Learning Objectives

By the end of this lesson, you will be able to:

Explain the key provisions of the Money Laundering (Prevention and Prohibition) Act 2022 and why it replaced the 2011 Act.

Describe how the Terrorism Prevention and Prohibition Act 2022 complements the AML framework.

Outline what the EFCC AML/CFT/CPF Regulations 2024 require of Designated Non-Financial Businesses and Professions.

Identify the roles of EFCC, SCUML, NFIU, ICPC, IMBLN, NIESV, and REDAN in Nigeria’s AML/CFT institutional framework.

State the specific compliance obligations that apply to registered mortgage brokers and estate professionals.

Describe the penalties for AML/CFT non-compliance, including daily fines and imprisonment.

Introduction

Nigeria didn’t always have this architecture. For years, the country’s AML framework was fragmented, under-enforced, and out of step with international standards. That changed meaningfully when the Money Laundering (Prevention and Prohibition) Act 2022 and the Terrorism Prevention and Prohibition Act 2022 were both signed into law.

The result: a coherent, FATF-aligned statutory framework backed by implementing regulations and a network of agencies with real enforcement powers. And in October 2025, FATF confirmed Nigeria’s exit from its grey list.

You’re in this perimeter now. As a mortgage broker or lender regulated by IMBLN, you’re a DNFBP under Nigerian law.

The ML(PP) Act 2022 is Act No. 14 of 2022. It replaced the Money Laundering (Prohibition) Act 2011 entirely. The 2011 Act had serious gaps: it didn’t adequately cover DNFBPs, lacked beneficial ownership transparency provisions, and penalties were insufficient to deter serious operators.

The 2022 Act is explicitly designed to align with FATF Recommendations.

Section 30 lists the Designated Non-Financial Businesses and Professions subject to the Act’s full compliance obligations.

Real estate dealers are on that list. So are estate developers, estate agents, and estate brokers. Mortgage brokers appear explicitly. This isn’t a matter of interpretation. The law names your profession.

Designation means Customer Due Diligence, record-keeping, Suspicious Transaction Reporting, registration with SCUML, and exposure to sanctions if you fail to comply.

Section 28 empowers the Attorney-General of the Federation to make regulations implementing the Act. This is the legal basis for the EFCC AML/CFT/CPF Regulations 2024.

For individuals convicted of money laundering: 4 to 14 years imprisonment.

For corporate entities: fines from N5 million to N25 million. Officers of the corporate body are prosecuted alongside the company.

For failing to report a suspicious transaction: 2 to 5 years imprisonment for individuals and N10 million to N50 million for companies.

Any transaction of N5 million or above involving an individual must be reported to the NFIU as a Cash Transaction Report (CTR). For corporate customers, the threshold is N10 million.

The same thresholds apply to Cross-Border Transaction Reports (CBTRs).

Structuring is the practice of deliberately splitting transactions to stay below reporting thresholds. It’s also called smurfing. It’s a standalone criminal offence.

If a client breaks a N12 million payment into three tranches of N4 million each to avoid CTR filing, that’s a crime. If you assist with it, knowingly or recklessly, you’re criminally liable too.

The TPPA 2022 is Act No. 15 of 2022. It arrived alongside the ML(PP) Act as companion legislation. The Act consolidates and strengthens Nigeria’s counter-terrorism legal framework.

It criminalises not just direct terrorism financing but also provision of funds or property where there’s reasonable suspicion that those resources might be used for terrorism.

Money laundering is typically about cleaning proceeds of past crimes. Terrorism financing can involve entirely legitimate funds diverted to violent purposes.

For mortgage professionals, the most practically relevant provision is the obligation to report suspected terrorism financing through the same STR mechanism via the NFIU’s goAML platform.

The TPPA 2022 creates additional offences around dealing with listed persons and entities. UNSC-listed individuals and entities are off limits.

The CPF in AML/CFT/CPF stands for Counter-Proliferation Financing, which addresses the financing of weapons of mass destruction programmes. FATF’s Recommendation 7 specifically requires countries to implement targeted financial sanctions related to proliferation financing.

In daily practice, CPF compliance primarily means screening clients against sanctions lists and refusing to transact with sanctioned entities.

The EFCC AML/CFT/CPF Regulations 2024 are the implementing instrument made by the Attorney-General under Section 28 of the ML(PP) Act 2022. If the Act is the law, the Regulations are the rulebook.

All DNFBPs must register with SCUML within 3 months of the Regulations coming into force, or within 3 months of commencing business. Failure to register is an offence.

Registration requires submitting your business details, identifying your compliance officer, and providing documentation of your ownership structure.

Before you hire anyone into a role with AML responsibilities, you need to screen them. Criminal background checks are mandatory for relevant staff.

The Regulations set out a tiered CDD framework. Standard CDD applies to most clients. Enhanced Due Diligence (EDD) applies to PEPs, high-risk jurisdictions, and complex ownership structures. Simplified CDD is available for demonstrated low-risk cases.

CDD must be completed before you act for a client. Not during, not after. Before.

Beneficial ownership is not optional. If a company is buying a property, you need to identify the natural persons who ultimately own or control that company.

All CDD records, transaction records, and STR filings must be kept for a minimum of 5 years from the end of the business relationship or the date of the transaction.

Suspicious Transaction Reports go to the NFIU via the goAML platform. The NFIU updated its STR Guidelines in December 2024 with a critical change: STRs must now be filed within 24 hours of the suspicion arising.

Register on goAML now, before you need to use it.

The EFCC is the lead AML/CFT enforcement agency. It has powers to investigate, arrest, prosecute, and seek asset forfeiture orders. SCUML operates under the EFCC’s institutional umbrella.

SCUML is the AML/CFT supervisor for all DNFBPs in Nigeria. It registers DNFBPs, monitors their compliance, and supervises their AML programmes. If you’re a mortgage broker, SCUML is your AML regulator.

SCUML can conduct compliance examinations and impose administrative sanctions, including financial penalties and referral to the EFCC for criminal prosecution.

The NFIU is Nigeria’s Financial Intelligence Unit. It receives all STRs and CTRs from reporting entities, analyses them, and produces financial intelligence for law enforcement agencies.

The NFIU operates the goAML platform.

The ICPC handles corruption and related offences. The ICPC-IMBLN Joint Task Committee was inaugurated on 11 March 2026. Its mandate includes building shared intelligence, developing AML/CFT curriculum content, and running enforcement campaigns.

IMBLN is your professional regulator. On AML/CFT, IMBLN ensures registered practitioners understand their obligations. Failure to comply with AML requirements is a disciplinary offence under IMBLN’s Code of Conduct.

NIESV is the professional body for estate surveyors and valuers. Its members are classified as DNFBPs under Section 30. Knowing this helps you understand the full network of obligations around a transaction.

REDAN is a self-regulatory body for real estate developers. Its members are also DNFBPs. When you deal with a developer counterparty, REDAN membership is a due diligence data point.

If you’re practising as a mortgage broker and you’re not SCUML-registered, you’re operating illegally. Your SCUML certificate is a business credential.

Identity verification. Beneficial ownership. Risk assessment. Suspicious transaction reporting (within 24 hours via goAML). Cash threshold reporting (CTRs). Record-keeping (5 years). Training.

Politically Exposed Persons require Enhanced Due Diligence. EDD means a deeper source-of-funds investigation, senior management sign-off on the relationship, and ongoing monitoring.

SCUML daily fines: N250,000 to N1,000,000 per day for continuing non-compliance.

Criminal penalties (individuals): 2 to 5 years imprisonment for compliance failures.

Company fines: N10 million to N50 million.

The firms that stay out of trouble are the ones where AML obligations are embedded into daily practice. A written AML policy that staff have actually read. A designated compliance officer with real authority. A CDD process built into your client onboarding workflow.

Case Study: The Mortgage Broker Who Almost Missed the Pattern

Chukwuemeka is a registered mortgage broker in Lagos. In early 2025, a new client, a property developer, came to him seeking to arrange financing for the purchase of three adjoining commercial plots in Ikoyi. The total transaction value was N180 million.

The developer’s company was registered in Nigeria but had two additional holding companies: one in the UAE and one in a jurisdiction with low transparency standards. The developer explained this structure was for tax efficiency.

Chukwuemeka ran standard CDD. He verified the Nigerian company’s CAC registration, obtained a copy of the director’s passport, and confirmed the property titles. But he stopped there. He didn’t trace the ultimate beneficial ownership. He didn’t ask for source-of-funds documentation. He didn’t file an STR despite the complex ownership structure, the cross-border elements, and the high transaction value.

The transaction completed. Six months later, the EFCC contacted Chukwuemeka. The developer was under investigation for procurement fraud. The Ikoyi plots had been purchased using those proceeds.

SCUML initiated a compliance examination. Inspectors found that his CDD process had no beneficial ownership tracing. His AML policy hadn’t been updated. His staff had received no AML training.

SCUML imposed a daily fine. IMBLN’s Disciplinary Committee opened proceedings against him for professional negligence. The transaction was frozen pending the EFCC investigation. His firm’s reputation in Ikoyi took a serious hit.

The lesson: partial compliance isn’t compliance. Standard CDD on a complex, high-value, cross-border transaction isn’t enough. You have to follow the structure to the ultimate beneficial owner, ask about source of funds, and file an STR when the answers don’t satisfy you.

KEY TAKEAWAYS

The ML(PP) Act 2022 replaced the 2011 Act with a stronger, FATF-aligned framework. Section 30 names mortgage brokers and real estate dealers as DNFBPs.

The Terrorism Prevention and Prohibition Act 2022 is companion legislation covering terrorism financing and counter-proliferation financing.

The EFCC AML/CFT/CPF Regulations 2024 require DNFBP registration with SCUML within 3 months, criminal background checks for relevant staff, full CDD before acting for clients, and STR filing within 24 hours via goAML.

Seven institutions form the framework: EFCC, SCUML, NFIU, ICPC, IMBLN, NIESV, and REDAN.

Cash Transaction Reports are required for individual transactions of N5 million and above, and N10 million and above for corporates. Structuring is a standalone criminal offence.

Penalties for non-compliance: daily fines of N250,000 to N1,000,000, imprisonment of 2 to 5 years for individuals, and N10 million to N50 million fines for companies.

Knowledge Check (10 Questions)

1. Which Act replaced the Money Laundering (Prohibition) Act 2011?

   1. The EFCC (Establishment) Act 2004
   2. The Money Laundering (Prevention and Prohibition) Act 2022
   3. The Terrorism Prevention and Prohibition Act 2022
   4. The IMBL Act 2022

2. Under Section 30 of the ML(PP) Act 2022, which of the following is listed as a DNFBP?

   1. Commercial banks
   2. Insurance companies
   3. Mortgage brokers and real estate dealers
   4. Telecommunications companies

3. Under the EFCC AML/CFT/CPF Regulations 2024, within what timeframe must a new DNFBP register with SCUML after commencing business?

   1. 1 month
   2. 2 months
   3. 3 months
   4. 6 months

4. What is the cash transaction reporting threshold for individual clients under the ML(PP) Act 2022?

   1. N1 million
   2. N2 million
   3. N5 million
   4. N10 million

5. Following the December 2024 NFIU STR Guidelines update, within how many hours must a suspicious transaction report be filed?

   1. 6 hours
   2. 12 hours
   3. 24 hours
   4. 72 hours

6. Which body operates the goAML platform for STR submission?

   1. SCUML
   2. EFCC
   3. NFIU
   4. ICPC

7. The ICPC-IMBLN Joint Task Committee was inaugurated on which date?

   1. 10 June 2024
   2. 1 October 2025
   3. 11 March 2026
   4. 17 April 2026

8. What is structuring (smurfing) in the context of AML compliance?

   1. Organising a client’s property portfolio across multiple asset classes
   2. Deliberately splitting transactions to stay below reporting thresholds
   3. Using a holding company structure to purchase property
   4. Filing multiple CTRs for the same transaction

9. What daily fine range can SCUML impose on a non-compliant DNFBP?

   1. N50,000 to N100,000
   2. N100,000 to N200,000
   3. N250,000 to N1,000,000
   4. N1,000,000 to N5,000,000

10. Nigeria was removed from the FATF grey list in which month and year?

    1. June 2024
    2. January 2025
    3. October 2025
    4. March 2026

Answers

Answers: 1. (b) 2. (c) 3. (c) 4. (c) 5. (c) 6. (c) 7. (c) 8. (b) 9. (c) 10. (c)

Further Reading

Money Laundering (Prevention and Prohibition) Act 2022, Act No. 14 of 2022

Terrorism Prevention and Prohibition Act 2022, Act No. 15 of 2022

EFCC AML/CFT/CPF Regulations 2024

NFIU Suspicious Transaction Reporting Guidelines (December 2024 edition)

SCUML DNFBP Registration Procedures and Requirements

Investment and Mortgage Brokers’ Licensing Act 2022

IMBLN Code of Conduct for Registered Practitioners

ICPC-IMBLN Joint Task Committee Inaugural Address, 11 March 2026

FATF Recommendation 12 (PEPs) and Recommendation 7 (Targeted Financial Sanctions)

FATF Nigeria Mutual Evaluation Report

IMBL Nigeria Certification