New Act Mandates Sanctions on Nigerian Officials Over Blasphemy Laws, Designating Nigeria a 'Country of Particular Concern'

The Nigeria Religious Freedom Accountability Act of 2025 is a clear signal that the U.S. is stepping up pressure on Nigeria over religious freedom issues. Simply put, this legislation requires the President to impose sanctions on specific Nigerian officials, judges, and law enforcement who enforce or promote blasphemy laws, or who tolerate violence by terror groups like Boko Haram.

The Mandate: Sanctions and Accountability

This bill doesn't leave much wiggle room for the executive branch. It mandates that the Secretary of State create an annual report listing Nigerian individuals who meet three specific criteria related to religious persecution (SEC. 2). These criteria include high-level federal or state officials (like governors) who actively push for or maintain blasphemy laws, officials who tolerate religiously motivated violence by non-state actors, and judicial or law enforcement personnel who actually prosecute people under these laws.

Crucially, once this report is done, the President must immediately slap sanctions on everyone named, using the authority of Executive Order 13818. This is the order typically used to freeze assets and block property of serious human rights abusers and corrupt actors. This means a Nigerian state official who signed a bill enforcing a blasphemy law could suddenly find their U.S.-based assets frozen and travel restricted. The first report requires a look back of 10 years, meaning officials who acted years ago could still be targeted.

Automatic Designation: CPC and EPC

Beyond individual sanctions, the Act forces the Secretary of State to officially label Nigeria as a "Country of Particular Concern" (CPC) for severe religious freedom violations (SEC. 3). For those unfamiliar with the policy lingo, the CPC designation is a big deal; it triggers potential restrictions on U.S. aid, trade, and other diplomatic interactions. It’s a formal diplomatic condemnation.

The bill also requires the designation of Boko Haram and ISIS-West Africa as "Entities of Particular Concern" (EPC). While these groups are already recognized threats, formally mandating these designations removes the Secretary of State’s usual discretion in making these calls.

The Diplomatic Tightrope

This mandatory approach is where things get interesting—and potentially complicated. Foreign policy usually relies on the flexibility of the executive branch to use sanctions and designations as leverage in negotiations. This Act largely removes that flexibility. The Secretary of State can only waive the CPC designation for Nigeria if they can certify that both Boko Haram/ISIS-West Africa are no longer operating in the country and that no Nigerian government is enforcing blasphemy laws (SEC. 3). That’s a very high bar.

For the Nigerian government, this means facing mandatory U.S. sanctions and a major diplomatic downgrade, regardless of any diplomatic progress they might be making behind the scenes. For the U.S., while the goal is clearly to protect religious freedom—benefiting those facing persecution—the lack of discretion could strain cooperative efforts on other fronts, like counterterrorism, especially since the criteria for identifying officials who “tolerate” violence can be open to interpretation (SEC. 2).