Building Nigeria’s AML/CFT Sanctions Regime for Legal Practitioners: An Opportunity to Shape Professional Accountability
Call for Applications: Technical Expertise Needed to Support the Nigerian Bar Association
Nigeria’s exit from the FATF Grey List in October 2025 marks a critical juncture for the country’s anti-money laundering and counter-terrorism financing architecture. Yet maintaining this delisting status requires sustained reform—and one pressing gap has been identified: the legal profession lacks a dedicated, risk-aligned sanctions framework to enforce AML/CFT compliance.
The Nigerian Bar Association’s Anti-Money Laundering Committee (NBA-AMLC), in partnership with the African Center for Governance and with support from the UK Foreign, Commonwealth & Development Office (FCDO), is now seeking qualified consultants to develop a comprehensive sanctions regime that will strengthen professional accountability while protecting the integrity of Nigeria’s legal sector.
The Challenge
The 2024 Legal Sector Risk Assessment identified significant money laundering, terrorism financing, and proliferation financing vulnerabilities within the legal profession. While the NBA’s Rules of Professional Conduct 2023 contain general disciplinary provisions, there is no dedicated framework specifically addressing AML/CFT non-compliance by legal practitioners.
This gap limits the NBA-AMLC’s supervisory authority and weakens the deterrent effect of professional discipline. Building an effective sanctions regime requires technical expertise in three intersecting domains: professional disciplinary law, legal ethics regulation, and AML/CFT compliance.
What We’re Looking For
We’re inviting qualified individual consultants and consulting firms with demonstrated expertise in professional disciplinary law, legal ethics, and AML/CFT regulation to lead a 12-week, 25-day assignment delivering:
- A comprehensive comparative analysis of sanctions regimes applied by legal self-regulatory bodies in comparable jurisdictions
- A risk-aligned sanctions framework defining AML/CFT offence categories and a graduated, proportionate sanctions ladder
- Clear procedures for investigation, hearing, and enforcement
- An enforcement procedures manual and adoption brief ready for NBA Council consideration
- Full technical and secretariat support to a specialised drafting team composed of six experienced members from the Legal Practitioners Disciplinary Committee and Body of Benchers
The assignment is structured in five phases—from inception and comparative research through drafting, stakeholder validation, and finalisation—allowing flexibility in scheduling while maintaining rigorous quality.
Who Should Apply
Mandatory qualifications:
- Legal registration in Nigeria or an internationally recognised jurisdiction (for firms) or current legal practice qualification (for individual consultants)
- Minimum 7 years of experience in at least two of: professional disciplinary law, legal ethics, AML/CFT compliance, or regulatory enforcement design
- Demonstrated experience drafting disciplinary codes or sanctions frameworks
- At least one completed assignment with a bar association, law society, professional disciplinary body, or financial intelligence unit
- Team leader must hold a postgraduate degree in Law and have familiarity with the Nigerian Rules of Professional Conduct
Desirable experience:
- Prior work with FATF member or FATF-style regional body AML/CFT sanctions regimes for legal professionals
- Familiarity with the NBA’s Rules of Professional Conduct 2023 and the LPDC
- Experience facilitating consensus-building with senior regulatory and disciplinary bodies
- Previous work with FCDO, EU, GIZ, UNODC, or equivalent development partners
Application Details
Complete applications—including technical proposal, CV/organisational profile, sample deliverable, professional registration, and financial proposal—must be submitted as a single PDF or ZIP package to:
info@africancenterdev.org
Subject line: “RFA/OBJ2/ACT5/2026”
Application Deadline: 14th July 2026
The financial proposal should specify proposed daily professional fees (in Nigerian Naira), total fees calculated against 25 billable days, and any reimbursable costs. Applications will be evaluated on technical merit; the highest-ranked applicant’s financial proposal will be reviewed during contract negotiation.
Download the Full RFA
For complete details on scope, deliverables, evaluation criteria, and submission requirements:
👉 Download the Full Request for Applications (PDF)
This is an opportunity to directly shape how Nigeria’s legal profession approaches AML/CFT compliance—strengthening both professional accountability and the country’s broader anti-corruption architecture at a critical moment.
Questions? Contact the African Center for Governance at info@africancenterdev.org or refer to the full RFA document for additional guidance.
