Nonprofits across the country have begun to witness a trend of routine inspection by officials of the Special Control Unit against Money Laundering, SCUML and Economic Financial Crimes Commission, EFCC. These visits are part of the mandate of SCUML and EFCC to determine the compliance rate of Nigerian NPOs with the Anti-Money Laundering and Countering the Finance of Terrorism, AML/CFT regime and serve as a way for government to better keep track of the activities of NPOs. Ultimately, they help to ensure that NPOs are not vulnerable to risks of being used as conduits for Money Laundering, ML and Terrorism Financing, TF.
A routine inspection by SCUML is often heralded by an official letter stating the dates and time the visit will occur; along with a list of documents they would like to see during their visit (Below is the list). The Executive Director or whoever is the head of the organisation is expected to be available to receive them.
DOCUMENTS TO BE MADE AVAILABLE BY YOUR ORGANIZATION – NGO
- General/Sales transaction ledger (2014 to date)
- Statement of accounts for the last 12 months
- Organisational chart (Organogram)
- AML/CFT related policies/manual for staff training
- Summary of litigation by and against your institution, including current status and the potential impact upon conclusion
- List of your institution’s affiliated companies/subsidiaries
- Breakdown of all grants, donations, contributions and gifts made to your organisation (including material donations) above N1million from 2014 to date
- Summary of all completed and ongoing programmes/projects from 2014 to date
- List of beneficiaries of your programmes/projects in tune of N160,000 and above from 2014 to date
Note that the team will sight the originals of the documents listed above.