Implementation of FATF Countermeasures Against the Islamic Republic of Iran

ECONOMIC AND FINANCIAL CRIMES COMMISSION SPECIAL CONTROL UNIT AGAINST MONEY LAUNDERING Head Office: No. 15 Fomella Street, Off Adetokunbo Ademola Crescent Wuse II, Abuja Tel: 0809 6492 000 Email: info@scuml.org

EFCC/SCUML/HQ/04/VOL.1/083

7th January, 2026

Circular to all DNFBPs, Self-Regulatory Bodies (SRBs) and Trade Associations

IMPLEMENTATION OF FATF COUNTERMEASURES AGAINST THE ISLAMIC REPUBLIC OF IRAN

Background

The Financial Action Task Force (FATF), in its Public Statement titled "Jurisdictions subject to a FATF call on its members and other jurisdictions to apply countermeasures", dated 24th October, 2025, has reiterated its call on all jurisdictions to apply effective countermeasures against the Islamic Republic of Iran.

Despite Iran's re-engagement with the FATF and recent updates on the ratification of the United Nations Convention against Transnational Organized Crime (Palermo Convention), the FATF has determined that:

• Iran has failed to address the majority of deficiencies in its AML/CFT action plan since 2016;
• Reservations entered by Iran to the Palermo Convention are overly broad and inconsistent with FATF standards;
• Significant terrorist financing (TF) and proliferation financing (PF) risks continue to emanate from Iran; and
• Iran remains subject to United Nations Security Council Resolutions relating to nuclear non-proliferation.

Accordingly, Iran remains listed as a High-Risk Jurisdiction subject to a Call for Action, and all jurisdictions are required to apply countermeasures in line with FATF Recommendation 19.

1. Mandatory Countermeasures

DNFBPs, SRBs, and Trade Associations are hereby directed to immediately apply the following FATF-prescribed countermeasures in respect of Iranian nationals, entities, arrangements, and transactions linked to Iran, as part of their AML/CFT/CPF obligations;

1.1 Enhanced Risk Mitigation and Restrictions

DNFBPs shall:

• Refuse or prohibit the establishment of business relationships, subsidiaries, branches, or representative arrangements involving Iranian financial institutions, entities, or arrangements, where applicable to DNFBP activities;
• Refrain from entering into new business relationships or transactions with Iranian nationals or entities where adequate AML/CFT controls cannot be demonstrably applied.

1.2 Enhanced Customer Due Diligence (CDD)

Where engagement with Iranian nationals or entities is legally unavoidable:

• Apply enhanced due diligence (EDD) measures, including senior management approval;
• Establish and document the source of funds and source of wealth;
• Conduct enhanced ongoing monitoring of transactions and business relationships.

1.3 Proliferation Financing and Terrorist Financing Controls

DNFBPs shall:

• Assess and mitigate proliferation financing risks associated with Iran, in line with relevant UNSCRs;
• Screen customers, beneficial owners, and counterparties against UN sanctions lists and relevant national designation lists;
• Immediately freeze assets and report where TF or PF suspicions arise, in accordance with applicable laws.

1.4 Reporting Obligations

All DNFBPs are reminded that:

• Any attempted or completed transaction involving a Iranian nationals, entities or suspected Iran-linked arrangements must be immediately reported to SCUML;
• Such reports should be treated as high-risk and accompanied by relevant documentation and due diligence findings;
• Where suspicion arises, DNFBPs must also file Suspicious Transaction Report to the NFIU, in line with section 7 of the ML(PP)A,2022 and section 84 of the TPPA, 2022.

2. Responsibilities of SRBs and Trade Associations

Self-Regulatory Bodies and Trade Associations are required to:

• Disseminate this circular to all members without delay;
• Sensitise members on Iran-related AML/CFT/CPF and sanctions risks;
• Support compliance monitoring and promptly escalate any identified breaches to SCUML.

3. Supervisory and Enforcement Actions

This circular is issued in furtherance of section 31 of the EFCC (AML/CFT/CPF for DNFBPs and Other Related Matters) Regulations, 2024. Consequently, failure to comply with these directives constitutes a breach of applicable AML/CFT/CPF obligations and may attract regulatory, administrative or enforcement actions, in accordance with Nigerian laws and regulations.

SCUML will continue to monitor compliance with Iran-related targeted financial sanctions and countermeasures, consistent with FATF guidance and international best practices.

Please ensure immediate and full compliance.

[Signature] Harry Erin, fsi 07.01.26 Director, Special Control Unit against Money Laundering (SCUML) Economic and Financial Crimes Commission (EFCC)

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