Financial crime investigation in Nigeria – why it matters for trade

Financial crime investigation in Nigeria has moved from a background compliance issue to a core business risk, especially for companies involved in import/export, wholesale distribution, FMCG and logistics.

Regulators such as the Economic and Financial Crimes Commission (EFCC), the Central Bank of Nigeria (CBN) and the Nigerian Financial Intelligence Unit (NFIU) closely monitor cross-border payments, trade finance, and foreign exchange utilisation. For trading and distribution businesses, that means:

• Tighter scrutiny on international transactions

• More documentation checks at banks and ports

• Higher expectations around customer and supplier due diligence

Working with partners such as Wigmore Trading who understand these risks can significantly reduce exposure and operational delays.

Key risks driving financial crime investigation in Nigeria

1. Trade-based money laundering in imports and exports

Trade-based money laundering (TBML) is a major focus of financial crime investigation in Nigeria. It involves using legitimate trade transactions to disguise illicit funds. Common red flags include:

• Over-invoicing or under-invoicing of imported goods

• Ghost shipments or falsified bills of lading

• Mismatches between goods declared and goods received

• Complex routing of payments through multiple jurisdictions

Importers, exporters and wholesalers dealing in high-value or high-volume goods (such as FMCG, electronics, or food commodities) are particularly exposed. Robust documentation and independent verification of suppliers, pricing and logistics help to protect against TBML.

2. Foreign exchange misuse and documentation gaps

Access to foreign exchange (FX) remains tightly controlled in Nigeria. Financial crime investigation teams frequently review:

• Sources of FX used for imports

• Supporting documents (Form M, pro forma invoices, final invoices, packing lists)

• Evidence that imported goods actually arrive in Nigeria

Any inconsistencies can trigger reviews or delays at banks, customs or regulators. Businesses that trade across multiple African markets need consistent, well-organised paperwork to satisfy Nigerian FX and customs controls.

3. Fraud and diversion in wholesale and FMCG distribution

Financial crime investigation in Nigeria is not limited to banks. Trading and distribution companies also face:

• Invoice fraud and duplicate billing

• Collusion between staff and third-party transporters

• Diversion of stock in transit

• Fake suppliers or shell distributors

For FMCG and wholesale distribution, where goods move quickly and often on credit, a structured control framework and vetted partner network are essential.

Regulatory expectations around financial crime investigation in Nigeria

1. Know Your Customer (KYC) and Know Your Business (KYB)

Regulators expect both financial institutions and trading companies to understand who they are dealing with. This includes:

• Verifying company registration and beneficial ownership

• Checking directors and shareholders against sanctions and watchlists

• Understanding the nature of the customer’s business and typical transaction patterns

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For import/export and logistics activities, this due diligence extends to intermediaries such as freight forwarders, customs agents and warehouse operators.

2. Record keeping and transaction monitoring

Financial crime investigation in Nigeria relies heavily on the quality of records kept by businesses. That means:

• Maintaining accurate, complete trade documentation

• Storing contracts, invoices, shipping papers and payment records for the required period

• Monitoring transactions for unusual amounts, destinations or patterns

Companies that manage large product portfolios or serve multiple African markets benefit from structured, centralised document management.

3. Cross-border compliance in African trade

As regional trade within Africa grows, companies must consider:

• Anti-money laundering (AML) and counter-terrorist financing rules in each jurisdiction

• Sanctions and export control requirements

• Compliance with regional trade agreements where applicable

This is particularly relevant for Nigerian businesses importing into or exporting from markets where regulatory expectations differ. Having a partner experienced in African trade logistics and documentation, like Wigmore Trading, makes cross-border compliance more manageable.

How financial crime investigation in Nigeria affects daily operations

Impact on shipping, customs and logistics

Increased financial crime scrutiny can affect:

• Clearance times at ports: Additional checks on invoices or FX documentation may delay release of goods.

• Costs: Storage, demurrage and administrative costs rise if documentation is incomplete or inconsistent.

• Risk of seizure or investigation: Inaccurate declarations or suspicious patterns can trigger deeper investigations.

A well-organised supply chain, supported by reliable logistics partners, reduces the chance of documentation errors that attract attention from investigators.

Impact on banking and payments

Banks are on the front line of financial crime investigation in Nigeria. As a result, businesses may see:

• Longer processing times for international payments

• Requests for additional documents to justify transactions

• Rejection of transactions that do not meet compliance standards

Establishing clear, consistent trade documentation and counterparties with strong compliance profiles helps keep payments flowing smoothly.

Practical steps to manage financial crime investigation risk

1. Strengthen due diligence on suppliers and customers

For importers, exporters and wholesale distributors, due diligence should include:

• Company registration checks and verification of physical addresses

• Reviewing trade history and references where available

• Evaluating price reasonableness to detect over- or under-invoicing

• Confirming logistics routes and warehousing arrangements

Wigmore Trading works with established supplier networks and pre-vetted logistics partners, which can help reduce onboarding risk for new counterparties.

2. Standardise trade documentation and workflows

To withstand financial crime investigation in Nigeria, companies should:

• Use standard templates for invoices, purchase orders and contracts

• Ensure all documents correspond (values, quantities, Incoterms, product descriptions)

• Keep digital copies of all shipping and customs documents

• Train staff on how to complete and review documents correctly

Where businesses rely on external partners for sourcing or logistics, they should choose partners who can provide transparent, accurate documentation for every shipment. Wigmore Trading’s sourcing and logistics teams can support with compliant paperwork from supplier through to delivery.

3. Build controls into inventory and distribution

For FMCG and wholesale distribution, strong internal controls help prevent fraud and diversion. Consider:

• Segregation of duties between ordering, receiving and accounting

• Regular stock counts and reconciliation with system records

• Use of tracking and proof-of-delivery in logistics

• Clear credit and collection policies for distributors and retailers

Working with experienced distribution partners like Wigmore Trading can support controlled expansion into new Nigerian or regional markets, with processes designed to reduce loss and fraud risk.

4. Work with compliance-aware logistics and sourcing partners

Partners directly influence your financial crime risk profile. When choosing sourcing, logistics or distribution partners, assess:

• Their experience operating under Nigerian and regional regulations

• How they manage KYC/KYB and documentation

• Their track record of handling cross-border shipments without compliance issues

Wigmore Trading operates across multiple African markets, combining sourcing, wholesale distribution and logistics support with practical understanding of compliance expectations. This helps clients maintain continuity of supply while staying aligned with regulatory requirements.

The strategic value of getting financial crime compliance right

Treating financial crime investigation in Nigeria as a strategic priority – rather than a box-ticking exercise – offers several benefits:

• More reliable access to banking and trade finance

• Faster customs clearance and fewer shipment disputes

• Stronger reputation with regulators and international partners

• Reduced risk of penalties, seizures or reputational damage

For companies looking to grow their import/export or distribution footprint in Nigeria and across Africa, building compliance into the supply chain from the start is a competitive advantage. Working with partners such as Wigmore Trading who combine commercial experience with practical compliance awareness supports sustainable growth.

Conclusion: turning financial crime investigation in Nigeria into a business advantage

Financial crime investigation in Nigeria is reshaping how trade and distribution businesses operate. Importers, exporters, wholesalers and FMCG distributors that invest in strong due diligence, accurate documentation and control over their logistics flows will be better placed to withstand regulatory scrutiny and maintain smooth operations.

By aligning sourcing, logistics and distribution processes with regulatory expectations – and partnering with experienced providers – businesses can reduce risk while keeping goods moving across Nigerian and regional markets.

Wigmore Trading can help. From sourcing and wholesale supply to logistics coordination and compliant documentation across African trade lanes, Wigmore Trading supports companies that want to trade confidently while managing financial crime risks.