Nigeria’s FATF Exit: Implications for Business and Growth — Tope Edward

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A Multifaceted Professional: Tope Edward Fagbamigbe

Tope Edward Fagbamigbe, a legal practitioner, has consistently demonstrated a unique ability to dissect complex legal, financial, and developmental issues. In this interview, he reflects on Nigeria’s evolving financial landscape, the implications of the Grey List removal, and the ongoing Ibadan corridor expansion controversy.

The name Tope Edward means different things to different people—, a lawyer, speaker and writer with interests in real estate among other things. How have you been able to juggle all these things together?

Thank you. I should say firstly, that my full name is Tope Edward Fagbamigbe; I’m a lawyer. I`m into a number of very interesting endeavours. I host an evangelical radio program called His Sanctuary on foremost radio station, Fresh, 105.9 FM, Ibadan. I also host a daily motivational program on the same station. These are non-profit projects. I consider it a privilege to be blessed with the gift and time to impact lives through these platforms. I write. I speak. I also sit on the board of a foremost Real Estate company. I won’t deny that I’m blessed and I’m very thankful. I attended Olabisi Onabanjo University and at that time I thought I needed to keep busy while I was schooling and so I decided to come over to Ibadan to learn the art of radio broadcasting. I walked into Splash FM, it was just starting as that time so I asked if I could be given an opportunity to learn broadcasting and I was given an opportunity as it turned out, I soon realised that I was gifted in that area.

Understanding the Grey List Removal

Recently, there was something in the news about Nigeria’s removal from the Financial Action Tax Force ‘Grey List’ – what exactly does that mean?

Nigeria was placed on the ‘Grey List’ by the Financial Action Tax Force alongside 21 other countries including South Africa in 2023. What that simply means is that Nigeria was placed under increased monitoring by The Financial Action Tax Force and this would have had a consequential negative effect on our reputation in the international business landscape.

How does this affect Nigeria’s image among the comity of nations and in the business world?

Let me break it down this way, if you`re not on the grey list, it means you have been identified by the Financial Action Tax Force to have strong strategic processes to counter Money Laundering and Terrorist Financing. Per contra, being the on the grey list means you have been identified to have weak strategic processes to counter Money Laundering and Terrorist Financing. The Implication of that for Nigeria is that international bodies or persons who want to do business in or with Nigeria may be hesitant to deal. It also means that parties considering doing business with us, may have to put more cost, more effort, more time into multiple layers of due diligence before going ahead.

Impact of Grey List Removal

In your view, what were Nigeria’s major losses during this period, and now that the country has been removed from the list, how do you think this will immediately shape its global image?

Specifically, Nigeria has been on the list since 2023 but was removed from the list in October 2025. What Nigeria would have lost for being on that list, I may not be able to tell you here but parties who otherwise would have done business with Nigeria like I said, having seen that Nigeria was on the grey list may have been hesitant. Secondly, the cost and the human resource that will be needed to do due diligence to investigate could be discouraging for some investors. So being on the grey list would have created losses for Nigeria in ways we can’t even begin to imagine.

What makes this matter especially significant to you, and why do you feel strongly compelled to address it?

As a lawyer, I have participated in a lot of engagements with the Economic and Financial Crimes Commission (EFCC) and other relevant agencies of government on this issue. I observed that these agencies left no stone unturned. They put a lot of resources, a lot of time and effort into putting the required structure in place which culminated in the removal of Nigeria from the Grey List. They did a lot of public engagement, conferences, trainings, seminars some of which we attended. I can state factually that, in the past, individuals purchasing property could simply make payments of ₦5 million, ₦10 million, or even as high as ₦100 million without any obligation to report the transaction to any authority. Those days are gone. Nigeria has significantly raised its compliance standards, and the relevant agencies have strengthened their operations by putting proper structures and processes in place to detect, deter, and combat terrorism financing and money laundering across the country.

Regulatory Measures and Compliance

Take for instance, the Special Control Unit Against Money Laundering (SCUML), created by the Money Laundering (Prohibition) Act of 2004, now amended as the Money Laundering (Prohibition) Act 2022, implement anti-money laundering measures in Nigeria. Its creation was part of a broader effort to comply with recommendations from the Financial Action Task Force (FATF) on combating money laundering and terrorist financing. It is significantly more difficult for anyone to launder money through the financial system today. Take the real estate sector for example. Today, if you receive any payment above ₦5 million, you are required to report it to the relevant authorities within 24 hours stating who made the payment, the purpose of the payment, and all supporting information. In addition, before accepting such funds, you must conduct proper due diligence and carry out fully Know Your Customer (KYC) checks. This ensures that you do not find yourself in a situation where someone pays ₦200 million and later becomes untraceable. With these measures, every player can be identified, and once people know they can be traced, they are discouraged from using cash or non-cash based transactions for illicit purposes. As a result, the frequency of laundering money drops significantly.

There have been growing claims that money laundering activities are increasingly being disguised through real estate transactions, which explains the sudden rise in real estate companies and the large volumes of funds flowing into the sector. With the current regulatory provisions and compliance mechanisms now in place, why do we still see this proliferation of real estate businesses and the continued injection of substantial capital into the industry? Does this trend reflect genuine economic growth and improved financial capacity among Nigerians, or is there another factor at play?

First of all, the increased activity in the real estate sector signifies development. It also shows that substantial funds are circulating within the economy, including money coming from Nigerians abroad who are investing back home. That in itself is a positive sign. However, based on the provisions of the Money Laundering (Prevention and Prohibition) Act, real estate companies are specifically required to report transactions above certain thresholds. From my experience, the moment you present the mandatory KYC forms to prospective property buyers—requesting their names, account details, source of income, and the origin of the funds they intend to use, some of them immediately withdraw from the transaction. They drop the forms and walk away, saying they are no longer interested. That alone suggests that the source of their funds may not be unquestionable. I have personally witnessed two or three instances. The Act also provides that where you have received money, which you subsequently have a reason to believe is suspicious; you have a duty to make a formal Suspicious Transaction Report immediately. Once that report is submitted, the agencies step in and investigate. Overall, it is a gradual process, but the message is spreading. The EFCC, for example, conducts extensive public sensitisation and stakeholder engagement on these issues. Real estate practitioners are becoming more aware of their obligations and the consequences of non-compliance—ranging from fines to imprisonment.

Infrastructure Development and Public Interest

The ongoing controversy surrounding the corridor expansion and the Circular Road project in Oyo State has become quite prominent, especially with reports of lands and houses being demolished or acquired to make way for the construction, what is your perspective on this development?

This government has performed well in the area of infrastructural development, and that is significant because infrastructure is a proven catalyst for growth anywhere in the world. Late President Franklin D Roosevelt, former President of the United States, revived the American economy in the 1930s through massive infrastructural projects, and the logic remains the same today: when governments invest in building roads, housing, new GRAs, bridges, hospitals, and other infrastructure, the funds released flow directly into the economy. From conception to execution, that money circulates through the contractors, professionals: architects, lawyers, town planners, engineers, and every one of them, in turn, spend within the state. School fees are paid, cars are purchased, businesses are patronised, and the economic ripple effect becomes visible across different strata. In the case of Oyo State, Governor Makinde has adopted a public–private partnership model, inviting investors to participate in the development of the state. Lands that had long existed without meaningful utilisation were allocated under PPP arrangements, allowing private investors to put their resources into the projects while the government focuses on regulation and oversight. These lands were always there, unused, but through developmental initiatives, they are now attracting investment, generating revenue, and stimulating economic activity across the state. Many of the investors involved in these projects are coming from Lagos, Port Harcourt, Abuja and the diaspora and they are bringing their capital into Oyo State. During construction, they hire masons locally, purchase granite and other building materials within the state, and in many cases engage lawyers, architects, and other professionals. All of these inject money directly into the state’s economy, and the money goes round, stimulating economic growth. What is more, the buildings being constructed all over the state, as well as the roads and other infrastructure the government is developing, will serve the people for the next 50 to 100 years. It is, therefore, a win-win situation. Oyo State is experiencing increased economic activity, and real estate has become a major corridor through which the state’s economy is evidently growing. The government deserves commendation for taking a creative approach in this regard.

Secondly, on the issue of compulsory acquisition of property by the government, I think we need to see things from the perspective of the law: The Land Use Act vests all land in each state in the governor, who holds and administers all land in trust for the people. The Act also empowers the government to acquire land for public interest. When you consider projects such as the construction of major bridges or the development of the Circular Road, these are initiatives designed to serve the wider public interest. If certain properties fall within the designated route of such infrastructure, can we insist that the interest of an individual landowner should override a project meant to benefit an entire state or even the nation? In law, this is where the principle of overriding public interest applies. The government is fully empowered to acquire the required corridors, provided that adequate compensation is paid to affected landowners. That, in my view, is where the current challenge lies. I sincerely sympathise with property owners whose buildings fall within the affected corridors. It is essential that the government ensures timely, fair, and transparent compensation for all those whose properties are being acquired.

Addressing the Crisis and Due Diligence

The current situation calls for dialogue and engagement with the affected people, and the government and those affected must be truthful. As a lawyer, I have observed with keen interest, several cases of government acquisition in Oyo State undertaken in the public interest. In some of those instances, where ‘sufficient’ compensation was paid running into millions and even tens of millions—there were no complaints. Duplexes and mansions were demolished to make way for public projects, yet the process was smooth because affected owners were duly compensated. That is the standard the government must uphold. While acquiring land along the current corridor, it must ensure that fair and adequate compensation is provided. At the same time, it is important to acknowledge that there are individuals occupying parts of that corridor who, under the land laws, should not have been there in the first place. Even in such cases, the government should still act with fairness and sensitivity. After all, it is a government of the people, by the people, and for the people. By paying compensation where appropriate—and by presenting a clear, transparent plan for how affected residents will be treated, the government can maintain public trust and reduce tension surrounding the project.

How do you think this crisis can be resolved? The protest has lasted for days, and the affected property owners whose lands or buildings were seized or may be demolished do not appear willing to back down. In your view, what steps can the government take to address the situation effectively?

The property owners have a legitimate right to express their grievances, and they are entitled to continue doing so peacefully until the government genuinely listens, engages with them, and reaches a fair agreement on compensation. We must not forget the human element involved here: many of these individuals are retirees, people who have invested their entire life savings into building or acquiring these properties. Government must remember that it exists to serve the people. Power ultimately rests with the populace. The people are, in essence, the employers of the government, and the government is accountable to them. It is therefore imperative that the authorities hear their concerns and respond with fairness, empathy, and transparency.

Where do you think people often get it wrong in situations like this? Many of the affected houses and properties were demolished, yet before acquiring land there are established processes that reveal whether the area is under government acquisition, earmarked for future projects, or falls within a designated road corridor. How can prospective buyers verify these things, and do you believe people actually conduct the necessary due diligence before purchasing land?

In my experience, some people conduct due diligence, but many do not—and that is where the problem starts. Even among those who attempt it, a good number do it haphazardly. They simply go through the motions without following the proper steps. When you are buying land or property, your first port of call should be your lawyer`s chambers. A lawyer is professionally trained to analyse documents, interpret their implications, and advise you on foreseeable risks. If the lawyer encounters technical details, particularly concerning survey plans, he will engage a surveyor. A qualified surveyor will examine the survey plan, visit the site, take accurate coordinates, and compare them with official records. That is often how you discover if the property falls within an area marked for future government projects or if there is any encumbrance affecting the land. Unfortunately, the majority of people skip this process entirely. Some even attempt due diligence from their living rooms, calling someone at the land registry or sending a snapshot of a survey plan to an acquaintance. The person at the other end is merely looking at a piece of paper. He is not inspecting the property physically, and he cannot verify whether the document corresponds to the actual plot being sold. It is entirely possible that the survey plan you send for verification belongs to a different piece of land altogether. They may tell you, based on that paper that the land is free from acquisition — yet the actual location on ground may be directly in the path of a government project. This is why physical verification is non-negotiable. The coordinates on the ground must match the coordinates on the survey plan. Only a licensed surveyor can confirm that. When people fail to engage the professionals lawyers, surveyors, and in some cases town planning experts they expose themselves to serious risks.

And we see the consequences every day. Some people lose their properties entirely. Others are forced to renegotiate or repurchase properties they supposedly paid for. The emotional and financial cost is huge, especially for families who invested their savings into those properties. The safest approach is simple: always consult a lawyer before purchasing any property. It may seem like an extra step, but it saves you from enormous stress, uncertainty, and potential loss.

Perspectives on Leadership and Governance

Now, regarding the Oyo State Real Estate Conference, where you delivered a speech that sparked considerable discussion and concern. What exactly did you say at that event that led some people to feel you might not be fully aligned with their interests?

I want to emphasize that I am firmly on the side of the people, on the side of fairness and justice. At the Oyo State Real Estate Conference, I made several points that I think are important. First, I acknowledged that the government has performed well in developing the city; a significant amount of money is flowing into Oyo State, and that demonstrates clearly that the government playing its role effectively. Second, I highlighted that developers, investors, and other stakeholders are moving in and doing business but they must also build trust. You should not promise the world and deliver a village. You cannot assure people of estates and infrastructure and then fail to deliver. Developers must be transparent and take responsibility, especially considering the prevalence of land and real estate scams. Sustained trust in the sector requires consistent, accountable action. Third, I pointed out that the current boom in Real Estate and economic activity in Oyo State is not accidental. It is the result of good governance, showing that the people made right choice, voting Governor Seyi Makinde into office. As we approach the end of his second term, it is crucial that the next leadership also has vision. The incoming leadership must build upon the foundations laid by previous administrations, and not truncate projects or abandon progress. Oyo State has benefited from continuity: late Governor Abiola Ajimobi carried on and completed some projects late Governor Akala had embarked upon. Governor Makinde picked up where Ajimobi left off, completing many of these projects. The circular road project, for instance, was not originally conceived by Governor Makinde, yet he pursued it because it aligns with a broader vision beyond partisan politics. Ultimately, we must choose leaders with foresight, leaders who will continue the work in the best interest of the people. And the power to select such visionary leadership rests with the citizens themselves.

Career Choice and Passion for Law

Why did you choose to pursue a career in law, and what inspired you to follow it through?

Law is the profession I have always been deeply passionate about. From an early age, I was fascinated by the way the Law shapes society, protects rights, and ensure justice. I decided to follow through because I wanted to be part of that process—helping people navigate challenges, solve disputes, and uphold fairness. Over the years, I have come to appreciate not just the intellectual rigor, but also its ability to make a tangible difference in people’s lives. Choosing this path was a conscious decision to align my career with my values and my desire to contribute meaningfully to society.






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