated 60 million people engaged in non-medical opioid use in 2021, with 31.5 million using opiates primarily². Most of the proceeds generated from drug trafficking accumulate in the country of consumption, with organised criminal groups profiting from the local sale of drugs. However, as the funds move towards these criminal groups who manage the larger scale shipments, the proceeds and the goods can de-couple and the proceeds may move through more complex money laundering schemes. Criminal groups that operate in an organized manner incur significant costs related to smuggling and procuring drugs and the creation of synthetic opioids (if they engage in clandestine production). These expenses include acquiring manufacturing tools and equipment and hiring specialized labor, such as chemists, to conduct the synthesis. The process may involve intermediary countries and companies facilitating precursor product smuggling. To ensure the arrival of these products, criminal organizations may resort to bribing officials. Regarding the different stages of money laundering, the placement phase typically occurs within the country where the consumer is located. The layering and integration phases often involve bulk cash smuggling, front companies, money value transfer services, trade-based money laundering, or correspondent banking arrangements (particularly for trade-related financial transfers). Criminal organizations use a variety of money laundering schemes, indicating that there is no one "business model" for these activities3. The history of drug abuse in Nigeria dates back to the pre-colonization era when man settled from being a gatherer to a farmer. Among the first crops, he cultivated included intoxicants such 1 https://www.unodc.org/res/WDR-2023/WDR23_Exsum_fin_SP.pdf 2 ibid 3 https://www.fatf-gafi.org/content/fatf-gafi/en/publications/Methodsandtrends/Money-laundering-fentanyl- synthetic-opioids.html 6 Page

as wine, strong tobacco and other hard substances. However, the introduction of illicit drugs in Nigeria did not originate within the country. World War II veterans who returned from Malaysia and Burma (present day Myanmar) brought concealed packets of cannabis as souvenirs, leading to the illegal cultivation of cannabis as farm produce. Although drug trafficking was low between the 60s and 70s, research shows that the 1980s saw the introduction of drugs like Cocaine, Heroin, and Hallucinogens into the country. The Nigerian Government took several measures to monitor drug production, circulation, distribution, and consumption in response⁴. The illicit trafficking of narcotic drugs and psychotropic substances pose a significant global challenge, with severe social, economic, and security implications. This issue, intricately connected with money laundering activities, threatens the stability and development of nations worldwide. Nigeria, as a prominent regional economic power in Africa, has been grappling with the intricate web of illicit drug trafficking and its associated money laundering schemes. Nigeria's geographical location, extensive transportation networks, and complex socio-economic dynamics make it vulnerable to drug trafficking and money laundering. Based on aggregate reporting to UNODC, by Nigeria and other countries, on the main cocaine trafficking routes during 2018-2021, trafficking of cocaine was reported from Nigeria to 20 countries or territories, including countries within the sub-region (Burkina Faso, Mali, Niger, Ghana, Senegal, Liberia), transit countries in Africa (Algeria, Ethiopia, Morocco), and countries and territories in the Asia- Pacific region (Australia, China, Hong Kong, India, Malaysia, Sri Lanka), in the Near and Middle East/ South-West Asia (Pakistan, Saudi Arabia, United Arab Emirates) and in Europe (Turkiye, United Kingdom). Illicit trafficking in narcotic drugs and psychotropic substances is an international term that includes many offences involving narcotic drugs and psychotropic substances such as the production, cultivation, import, smuggling and promotion. The term extends to include crimes related to tools and means of transporting used in the commission of the offences and the diversion of precursors and chemicals used in the illicit manufacture of narcotic drugs and psychotropic substances as well as crimes related to proceeds used in or resulting from illicit trafficking according to Article (3) of the United Nations Convention Against Illicit Trafficking in Narcotic Drugs and Psychotropic Substances (1988) (Vienna Convention). According to the United Nations Office on Drugs and Crime (UNODC), Illicit drug trafficking is a global trade involving the cultivation, manufacture, distribution and sale of substances which are subject to drug prohibition laws. The rising prevalence of illegal drug trafficking across the globe 4 https://peakng.com/history-of-drug-abuse-in-nigeria/ 5 https://www.unodc.org/documents/data-and-analysis/cocaine/Global_cocaine_report_2023.pdf 6 https://www.menafatf.org/sites/default/files/Illicit_Trafficking_and_ML_Eng.pdf 7 Page

(IDT) is one of the major threats to security, economic growth, and human life. The majority of Nigeria's borders are porous, allowing for the simple entry, transportation, and exit of drugs. However, Nigeria's struggling economy, insecurity, high under-employment rate, poverty, inability of the government to provide for basic needs, high level of corruption, and prevalence of the "get rich quick" syndrome among young people are among the many problems that contribute to the state's illicit drug trafficking industry. According to WHO data, about 200,000 people per year die from drug abuse. More than 11 million disability-adjusted life-years are lost every year due to consumption of drugs (opiates, cocaine and amphetalmines), equivalent to some 19 years per 100 drug use.7 Drug trafficking has profound negative effects, such as, increase in drug abuse and related psychological disorders, drug-induced crimes and generate illegal funds for criminals which can be deployed to corrupt public officials, undermine the integrity of national institutions, create distortions in the economy (e.g., inflation) create communal violence, fund insurgency and hijack political power. Through the transiting of illicit drugs, traffickers are able to develop new markets in the countries of transit thereby creating an active drug user population in the country of transit.8 The 2022 National Inherent Risk Assessment (NIRA) of Money laundering in Nigeria has identified drug trafficking as a high-risk predicate crime in Nigeria. The report highlights the proficiency of Nigerian drug cartels in dealing with and trafficking drugs, including psychotropic substances. The use of clandestine laboratories for methamphetamine production has been discovered in various locations in the country. As a result, Nigeria is becoming a significant consumer of hard drugs, transitioning from a transit country. The National Drug Law Enforcement Agency (NDLEA) has reported various drug syndicates operating with high levels of sophistication. Some cartels operate independently, using different laundering methods, with the possibility of connivance between the subjects of investigation, bank officials, and professionals like accountants and lawyers. The report also notes that drug trafficking generates many proceeds, with over 3 million USD worth of drugs seized between 2019 and 2021. Similarly, it has been reported that Nigeria is a significant producer and consumer of cannabis⁹, which was confirmed by the NIRA findings. Four years ago, Nigeria had the highest number of cannabis consumers globally, with 10.6 million people using the drug. The 2022 World Drug Report reveals that illegal drug markets can negatively affect the municipal, community, or 7 https://www.unodc.org/documents/data-and-analysis/Studies/Illicit_financial_flows_2011_web.pdf 8 https://www.giaba.org/media/f/118_final-drugs-typologies-report-dev071811---english.pdf 9 Drug trafficking, consumption rate worry stakeholders | The Guardian Nigeria News - Nigeria and World News News The Guardian Nigeria News – Nigeria and World News 8 Page

individual environment. The carbon footprint of indoor cannabis cultivation is much higher than outdoor cultivation, with estimates ranging from 16 to 100 times more. Additionally, the carbon footprint of 1 kilogram of cocaine is 30 times greater than that of cocoa beans. Environmentally harmful practices associated with illegal drug production include deforestation from cocoa cultivation and the generation of large amounts of waste during the production of synthetic drugs. This waste can be up to 30 times the volume of the finished product, and its disposal can directly or indirectly impact organisms, animals, and the food chain. Thus, at every stage of the production and supply of class A narcotics 10, there is intense competition between rival organized crime groups that frequently results in fatalities. Additionally, there is corruption across the entire drug supply chain, including the involvement of dishonest port and airport personnel. Consequently, drug trafficking organizations frequently engage in a variety of other crimes, and the money made from selling illegal narcotics is used to finance these other crimes, such as purchasing illegal weapons and supporting terrorism. Drug trafficking-related crimes are typically violent, have a clear correlation to illegal usage of weapons and gang-related knife attacks, and traffickers frequently prey on the young and defenseless. In the above light, raising awareness among reporting entities and law enforcement agencies about the different methods used by drug traffickers to move illegal drugs and launder their profits is crucial. To achieve this goal, a team of experts from agencies responsible for regulating and enforcing drug trafficking offences and monitoring suspicious transactions were selected to collaborate with NFIU in conducting this study in order to detect and prevent drug trafficking in Nigeria. The NFIU leverages section 3(1)(0) and 23(2)(b) of the Nigerian Financial Intelligence Unit Act, 2018 to conduct the study. 1.1 OBJECTIVE OF THE REPORT The main purpose of this report is to investigate and understand the different types and methods used by individuals and criminal organizations involved in illicit drug trading in Nigeria. It will also examine the ways they conceal the proceeds generated from drug trafficking, using both traditional and modern methods of money laundering. By studying these patterns, law enforcement agencies, policymakers, and stakeholders can gain a better understanding and develop specific strategies to effectively disrupt and dismantle these criminal networks. The report also aims to achieve the following objectives: 10 This is an illegal narcotic drug classified as being of the most harmful and addictive kind, possession or sale of which incurs the most severe legal penalties. 9 Page

35. To analyze and understand criminal networks involved in drug trafficking, activities and their impact on Nigeria's public health, security, and economic stability.
36. Review the existing legal and regulatory frameworks to identify gaps and challenges in enforcing and implementing anti-money laundering, counter financing of terrorism, counter financing of proliferation (AML/CFT/CPF) measures.
37. Enhance International cooperation, information sharing, and capacity building crucial to combating illicit activities, focusing on Nigeria.
38. To highlight vulnerable sectors and jurisdictions involved in the organized crime of illicit drug trafficking and identify typologies related to drug trafficking and money laundering to facilitate evidence-based policy-making and targeted interventions.
39. To provide recommendations based on the findings to enhance the capacity of law enforcement and intelligence agencies, policymakers, reporting entities and stakeholders and promote collaboration to disrupt and dismantle criminal networks involved in money laundering through drug trafficking. 1.2 METHODOLOGY/ SCOPE/LIMITATION To compile this report, an extensive review of existing literature, reports, open-source information and studies on illicit drug trafficking and money laundering in Nigeria has been conducted. Valuable insights from previous typologies reports, United Nations conventions such as the United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances, and other relevant international agreements have been incorporated to provide a comprehensive overview of the current landscape. The report also benefits from the analysis of questionnaire responses from drug enforcement agencies, investigative agencies, border control agencies and reporting entities identified to be vulnerable to money laundering through illicit trafficking in drugs & psychotropic substances. 10 | Page

CHAPTER 2: CONCEPTUAL FRAMEWORK FOR ILLICIT TRAFFICKING IN NARCOTIC DRUGS AND PSYCHOTROPIC SUBSTANCES This section serves as a foundational component of the report by providing clear definitions of key terms and concepts related to illicit trafficking in narcotic drugs and psychotropic substances, as well as money laundering. A shared understanding of these terms is essential for effective communication and comprehension throughout the report. The definitions provided herein are based on established international conventions, scholarly literature, and legal frameworks. 40. DEFINITION OF NARCOTIC DRUGS: The Single Convention on Narcotic Drugs, 1961, and as amended by the 1972 Protocol stipulated in Article 1(j) that “drug means any of the substances in Schedule I and II, whether natural or synthetic” and in Article 1(u), the Single Convention stipulated that “Schedule I”, “Schedule II”, “Schedule III” and “Schedule IV” mean the correspondingly numbered lists of drugs or preparations annexed to this Convention, as amended from time to time in accordance with Article 311”. The United Nations Convention Against Illicit trafficking in Narcotic Drugs and Psychotropic Substances, 1988, defined narcotic drugs in Article 1(n) saying “Narcotic drug means any of the substances, natural or synthetic, in Schedules I and II of the Single Convention on Narcotic Drugs, 1961, and that Convention as amended by the 1972 Protocol amending the Single Convention on Narcotic Drugs, 1961”. 41. DEFINITION OF PSYCHOTROPIC SUBSTANCES: Article 1(e) of the Convention on Psychotropic Substances, 1971 stated that: “Psychotropic substance means any substance, natural or synthetic, or any natural material in Schedule I, II, III or IV. Article 1(g), the Convention stipulated that: “Schedule I”, “Schedule II”, “Schedule III” and “Schedule IV” mean the correspondingly numbered lists of psychotropic substances annexed to this Convention, as altered in accordance with Article 212". Drug Trafficking is a global illicit trade involving the cultivation, manufacture, distribution and sale of substances which are subject to drug prohibition laws. 13 11 The Single Convention on Narcotic Drugs, 1961, United Nations Publication, New York, 1979, and the Single Convention on Narcotic Drugs, 1961 as amended by the 1972 Protocol, United Nations Publication, New York, 1979. 12 Convention on Psychotropic Substances, 1971, United Nations Publication, New York, 1979. 13 https://www.unodc.org/unodc/en/drug-trafficking/index.html 11 Page

CHAPTER 3: NIGERIA'S LEGAL AND INSTITUTIONAL FRAMEWORK FOR COMBATTING ILLEGAL TRAFFICKING OF NARCOTICS AND PSYCHOTROPIC SUBSTANCES Nigeria has implemented legal and institutional measures to prevent the illegal trafficking of narcotics and psychotropic substances within its borders. To this end, the country has ratified several international conventions: the United Nations Single Convention on Narcotics and Controlled Substances (1961), the United Nations Convention on Psychotropic Substances (1971), and the United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (1988). These conventions are meant to ensure that these substances are used exclusively for medical and scientific purposes and to prevent their diversion for illegal activities. By adhering to these conventions and domesticating them into National Legislation, Nigeria is taking a solid stance against illicit drug trafficking and prioritizing the safety and well- being of its citizens. Notably, below institutions recognize and implement illegal drug prohibition and AML/CFT laws and regulations in line with Nigeria's AML/CFT/CPF regime 42. THE NATIONAL DRUG LAW ENFORCEMENT AGENCY (NDLEA) Until the advent of the National Drug Law Enforcement Agency (NDLEA), the Board of customs and Excise (now Nigeria Customs Service) and the Nigeria Police were the major drug interdiction organs of government, while the Federal Welfare Department was charged with the counseling, treatment and rehabilitation of drug dependent persons. From the activities of the Agency over the years, it is evident that government made no mistake in establishing the body that has become the reference point and the leading light in global efforts against drug cultivation, trafficking and abuse. The NDLEA, established by Decree No. 48 of 29th December 1989, is a federal law enforcement agency responsible for drug policy and control in Nigeria. Its mandate involves preventing the production, importation, exportation, sale, and trafficking of psychoactive substances. To investigate ML-related cases through illicit drug trafficking, the Agency enforces the provisions of the Money Laundering (Prevention and Prohibition Act) 2022, Proceeds of Crime (Recovery and Management) Act 2022, Mutual Legal Assistance in Criminal Matters Act 2019, and other relevant laws. It created specialized departments such as the Directorate of Assets and Financial Investigation, which houses domestically and internationally trained and skilled financial investigators who are dedicated to investigating money laundering cases arising from illegal drug trafficking, tracing, investigating, and seizing of proceeds of crime. This Directorate is also tasked with offering mutual legal assistance when necessary. Another specialized department created by the Agency under the Proceeds of Crime (Recovery and Management) Act, 2022 is the Proceeds of Crime Management Directorate (PCMD), which is responsible for confiscating proceeds of assets. 12 Page

Also, the Agency created Digital Forensic Unit and Intelligence Data Centre to aid in detecting and investigating drug trafficking and Money Laundering, respectively. The Agency also collaborates with financial institutions, Corporate Affairs Commission, National Identity Management Commission, and other relevant agencies in intelligence sharing. The Agency has equally executed MoU with Nigerian Customs Service, The INTERPOL, Gambia, India, Saudi Arabia, South Africa, etc. The NDLEA has a National Drug Control Master plan (2021 – 2025) which is a strategic instrument for addressing the complex issues of drug trafficking, production, cultivation and use in Nigeria. The Plan contains four strategic pillars that culminate in an integrated multi-sectoral strategic and operational plan to comprehensively address drug issues in Nigeria. The pillars are: Supply Reduction; Drug Demand Reduction; Access to Controlled Medicines for Medical and Scientific Purposes; and Governance and Coordination. Each of the strategic pillars is anchored in one or two MDAs of the Government that will be responsible for achieving desired outcomes. 43. THE NATIONAL AGENCY FOR FOOD AND DRUG ADMINISTRATION AND CONTROL (NAFDAC) NAFDAC, established by Decree No. 15 of 1993 and amended by Decree No. 19 of 1999, is responsible for regulating and controlling the production, importation, exportation, distribution, advertising, sale, and use of regulated products like food, drugs, cosmetics, medical devices, packaged water, chemicals, and detergents. It was officially established in October 1992. The Narcotic and Controlled Substances Directorate of NAFDAC ensures that narcotic and psychotropic substances are used solely for medical and scientific purposes and prevents misuse. This includes bulk and finished narcotics, psychotropic substances/drugs, and precursor chemicals, such as opioids for pain relief in patients with HIV/AIDS, cancer, sickle cell anemia, and more. The agency also collaborates with the NDLEA in the control of drug abuse and misuse in Nigeria 44. THE NIGERIA POLICE FORCE (NPF) According to the 1999 Constitution of Nigeria, Sections 214 to 216 establish the Nigeria Police Force as the only police force in the country. The Nigeria Police Act 2020 regulates the Force, as mentioned in Section 4. The Police have the authority to prevent and detect crime, arrest wrongdoers, maintain law and order, safeguard lives and property, and enforce all laws and regulations they are directly responsible for. In cases of drug trafficking, the Police usually refer the cases to the NDLEA. 45. THE NIGERIA CUSTOMS SERVICE (NCS) The Nigerian Customs Service (NCS) is an agency that was established by section 1 of the Nigeria Customs Service Act 2023. One of their primary functions is to prevent the smuggling of goods 13 Page

including illegal drugs and weapons and safeguard businesses against illegal trade practices. They also collaborate with other government agencies to achieve the common goal of advancing Nigeria's interests. similar to the Police, in cases of illicit drug trafficking, NCS usually refer cases to the NDLEA. Furthermore, the NCS plays an important part in the country's economic life. The NCS' actions have an impact on almost every area of the economy, whether directly or indirectly. The NCS service's functions include, but are not limited to, the following: Collecting of revenue (import and Excise duties and other taxes) Anti-smuggling activities i. ii. iii. Security functions iv. Generating statistics for planning and budgeting purposes v. Working in collaboration with other agencies in all approved ports and border stations vi. Engage in Research, planning and enforcement of fiscal policies of government. Import and exports shall where applicable, be subject to prohibitions and restrictions by the NCS relating to the protection of the health and life of humans, animals or plants; currency and other negotiable instruments as prescribed in the Money Laundering (Prevention and Prohibition) Act 2022; controlled goods imported or exported in line with relevant international laws, conventions and agreements, amongst others. 46. NIGERIA IMMIGRATION SERVICE (NIS) The NIS has the authority to oversee immigration matters in Nigeria, as outlined in the Nigeria Immigration Act (NIA), Cap II Laws of the Federal Republic of Nigeria, 2015. The immigration Service is empowered by Section 2 of the Immigration Act, 2015. The Service is responsible for: i. Control of persons entering or leaving Nigeria ii. The issuance of travel documents and passports to Nigerians iii. The issuance of Residence Permit to foreigners in Nigeria iv. Border surveillance control and patrol (land, sea and air) v. Enforcement of laws and regulations with which they are directly charged vi. The performance of such paramilitary duties within or outside Nigeria as may be required of them under the authority of the Act or any other enactment. In cases where they discover drug trafficking, they usually transfer the case to the NDLEA. 47. DEPARTMENT OF STATE SERVICES (DSS) The DSS carries out its duties and responsibilities using Instrument SSS No.1 of 1999, as outlined in Section 6 of the National Security Agencies (NSA) Act 1986 Cap. 74, LFN 2004. Its main functions, among others, are focused on preventing and detecting any crime that threatens the internal security of Nigeria and investigating terrorism offences. Additionally, the department 14 Page

works closely with other agencies to combat illegal drug trafficking. As with other agencies, cases of drug trafficking are referred to the NDLEA for prosecution. 48. THE ECONOMIC AND FINANCIAL CRIMES COMMISSION (EFCC) The EFCC has been given the power to fight against financial and economic crimes by the Act. This includes the ability to investigate, prosecute, and punish those who engage in these offenses. The Commission is also responsible for enforcing other laws and regulations related to economic and financial crimes, such as the Economic and Financial Crimes Commission Establishment Act (2004), the Money Laundering (Prevention & Prohibition) Act 2022, the Advance Fee Fraud and Other Fraud Related Offences Act 1995, the Failed Banks (Recovery of Debts) and Financial Malpractices in Banks Act 1994, the Banks and other Financial Institutions Act 1991, and miscellaneous offenses. 49. NIGERIAN FINANCIAL INTELLIGENCE UNIT (NFIU) The NFIU is the central body in Nigeria for