The idea of writing this post is help our clients and other Nigerian business owners who are yet to be in the hook of EFCC for SCUML Non-Compliance and those who are in already to know what to do. The post contain how to respond to FCC Notification Of Compliance Inspection and other precautionary in the future. They said, “Ignorant of The Law is Not An Excuse”.
Our aim of writing this post is to educate our high esteem clients/ Nigerian business owners and we plead that you help other by sharing this post to save many from falling a victim.
Questions
- Is your company registered with The Special Control Unit Against Money Laundering (SCUML)?
- Has your bank asked you SCUML certificate as a requirement to open a bank account for you?
- Do you know SCUML is all about? This post is for you.
The Economic and Financial Crimes Commission (EFCC) are inviting companies to determine if they are abiding by the law that established the SCUML and where you default for any reason, it may not be a good experience you in their hand.
Read: NCEC Certificate Registration
Designated Non-Financial Businesses and Professions (DNFBPs) in Nigeria are required to submit Currency Transaction Reports (CTRs) and Cash-Based Transaction Reports (CBTRs) to the Special Control Unit Against Money Laundering (SCUML) for transactions exceeding set thresholds.
After obtaining SCUML certificate, the Economic and Financial Crimes Commission (EFCC) backed by Money Laundering (Prevention and Prohibition) Act, 2022 is expecting you to do the followings;
Reporting Obligations Requirements:
Effective January 1, 2026, SCUML will no longer accept CTRs/CBTRs via email. All reports must be submitted exclusively through the SCUML portal. The website is not working as at the time we post this message. Keep checking to know when it is up.
- Thresholds
– Individuals: Cash transactions of N5,000,000 (5 million) and above within 7 days of the transaction.
– Corporate Bodies: Cash transactions of N10,000,000 (10 million) and above within 7 days of the transaction.
- NIL Report:Even if no qualifying transactions occur within a month, a NIL report must be filed to maintain compliance.
- Timeline:Monthly, typically by the first week of the following month.
Rendering Reports Pre-2026, you send Email to “report@scuml.org.ng”.
Read: NCDMB or Local Content Certificate Registration
How to Render Report
Effective from January 1, 2026, you use SCUML portal.
- Visit SCUML portal, login into your account with your username and password obtained from SCUML, fill in the details and submit.
- Copying the respective SCUML zonal office email where the business is registered is important.
- Retain Evidence:Save all sent emails and acknowledgment receipts from SCUML as evidence of compliance for EFCC inspections.
Required Information for CTR Template
When filling out the CTR template, the following details are required:
- Beneficiary Information: Name, full address, occupation, and phone number of the person/entity conducting the transaction.
- Transaction Details: Date of transaction, nature of service (e.g., rent, purchase), and total amount.
- Identification: Valid ID type and ID number (e.g., CAC registration number for companies).
Other Things To Note:
- Develop an Anti-Money Laundering and Counter-Terrorism Financing policy manual for your organization.
- Appoint an inhouse compliance staff and notify SCUML.
- EFCC may invite you and request you come along with the followings;
– Daily General Ledger/ General receipts booklet.
– Bank(s) statement of account for past 2 or 3 years.
– Evidence of registration with SCUML.
– Anti-Money Laundering and Counter-Terrorism Financing policy manual.
Read: Oil and Gas Business Permit/ Licenses
Conclusion:
When you are invited by the Economic and Financial Crimes Commission (EFCC), please remain calm even if you felt that you have defaulted because your panic will cause you to make more mistakes.
If the invitation date/time is not convenience for you, you can call the mobile number in the invitation letter to inform them when you will be available.
You can honour the invitation along with your lawyer in case you feel you cannot go alone.
Before going for the invitation, go through your inspection checklist if they are complete.
Expect EFCC SCUML officer to educate you on your obligations as a DNFBP and they may issue you a warning letter that will contained what you are to comply within a period.