Naftogaz v Gazprom: The AIFC Court's USD 1.4 Billion Enforcement Order and What It Means for International Arbitration Practice
Following the designation by the U.S Department of Treasury of a Nigerian National and three Nigerian companies allegedly involved in terrorism financing, the Central Bank of Nigeria (CBN) has issued a circular directing all banks, payment service banks, and other financial institutions to immediately implement sanctions against six individuals and four Nigeria-based Money Service Businesses (MSBs)/Bureaux de Change (BDCs) designated by the Nigeria Sanctions Committee (NIGSAC) and the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) pursuant to Executive Order 13224 (as amended).
The directive, contained in Circular No. CMD/FCS/PUB/CIR/002/011 dated 24 June 2026, follows an update to the Nigeria Sanctions List as of 18 June 2026. The CBN stated that the designations constitute binding sanctions measures requiring immediate implementation by all regulated financial institutions and was to take effect immediately.
The direction by CBN to all regulated financial institutions include the following mandatory sanctions measures:
- Immediate screening and identification
- Immediate asset freezing without prior notice
- Prohibition of dealings either directly or indirectly
- Reporting to NFIU and CBN within 48 hours of the publication of the circular, including a “NIL Report” where no matches are identified
The CBN further stated that compliance with the directive will be monitored through off-site reviews, on-site examinations, and supervisory engagements. It also warned that the submission of false or misleading information will constitute a regulatory violation and may attract sanctions under the Banks and Other Financial Institutions Act (BOFIA), 2020 and other applicable laws.
Sources:
Implementation of Sanctions Designations – NIGSAC and OFAC (E.O. 13224, as Amended), 24 June 2026. https://www.cbn.gov.ng/Out/2026/CCD/CIRCULAR%20TO%20BANKS%20AND%20OFIs%20ON%20NIGSAC%20AND%20OFAC%20DESIGNATIONS%20AND%20COMPLIANCE%20ACTIONS.pdf
Nigeria Sanctions Committee (NIGSAC) – Nigeria Sanctions List. https://nigsac.gov.ng/IndSancList