1. NPOs are required to file cash-based
transactions for cash transactions in
excess of $1,000 or its naira equivalent
(as stipulated under Section 5 of the
Money Laundering Prohibition Act):
Before embarking on any transaction of the value of
$1,000 USD or its equivalent, NPOs are required
to conduct Know Your Customer (KYC) on the
customer using the customer’s identity records with
photograph and send these records to SCUML
within 7 days of the transaction (CBTR).
Non-compliance attracts a fine of 250,000
(relatively).
2. NPOs are to file Currency Transactions
Reports - CTRs (as stipulated under
section 10 of the Money Laundering
Prohibition Act) to SCUML of any single
transaction:
Lodgment or transfer of funds in excess of 5 million
naira or its equivalent in the case of an individual or
10 million naira in the of body corporate within 7
days from the date of transaction via SCUML online
reporting platform on the SCUML Website: www.scuml.org
CONSEQUENCES OF NON-DISCLOSURE
Liable to a fine of not less than N250,000
and not more than N1 million (relatively).
How to file a Cash/Currency Transaction Report
Download the template from the SCUML website on
https://scuml.org/scuml/index.php/downloads/dnfisreporting-template/
item/12-ctr-cbt-online-reporting-template-for-allthe-dnfis-sector
NPOs must conduct KYC (know your
customers)
o
The eCTR template is divided under these basic headings:
DNFI (reporting institution) – Name of organisation
making the report
Name of Client/Source of Fund (donors, grantors,
financial contributors to the NGO. An NPO could
be the “Client/Source of Fund” if the funds are
generated internally).
Beneficiary - Name of the recipient organisation or
body
Transaction details – the engagement in which the
funds of a “Client/Source of Fund” is committed in
actualization.
Agents/ Representative - In cases where an NPO is
acting as a coordinating beneficiary between a donor
and other beneficiary organizations
Name of Company/ Customer-i.e. the beneficiary.
Corporate beneficiaries should state their full
business name under the column for “last name”.
Address: Location of the office or branch of the
Non- Profit Organization where the transaction took
place.
All Cash Based Transaction Reports (CBTR)
and Currency Transaction Reports (CTR)
should be forwarded to info@scuml.org and
a copy also sent to the respective SCUML
Zonal office email address where your
organization is located.
3. NPOs must conduct KYC (know your
customers) or CDD (customer due
diligence) before commencement of any
credible relationship/transaction
CDD or KYC simply means the act of performing
background checks on the beneficiary or sponsors to
ensure they are risk assessed of ML and TF before
being on-board, especially on international payments
relating to NPO programmes. These are necessary
because organisations could ignorantly receive
donor funds from people whose aims are basically
to launder funds, finance terrorism or maybe cause
some kind of mayhem.
How to conduct CDD:
I. Data Collection: to identify and obtain
information from the sponsor/donor/beneficiary.
For Individuals