Learning Objectives

After completing this lesson, you will be able to:

Identify the specific red flags that signal suspicious activity in Nigerian real estate transactions.

Describe the step-by-step process for escalating and filing a Suspicious Transaction Report via goAML.

Explain the thresholds and procedures for Currency Transaction Reports and Cash-Based Transaction Reports.

State the criminal offence of tipping off and the legal protections available to good-faith reporters.

Describe FATF’s 40 Recommendations and Nigeria’s removal from the FATF grey list in October 2025.

Apply international best practices in AML/CFT to your daily work as a real estate professional.

Most money laundering doesn’t announce itself. You have to read the signals, and real estate throws off a lot of them.

Any individual buying property with cash above N5 million triggers a mandatory Currency Transaction Report. Corporate buyers cross the threshold at N10 million.

The red flag is when someone structures the cash to stay below those thresholds. Multiple payments. Multiple buyers on paper. Different accounts. That pattern is structuring or smurfing, itself a money laundering offence.

A client who refuses to provide a government-issued ID, proof of address, or source of funds documentation is refusing to let you do your job. Under the ML(PP) Act 2022, you cannot proceed if CDD requirements aren’t met. Walk away. Then consider whether the refusal warrants an STR.

A property bought and sold within a short window at a significant price difference is a classic laundering technique. Dirty money goes in at the purchase price. Clean money comes out at the sale price.

Overpaying lets a buyer inject illicit cash into a legitimate-looking transaction. Underpaying conceals value being transferred informally. If a deal is priced more than 20% above or below comparable sales, find out why.

Someone other than the named buyer pays. The buyer is clearly acting on behalf of an undisclosed party. These become red flags when the client is evasive about who the true beneficiary is.

You need to know who the ultimate beneficial owner is. Full stop.

PEPs are high-risk by definition. Enhanced due diligence applies to every PEP transaction: senior management sign-off, deeper source-of-funds verification, heightened monitoring.

Clients who genuinely have nothing to hide almost always cooperate. Reluctance or evasion is itself a signal. Document the question and the response. If inadequate, escalate internally and consider filing an STR.

The NFIU updated its STR Guidelines on 13 December 2024.

Step 1: Internal Escalation to the Compliance Officer

Escalate to your firm’s Compliance Officer immediately, in writing, with all relevant documentation. Your Compliance Officer has 72 hours to investigate.

Don’t conduct your own investigation beyond what’s needed to document the initial concern. Don’t tip off the client.

Step 2: Investigation Within 72 Hours

The Compliance Officer gathers facts, checks for prior STRs, and assesses plausibility of any explanation. If the suspicion is resolved, document why. If not, move to Step 3.

Step 3: STR Filed to NFIU Within 24 Hours via goAML

The goAML platform is the UNODC-developed system used by over 15,000 Nigerian reporting entities. The 24-hour clock starts when the Compliance Officer determines an STR should be filed.

Alternative submission: nfiucompliance@efccnigeria.org (use only if goAML is unavailable).

What the STR Narrative Must Contain

Alert trigger details: dates, amounts, client behaviour, missing or inconsistent documents.

Prior STR history on the subject.

Remedial actions taken: CDD steps, transaction suspension, enhanced due diligence.

Be factual. Be specific. Avoid vague statements.

Record Retention

Retain copies of all STRs and supporting documentation for at least five years. A clear paper trail protects you. A missing file does the opposite.

STRs are triggered by suspicion. CTRs and CBTRs are not. They’re mandatory for every qualifying transaction.

CTRs go to the NFIU. Thresholds: N5 million for individuals, N10 million for corporates. Filing a CTR does not mean you think the client is a criminal. Many legitimate property transactions will cross these thresholds.

What you cannot do is structure payments to avoid crossing the threshold.

CBTRs go to SCUML. They apply specifically to cash transactions, regardless of threshold, within the real estate sector. CTRs are about transaction size. CBTRs are about payment method.

Both report types must be retained for five years. Missing reports are a compliance failure. If you’re unsure whether to file, err on the side of filing.

Tipping off means telling a client, suspect, or anyone connected to them that you have filed an STR, that an investigation is underway, or that regulatory scrutiny is coming.

It doesn’t have to be explicit. A pointed remark. An unexplained change in behaviour. Becoming unavailable. Any communication that could alert the subject.

Under the ML(PP) Act 2022, tipping off is a criminal offence.

Conviction can result in imprisonment. Your professional registration will be affected. STR investigations only work if the subject doesn’t know they’re coming.

The ML(PP) Act 2022 provides explicit protection. You cannot be sued for defamation, breach of contract, or breach of confidentiality because you filed an STR in good faith.

Your identity as a reporter can be kept confidential. You’re protected from employer retaliation.

The Federal Government’s Whistleblower Protection Policy (2016) adds financial rewards of up to 5% of recovered assets.

FATF sets the global standard. Its 40 Recommendations cover customer due diligence (Rec 10), suspicious transaction reporting (Rec 20), and real estate agent obligations (Rec 22).

Recommendation 22 specifically applies to DNFBPs, including real estate agents. It requires you to apply CDD measures, record-keeping, and STR obligations in the same way that banks do.

Nigeria was placed on the FATF grey list because of deficiencies in its AML/CFT framework. The ML(PP) Act 2022 was part of the action plan to address those deficiencies.

Nigeria was removed from the FATF grey list in October 2025. But removal is not the end. FATF will continue to monitor Nigeria’s progress.

GIABA, the Inter-Governmental Action Group against Money Laundering in West Africa, is the FATF-style regional body. Real estate features prominently in GIABA’s regional typologies.

A compliant real estate firm has: a written AML/CFT policy that staff have actually read; a designated Compliance Officer with real authority; a risk-based approach to CDD; a working relationship with goAML; and a culture where reporting suspicions is normal.

International best practice also includes regular staff training (at least annually), independent audits of AML procedures, and a documented transaction monitoring system.

EFCC: 4,111 convictions and 975 real estate seizures in 2024. Daily fines for ongoing non-compliance: N250,000 to N1 million per day. Licence revocation. Imprisonment.

Case Study: The Ikoyi Apartment — How One Broker Caught a Laundering Attempt and Filed a Winning STR

Chidi Eze, a registered IMBLN broker in Lagos, was engaged to facilitate the sale of a three-bedroom apartment in Ikoyi priced at N180 million. The buyer made first contact via WhatsApp and requested to view the property alone without Chidi present.

At the initial meeting, the buyer arrived with a representative who did all the talking. When Chidi asked for the buyer’s BVN, government-issued ID, and proof of address, the representative said the buyer was a very private person and offered a letter from a law firm instead.

Chidi recognised this immediately: reluctance to provide standard CDD, third-party representation, and a lawyer’s letter as substitute for direct identification — textbook red flags.

He told the representative he could not proceed without proper documentation. That same day, he escalated internally to his firm’s Compliance Officer. They documented three specific red flags. Within 72 hours, the Compliance Officer determined an STR should be filed.

Chidi submitted the STR via goAML the next morning, within the 24-hour window. The narrative detailed all three alert triggers, confirmed no prior STR history, and documented that the transaction had been suspended pending CDD resolution.

Three months later, the NFIU contacted the firm to advise that the STR had contributed to a broader investigation. The buyer was subsequently linked to a network under EFCC scrutiny for fraud proceeds.

Chidi never received any adverse action. His firm’s compliance record was reviewed during a SCUML inspection and rated satisfactory. The decision that protected him was simply following the process exactly as the NFIU Guidelines require.

KEY TAKEAWAYS

Red flags in real estate include cash structuring, refusal to provide ID, rapid buy-sell cycles, prices far above or below market, nominee arrangements, PEP involvement, and reluctance to explain source of funds.

The STR process: internal escalation to Compliance Officer, investigation within 72 hours, STR filed to NFIU within 24 hours via goAML. Narrative must cover alert triggers, prior STR history, and remedial actions taken.

CTRs go to NFIU at thresholds of N5M (individuals) and N10M (corporates). CBTRs go to SCUML for cash transactions. Both are mandatory even when not otherwise suspicious.

Tipping off is a criminal offence under the ML(PP) Act 2022. File the report, stay silent.

Good-faith STR reporters are protected from civil liability. The Whistleblower Protection Policy (2016) adds confidentiality and financial rewards of up to 5% of recovered funds.

Nigeria was removed from the FATF grey list in October 2025. FATF Recommendation 22 applies directly to real estate agents. Non-compliance carries daily fines of N250K to N1M, licence revocation, and imprisonment.

Knowledge Check (10 Questions)

1. A client proposes paying N8 million in two separate cash installments of N3.9 million each. What is this behaviour called and what should you do?

   1. Legitimate installment payment; proceed normally
   2. Structuring (smurfing); treat as a red flag and consider filing an STR
   3. A CTR trigger; file the CTR and proceed with the transaction
   4. Enhanced due diligence trigger; request additional ID only

2. Under the NFIU’s December 2024 STR Guidelines, within how many hours must an STR be filed?

   1. 12 hours
   2. 24 hours
   3. 48 hours
   4. 72 hours

3. Which platform does the NFIU use for STR submissions in Nigeria?

   1. NIBSS STR Portal
   2. goAML
   3. SCUML Online
   4. EFCC E-Compliance

4. Currency Transaction Reports for individual transactions must be filed to the NFIU at what threshold?

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

5. Cash-Based Transaction Reports (CBTRs) are filed to which body?

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

6. Which of the following does the STR narrative NOT need to include?

   1. Alert trigger details
   2. Prior STR history on the subject
   3. Remedial actions taken
   4. The client’s full tax filing history

7. What does tipping off mean under the ML(PP) Act 2022?

   1. Giving financial tips to a Compliance Officer
   2. Disclosing to a suspect that an STR has been filed or an investigation is underway
   3. Reporting a colleague’s misconduct to IMBLN
   4. Voluntarily disclosing your own suspicious transactions

8. Nigeria was removed from the FATF grey list in:

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

9. FATF Recommendation 22 specifically applies to:

   1. Central banks only
   2. Designated non-financial businesses and professions, including real estate agents
   3. EFCC investigators
   4. Foreign exchange dealers exclusively

10. In the case study, Chidi’s STR narrative documented all of the following red flags EXCEPT:

    1. Refusal to provide ID
    2. Nominee arrangement with an undisclosed principal
    3. Evasiveness about the buyer’s business background
    4. Cash payments structured below the CTR threshold

Answers

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

Further Reading

NFIU STR Guidelines (updated 13 December 2024)

Money Laundering (Prevention and Prohibition) Act 2022

goAML User Guide for DNFBPs (UNODC/NFIU)

FATF 40 Recommendations, especially Recommendations 10, 20, and 22

FATF Mutual Evaluation Report: Nigeria

GIABA Typologies Report: Money Laundering Through Real Estate in West Africa

SCUML Guidelines for Real Estate Practitioners on CBTR

Federal Government Whistleblower Protection Policy, 2016

EFCC Annual Report 2024

IMBLN AML/CFT Compliance Manual

IMBL Nigeria Certification