SCUML is charged with the responsibility of monitoring, supervising and regulating the activities of Designated Non Financial Institutions (DNFIs) in line with the Money Laundering (Prohibition) Act ML(P)Act 2011 and the Prevention of Terrorism Act (PTA) 2011.
i. Certificate of Incorporation. ii. Article and Memorandom of Association. iii. Tax Clearance Certificate ( Not Applicable to NGOs). iv. Audited Financial Report. v. Authorised Operational License ( Not Applicable to NGOs). vi. Company/Organization Profile. vii. Constitution ( For NGOs Only) vii. Agreement Signed between the NGO and the National Planning Commission ( For International NGOs Only)
Money Laundering is a process by which criminals attempt to hide or disguise the true origin and ownership of their ill-gotten wealth to make it look legitimate. The purpose is to avoid prosecution, conviction and confiscation of the ill-gotten wealth
Section 25 of the ML (P) Act defines DNFIs as dealers in Jewellery, Cars and Luxury Goods, Precious Stones and Metals, Real Estate, Estate Developers, Estate Surveyors and Valuers, Estate Agents, Chartered Accountants, Audit Firms, Tax Consultants, Clearing and Settlement Companies, Hotels, Casinos, Supermarkets, Dealers in Mechanized Farming Equipment and Machineries, Practitioners of Mechanized Farming, Non Governmental Organizations (NGOs) or such other businesses as the Federal Ministry of Trade and Investment or appropriate regulatory authorities may from time to time designate.
Dealers in Jewelleries , Dealers in Luxury Goods, Chartered/Professional Accountants, Audit Firms, Tax Consultants, Clearing and Settlement Companies, Legal Practitioners, Trust and Company Service Providers. Estate Surveyors and Valuers, Hotels and Hospitality industry, Dealers and Miners of Precious Stones and Metals, Pool Betting, Casino and Lottery, Supermarkets, Non-Governmental Organizations, Consultants and Consulting companies, Construction Companies, Estate Agents, Dealers in Real Estate, Importers and Dealers in cars and vehicles Dealers in Mechanized farming equipment and machinery. Practitioners of mechanized farming and any other business(es) as may be designated from time to time by the Federal Ministry of Trade and Investment or SCUML
Special Control Unit against Money Laundering (SCUML) and Economic Financial Crimes Commission (EFCC) are the regulatory authorities for the implementation of the AML/CFT regime in respect to the DNFI sector in Nigeria.
No! Registration can be done on the SCUML website at NO COST.
A suspicious transaction is a transaction in which a DNFI suspects that it may involve proceeds of any of the offences specified in the Money Laundering (Prohibition) Act 2011 as amended, regardless of the value involved; or (a) Appears to be made in circumstances of unusual or unjustified complexity; or (b) Appears to have no economic justification or lawful objective; or (c) Gives rise to suspicion that it may involve financing of terrorism. STR has no threshold; it could be based on any amount. This report should be submitted to the Nigeria Financial Intelligence Unit (NFIU) solely.
A CTR is a report that Designated and Non-Financial Institutions (DNFIs) are statutorily required to file with the Nigeria Financial Intelligence Unit (NFIU) on transactions that involve amounts in excess of N10,000,000 (Ten Million Naira) and N5,000,000 (Five Million Naira) for corporate bodies and Individuals respectively. However, based on the Memoradum of Understanding between Special Control Unit against Money Laundering and the Nigerian Financial Intelligence Unit, DNFIs are to report CTRs directly to SCUML.
This is a report that Designated Non-financial Institutions are required to file with the Special Control Unit against Money Laundering (SCUML) for each deposit, purchase or sale and other payments , by a customer to the DNFI, which involves cash transaction in excess of $1,000 or its equivalent in Naira or other currencies.
The reporting threshold is $1,000 or its equivalent and above for all transactions.
All Cash Based Transaction Reports (CBTR) and Currency Transaction Reports (CTR) should be forwarded to firstname.lastname@example.org and a copy also sent to the respective SCUML Zonal office email address where your organization is located as detailed below: Lagos Zonal Office (Lagos, Oyo, Ogun, Osun, Ekiti and Ondo States): email@example.com Enugu Zonal Office (Enugu, Ebonyi, Abia, Imo and Anambra States): firstname.lastname@example.org Kano Zonal Office (Kano, Sokoto, Kebbi, Zamfara, Katsina, Jigawa and Kaduna States: email@example.com Port Harcourt Zonal Office (Rivers, Bayelsa, Akwa Ibom, Cross River, Delta and Edo States): firstname.lastname@example.org Gombe Zonal Office (Gombe, Bauchi, Yobe, Borno, Adamawa and Taraba States): email@example.com STRs are to be sent via the NFIU website – www.nfiu.gov.ng
No. it is a legal requirement designed to protect legitimate businesses and professions as well as their customers.
A compliance officer is an officer at management level who will coordinate AML/CFT activities within the DNFI and liaises with SCUML.
Yes, they should report for the protection of their business and sanitization of the industry and economy.
All activities are regarded as transactions, provided it is service rendered and paid for, i.e. currency (cash transactions). It will not be possible to be classified since legal practitioners in Nigeria do not engage in specialized practices.
No, it is a requirement of the law.
No, it is illegal.
This is in accordance with the powers conferred on the Minister in charge of commerce to make further designations of DNFIs subject to section 25 of the ML (P) Act 2011. Such designation is usually made where a sector is found to be vulnerable to money laundering.
Yes, cumulative amount of grant should be reported as soon as the agreement for the funding is concluded. Subsequently released funds from the grant agreement that meet currency transaction reporting or cash transaction reporting threshold should be reported with reference to the first report.
Yes, for the purpose of anti money laundering and counter-terrorist financing.