FinCEN stated that Nigeria had enacted significant reforms to its  counter-money laundering system, and had taken concrete steps to bring those reforms into effect. It also stated that enhanced scrutiny is no longer necessary.

However, remember the rash of major corruption and money laundering cases in Nigeria recently appearing in the world's press, and govern yourself accordingly when presented with a client or transaction involving Nigeria or its nationals. Politically Exposed Persons (PEPs) from Nigeria should remain high risk and subject to enhanced due diligence and verified Source of Funds enquiries, in our opinion.


For those who wish to review the exact language of the FinCEN Advisory, visit:
http://www.fincen.gov/Nigeria_Withdrawal.pdf