The Brig Gen Mohamed Buba Marwa (Rtd), Chairman/CEO, National Drug Law Enforcement Agency, NDLEA, has strongly advocated that business especially those in the financial industry should imbibe a culture that work against infiltration of illicit funds into business operations.
Brig Gen Mohamed Buba Marwa (Rtd), represented by AGG Archie-Abia Ibinabo, fsi, NDLEA Director Seaports Operations, made the remark at the Association of Enterprise Risk Management Professionals (AERMP) conference and induction on Saturday August 16, 2025 at the James Hope University, Lekki, Lagos
Brig Gen Mohamed Buba Marwa (Rtd) was a special guest at the conference and induction themed: Investment and Security Act 2025: Implication for Enterprise Risk Management and Compliance in the Financial Markets.
FULL SPEECH
PROTOCOL
I am delighted to be here in your midst and very happy for the opportunity to deliver this remark. I will start by appreciating everyone who is participating in this conference and also commending the organisers, for indeed, this is a significant development.
Your Association is reputed for providing a multi-disciplinary learning platform for financial regulators, operators, and risk experts operating in Nigeria’s financial markets. It is therefore not surprising that the theme of this conference is focused on The Investment and Securities Act 2025: Implications for Enterprise Risk Management & Compliance in the Financial Markets, which could be more timely or relevant.
Our country has made progress since the return to democracy in 1999. We have had 25 years of uninterrupted democracy, and through thick and thin, we have continued to deepen the rule of law. Conferences such as this are avenues to further deliberate and come up with policy directions and new vistas on how to strengthen our laws and our democracy.
- In today’s interconnected world, the stability of our financial markets depends not only on economic factors but also on how well we anticipate and respond to risks that cut across political, behavioural, and criminal domains. The new Act is a legislative recognition of that reality. It emphasizes a shift from reactive compliance to proactive, risk-based governance.
- Risk and Compliance in the New Regulatory Era
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Under the 2025 Act, risk management is no longer a support function; it is a strategic imperative. The Act places greater accountability on boards, executives, and compliance officers to ensure that their organizations can identify vulnerabilities early, respond quickly, and recover with resilience.
In practice, this means:
- A) Continuous risk assessments that incorporate financial, operational, and reputational threats.
- B) Embedding compliance into every department, not just the legal or risk units.
- C) Using technology and analytics to detect irregularities before they escalate into crises.
Compliance is now a culture, a way of doing business, not just a checklist for regulators.
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The NDLEA Perspective: Criminal Infiltration of Legitimate Enterprises
From my vantage point at the NDLEA, I see a significant intersection between our work and the financial markets. The infiltration of illicit funds particularly proceeds from drug trafficking, into legitimate businesses is one of the most under-recognized risks facing corporate Nigeria today.
Money laundering is not just a financial crime; it is a business contamination risk. It enables criminal organizations to gain influence in legitimate markets, distort competition, and destabilize the very structures that risk managers and compliance officers are tasked to protect.
- How Drug Proceeds Impact Financial Markets
The proceeds of drug trafficking are vast, and their handlers are sophisticated. They use layers of transactions, shell companies, and international transfers to obscure the origins of funds. If these illicit proceeds enter the investment and securities space unchecked, they can:
- A) Inflate asset prices artificially.
- B) Facilitate hostile or covert takeovers of legitimate companies.
- C) Undermine the credibility of Nigerian markets in the eyes of global investors.
The Investment & Securities Act 2025 strengthens the requirement for enhanced due diligence. This means verifying beneficial ownership, understanding the source of funds, and reporting suspicious transactions in real-time.
- Forfeiture Laws and Their Business Implications
Let me be very clear: Nigerian law empowers the government to forfeit businesses and assets proven to have knowingly facilitated or benefited from drug-related activities. The NDLEA has already enforced such measures, and under the new legal framework, the scope is even broader.
For a business, forfeiture is not just a loss of assets, it is a total collapse of operations, jobs, and reputational standing. This is why enterprise risk management must include:
- A) Regular compliance audits.
- B) Training for all employees on red flags of illicit transactions.
- C) Board-level oversight of anti-money laundering (AML) obligations.
- Real-World Impacts on Enterprises
Let us be practical. The risks for businesses include:
Legal: Lawsuits, criminal charges, and regulatory sanctions.
Financial: Frozen accounts, asset seizures, and loss of investor capital.
Reputational: Permanent loss of brand trust, making recovery nearly impossible.
Operational: Disruption to supply chains, partnerships, and access to credit.
A single compliance failure can trigger a cascade of these consequences.
- Building a Culture of Compliance and Integrity
A robust security and compliance culture should be:
Organization-wide: From the CEO to the newest hire.
Integrated: Linked to every strategic decision, contract, and investment.
Proactive: Anticipating risks rather than reacting to crises.
Collaborative: Working closely with regulators, law enforcement, and industry peers.
This culture is the first and most effective defence against the infiltration of illicit funds into your business operations.
- 10. NDLEA Asset Seizures and the Wider Economic Impact of Drug Abuse
In our fight against drug trafficking, the NDLEA has intensified efforts to identify, trace, and seize the assets of major drug barons. These forfeitures not only disrupt criminal networks but also send a strong deterrent signal that illicit wealth will not be allowed to thrive in our economy. Besides enforcement, we must also recognize the socio-economic toll of drug abuse itself. According to the United Nations Office on Drugs and Crime (UNODC), about 14.3 million Nigerians aged 15–64 abuse drugs annually, a figure significantly higher than the global average. This growing population of drug users poses a serious threat to our national productivity: workplace and road accidents, premature deaths, absenteeism, and chronic health issues reduce labour efficiency. More troubling still is the diversion of scarce developmental funds toward rehabilitation, medical treatment, and law enforcement operations, resources that could otherwise fuel education, infrastructure, and economic growth. The human and economic costs of drug abuse therefore make this a problem that corporate Nigeria cannot afford to ignore.
11.Public managers need to be aware of this salient fact because, “the rule of law itself depends just as much, if not more, on public sector professionals upholding it in their work than it does on laws and courts and the other external mechanisms that are there when things go wrong.”
12.The onus is on public service managers to understand the application of our laws in policymaking and implementation to enhance national development.
13.As head of a public service agency, namely the National Drug Law Enforcement Agency, NDLEA, I can give an experiential perspective of how adherence to the law of the land has contributed to the accelerated development of the agency and enhanced a positive and far-reaching change in the landscape of drug law enforcement in the country.
The NDLEA I came into on January 18, 2021, was facing existential challenges, both domestically and globally. For three decades, the agency was stuck in a rut. It was not functioning as it should. Consequently, our country became a haven for drug traffickers and the drug abuse culture thrived. Not many people could connect these developments with the state of anomie that spread across the country. But I tell you, the security challenges we are grappling with today were catalysed by the indiscriminate proliferation of illicit drugs within the country and the unrestrained influx of controlled substances into our territory. Studies have shown that indiscriminate access to illicit substances and increase in abuse of illicit substances contribute to violent crimes such as cult-related killings, armed robbery, bandity and terrorism, ills that have besieged our country.
With the world now a global village, no country is safe from the illicit trafficking trade because it is perpetuated by transnational criminal organisations. This means that the challenges to regulatory law enforcement are both national and global in scope. These include jurisdictional complexities, whereby differences in legal frameworks, enforcement capacities and cultural norms pose challenges to addressing certain national and global issues. Technological advancements such as cryptocurrency, the digital economy and constantly mutating internet fraud pose further challenges to the regulation of existing laws. Just as well, cross-border trafficking and money-laundering exploit gaps in nations’ legislation. And, of course, resource constraints are a big challenge.
So, over four years ago, when we kicked off the process of overhauling our systems and processes, we had our eye on doing everything correctly by the law, from arrest through prosecution and staying in line with the criminal justice process. From forging partnerships at home and abroad with other agencies to treatment procedures and various SOPs, we did and are still doing everything in tune with global best practices and protocols.
The National Drug Control Master Plan 2021–2025 fosters synergy between NDLEA and other regulatory and security agencies involved in the drug control efforts. In addition to this, we signed MoUs with national organisations, including Customs, NAFDAC and Immigration, among others. We built bilateral relationships with counterparts in other countries to improve international cooperation, and we ensure that we keep to the terms of the pacts. We revised our operations in line with existing global laws and national laws. All we did was untie the Gordian knots that had kept NDLEA non-functional for years.
18 The key is our propensity to do everything ‘by the law,’ which has enhanced transparency in our operations, fostered equality, equity and fairness within the organisation, earned us respect and made us respectable, improved our efficiency and won support and partnership from peers, partners and governments around the world. We were able to do in four years what we could not do in 30 years, and the immense gains served only to deepen our commitment to the rule of law. There is still more to do. We will continue to let our actions and activities be guided accordingly.
19 To conclude my message, I wish to congratulate and commend the Association for maintaining a good track record in organising successive and successful conferences and providing a platform aimed at bringing people at all levels together to share experiences and learn from one another to engineer social change in our financial market and subsequently bring about sustainable development in the country.
20.Your focus on the Investment and Securities Act 2025 and its implications for enterprise risk management and compliance in the financial markets is particularly commendable because where the rule of law prevails, such a nation is placed on the path of progress and will be characterised by development indices such as peace and security, economic growth and increased investment, among others. No country has ever gone to great heights without observing the rule of law.
On a final note, I wish the organisers a successful outing and sincerely hope that participants will have robust discussions that will stimulate new areas of reference for leadership.
Distinguished ladies and gentlemen, I wish you a successful conference. I thank you for the opportunity to address this gathering.
Thank you for listening.
God Bless Federal Republic of Nigeria.