Nigeria has crossed a milestone it spent more than a decade chasing. The 2026 Access to Financial Services in Nigeria (A2F) survey by EF InA puts formal financial inclusion at 73 percent, surpassing the national target of 70 percent. Digital financial services have grown even faster, reaching 64.4 percent of adults, up from 45 percent in 2023.
The Central Bank of Nigeria (CBN) has begun work on the next National Financial Inclusion Strategy, NFIS 4.0, which is expected to emphasise consumer protection, trust, digital safety and financial health. As the strategy takes shape, one risk deserves explicit attention: money mule recruitment. Expanding access must go hand in hand with protecting accounts from criminal exploitation.
Fraud needs somewhere to land.
Public discussions of digital fraud often focus on victims deceived into transferring money. Less attention goes to the accounts receiving stolen funds. Proceeds may pass through multiple accounts, be withdrawn through agents or converted into other assets, making investigations and recovery difficult.
Some accounts belong to people recruited through fake job offers, promises of easy income or requests to receive money for strangers. Others knowingly rent out their accounts. These money mules help criminals receive, move and conceal illicit proceeds. The Nigerian Financial Intelligence Unit’s 2025 Annual Report describes illicit funds broken into smaller transfers and routed through networks of money mules, including students, small-business owners and relatives, to avoid reporting triggers.
The Nigeria Inter-Bank Settlement System (NIBSS) reported that digital payment fraud losses fell 51 percent to ?25.85 billion in 2025, an encouraging development. Yet, it also flagged a 34 percent drop in fraud reporting in the final quarter, warning that unreported incidents allow perpetrators to move between institutions. These figures do not measure mule activity directly, but they show why fraud prevention cannot stop at the initial fraudulent transfer. It must also follow the accounts receiving and moving the money.
Why new customers can be exposed
Money mule recruiters can exploit financial pressure and limited awareness of financial crime. EFInA’s 2026 findings show that only about 31 per cent of formally included adults are financially healthy. Access to an account has not necessarily translated into financial security.
For someone facing economic pressure, quick money for receiving and forwarding funds may seem harmless. Yet the funds could be criminal proceeds, exposing that person to account restrictions, investigations and possible prosecution. New accounts also have limited transaction histories, making unusual activity harder to assess. The challenge is to prevent misuse without unfairly excluding legitimate customers.
Balancing financial inclusion and fraud prevention
This is the policy tension NFIS 4.0 must resolve. Inclusion policy asks institutions to bring more first-time customers into the formal system. Fraud policy increasingly requires them to scrutinise accounts receiving suspicious funds.
Under a circular in force since July, the CBN requires banks, other financial institutions and payment service providers to monitor instant payments for fraud. It also maintains a temporary watchlist for BVNs flagged in suspected fraud. The CBN’s draft guidelines on authorised push payment fraud propose early-warning systems for suspicious accounts and shared reimbursement costs for eligible victims where neither institution is found responsible.
These are sensible measures. But without safeguards, institutions could respond by restricting customers with thin transaction histories, including the very people inclusion initiatives seek to reach. A newly opened account is not suspicious in itself, and irregular income is not evidence of financial crime. Effective prevention should target patterns of misuse, not the characteristics of being new to banking.
What NFIS 4.0 should do?
Strengthen awareness of money mule recruitment. Financial literacy programmes already teach consumers to protect their PINs and recognise suspicious messages. They should also explain the dangers of renting out accounts, receiving money for strangers or accepting job offers that require forwarding funds. These warnings belong in account-opening materials, community outreach and agent banking networks, often a customer’s first contact with formal financial services.
Promote proportionate safeguards. Institutions should examine suspicious patterns, including rapid pass-through transfers, multiple unrelated senders and immediate withdrawals, without excluding customers simply because they lack transaction histories. Such behaviour may justify closer scrutiny, but not automatic conclusions of wrongdoing. Monitoring should respond to activity, not assumptions about customers.
Measure account misuse and prevention outcomes. NFIS 4.0 should track suspected account misuse, confirmed money mule cases and investigation outcomes alongside measures of access and usage. Separating allegations from established findings would help assess whether controls are detecting criminal activity without unfairly penalising new customers.
Protect customers from wrongful restrictions. Early-warning systems will sometimes flag innocent people. Where legally permissible, customers should receive clear notice, prompt reviews and accessible complaint channels when their accounts are restricted. A first-time customer locked out without recourse may lose confidence in formal banking altogether.
Safe for users and safe from misuse
NFIS 4.0’s focus on trust and digital safety should address both sides of the problem: protecting people from being defrauded and preventing their accounts from being used to defraud others. Money mule prevention and safeguards against wrongful exclusion belong in the same strategy.
Inclusion should bring Nigerians into the formal financial system, not into someone else’s fraud.