By Lukman Bolaji Tairu
Abstract
President Muhammadu Buhari, on 12th May, 2022, signed the Money Laundering (Prevention and Prohibition) Act, into law to address the lethal effect of money laundering activities and related crimes in Nigeria and ensure compliance with international anti-money laundering instruments, best practices and standards spearheaded by the Financial Action Task Force. The Act repealed the Money Laundering (Prohibition) Act, No. 11, 2011 to provide an effective and comprehensive legal and institutional framework, for the prevention, prohibition, detection, prosecution and punishment of money laundering and other related offences in Nigeria. Equally, it established the Special Control Unit Against Money Laundering under the Economic and Financial Crimes Commission with a mandate to, inter alia, register, certify, monitor, and supervise, necessary enforcement actions to ensure compliance and conduct off-site, on-site, and on the spot checks, inspection of designated non-financial businesses and professions for money laundering control and supervision under the Act, relevant laws and applicable regulations. This paper aims to assess the proprietary of the inclusion of legal practitioners in the operation of the Act and identify the superadded obligations imposed on legal practitioners. It also considers, on the same matter, the decisions in Central Bank of Nigeria v. Registered Trustees of the Nigerian Bar Association and Federal Republic of Nigeria v. Chief Mike Ozekhome (SAN) and posits that the Act did not properly capture legal practitioners or overrule the position of courts in those cases.
Keywords: Legal Practitioners, Anti-Money Laundering
INTRODUCTION
To follow the global best practices in the fight against money laundering as spearheaded by the Financial Action Task Force (FATF)[2], the Federal Government of Nigeria through the Federal Ministry of Justice and other relevant stakeholders evaluated the country’s Anti-Money Laundering (AML) regime in line with the Mutual Evaluation carried out by the Inter-Governmental Action group against Money Laundering in West Africa, recognised by its French acronym (GIABA)[3]. The deficiencies identified in the country’s Anti-Money Laundering/Combating of Terrorism (AML/CFT) during the evaluation birthed the Money Laundering (Prevention) Bill 2022 transmitted to the National Assembly in a letter dated 12th April, 2022.[4] The Nigerian Senate on 16th March, 2022 passed the Bill while the Green Chamber, the House of Representatives adopted it on the 4th May, 2022. The President put the final seal on the Bill by signing it into law as Money Laundering (Prevention and Prohibition) Act, 2022 (MLPPA) on the 12th May, 2022 making it a law passed within a short period, a feat that cannot be matched by thousands of Nigerian legislations.
Even though the fear of the FATF’s “negative statement blacklisting” cited as the reason for the introduction of the new law is commendable; it was the beginning of wisdom for the government as indicated by the expeditious process of the passage of the law. This is to address the deficiencies in the old law and bring the country’s AML legal regime in conformity with FATF recommendations. Before the enactment, the inclusion of legal practitioners in the meaning of the Designated Non-Financial Institution (DNFI) under the repealed Money Laundering (Prohibition) Act, 2011 (the Old Act) was struck down by the court in the cases of Central Bank of Nigeria v. Registered Trustees of the Nigerian Bar Association[5]and Federal Republic of Nigeria v. Chief Mike Ozekhome (SAN)[6]
The MLPPA employs the appellation: Designated Non-Financial Business and Profession (DNFBP) to replace DNFI used in the old Act and re-includes legal practitioners in its definition.[7] This re-inclusion was done without addressing the salient issues that necessitated the exclusion of legal practitioners from the meaning of DNFI and operation of the old Act by the Court in the above decisions and in this author’s opinion, same leaves more to be desired.
Consequently, this paper seeks to analyse the anti-money laundering (AML) regime under the MLPPA through these judicial decisions decided before the enactment of the law. The paper juxtaposes the old Act with the MLPPA identifying the additional obligations on legal practitioners which were hitherto not in the old Act. It concludes that the above decisions of the Court are still extant notwithstanding the provisions of the MLPPA.
Designated Non-Financial Businesses and Professions (DNFBPs)
Under Section 30 of the MLPPA, the phrase “designated non-financial businesses and professions” or DNFBPs”[8] has the same meaning as “Designated Non-Financial Institutions” used in the 2011 Act but with the inclusion of additional businesses and professions. DNFBPs are defined to include licensed legal practitioners and Notaries.
Legal Practitioners’ Superadded Obligations under the MLPPA 2022.
The legal profession in Nigeria is well regulated by the Legal Practitioners Act, 1975 (LPA)[9] and the Rules of Professional Conduct for Legal Practitioners (“the RPC” or “the Rules”)[10] subsidiary legislation made under the LPA.[11] The RPC contains more than enough provisions to guide legal practitioners in navigating their ways against the corruptive virus of our time.[12]
Under the Rules, it is the mandatory general responsibility of a legal practitioner to uphold and observe the rule of law, promote and foster the cause of justice, maintain a high standard of professional conduct, and not engage in any conduct unbecoming of a legal practitioner.[13] In representing a client, a legal practitioner may refuse to aid or participate in conduct that she believes to be unlawful even though there is some support for an argument that the conduct is legal.[14] The RPC puts the interest of the law over and above that of the legal practitioner’s client to the extent that the legal practitioner shall keep strictly within the law notwithstanding any contrary instruction by her client and, if the client insists on a breach of the law, the legal practitioner shall withdraw his service.[15]
It is also incumbent on a legal practitioner to use his best endeavours to restrain and prevent his client from committing misconduct or breach of the law[16] and he shall not as a professional give service or advice to the client that he knows or ought reasonably to know is capable of causing disloyalty to, or breach of, the law, or bringing disrespect to the holder of a judicial office, or involving corruption of holders of any public office.[17] As part of the legal practitioner’s duty to represent a client within the bounds of the law, he shall not counsel or assist his client in conduct that he knows to be illegal or fraudulent.[18] Where a legal practitioner contravenes any of the provisions of the Rules or fails to perform any of the duties imposed by the Rules, he shall be guilty of professional misconduct and liable to punishment as provided in Legal Practitioners Act, 1975.[19]
Therefore, it is safe to conclude that, in Nigeria, the overwhelming general requirement of the Rules is that legal practitioners must not infringe that law or facilitate an infringement of the law. This obligation is vital in upholding professional standards and obviously extends to activities of bribery and corruption.[20]
The above are some of the sundry duties and responsibilities of legal practitioners in their relationship with clients before the additional obligations and fines such as suspension, revocation, or withdrawal of license by the appropriate licensing authority as the circumstances may demand introduced by the MLPPA[21].
The Superadded Obligations
The MLPPA 2022 retains some provisions of the old Act which were declared as inapplicable to legal practitioners in Nigeria. Apart from being an update on the provisions of the old Act, the MLPPA imposes additional obligations on legal practitioners. Unlike the old Act which requires DNFIs to report suspicious transactions to the Commission within 7 days after the transaction and take appropriate action to prevent the laundering of proceeds of crime or an illegal act, Section 7(2) of the MLPPA imposes a duty on a legal practitioner to within 24 hours of any suspicious transaction draw up a written report containing all relevant information together with the reasons and identity of the principal and/or beneficiary of such transaction and take appropriate action to prevent the laundering of the proceeds of a crime or an illegal act with a report of the suspicious transaction and actions to Special Control Unit against Money Laundering (SCUML) established under the Economic and Financial Crimes Commission.[22]
Like a financial institution, a legal practitioner as a “designated non-financial professional” shall identify and assess the money laundering and terrorism financing risks that may arise concerning the development of new products and new business practices, including new delivery mechanisms, and the use of new or developing technologies for both new and pre-existing products following the requirements specified by the regulatory authorities.[23] Also, legal practitioners are to undertake the risk assessment prior to the launch or use of such products, business practices and technologies; and take appropriate measures to manage and mitigate the risks.[24]
While these provisions are welcome development aimed at conforming to the recommendations of the FATF towards combating money laundering, it is arguable that the majority of legal practitioners may not be able to comply with these provisions. For instance, how will a legal practitioner engaged by a client after the launch of new products or business practices undertake risk assessment or take measures to manage or mitigate risks? These additional obligations such as undertaking risk assessment and taking measures geared towards managing or mitigating risks are alien roles or demands to legal practitioners. Therefore, it is contended that assuming but not conceding that legal practitioners have been properly captured by the MLPPA, is not enough because there is a need for a specific AML regulation for the supervision of the profession and enforceable by relevant professional bodies.[25]
Is the MLPPA applicable to legal practitioners?
The important question here is whether the provisions of Sections 6 and 30 MLPPA can operate side by side with the provisions of LPA in the regulation of legal practitioners? In essence, can the MLPPA be interpreted as curtailing or short-circuiting continuous application of the LPA or superseding the LPA in the regulation of the relationship between a legal practitioner and his client?
Relying on the recent cases of CBN v. Registered Trustees of the NBA[26] and FRN v. Ozekhome[27] albeit decided under the repealed MLP. It is contended that the provisions of the LPA will continue to take precedence over the MLPPA on issues relating to the relationship of legal practitioners and their clients notwithstanding the inclusion of legal practitioners in the meaning of DNFBPs under the MLPPA. Before considering this issue further an overview of the position of the law prior to the enactment of the MLPPA is apposite.
The position under the repealed Act.
The repealed Act re-enacted the AML regime and lumped legal practitioners with other businesses referred to as Designated Non-Financial Institutions. Following this development and several complaints regarding the potential encroachment of the old Act on the lawyer/client privilege, the Nigerian Bar Association (NBA) challenged the provisions of the old Act at the Federal High Court.[28]The NBA’s main grouse was that the provisions of Sections 5 and 25 of the old Act conflicted with the specific provisions of the LPA regulating and governing legal practice in Nigeria. Therefore, it urged the Court to declare the provisions of the Act as they relate to legal practitioners, void.
The Court found in favour of the NBA and held that the LPA and old Act cannot operate side by side or at the same time insofar as the old Act relates to legal practitioners because of the violent conflicts between the two legislations as they affect legal practitioners, their clients and legal practice in Nigeria. Furthermore, the Court held that Sections 5 and 25 of the old Act cannot operate side by side with Section 192(1) of the Evidence Act, 2011 which provides for the privilege of professional communication between client and legal practitioner. This decision was affirmed by the Court of Appeal which also found that the provisions of Sections 5 and 25 of the old Act are invalid, null and void insofar as they purport to apply to legal practitioners because it was not the intention of the lawmakers to bringing legal practitioners under the old Act vide Section 25 and that the meaning of business transactions as defined under the Act are not the primary calling of legal practitioners as the inherent confusion created by the old Act would have been avoided by an “amendment or repeal enactment or clause’’ in the Act.[29]
More recently, the Court of Appeal reaffirmed its earlier decision in the CBN case[30]in Federal Republic of Nigeria v. Chief Mike Ozekhome (SAN)[31]where the Respondent, a senior legal practitioner obtained an order from the Federal High Court sitting in Ekiti State to vacate the interim order freezing the account belonging to and operated by his law firm (Mike Ozekhome’s Chambers) for 120 days. The argument of the Appellant that the sum of N75,000,000.00 (Seventy-Five Million Naira) professional fees for the services rendered by the Respondent in prosecuting actions before various Courts, transferred to the Respondent by the then Governor Ayodele Fayose was from unlawful origin was rejected by the Court. The Court affirmed the decision of the lower court that it is not a requirement of the law that a legal practitioner would go into inquiry before receiving his fees from his client, to find out the source of the fund from which he would be paid. Also, the court found that the lower Court was right to have followed the decision in the CBN case which reaffirmed the position that Legal Practitioners are excluded from those tagged “Designated Non–Financial Institutions” under Section 25 of the MLA.
This is the position of the law before the MLPPA purporting to reinstate the position before these decisions using the phrase “designated non-financial businesses and professions” (DNFBP)[32] to include licensed legal practitioners in its operation and imposed additional AML measures on members of the profession.
Sections 6 and 30 of the MLPPA – (The new law)[33]
Under the MLPPA, DNFBPs are mandated to submit a declaration of their activities to the SCUML. In the case of new business, the submission shall be before the commencement of the new business but for business existing before the commencement of the Act, the submission is to be done within 3 months from the commencement of the Act[34].
In addition, before any transaction involving a sum exceeding US$1,000 or its equivalent, the DNFBPs shall identify the customer by requiring him to fill out a standard data form, present his international passport, driving license, national identity card or such other document bearing his photograph as may be prescribed by the SCUML; and record all transactions in chronological order, indicating each customer’s surname, forenames and address in a register numbered and forward the form and documents to SCUML[35].
A register kept in that regard shall also be forwarded to the SCUML and preserved by the DNFBP for at least five years after the last transaction recorded in the register.[36]
Any DNFBP that fails to comply with the requirements of customer identification and the submission of returns on such transaction within seven days from the dates of the transaction commits an offence and is liable on conviction to a fine of N250,000 for each day during which the offence continues; and suspension, revocation or withdrawal of license by the appropriate licensing authority as the circumstances may demand[37].
It is interesting that despite the decisions of the Court in CBN v. Registered Trustees of NBA[38] and FRN v. Ozekhome[39], the lawmakers included legal practitioners in the meaning of DNFBPs under Section 30 of the MLPPA. Also apparently in the bid to cure one of the lacunae identified under the old Act and “properly” bring legal practitioners under the AML framework, the MLPPA excludes the reliance on professional privilege and invocation of client confidentiality by legal practitioners in respect of the purchase or sale of property, purchase or sale of any business, managing of client money, securities or other assets, opening or management of bank, savings or securities accounts, creation, operation or management of trusts, companies or similar structures or anything produced in furtherance of any unlawful act[40].
While this development is good for the AML legal regime, the law as espoused in the above cases cannot be said to have been extinguished by the provisions of Sections 6 and 30 of the MLPPA or any part thereof. This is because the question of whether (or not) the draftsman has adequately blocked the inherent loopholes or properly included legal practitioners in the provisions of the MLPPA cannot be comfortably answered in the affirmative for apparent reasons.
Firstly, while it is trite that the legislature can at any time repeal or amend laws, the provisions of the MLPPA cannot be said to have altered the pronouncements of the court in CBN v. Registered Trustees of the NBA and FRN v. Ozekhome because there is no presumption that by legislating, parliament intends to change the law.[41] More so, it is firmly settled that in the absence of any clear indication to the contrary, the legislature can be presumed not to have altered judicial precedents.[42] A look at the provisions of Section 11(4) of the MLPPA which excludes the plea of legal professional privilege and invocation of client confidentiality as enshrined in Section 192 of the Evidence Act, 2011 will suggest that these defences are no longer open to legal practitioners in respect of certain transactions and services rendered because of the use of “notwithstanding anything to the contrary in any other law or regulation” used by Section 11(1) of the law.[43] Plausible as that suggestion may sound, it is contended that this provision alone is not enough to bring legal practitioners under the meaning of DNFBP in the MLPPA.
Secondly, a corollary of the above established principles of law is that where there is a change in law, the new law merely replaces the old law as the prevailing law but does not alter or affect the legal regime including the rights and obligations created or extinguished under the old law.[44] Ergo, it is also contended that the inclusion of legal practitioners in the definition of DNFBNPs under the MLPPA has not altered, extinguished or affected the pronouncements of the court in CBN v. Registered Trustees of the NBA and FRN v. Ozekhome on the provisions of the old Act as the MLPPA did not repeal the provisions of the LPA which makes elaborate provisions on the regulation of legal practice in Nigeria.
The LPA being the specific law governing the practice of law with specific provisions will always override the MLPPA which is an enactment with general provisions purporting to regulate the practice of law.[45]
Essentially, the extant position is that Sections 5 and 25 of the old Act (now Sections 6 and 30 of the MLPPA, 2022) insofar as they relate to legal practitioners must give way to the provisions of the LPA notwithstanding the reintroduction or inclusion of legal practitioners in the meaning of DNFBPs under the MLPPA.[46]
Finally, most of the obligations imposed on legal practitioners by the MLPPA are not only alien to legal practice but also inherently laden with demands which can only be met with intense financial requirements.
Conclusion and Recommendations
The MLPPA is, without doubt, a law enacted at the appropriate time when corruption is fighting back and challenging our resolve to face it with the requisite energy and legal frameworks. It is also not deniable that clients are using various money laundering schemes to involve legal professionals in the actualisation of their illegal aims.
Obviously, the positive enforceability of the MLPPA will go a long way to push the fight against corruption to the desired pedestal. This pedestal cannot be reached and the war against corruption cannot be won without the key roles and active involvement of stakeholders like legal practitioners who are officers of the court and ministers in the temple of justice. The legal profession is composed of men of integrity bound by the rule of law, ethics and ethos specified in the Rules of Professional Conduct and subject to disciplinary sanctions. Legal practitioners as “gatekeepers” should not be seen as aiding or abetting the commission of the offence of money laundering or any other offence for that matter.
It is strongly believed that legal practitioners are endowed with the requisite capacity and capability to adapt to the additional obligations imposed on the members of the profession by the MLPPA. However, it should also be added that finances can greatly limit the ability to adjust to these new roles.
Be that as it may, the right thing must be done. It is therefore recommended that in addition to the standards stipulated by the RPC, there should be a specific AML regulation that will strictly apply to the practice of law. Such regulation should be applied by the Legal Practitioners Disciplinary Committee which is charged with the duty of considering and determining any case where it is alleged that a legal practitioner has misbehaved in his capacity as such or should for any other reason be the subject of disciplinary proceedings.
There is equally the need for the inclusion of provisions aimed at achieving some of the stipulations of the MLPPA in the Legal Practitioners Act (Repeal and Re-enactment) Bill currently being considered by the National Assembly with consideration of specialities, size, scale and expertise among legal practitioners and forestall any issue of conflict.
Finally, it is commended that there should be a synergy of efforts by the SCUML, NBA and other relevant bodies towards the development of strategies against the war on corruption.
Notes
[*]Lukman Bolaji Tairu is a dispute resolution, emerging laws and transactional practitioner based in Federal Capital Territory, Abuja.
[2]FATF is an international policy making body that develops and promotes national and international policies to combat money laundering and terrorist financing by setting standards, monitoring effective compliance with those standards and identifying money laundering and terrorist financing threats.Though the FATF has no authority to impose laws on any jurisdiction, the group exerts international political pressure on its member states to enact its anti-money laundering (AML) and combating the financing of terrorism (CFT) recommendations.
[3]GIABAis a specialized institution of the Economic Community of West African States (ECOWAS) responsible for facilitating the adoption and implementation of Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) in West Africa. It is a FATF-Styled Regional Body (FSRB) working with its member States to ensure compliance with international AML/CFT standards. https://www.giaba.org/ (assessed 20th July, 2022). See also; GIABA’s Mutual Evaluation Report – “Anti-money laundering and counter terrorism financing measures: The Federal Republic of Nigeria” August, 2021.
[4]https://tribuneonlineng.com/buhari-requests-senate-to-pass-money-laundering-terrorism-prevention-bills/ (accessed 28th July, 2022); see also: https://placng.org/Legist/senate-passes-money-laundering-prohibitionbill/#:~:text=The%20Nigerian%20Senate%20on%2016,Prevention%20%26%20Prohibition)%20Bill%202022. accessed 29th July, 2022)
[5]Unreported– Appeal No: CA/ABJ/202/2015 delivered on 14th June, 2017
[6](2021) LPELR-54666(CA)
[7] DNFBP used under the MLPPA is largely the same with the meaning of DNFI used by the old Act. However, the former phrase has a wider meaning.
[8] In the Nigerian context, the phrase “designated non-financial businesses and professions” (“DNFBP”) was used in the Central Bank of Nigeria Circulars Ref: FPR/CIR/GEN/VOL.1/028 and FRP/DIR/GEN/CIR/03/001 respectively dated 2nd August, 2012 and 25th February, 2013. The latter circular extended the period that an existing Designated Non-Financial Businesses and Professions DNFBPs were to update their account information in all banks and other financial institutions with evidence of registration with SCUML from six (6) months to three (3) months failing which they would not be allowed to operate such accounts until they comply with the directive.
[9]See for instance Sections 10, 11, 12 and 13 of the Legal Practitioners Act.
[10]See the Rules of Professional Conduct for Legal Practitioners, 2007.
[11]Section 12(4) of the LPA
[12]Layi Batunde SAN, “Legal Practitioners’ Role and Rule of Professional Conduct” in his paper delivered at the Alao Aka Bashorun Memorial Lecture organized by the Nigerian Bar Association (NBA), Ikeja , Reported by Titilope Joseph in Independent.ng on 4th February, 2022 https:independent.ng/legal-practitioners-roles-and-rules-of-professional-conduct/(accessed 4th July, 2022)
[13]Rule 1 of the RPC
[14]Rule 15(1) of the RPC
[15]Rule 15(2)(a) of the RPC
[16]Rule 15(2)(b) of the RPC
[17]Rule 15(3)(a) of the RPC
[18]Rule 15(3)(i) of the RPC
[19] Rule 55 of the RPC.
[20]Ibrahim Abdullahi (2016) “The Role of Legal Practitioners in the Fight against Corruption in Nigeria” International Journal of Innovative Legal & Political Studies 4(3), July-Sept. pp. 25-33, available at: https://seahipaj,org/jounals-ci/sept-2016/IJILPLS/full/IJILPS-S-3-2016.pdf (accessed 4th July, 2022).
[21]See Section 6(3) of the Act.
[22] A legal practitioner who fails to comply with these provisions commits an offence and is liable on conviction to a fine ofN1,000,000 for each day during which the offence continues but the legal practitioner, their officers and employees who carry out their duties under the provisions in good faith shall not be liable to any civil or criminal liability or have any criminal or civil proceedings brought against them by their client. See Section 7(10) and (11) of the Act.
[23]Section 13(1) of the Act
[24]Section 13(2) of the Act
[25]See Stephen Revell – Freshfields Bruckhaus Deringer LLP “The Financial Action Task Force – Lawyers as “Gatekeepers”: Risk-Based Approach Guidance for Legal Professionals” 22 May 2009 – https://www.anti-moneylaundering.org (accessed 29th July, 2022). See also the Central Bank of Nigeria (Anti-Money Laundering, Combating the Financing of Terrorism and Countering Proliferation Financing of Weapons of Mass Destruction in Financial Institutions) Regulations, 2022 released on 20th May, 2022.
[26]Ibid
[27]Ibid
[28] Suit No: FHC/ABJ/CS/173/2013
[29]Ibid
[30]Ibid
[31]Ibid
[32]DNFBFs
[33]The Sections 6 and 30 of the MLPPA, 2022 are the same with the provisions of Sections 5 and 25 of the old Act, 2011 respectively except that DNFBPs used under Section 30 of MLPPA has a wider meaning.
[34] See Section 6(1)(a) of the MLPPA
[35] See Section 6(1)(a) and (c) of the MLPPA
[36] See Section 6(2) of the MLPPA
[37] See Section 6(3)(a) and (b) of the MLPPA
[38]See Note 5 Ibid
[39]Ibid
[40] Section 11(4)(a)-(e) of the MLPPA
[41] See Unity Life & Fire Insurance Company Limited v. D. A. Ladega & Ors (1994)LCN/0190(CA). See also; Planmouth Limited v. Republic of Zaire. (1981) 1 All E.R. 1110 at 1114
[42] See Savannah Bank (Nig.) Ltd. v. Ajilo (1989) 1 NWLR (Pt. 97) 305. See also; Black-Clawson International Ltd. v. Papier Werke Waldh of Aschaffenburg A.G (1975) 1 All E.R. 810 at 814(e) per Lord Raid.
[43]The Supreme Court has held that when term “notwithstanding” is used in a section of a statute, it is meant to exclude an impinging or impeding effect of any other provision of the statute or other subordinate legislation so that the said section may fulfill itself. See : NDIC v. Okem Enterprise Ltd & Anor (2004) LPELR-1999(SC) Per Samson Odemwingie Uwaifo, JSC (Pp 55 – 55 Paras D – F).
[44]See Section 6(1)(a) (b) and (c) of the Interpretation Act Cap. 123, LFN 2004.
[45] See Omini & Ors v. Yakurr LGA & Ors (2019) LPELR-46300(CA) Pp. 10-13, Paras. B-B; F. B. N. Plc v. Maiwada (2013) 5 NWLR (Pt. 1348) 444 at 49.
[46] Ibid Note 39.
References
GIABA’s Mutual Evaluation Report – “Anti-money laundering and counter terrorism financing measures: “The Federal Republic of Nigeria” August, 2021. Layi Batunde SAN, “Legal Practitioners’ Role and Rule of Professional Conduct” in his paper delivered at the Alao Aka Bashorun Memorial Lecture organized by the Nigerian Bar Association (NBA), Ikeja , Reported by Titilope Joseph in Independent.ng on 4th February, 2022 https:independent.ng/legal-practitioners-roles-and-rules-of-professional-conduct/(accessed 4th July, 2022) Ibrahim Abdullahi (2016) “The Role of Legal Practitioners in the Fight against Corruption in Nigeria” International Journal of Innovative Legal & Political Studies 4(3), July-Sept. pp. 25-33, available at: https://seahipaj,org/jounals-ci/sept-2016/IJILPLS/full/IJILPS-S-3-2016.pdf (accessed 4th July, 2022). Stephen Revell – Freshfields Bruckhaus Deringer LLP “The Financial Action Task Force – Lawyers as “Gatekeepers”: Risk-Based Approach Guidance for Legal Professionals” 22 May 2009 – https://www.anti-moneylaundering.org (accessed 29th July, 2022). See also the Central Bank of Nigeria (Anti-Money Laundering, Combating the Financing of Terrorism and Countering Proliferation Financing of Weapons of Mass Destruction in Financial Institutions) Regulations, 2022 released on 20th May, 2022.