June 10, 2025

SCUML in Nigeria: All You Need to Know for Mandatory Business Compliance

by Eko Solicitors

INTRODUCTION

SCUML, we are frequently approached by clients seeking our assistance after receiving a “friendly” invitation from the Economic and Financial Crimes Commission (EFCC) regarding breaches of the Money Laundering Act. These breaches often involve undeclared funds during business transactions and non-compliance with the regulations of the Special Control Unit against Money Laundering.

In many cases, such visits result in the client paying substantial penalties or fines—typically for failing to obtain a SCUML certificate or neglecting to file Currency Transaction Reports (CTRs). Most business owners only become aware of SCUML requirements when attempting to open a current account at a bank, where the certificate is one of the mandatory prerequisites.

After securing the SCUML certificate and opening the account, many quickly lose sight of the law’s broader purpose. Without proper legal guidance, they often remain unaware of the ongoing obligation to submit financial transaction reports to SCUML.

This article aims to inform and educate the public on the importance of not only obtaining a SCUML certificate but also maintaining continuous compliance as required by law. Doing so can help individuals and businesses avoid the financial penalties that often arise from a lack of awareness.

WHAT IS SCUML?

The Special Control Unit against Money Laundering (SCUML) is a department under the Economic and Financial Crimes Commission charged with the responsibility of registering, monitoring, and supervising the activities of Designated Non-Financial Businesses and Professions ( DNFBPs) in line with the Money Laundering (Prevention & Prohibition) Act, 2022 (MLPP Act) and Economic & Financial Crimes Commission (Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation of Weapons of Mass Destruction for Designated Non-Financial Businesses and Professions and other Related Matters) Regulations, 2022.

WHAT IS MONEY LAUNDERING?

“Money laundering is the process by which criminals conceal the origin and ownership of illegally obtained funds to make them appear legitimate. The primary aim is to avoid detection, prosecution, and the potential confiscation of illicit wealth. In simple terms, it involves making ‘dirty’ money look clean.

SCOPE AND ROLE OF SCUML CERTIFICATE

The Designated Non-Financial Businesses & Professions are required under the regulatory laws and Regulations to carry out the following:

Register with the SCUML
Make Currency Transaction Reports (CTRs) to SCUML of any single transaction, lodgment or transfer of funds in excess of N5,000,000 or its equivalent in the case of an individual or N10,000,000 in the case of a corporate body within 7 days from the date of transaction via SCUML online reporting platform.
To make Cash Based Transaction Reports (CBTRs) to SCUML of any single transaction in excess of $1,000 or it is equivalent within 7 days from the date of transaction via SCUML online reporting platform.
Make Suspicious Transaction Reports (STRs) to the Nigeria Financial Intelligence Unit (NFIU).
To comply with all relevant provisions of the Money Laundering (Prevention & Prohibition) Act, 2022

DESIGNATED NON-FINANCIAL BUSINESSES AND PROFESSIONS (DNFBPs)

Section 30 of the MLPP 2022 Act defines DNFBPs as:

(a) automotive dealers,

(b) businesses involved in the hospitality industry,

(d) clearing and settlement companies,

(e) consultants and consulting companies,

(f) dealers in jewelries,

(g) dealers in mechanised farming equipment, farming equipment and machineries,

(h) dealers in precious metals and precious stones,

(i) dealers in real estate, estate developers, estate agents and brokers

(j) high value dealers,

(k) hotels,

(l) legal practitioners and notaries,

(m) licensed professional accountants,

(n) mortgage brokers,

(o) practitioners of mechanised farming,

(p) supermarkets,

(q) tax consultants,

(r) trust and company service providers,

(s) pools betting, or

(t) such other businesses and professions as may be designated by the Minister responsible for Trade and Investment.

REQUIREMENTS FOR SCUML REGISTRATION

The requirements for registration varies according to the type of businesses being carried out, however, the basic requirements are:

LIMITED LIABILITY COMPANIES

Certificate of Incorporation.
Article and Memorandom of Association.
Status Report or its Equivalent (CAC 1.1 or CAC 7 and CAC 2)
Tax Identification Number (TIN) Print out

BUSINESS NAME

Certificate of Incorporation.
Status Report (Form BN-01)
Tax Identification Number (TIN) Print out

NON-PROFIT ORGANISATIONS (NPOS)

NPOs are made up of:

a. Humanitarian/Charitable Organisations: International / Local,

b. Religious / Faith Based Organizations, and

c. Associations / Clubs.

Certificate of Incorporation
Incorporation of Trustees
Constitution
Tax Identification Number (TIN) or Tax Exemption Print Out
Copy of corporation Agreement (For international NGOs)

NPOs that are limited by Guarantee (LTG/GTE)

Certificate of Incorporation
Memorandum and Articles of Association
Status Report or its Equivalent (CAC 1.1 or CAC 7 and CAC 2)
Tax Identification Number (TIN) Print out.

FILING OF REPORTS

All Designated Non-Financial Businesses and Professions (DNFBPs) are required to report Suspicious Transactions Reports (STR), Currency Transaction Reports (CTR) and Cash Based Transaction Reports (CBTR).

Suspicious Transaction Reports are to be made when a DNFBP suspects that a transaction may involve proceeds of any of the offences specified in the Money Laundering Prevention and Prohibition Act 2022, 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

STR has no threshold; it could be based on any amount. Whether or not a DNFBP accepts a suspicious transaction from the client, such report should be made for the protection of their business and sanitization of the industry and economy. This report should be submitted to the Nigeria Financial Intelligence Unit (NFIU) solely.

Currency Transaction Reports (CTR) are reports that DNFBPs 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 Memorandum of Understanding between Special Control Unit against Money Laundering and the Nigerian Financial Intelligence Unit, DNFBPs are to report CTRs directly to SCUML.

Cash Based Transaction Reports (CBTR) are reports required to be filed with the Special Control Unit against Money Laundering (SCUML) by DNFBPs for each deposit, purchase or sale and other payments, by a customer to the DNFBPs, which involves cash transaction in excess of $1,000 or its equivalent in Naira or other currencies.

All Cash Based Transaction Reports (CBTR) and Currency Transaction Reports (CTR) should be reported on SCUML website or forwarded info@scuml.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): lagos@scuml.org

Enugu Zonal Office (Enugu, Ebonyi, Abia, Imo and Anambra States): enugu@scuml.org

Kano Zonal Office (Kano, Sokoto, Kebbi, Zamfara, Katsina, Jigawa and Kaduna States: kano@scuml.org

Port Harcourt Zonal Office (Rivers, Bayelsa, Akwa Ibom, Cross River, Delta and Edo States): ph@scuml.org

Gombe Zonal Office (Gombe, Bauchi, Yobe, Borno, Adamawa and Taraba States): gombe@scuml.org STRs are to be sent via the NFIU website – www.nfiu.gov.ng.

CONCLUSION

In conclusion, filing the required reports as and when due is a legal obligation for all DNFBPs and it is as important as obtaining the SCUML certificate. Businesses must comply with SCUML regulations, including reporting suspected suspicious transactions and maintaining accurate records. Non-compliance can lead to serious consequences, including fines, legal actions, reputational consequences for businesses and potential suspension or revocation of licenses and even closure.

For more information and assistance with SCUML registration and compliance do contact experienced legal practitioners.

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