Nigeria

2. Does Nigeria implement UN sanctions?

Yes; in 2016 for example, the Central Bank of Nigeria (CBN) directed banks and other financial institutions in Nigeria via a circular dated 21 September 2016 to implement the United Nations Security Council Resolution (UNSCR) 2270 (2016). By this resolution, the United Nations Security Council (“UNSC”) adopted Resolution 2270/2016 to impose additional sanctions on the Democratic Republic of Korea (“DPRK”) which conducted a nuclear test on 6 January 2016, contrary to the resolutions of the UNSC prohibiting proliferation of nuclear, chemical and biological weapons as well as their means of delivery. The circular directed the banks and other financial institutions to put measures in place to ensure maximum compliance with its provisions. The sanctions relating to banking and detailed in Articles 32 – 38 of the UNSCR 2270 (2016) include:

• that the asset freeze imposed by paragraph 8(d) of the resolution 1718 (2006) shall apply to all the funds, other financial assets and economic resources outside of the DPRK that are owned or controlled, directly or indirectly, by entities of the Government of the DPRK or the Worker’s Party of Korea, or by individuals or entities acting on their behalf or at their direction, or by entities owned or controlled by them,

• that states shall prohibit in their territories the opening and operation of new branches, subsidiaries, and representative offices of DPRK banks, prohibit financial institutions within their territories or subject to their jurisdiction from establishing new joint ventures and from taking an ownership interest in, or establishing or maintaining correspondent relationship with DPRK banks,

• that states shall take the necessary measures to close existing representative offices, subsidiaries or banking accounts in the DPRK within ninety days, if the state concerned has credible information that provides reasonable grounds to believe that such financial services could contribute to the DPRK’s nuclear or ballistic missile programs, or other activities prohibited by resolutions; and

• that all states shall prohibit public and private financial support from within their territories or by persons or entities subject to their jurisdiction for trade with the DPRK (including the granting of export credits, guarantees or insurance to their nationals or entities involved in such trade) where such financial support could contribute to the DPRK’s nuclear or ballistic missile programs or activities prohibited by resolutions.

Following Nigeria’s recommendation, on 22 May 2014, the UN Security Council’s Al-Qaida Sanctions Committee approved the addition of Boko Haram to its list of individuals and entities subject to the targeted financial sanctions and the arms embargo set out in paragraph 1 of Security Council resolution 2083 (2012), adopted under Chapter VII of the Charter of the United Nations.