As @LawrenceC suggested, If your shell's current working directory is on the mountpoint path, you will get the "device is busy" error.
ubuntu@myip:~/efs$ sudo umount ~/efs umount.nfs4: /home/ubuntu/efs: device is busy
ubuntu@myip:~/efs$ sudo umount ~/efs umount.nfs4: /home/ubuntu/efs: device is busy cd to a location other than the mountpoint to resolve the error.