FAQs
FAQ
SCUML means Special Control Unit against Money Laundering
It is because of its vulnerability to Money Laundering/Terrorist Financing.
SCUML registration is done online via our website (www.scuml.org)
No, Section 30 of the MLPPA, 2022 outlines the businesses and professions required to register with SCUML.
Visit the website www.scuml.org for specific registration guidelines.
All Corporate Affairs Commission (CAC) Incorporation documents, Tax Identification Certification from FIRS, Professional certificate/License where applicable.
Registration with SCUML is FREE
It takes 7 to 10 days after approval for e-certificate to be ready
The Money Laundering (Prevention and Prohibition) Act, 2022
Section 2,3,4,5,6,7,8,9,10 state DNFBPs obligation
Yes, an official letter should be written addressed to the Director SCUML requesting for training.
SCUML certificate are sent to the entity’s director email as captured on the portal.
All EFCC ZONAL offices.
By contacting the hotlines and emails of our various SCUML offices, or visiting the website.
A CTR is a report that Designated Non-Financial Businesses and Professions (DNFBPs) are statutorily required to file to SCUML 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. DNFBPs must report these transactions to help combat money laundering and other financial crimes.
This is a report that Designated Non-Financial Businesses and Professions (DNFBPs) 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 DNFBP, which involves cash transaction in excess of $1,000 or its equivalent in Naira or other currencies.
Both CTRs and CBTRs generally requires details about the transaction, including the amount, date, involved parties' identities, and the nature of the transaction. Ensure to maintain complete records to support the report.
What If a Customer Deliberately Breaks a Transaction into Smaller Amounts to Avoid CTR /CBTR Filing?
This practice, known as “Structuring,” is illegal. If a DNFBP suspects that a client / customer is structuring transactions to evade reporting requirements, you should file a Suspicious Transaction Report (STR) to the Nigerian Financial Intelligence Unit (NFIU).
A PEP is an individual who holds a prominent public position or function, such as government officials, high-ranking military officers, or executives in state-owned enterprises. Family members and close associates of PEPs are also regarded as PEPs under enhanced due diligence regulations.
For PEPs, enhanced due diligence measures are required. This includes obtaining senior management approval for establishing or continuing business relationships, monitoring the business relationship on an ongoing basis, and ensuring that adequate risk assessment procedures are in place.
All transactions involving a PEP are under obligation to be reported.
All Cash Based Transaction Reports (CBTR) and Currency Transaction Reports (CTR) and Politically Exposed Persons reports should be reported on SCUML website or forwarded [email protected] while a copy also sent to the respective SCUML Zonal office email address where your organization is located, respective SCUML email addresses listed on the website.
A suspicious transaction is a transaction in which a DNFBP suspects that it may involve proceeds of any of the offenses 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 (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.
Yes, they should report for the protection of their business and sanitization of the industry and economy.
You should file an STR as soon as you identify a transaction that appears suspicious. Timeliness is crucial in ensuring that authorities can investigate potential illicit activities effectively.
An STR typically includes details about the individual(s) or entities involved, the nature of the suspicious transaction, the amount, and the rationale behind the suspicion. Provide as much detail as possible without alerting the customer of the submission.
STRs should be filed solely to the Nigerian Financial Intelligence Unit (NFIU)
Failing to report a suspicious transaction can lead to serious consequences, including legal action against the DNFBP or individual, fines, sanctions and damage to reputation. It is crucial to maintain compliance with all reporting obligations
It is an arm of SCUML responsible for ensuring the compliance and enforcement of DNFBPs in line with provision of the MLPPA 2022.
It is a background examination carried out on an entity remotely.
It is an examination of an entity that we do physically by notifying the entity through a written letter) of our intention to examine/inspect them.
It is a physical examination of entity without prior notification.
It is conducted on an entity using a check list to ensure that all the requirements of the law are met.
To abide by the laws and comply with the AML/CFT guidelines.
Request For Information.
Self Regulatory Body(s).
We collaborate with NFIU as a sister agency in areas of intelligence sharing.
When there are infractions. A DNFBP is sanctioned when there are notable infractions and non-compliance to the AML/CFT policies and procedures.
i. Appointment of Compliance officer,
ii. Training of employees,
iii. Filing of statutory reports i.e. CBTR, CTR, STR, PEP, etc.
iv. Having an internal Audit unit,
v. Proper record keeping,
vi. To carry out KYC/CDD,
vii. Implementing TFS on their customers and clients,
viii. Subscribing to the simplified GOAML platform and NSC website.
ix. Classification of customers into Risk categories.
x. Obtain information on beneficial owners in transactions where the customer is an intermediary or representative of another party.
Small entities like one man business are also required to meet up with the obligations however, the MD/CEO is expected to nominate himself as the compliance officer and to ensure compliance with provisions of MLPPA.
Through a bank draft raised in favor of EFCC recovery account.
There is usually an additional penalty attached to the sanction, however in aggravate circumstances, the entity is prosecuted.
Yes, late payments attracts additional fines.
Consolidated revenue account of the Federal Government.
SCUML seal up only entities that failed to pay their sanctioned fines as a result of non-compliance to AML/CFT.