SCUML DNFBP transaction monitoring Nigeria starts with the Money Laundering (Prevention and Prohibition) Act 2022, which received presidential assent on 13 May 2022 and replaced the 2011 Act. The Act gives the Special Control Unit against Money Laundering (SCUML), a unit within the Economic and Financial Crimes Commission, the job of registering, monitoring and supervising designated non-financial businesses and professions.
Many DNFBPs see SCUML as a certificate to obtain. In practice it opens a set of continuing duties: due diligence, record-keeping, reporting and the ability to spot unusual activity. This article sets out those duties and a proportionate way to monitor for them.
Who is a DNFBP and what SCUML does
Section 30 of the 2022 Act defines the DNFBPs, which include real estate professionals, dealers in precious metals and stones, accountants and other professionals, and others. SCUML's published functions include registration and certification, sensitisation on obligations and monitoring and supervision. The Money Laundering regulations for DNFBPs of May 2024 confirm SCUML as the body responsible for registering, monitoring and supervising DNFBPs, and they extend registration and customer due diligence duties to DNFBPs operating in free trade zones.
SCUML registration is also commercially important. Industry commentary notes that banks verify a DNFBP's SCUML registration when onboarding it. Legal practitioners are a special case. The Federal High Court restrained enforcement of the 2011 Act's DNFBP provisions against lawyers in December 2014 and the Court of Appeal upheld that position in 2015, and the SCUML provisions of the 2022 Act were challenged again in a 2023 suit. The final position on appeal could not be confirmed, so law firms should take current advice rather than rely on general summaries.
The reports a DNFBP must be ready to make
Two report types matter. A suspicious transaction report is based on suspicion, not value. SCUML guidance says an STR can relate to any amount, and that a DNFBP suspecting structuring to avoid reporting thresholds should file one. Reports go to the Nigerian Financial Intelligence Unit (NFIU), and section 7(2) of the Act sets a 24-hour timeline from when a transaction is identified as suspicious.
The second is the currency transaction report for large cash transactions. Figures widely reported in commentary and in the NFIU's goAML update put domestic currency transaction reporting at ₦5 million for individuals and ₦10 million for corporates, and section 2 of the Act limits cash payments at similar levels. SCUML's guidance says DNFBPs file currency transaction reports with SCUML and send suspicious transaction reports solely to the NFIU. Reporting instructions are updated by circular, so check SCUML's current guidance before building the process.
Monitoring that fits a small business
A DNFBP rarely needs a bank-style system. It needs a reliable way to notice. Record every cash receipt and linked receipts in one register, so thresholds are tested automatically instead of by memory. Define a short list of red flags suited to the business: payment by unrelated third parties, cash for high-value property or gold, reluctance to identify beneficial owners, unexplained sources of wealth and sudden changes in transaction pattern.
Make escalation simple. Staff should know to report concerns to the compliance officer the same day, and the officer should record the decision and its reasoning. That trail is what SCUML and the NFIU will test, and it is what protects the firm when a report is later questioned.
Common gaps
Three weaknesses appear repeatedly. Registration is treated as the end of compliance. Customer due diligence is done at onboarding but not refreshed when behaviour changes. And suspicion is judged by value, so small transactions that form a pattern are missed. Each is fixable with process rather than technology.
Because the position is evolving, check SCUML's published guidance and the current text of the Act and regulations, and obtain local legal advice for sector-specific questions. A proportionate approach to SCUML DNFBP transaction monitoring Nigeria rests on a cash register, a short red-flag list and a documented escalation route.
