Board members at Still Earth Holdings spent part of this week reviewing anti money laundering procedures that now carry potential criminal consequences for directors, according to details released after a corporate compliance session involving the group’s subsidiaries in construction, petroleum and finance.

Nigeria’s financial regulators have intensified scrutiny of beneficial ownership disclosures, politically exposed persons and suspicious transaction reporting after repeated findings by the Nigerian Financial Intelligence Unit (NFIU) and the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA). Those findings identified persistent weaknesses in customer due diligence, record keeping and shell company detection across several sectors exposed to public contracting and cross-border payments.

Executives at the session said subsidiaries including Tirex Petroleum & Energy, Still Earth Construction and Still Earth Capital Finance were assessed against risks involving over invoicing, offshore transfers, contract splitting and undisclosed ownership structures. Those are not theoretical risks inside Nigeria’s current regulatory climate. The Economic and Financial Crimes Commission (EFCC) has repeatedly linked procurement fraud investigations to layered subcontracting structures and payments routed through nominee-controlled entities.

Under Nigeria’s Money Laundering (Prevention and Prohibition) Act 2022, companies operating in financial and designated non-financial sectors face mandatory obligations involving customer identification, suspicious transaction reporting and enhanced scrutiny for politically exposed persons. Penalties can include regulatory sanctions, freezing orders and criminal prosecution depending on the underlying transaction.

Executives acknowledged that explicitly.

A senior participant identified as Inyama told attendees the training was designed to help directors recognise when money laundering or terrorism financing “may be taking place” during international business transactions. He also warned that companies failing to identify beneficial owners could face “fines, sanctions and even imprisonment.”

The Corporate Affairs Commission began implementing beneficial ownership disclosure requirements after amendments tied to Nigeria’s Companies and Allied Matters Act reforms. Those rules were introduced partly to address longstanding criticism from international observers who argued that opaque company structures allowed politically connected individuals to conceal control of assets and procurement vehicles.

Transparency International and the Natural Resource Governance Institute have both documented how energy contracting structures in several African jurisdictions can obscure ownership trails through intermediary companies registered outside the operating country. Nigeria’s petroleum industry has faced repeated scrutiny over crude allocation deals, import financing arrangements and offshore-linked payment systems.

Public infrastructure contracts frequently involve large cash flows, subcontracting chains and emergency procurement exemptions. Anti corruption investigators have previously identified inflated invoicing and project fragmentation as recurring methods used to bypass approval thresholds inside both federal and state contracting systems.

Company representatives stated that the board intended to standardise compliance practices across subsidiaries operating in different sectors. The message from management was blunt. Governance failures in one subsidiary could create liability and reputational exposure for the broader group.

Our analysis of recent enforcement notices published by the Central Bank of Nigeria showed regulators are imposing wider institutional accountability standards instead of isolating compliance failures to lower level staff. Banks and financial institutions sanctioned over the last three years were repeatedly cited for systemic failures in internal oversight rather than isolated reporting errors.

Participants reviewed suspicious transaction reporting obligations, customer due diligence standards, targeted sanctions screening and Know Your Customer procedures. Case studies reportedly focused on politically exposed persons, shell entities and offshore counterparties involved in high risk transactions.

The politically exposed persons issue matters especially in Nigeria.

PEPs include current or former senior government officials, politically connected individuals and their associates whose access to public resources creates elevated corruption risk under international compliance standards. Financial institutions and designated entities are expected to apply enhanced scrutiny to those transactions under Financial Action Task Force recommendations.

Nigerian enforcement agencies have struggled historically with that standard.

Several high profile corruption cases over the last decade involved politically connected contractors whose ownership structures were concealed through proxies or layered entities. Court filings in multiple EFCC prosecutions referenced nominee directors, relatives and shell companies allegedly used to disguise beneficial control.

Some cases remain unresolved.

Still Earth concluded the session by approving a series of board level resolutions, including a zero tolerance policy on money laundering and terrorism financing, annual compliance training programmes and independent audits designed to test internal controls. The company also announced plans to establish compliance committees responsible for oversight functions across subsidiaries.

Yet the effectiveness of those resolutions will depend less on declarations than implementation records. Nigerian compliance frameworks often appear strongest during policy launches and weakest during enforcement. Independent audit findings, internal whistleblower protections and suspicious transaction reporting volumes usually reveal whether compliance systems operate beyond presentation slides and board communiqués.

The Central Bank of Nigeria, Securities and Exchange Commission and EFCC have all increased penalties tied to reporting failures, weak internal controls and inadequate customer verification procedures. In several recent enforcement actions involving financial institutions, regulators imposed sanctions running into billions of naira.

Legal advisers interviewed after the training said directors are increasingly requesting personal liability briefings because regulatory investigations now examine whether boards exercised meaningful oversight or merely approved compliance policies without enforcement mechanisms.

Still Earth’s anti money laundering training focused heavily on beneficial ownership and politically exposed persons because regulators now treat those areas as enforcement priorities.

Subsidiaries in petroleum, finance and construction were singled out for sector-specific risks including over invoicing, shell companies and offshore payments.

Nigerian regulators are increasingly holding boards responsible for compliance failures instead of blaming only operational staff.

The company approved independent audits and compliance committees, but those measures will matter only if reporting records and enforcement actions support the claims later.

Why are companies suddenly focusing so heavily on AML compliance?

Because Nigerian regulators and international watchdogs have increased pressure after repeated findings about weak ownership disclosure and transaction monitoring. Directors now face personal exposure in some investigations.

What exactly is a politically exposed person?

A PEP is someone with prominent public influence, usually a government official or close associate. Transactions involving them require enhanced scrutiny because corruption risks are considered higher.

Do independent compliance audits actually prevent fraud?

Sometimes. But audits only work if companies allow real access to records and act on findings. Plenty of firms commission audits that produce recommendations nobody enforces.

The next unresolved question may emerge from enforcement rather than policy. Nigeria remains under continuing international scrutiny over anti money laundering controls, and future evaluations by GIABA and related monitoring bodies will examine whether companies are implementing beneficial ownership verification in practice. If regulators identify systemic failures inside designated non-financial institutions, penalties could move beyond administrative sanctions into criminal proceedings before the Federal High Court, where asset forfeiture powers and multimillion-naira liability claims remain available under the 2022 anti money laundering framework.