Overview of Suspicious Transactions in Nigeria
In 2024, Nigerian financial institutions and other reporting entities significantly increased their efforts to detect and report suspicious transactions. These activities were aimed at combating money laundering, terrorism financing, and other illicit financial practices. The Nigerian Financial Intelligence Unit (NFIU) received a total of 82,143 Suspicious Transaction Reports (STRs), which marked a substantial rise in the number of such reports compared to previous years.
The NFIU’s 2024 Annual Report highlighted that the agency received an impressive 25,819,719 Currency Transaction Reports (CTR) and 23,364 Suspicious Activity Reports (SARs). This data was obtained by Sunday PUNCH and published on the NFIU’s website. According to the report, the NFIU receives threshold-based disclosures, suspicious transaction and activity reports, as well as regulatory submissions related to anti-money laundering (AML), counter-terrorist financing (CTF), and counter-proliferation financing measures.
Key Players in Reporting Suspicious Activities
Deposit Money Banks (DMBs) were the primary contributors to the STRs, submitting 73,531 reports, which accounted for approximately 89.5% of all STRs received during the year. Other Financial Institutions filed 5,442 reports, while capital market operators and insurance companies submitted 1,796 reports. Designated Non-Financial Businesses and Professions (DNFBPs) accounted for 1,013 reports, and Virtual Asset Service Providers (VASPs), including digital asset operators, filed 361 suspicious transaction reports.
The report emphasized that suspicious transaction reports are mandatory whenever a reporting entity identifies a transaction or activity potentially linked to money laundering, terrorist financing, proliferation financing, or other unlawful conduct. Section 7 of the Money Laundering Prohibition Act (MLPAA) mandates all reporting entities, including financial institutions and designated non-financial institutions, to submit a report if they determine that the activity or transaction is suspicious and possibly linked to illegal activities.
Growth in Suspicious Transaction Reporting
Quarterly data revealed a steady increase in suspicious transaction reporting by banks throughout the year. DMBs filed 14,744 STRs in the first quarter, 17,031 in the second quarter, 20,052 in the third quarter, and 21,704 in the fourth quarter. Other Financial Institutions also saw sustained growth, with filings rising from 842 in the first quarter to 1,908 in the fourth quarter.
The NFIU also received 23,364 Suspicious Activity Reports in 2024. Banks again accounted for the largest share with 19,873 reports, followed by Other Financial Institutions with 2,071 reports and capital market and insurance firms with 1,382 reports. DNFBPs filed 38 SARs, while no SARs were recorded from VASPs during the period.
Currency Transaction Reports
Beyond suspicious transactions, reporting entities submitted 25.82 million Currency Transaction Reports (CTRs) to the NFIU. Deposit Money Banks accounted for 23.16 million of these reports, representing about 89.7% of the total. Other Financial Institutions filed 2.53 million reports, while capital market and insurance companies submitted 127,726 reports.
Financial institutions are required to report transactions above N5m for individuals and N10m for legal persons to the NFIU within seven days. All incoming and outgoing transfers exceeding $10,000, whether conducted by a single individual or aggregated within a day, must be reported within 24 hours.
Compliance and Enforcement Activities
As part of its compliance and enforcement activities, the NFIU conducted 1,317 off-site examinations and 98 on-site examinations across several states in Nigeria. The agency also issued guidelines on the identification, verification, and reporting of suspicious transactions related to money laundering, terrorism financing, and proliferation financing. These guidelines were introduced to improve the quality of Suspicious Transaction Reports, reduce false positives and defensive filings, and ensure effective risk-based measures against criminal abuse of the financial system.
The NFIU onboarded 483 reporting entities onto its reporting platforms during the year and registered 1,317 entities on the NIGSAC portal. It also disclosed that 44,256 DNFBPs were enrolled on a simplified suspicious transaction reporting platform developed jointly with SCUML to improve compliance across sectors such as real estate, casinos, dealers in precious metals and stones, legal practitioners, accountants, and trust service providers.
Emerging Financial Crime Risks
The NFIU identified several emerging financial crime risks from its analysis of reports received during the year. These included frequent cash withdrawals from government accounts at the state and local government levels, the use of corporate entities as intermediaries for transactions involving virtual asset service providers, misuse of personal bank accounts for business transactions to evade taxes, and the diversion of public funds through third-party entities.
The agency also raised concerns over the use of illegal Bureau de Change operators to launder funds for politically exposed persons and some government agencies. It warned that emerging technologies, including artificial intelligence tools, online file converters, and digital platforms, could expose institutions to data breaches, fraud, and regulatory violations if not properly managed.
Intelligence Dissemination and International Cooperation
The NFIU disseminated 3,030 proactive intelligence reports and 1,866 reactive intelligence reports to competent authorities in 2024 to support investigations and prosecutions relating to money laundering, terrorism financing, and associated crimes. Among the top offences linked to intelligence reports disseminated during the year were corruption, fraud, stand-alone money laundering, criminal tax offences, and illicit trafficking in narcotic drugs and psychotropic substances.
The NFIU also strengthened international intelligence cooperation, receiving 84 requests from foreign financial intelligence units and making 109 requests to its counterparts abroad. The report noted that the agency received 143 spontaneous disclosures from foreign intelligence units, some of which were shared with domestic agencies to support investigations.
