The Securities and Exchange Commission (SEC) has directed all Capital Market Regulated Entities (CMREs) in Nigeria to immediately identify and freeze funds, assets and other economic resources belonging to individuals and organisations designated as terrorist financiers, warning that failure to comply could result in fines, suspension of operations or revocation of registration.
The directive, which covers individuals and entities designated by the Nigeria Sanctions Committee (NSC) and the United Nations Security Council, includes Tehrik-e Taliban Pakistan (TTP), its leader, Noor Wali Mehsud, and other persons and organisations placed on the relevant sanctions lists.
However, the order has generated concerns among some capital market operators, who disclosed that they were unaware of the recent circulars, raising questions about the effectiveness of communication between the regulator and institutions expected to implement the directives.
The latest sanctions were contained in circulars dated October 16, 19 and 22, 2026, with the notices published on the Commission’s website on October 27.
The SEC explained that the directives were issued pursuant to the Terrorism Prevention and Prohibition Act (TPPA), 2022, and required all regulated capital market institutions to take immediate action against the designated persons and entities.
Under the October 16 circular, the Nigeria Sanctions Committee designated three individuals and one organisation as terrorist financiers.
The individuals include Kim Jung Jong, a former representative of Tanchon Commercial Bank in Vietnam; Mounir El Motassadeq, who was convicted in Germany in 2007 for offences connected with terrorism; and Noor Wali Mehsud, the leader of Tehrik-e Taliban Pakistan.
The organisation designated under the same circular was Tehrik-e Taliban Pakistan, an armed group established in 2007 and based around the Afghanistan-Pakistan border.
The Commission directed regulated entities to identify and freeze, without prior notification, all funds, assets and economic resources belonging to the designated individuals and organisation that were in their possession or control.
According to the SEC, the affected institutions must immediately report the frozen assets and other actions taken in compliance with the sanctions to the Secretariat of the Nigeria Sanctions Committee.
They are also required to report attempted transactions involving the designated persons and entities, including relevant matches discovered during the examination of customer records.
The Commission further directed operators to file suspicious transaction reports with the Nigerian Financial Intelligence Unit (NFIU) to facilitate the examination of activities potentially connected to terrorism financing.
Capital market institutions must also cease transactions and other business dealings with designated individuals and organisations.
The Commission explained that operators were required to continue monitoring transactions and report any relevant findings to the Nigeria Sanctions Committee, including transactions identified through reviews of historical records.
The October 19 circular expanded the list of sanctioned individuals to include Paek Chang-Ho and Ra Ky’ong-Su following their inclusion on the United Nations Security Council’s consolidated sanctions list.
The SEC subsequently issued another circular on October 22, directing regulated entities to apply similar restrictions to DCB Finance Limited, which had also been designated under the United Nations and Nigerian sanctions frameworks.
The Commission made clear that the obligations attached to the designations took immediate effect and that operators were not required to wait for a separate notification before implementing the applicable restrictions.
In addition, capital market operators were directed to subscribe to the Nigerian Sanctions List (NigSac) Alerts system, which provides notifications whenever new individuals or organisations are designated.
The SEC maintained that the subscription requirement was intended to ensure that regulated institutions could obtain updated sanctions information and respond promptly.
Responding to enquiries about how the circulars were communicated, the Commission explained that its notices were distributed through its official website, registered industry associations and the Committee of Chief Compliance Officers of the Capital Market Operators in Nigeria (CCCOCIN).
It also maintained that regulated entities were expected to subscribe to NigSac Alerts to receive notifications of new designations.
Despite those arrangements, interviews with operators revealed differences in their awareness of the sanctions notices and their understanding of the compliance requirements.
Charles Fakrogha, Chief Executive Officer of ECL Asset Management Limited, acknowledged that regulated firms had a responsibility to review sanctions lists and determine whether any designated individual or entity appeared among their customers.
He explained that compliance required institutions to examine their records and establish whether any affected person or organisation had maintained an account or conducted transactions through them.
Fakrogha, however, identified practical difficulties associated with screening customer information, particularly where financial institutions had acquired other firms and inherited substantial customer records.
According to him, some operators managed portfolios involving as many as 20,000 customers, making comprehensive screening a demanding exercise.
He disclosed that he became aware of the recent directives when they were discussed during the Annual General Meeting of the Association of Securities Dealing Houses of Nigeria on October 28 and 29.
Fakrogha maintained that the effectiveness of the sanctions regime depended partly on ensuring that operators received and understood the relevant notices.
“The issue is primarily one of awareness,” he said.
He consequently urged regulators to improve communication with institutions under their supervision to ensure that important compliance obligations were not overlooked.
Similarly, Abiodun Kebira, Chief Executive Officer of Globalview Capital Limited, acknowledged that he had not reviewed the recent circulars.
“To be honest, this is not something I have been paying attention to. I wouldn’t want to mislead you,” Kebira stated.
He explained that he had initially assumed the directives principally concerned foreign investors.
However, the SEC’s instructions apply to all capital market regulated entities, regardless of whether their customer portfolios consist mainly of Nigerian or foreign investors.
Kebira argued that important regulatory notices should be communicated directly to affected operators instead of depending primarily on trade associations to distribute them.
He maintained that direct notification would improve awareness and reduce the possibility of firms failing to comply with obligations because they had not received relevant information.
Also speaking, the Chief Executive Officer of MDU Capital Limited, Dr Ayodeji Ebo, confirmed that he was unaware of the three October circulars.
Ebo called for improved dissemination of regulatory information, particularly where the directives required immediate action and carried serious consequences for non-compliance.
“There needs to be better dissemination of information to ensure that operators are adequately informed and kept abreast of such developments,” he said.
He explained that instructions requiring the freezing of assets were ordinarily authenticated by regulated institutions before implementation to ensure that the directions originated from competent authorities.
His comments highlighted the importance of both timely communication and verification when institutions are required to restrict access to customers’ funds and other financial assets.
Olubunmi Ayokunle, Head of Financial Institutions Ratings at Augusto & Co., described asset-freezing directives as established safeguards within the financial system.
He explained that the requirements were particularly relevant to financial institutions involved in receiving, holding or managing customer funds.
The differing responses from operators have raised questions about whether the publication of regulatory notices on the SEC’s website and their distribution through industry associations provide sufficient awareness across the capital market.
The issue is particularly important because the directives impose immediate obligations on regulated institutions and do not exempt firms merely because their management has not personally reviewed the notices.
The latest circulars also form part of earlier measures introduced by the SEC to strengthen compliance with Nigeria’s anti-money laundering, counter-terrorism financing and counter-proliferation financing requirements.
In April 2026, the Commission directed capital market operators to freeze assets associated with 10 individuals and three organisations identified under relevant sanctions arrangements.
In August, the SEC issued another directive requiring operators to subscribe to NigSac Alerts following the designation of six individuals and three Nigerian entities.
The Commission also instructed capital market institutions in August to discontinue prohibited dealings involving North Korea and Iran in accordance with the Financial Action Task Force’s February 2026 plenary statement.
That directive additionally identified 20 jurisdictions requiring enhanced monitoring because of concerns related to financial crime and deficiencies in relevant control systems.
The October circulars therefore extend existing regulatory requirements to newly designated individuals and entities rather than establishing an entirely separate compliance framework.
The SEC warned that failure to implement the directives could constitute violations of the Investments and Securities Act, 2025, the Terrorism Prevention and Prohibition Act, 2022, and the SEC Anti-Money Laundering, Countering the Financing of Terrorism and Countering Proliferation Financing Regulations, 2023.
According to the Commission, non-compliance could attract regulatory sanctions, including monetary fines, suspension of operations and revocation of registration.
Other sanctions may also be imposed where permitted under the applicable legal framework.
The regulator stressed that its directives were binding on all capital market regulated entities, irrespective of whether individual firms had identified transactions involving the designated persons or organisations.
Operators are therefore required to screen their records, monitor ongoing and historical transactions, report relevant matches and implement restrictions where applicable.
The SEC also requires unusual or suspicious transactions to be promptly reported to the NFIU for further examination.
However, the Commission’s October notices did not disclose whether any Nigerian capital market operator had already identified or frozen assets belonging to the newly designated individuals or entities.
There was also no indication in the notices that any particular firm had been sanctioned for failing to comply with the latest directives.
The disclosures by market operators nevertheless underscore a possible gap between the publication of regulatory obligations and their effective implementation across the industry.
While the SEC maintains that its website, trade associations, compliance officers’ committee and NigSac Alerts system provide channels for communicating sanctions notices, some operators argue that more direct and consistent notification is necessary.
Post Title: “Freeze Terror-Linked Assets Immediately Or Face Sanctions” — SEC Orders Capital Market Operators To Act, Warns Of Licence Revocation By Naijaonpoint.