Peer Review of the Automatic Exchange of Financial Account Information 2024 Update

Nigeria

This report analyses the implementation of the AEOI Standard in Nigeria with respect to the requirements of the AEOI Terms of Reference. It assesses both the legal frameworks put in place to implement the AEOI Standard and the effectiveness of the implementation of the AEOI Standard in practice.

The methodology used for the peer reviews and that therefore underpins this report is outlined in Chapter 2.

Overall findings

AEOI legal framework

Nigeria’s legal framework implementing the AEOI Standard is in place but needs improvement in order to be fully consistent with the requirements in the AEOI Terms of Reference. While Nigeria’s international legal framework to exchange the information with all of Nigeria’s Interested Appropriate Partners (CR2) is consistent with the requirements, its domestic legislative framework requiring Reporting Financial Institutions to conduct the due diligence and reporting procedures (CR1) has deficiencies significant to the proper functioning of elements of the AEOI Standard. More specifically, deficiencies have been identified in relation to Nigeria’s enforcement framework.

Overall determination on the legal framework: In Place But Needs Improvement

Effectiveness of AEOI in practice

Nigeria’s implementation of the AEOI Standard is on track with respect to the requirements of the AEOI Terms of Reference to ensure the effectiveness of the AEOI Standard in practice. This includes ensuring that Reporting Financial Institutions correctly conduct the due diligence and reporting procedures (CR1) and exchanging the information in an effective and timely manner (CR2). Nigeria is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.

Overall rating in relation to the effectiveness in practice: On Track

General context

Nigeria commenced exchanges under the AEOI Standard in 2020.

In order to provide for Reporting Financial Institutions to collect and report the information to be exchanged, Nigeria:

• enacted the Income Tax (Common Reporting Standard) Regulations 2019;

• introduced The Income Tax (Common Reporting Standard) Implementation and Compliance Guidelines, 2019.

Under this framework Reporting Financial Institutions were required to commence the due diligence procedures in relation to New Accounts from 1 July 2019. With respect to Preexisting Accounts, Reporting Financial Institutions were required to complete the due diligence procedures on High-Value Individual Accounts by 31 December 2019 and on Preexisting Lower Value Individual Accounts and Entity Accounts by 31 December 2020.

With respect to the exchange of the information under the AEOI Standard, Nigeria is a Party to the Convention on Mutual Administrative Assistance in Tax Matters and activated the associated CRS Multilateral Competent Authority Agreement in time for exchanges in 2020.

Table 1 sets out the number of Financial Institutions in Nigeria that reported information on Financial Accounts in 2023 as defined in the AEOI Standard essentially because they maintained Financial Accounts for Account Holders, or relating to Controlling Persons, resident in a Reportable Jurisdiction. It also sets out the number of Financial Accounts that they reported in 2023. In this regard, it should be noted that Nigeria requires the reporting of Financial Accounts based on a prescribed list of exchange partners and some accounts may be required to be reported more than once (e.g. jointly held accounts or accounts with multiple related Controlling Persons), which is reflected in the figures below. These figures provide key contextual information to the development and implementation of Nigeria’s administrative compliance strategy, which is analysed in the subsequent sections of this report.

Table.1. Number of Financial Institutions reporting and Financial Accounts reported

	Number
Number of Financial Institutions reporting Financial Accounts in 2023	284
Number of Financial Accounts reported in 2023	81 796

Table 2 sets out the number of exchange partners to which information was successfully sent by Nigeria in the past few years (including where the necessary frameworks were in place, containing an obligation on Reporting Financial Institutions to report information, but no relevant Reportable Accounts were identified). These figures provide key contextual information in relation to Nigeria’s exchanges in practice, which is also analysed in subsequent sections of this report.

Table.2. Number of exchange partners to which information was successfully sent

 

	2020	2021	2022	2023
Number of exchange partners to which information was successfully sent	25	63	73	74

In order to provide for the effective implementation of the AEOI Standard, in Nigeria:

• Federal Inland Revenue Service (FIRS) (the tax authority) has the responsibility to ensure the effective implementation of the due diligence and reporting obligations by Reporting Financial Institutions and for exchanging the information with Nigeria’s exchange partners, supported by the various financial regulators in Nigeria;

• technical solutions necessary to receive and validate the information reported by Reporting Financial Institutions were put in place through an online portal; and

• the Common Transmission System (CTS) is used for the exchange of the information, along with the associated file preparation and encryption requirements.

It should be noted that the review of Nigeria’s legal framework implementing the AEOI Standard concluded with the determination that Nigeria’s domestic legal framework is In Place But Needs Improvement and its international legal framework is In Place. This has been taken into account when reviewing the effectiveness of Nigeria’s implementation of the AEOI Standard in practice and where particular identified gaps in Nigeria’s legal frameworks directly impact its implementation in practice, these are mentioned below.

Findings and conclusions on the legal frameworks

The detailed findings and conclusions on the AEOI legal frameworks for Nigeria are below, organised per Core Requirement (CR) and then per sub-requirement (SR) as extracted from the AEOI Terms of Reference (see Annex B).

CR1 Domestic legal framework: Jurisdictions should have a domestic legislative framework in place that requires all Reporting Financial Institutions to conduct the due diligence and reporting procedures in the CRS, and that provides for the effective implementation of the CRS as set out therein.

Determination: In Place But Needs Improvement

Nigeria’s domestic legislative framework is in place and contains most of the key aspects of the CRS and its Commentary requiring Reporting Financial Institutions to conduct the due diligence and reporting procedures, but it needs improvement in relation to the framework to enforce the requirements (SR 1.4). More specifically, the rules in Nigeria’s legislative framework to prevent persons or intermediaries from adopting practices intended to circumvent the reporting and due diligence procedures are insufficient in scope and it does not have an explicit legal basis to enforce a sanction for non-compliance if the Reporting Financial Institution is a legal arrangement.

SR 1.1 Jurisdictions should define the scope of Reporting Financial Institutions consistently with the CRS.

Nigeria has defined the scope of Reporting Financial Institutions in its domestic legislative framework in accordance with the CRS and its Commentary.

Recommendations:

No recommendations made.

SR 1.2 Jurisdictions should define the scope of Financial Accounts and Reportable Accounts consistently with the CRS and incorporate the due diligence procedures to identify them.

Nigeria has defined the scope of the Financial Accounts that are required to be reported in its domestic legislative framework and incorporated the due diligence procedures that must be applied to identify them in accordance with the CRS and its Commentary.

Recommendations:

No recommendations made.

SR 1.3 Jurisdictions should incorporate the reporting requirements contained in Section I of the CRS into their domestic legislative framework.

Nigeria has incorporated the reporting requirements in its domestic legislative framework in accordance with the CRS and its Commentary.

Recommendations:

No recommendations made.

SR 1.4 Jurisdictions should have a legislative framework in place that allows for the enforcement of the requirements of the CRS in practice.

Nigeria has a legislative framework in place to enforce the requirements in a manner that is largely consistent with the CRS and its Commentary. However, a deficiency has been identified. More specifically, Nigeria’s legislative framework does not include rules to prevent all relevant persons or intermediaries from adopting practices intended to circumvent the reporting and due diligence procedures as required and it does not include an explicit legal basis to enforce a sanction where a Reporting Financial Institution is a legal arrangement. These deficiencies relate to key elements of the required enforcement framework and are therefore material to the proper functioning of the AEOI Standard.

Recommendations:

Nigeria should amend its domestic legislative framework to include rules to prevent all Financial Institutions, persons and intermediaries from adopting practices intended to circumvent the due diligence and reporting procedures, rather than just those on whom the AEOI Standard imposes an obligation. 

Nigeria should amend its legislative framework to ensure that there is an explicit legal basis to enforce a sanction when there is non-compliance by a Reporting Financial Institution that is a legal arrangement.

CR2 International legal framework: Jurisdictions should have exchange relationships in effect with all Interested Appropriate Partners as committed to and that provide for the exchange of information in accordance with the Model CAA.

Determination: In Place

Nigeria’s international legal framework to exchange the information is in place, is consistent with the Model CAA and its Commentary and provides for exchange with all of Nigeria’s Interested Appropriate Partners (i.e. all jurisdictions that are interested in receiving information from Nigeria and that meet the required standard in relation to confidentiality and data safeguards) (SRs 2.1 – 2.3).

SR 2.1 Jurisdictions should have exchange agreements in effect with all Interested Appropriate Partners that permit the automatic exchange of CRS information.

Nigeria has exchange agreements that permit the automatic exchange of CRS information in effect with all its Interested Appropriate Partners.

Recommendations:

No recommendations made.

SR 2.2 Such an exchange agreement should be put in place without undue delay, following the receipt of an expression of interest from an Interested Appropriate Partner.

Nigeria put in place its exchange agreements without undue delay.

Recommendations:

No recommendations made.

SR 2.3 Jurisdictions should ensure that the exchange agreements in effect provide for the exchange of information in accordance with the requirements of the Model CAA.

Nigeria’s exchange agreements provide for the exchange of information in accordance with the requirements of the Model CAA.

Recommendations:

No recommendations made.

Assessed jurisdiction’s comments on the assessment of its legal frameworks

Nigeria has observed that under SR.1.4., this Report states that Nigeria’s Legislative framework is in place to enforce the requirements in a manner that is Largely consistent with the CRS and its commentary. However, the Report also highlighted a deficiency – that the Anti-avoidance Rule under Regulation 12 of Nigeria Income Tax (Common Reporting Standard) Regulations 2019 does not prevent ALL relevant persons, including intermediaries from adopting practices intended to circumvent the reporting and due diligence procedures as required.

Nigeria notes the Recommendation to amend its CRS legal framework to address this deficiency, and will take the required steps to update the text of Regulation 12 to meet the Agreed standard.

However, Nigeria hereby places on record that the text of the Nigeria CRS Regulations 2019, including the Anti-avoidance rule, was modelled after the OECD Global Forum CRS Rules that was made available to Nigeria’s Legal drafting team in 2018. We are now aware that the Global Forum learning from experience from reviews of CRS legal framework of over 100 jurisdictions, has in recent times issued a new version of CRS Rules, which amongst other things provides an updated text for the Anti-avoidance rule, with a view to ensuring that all persons in scope, are covered.

Nigeria will be guided by text of the latest version of the Global Forum Model CRS Rules, in our efforts to update the Nigeria Income Tax (Common Reporting Standard) Regulations 2019.

Findings and conclusions in relation to effectiveness in practice

The following table contains the detailed findings for Nigeria, organised per Core Requirement (CR) and then per sub-requirement (SR) as extracted from the AEOI Terms of Reference.

CR1 Effectiveness in practice: Jurisdictions should ensure that in practice Reporting Financial Institutions correctly implement the due diligence and reporting procedures, which includes a requirement for jurisdictions to have in place an administrative framework to ensure the effective implementation of the CRS.

Rating: On Track

Nigeria’s implementation of the AEOI Standard is on track with respect to ensuring that Reporting Financial Institutions are correctly conducting the due diligence and reporting procedures and are therefore reporting complete and accurate information. This includes ensuring effectiveness in a domestic context, such as through having an effective administrative compliance framework and related procedures (SR 1.5), and collaborating with exchange partners to ensure effectiveness (SR 1.6). Nigeria is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.

SR 1.5 Jurisdictions should ensure that in practice Reporting Financial Institutions identify the Financial Accounts they maintain, identify the Reportable Accounts among those Financial Accounts, as well as their Account Holders, and where relevant Controlling Persons, by correctly conducting the due diligence procedures and collect and report the required information with respect to each Reportable Account. This includes having in place:

• an effective administrative compliance framework to ensure the effective implementation of, and compliance with, the CRS. This framework should:

i. be based on a strategy that facilitates compliance by Reporting Financial Institutions and which is informed by a risk assessment in respect of the effective implementation of the CRS that takes into account relevant information sources (including third party sources);

ii. include procedures to ensure that Financial Institutions correctly apply the definitions of Reporting Financial Institutions and Non-Reporting Financial Institutions;

iii. include procedures to periodically verify Reporting Financial Institutions’ compliance, conducted by authorities that have adequate powers with respect to the reviewed Reporting Financial Institutions, with procedures to access the records they maintain; and

• effective procedures to ensure that Financial Institutions, persons or intermediaries do not circumvent the due diligence and reporting procedures;

• effective enforcement mechanisms to address non-compliance by Reporting Financial Institutions;

• strong measures to ensure that valid self-certifications are always obtained for New Accounts;

• effective procedures to ensure that each, or each type of, jurisdiction-specific Non-Reporting Financial Institution and Excluded Account continue to present a low risk of being used to evade tax; and

• effective procedures to follow up with a Reporting Financial Institution when undocumented accounts are reported in order to establish the reasons why such information is being reported.

Findings:

In order to ensure that Reporting Financial Institutions correctly conduct the due diligence and reporting procedures, Nigeria implemented all of the requirements in accordance with expectations. The key findings were as follows:

• Nigeria implemented an overarching strategy to ensure compliance with the AEOI Standard developed after conducting a risk assessment that took into account a range of relevant information sources, including the information reported by Reporting Financial Institutions and publicly available information, such as websites of the Reporting Financial Institutions, tax compliance performance and feedback from exchange partners. The FIRS also receives information from the AML authorities regarding their monitoring activities and sanctions imposed on Financial Institutions for non-compliance with AML/KYC obligations upon request. Nigeria’s compliance strategy facilitates compliance and incorporates a credible approach to verification and enforcement. Nigeria intends to keep its compliance strategy and risk assessment under review to ensure its effectiveness on an ongoing basis.

• Nigeria maintains a list of regulated Reporting Financial Institutions based on publicly available information, such as websites of Financial Institutions and information from regulatory bodies. Nigeria also follows-up with Reporting Financial Institutions that are identified as possibly incorrectly not reporting to ensure they report as required. With respect to non-regulated Entities that may be Financial Institutions for the purposes of the AEOI Standard, Nigeria checks whether Financial Institutions manage the assets of other Entities during its annual compliance activities and follows up as necessary. Nigeria also plans to request from Reporting Financial Institutions details of their Account Holders that are classified as Financial Institutions and is considering the use of its tax database to further identify such relevant Entities. Nigeria intends to continue to review its Financial Institution population on a routine basis.

• The institution (FIRS) responsible for implementing Nigeria’s compliance strategy has the necessary powers and resources to discharge its functions. With respect to resourcing, Nigeria has assigned the equivalent of eight full time staff and two supervisors to monitor and ensure compliance by Reporting Financial Institutions, which have access to IT systems and tools to conduct risk assessments (e.g. SQL, Power BI and Spreadsheets (Excel)). Overall, they appear to have effectively implemented an operational plan to verify compliance with the requirements, incorporating some appropriate compliance activities.

• The FIRS has carried out desk-based reviews of the information reported by Reporting Financial Institutions, using several risk factors, which informed the selection of Reporting Financial Institutions for onsite monitoring visits, designed to understand their processes in place to implement and comply with the AEOI Standard. This includes understanding the frameworks and procedures in place, as well as some limited spot checks to verify correct reporting. It made such visits to 55 Reporting Financial Institutions in 2021. As a result, some Reporting Financial Institutions that failed to conduct to carry out the required due diligence (including failing to obtain valid self-certifications) or failed to keep the required records were identified. These monitoring visits were primarily used to help improve the Reporting Financial Institutions’ understanding of the requirements.

• Building on the onsite monitoring visits, Nigeria conducted onsite audits of 37 Reporting Financial Institutions in 2023 to verify compliance including through the inspection of records held by the Reporting Financial Institutions and to enforce the requirements where appropriate.

• It appears that Nigeria has the ability to effectively enforce the requirements, including through the application of dissuasive penalties and sanctions for non-compliance, although it has not yet done so as its compliance activities and level of financial institution compliance were impacted by the COVID-19 pandemic. Consequently, Nigeria opted not to sanction Reporting Financial Institutions for non-compliance for 2020, 2021 and 2022 but to intensify CRS education and awareness programmes. Nigeria has not yet applied its penalties and sanctions for non-compliance.

• While Nigeria does not have a defined policy in place, it appears ready to take effective action to address circumvention of the requirements if such circumvention is detected. However, it will be somewhat constrained by the scope of its legal power to address circumvention. It also appears that action is being taken to ensure self-certifications are obtained as required and to follow up on undocumented accounts.

• It is noted that Nigeria does not have a jurisdiction-specific list of Non-Reporting Financial Institutions or Excluded Accounts for ongoing monitoring.

Table 3 provides a summary of the specific activities undertaken, or that are planned to be undertaken, in relation to each of the key parts of the framework described above.

Table.3. Activities undertaken

 

Activity type	Activities undertaken
Communication and outreach	Nigeria has carried out substantial communication and outreach activities, such as through a dedicated channel of communication (mailbox and phone line) for queries, sending regular AEOI-CRS Titbits to Reporting Financial institutions via emails, publishing detailed guidance and user manuals on the FIRS website and organising webinars / workshops with Financial Institutions.
Verifying that Financial Institutions are reporting as required	Nigeria has carried out substantial verification activities to ensure that Financial Institutions are reporting as required, including through contacting Financial Institutions following a comparative analysis of the data reported and collaborating with the financial regulators where reports are unexpectedly not received. Nigeria has developed a process to conduct such activities on a routine basis.
Verifying whether the information reported is complete and accurate	Nigeria has conducted a significant number of desk-based checks to verify whether the information being reported is complete and accurate. It accordingly identified some issues, commonly concerning high number of undocumented accounts, non-reporting, incorrect reporting, missing TINs, etc. It is following up on these issues with a view to ensuring future compliance. Nigeria also conducted monitoring visits of 55 Reporting Financial Institutions based on risk, to review their policies and procedures in 2022. Furthermore, Nigeria has conducted onsite audits of 37 Reporting Financial Institutions in 2023. It accordingly identified some issues, commonly concerning accounts for which information was reported incorrectly. It is following up on these issues with a view to ensure future compliance.
Enforcement	Following the activities mentioned above, Nigeria has not yet imposed penalties and sanctions, but has plans to do so in the near future.

In terms of the Financial Account information collected and sent by Nigeria, while the presence of the key data point of dates of birth and the level of undocumented accounts appeared to be in line with most other jurisdictions, it was found to include a much lower proportion of Tax Identification Numbers with respect to the individuals associated with the accounts when compared to most other jurisdictions. These are key data points for exchange partners to effectively utilise the information. Follow-up discussions confirmed that Nigeria is aware of this issue and is taking steps to address it.

Feedback from Nigeria’s exchange partners indicated that, compared to what they generally experience when seeking to match information received from their exchange partners with their taxpayer database, they achieved a much lower level of success when seeking to match information received from Nigeria. Furthermore, 12 exchange partners highlighted issues with respect to the information received such as missing, invalid, or incomplete Tax Identification Numbers, dates of birth and addresses. Follow-up discussions confirmed that Nigeria is aware of some of these issues and is seeking to improve the situation.

Based on these findings it was concluded that, overall, Nigeria is meeting expectations in ensuring that Reporting Financial Institutions correctly conduct the due diligence and reporting procedures, including by having in place the required administrative compliance framework and related procedures. It was also noted that there is room for improvement with respect to implementing a framework to identify non-regulated Entities and put in place a clearly defined policy to address circumvention. Nigeria is therefore encouraged to continue its implementation process accordingly, including in relation to the areas highlighted.

Recommendations:

Nigeria should implement its plans to identify or to follow-up with non-regulated Entities that are Financial Institutions for the purposes of the AEOI Standard.

Nigeria should put in place a clearly defined policy that, where circumvention is identified then action is taken to address it. Reference is made to the recommendation made during the assessment of Nigeria’s legal framework.

Nigeria should continue to address the issues raised by its exchange partners.

SR 1.6 Jurisdictions should collaborate on compliance and enforcement. This requires jurisdictions to:

a) use all appropriate measures available under the jurisdiction’s domestic law to address errors or non-compliance notified to the jurisdiction by an exchange partner; and

b) have in place effective procedures to notify an exchange partner of errors that may have led to incomplete or incorrect information reporting or non-compliance with the due diligence or reporting procedures by a Reporting Financial Institution in the jurisdiction of the exchange partner.

Findings:

In order to collaborate on compliance and enforcement, it appears that Nigeria implemented all of the requirements in relation to issues notified to them (i.e. under Section 4 of the MCAA or equivalent) in accordance with expectations. While no such notifications have yet been received, Nigeria has the necessary systems and procedures to process them as required. It also appears that Nigeria notifies its partners effectively of errors or suspected non-compliance it identified when utilising the information received.

Based on these findings it was concluded that Nigeria is fully meeting expectations in relation to collaborating with its exchange partners to ensure that Reporting Financial Institutions correctly conduct the due diligence and reporting procedures. Nigeria is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.

Recommendations:

No recommendations made.

CR2 Effectiveness in practice: Jurisdictions should exchange the information effectively in practice, in a timely manner, including by sorting, preparing, validating and transmitting it in accordance with the AEOI Standard

Rating: On Track

Nigeria’s implementation of the AEOI Standard is on track with respect to exchanging the information effectively in practice, including in relation to sorting, preparing and validating the information (SR 2.4), correctly transmitting the information in a timely manner (SRs 2.5 – 2.8) and providing corrections, amendments or additions to the information (SR 2.9). Nigeria is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.

SR 2.4 Jurisdictions should sort, prepare and validate the information in accordance with the CRS XML Schema and the associated requirements in the CRS XML Schema User Guide and the File Error and Correction-related validations in the Status Message User Guide (i.e. the 50000 and 80000 range).

Findings:

Feedback from Nigeria’s exchange partners did not raise any specific concerns with respect to their ability to process the information received from Nigeria and therefore with respect to Nigeria’s implementation of these requirements. More generally, one of Nigeria’s exchange partners reported rejecting more than 25% of the files received, reporting that it rejected 50% of files received, due to the technical requirements not being met. This is broadly in line with the general experience of other jurisdictions. It was noted that Nigeria has already successfully addressed the issues raised.

Based on these findings it was concluded that Nigeria is fully meeting expectations in relation to sorting, preparing and validating the information. Nigeria is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.

Recommendations:

No recommendations made.

SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.

Findings:

In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Nigeria linked to the CTS.

Based on these findings it was concluded that Nigeria is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Nigeria is encouraged to continue to ensure the ongoing effectiveness of its implementation.

Recommendations:

No recommendations made.

SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.

Findings:

Feedback from Nigeria’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Nigeria and therefore with respect to Nigeria’s implementation of this requirement.

Based on these findings it was concluded that Nigeria is fully meeting expectations in relation to exchanging the information in a timely manner. Nigeria is encouraged to continue to ensure the ongoing effectiveness of its implementation.

Recommendations:

No recommendations made.

SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.

Findings:

Feedback from Nigeria’s exchange partners did not raise any concerns with respect to Nigeria’s use of the agreed transmission methods and therefore with Nigeria’s implementation of this requirement.

Based on these findings it was concluded that Nigeria is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Nigeria is encouraged to continue to ensure the ongoing effectiveness of its implementation.

Recommendations:

No recommendations made.

SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.

Findings:

11 exchange partners highlighted delays in the sending of status messages by Nigeria, representing 13% of its partners. This represents a very high proportion of partners. It was noted that this was due to a technical issue which has since been resolved and that Nigeria has since sent status messages as required, including the messages impacted by the technical issue.

Based on these findings it was concluded that, Nigeria is meeting expectations in relation to the receipt of the information. Nigeria should continue its implementation process to ensure its effectiveness.

Recommendations:

No recommendations made.

SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.

Findings:

Nigeria appears ready to respond to notifications and to provide corrected, amended or additional information in a timely manner and no such concerns were raised by Nigeria’s exchange partners and therefore with respect to Nigeria’s implementation of these requirements.

Based on these findings it was concluded that Nigeria appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Nigeria is encouraged to continue to ensure the ongoing effectiveness of its implementation.

Recommendations:

No recommendations made.

Comments by the assessed jurisdiction

Nigeria acknowledges and appreciates the good work of the team of Assessors and their painstaking efforts to determine the state of affairs of the AEOI in practice in Nigeria, and to provide guidance for improvement of AEOI practices. We hereby state our continual commitment to conduct the AEOI system in conformity with the internationally agreed standards and to ensure we remain a reliable AEOI partner jurisdiction.