NFIU: Nigerian Banks File 92% of Suspicious Reports

• The Nigerian Financial Intelligence Unit received over 42,000 Suspicious Transaction Reports and more than 41.7 million Currency Transaction Reports in 2025.
• Deposit Money Banks accounted for approximately 92% of all Suspicious Transaction Reports and 89.2% of Currency Transaction Reports filed during the year.
• The Money Laundering (Prevention and Prohibition) Act mandates reporting of transactions exceeding N5 million for individuals or N10 million for legal entities within seven days.
• Virtual Asset Service Providers showed increased reporting activity in the second half of 2025, signaling growing regulatory engagement.
• The NFIU's 2025 Annual Report highlights continued risks to Nigeria's financial system and increased regulatory monitoring across various sectors.

For legal and compliance professionals within financial institutions, these findings highlight the imperative to ensure that internal reporting mechanisms for Suspicious Transaction Reports (STRs), Currency Transaction Reports (CTRs), and Suspicious Activity Reports (SARs) are not only robust but also strictly adhere to the requirements outlined in the Money Laundering (Prevention and Prohibition) Act.

The Nigerian Financial Intelligence Unit (NFIU) has published its 2025 Annual Report, detailing a significant volume of financial crime-related disclosures from various reporting entities. The report indicates that a total of 42,082 Suspicious Transaction Reports (STRs) were submitted to the agency during the year. Alongside these, the NFIU also processed 41,716,214 Currency Transaction Reports (CTRs) and 10,513 Suspicious Activity Reports (SARs), underscoring persistent risks within Nigeria’s financial system and an intensified focus on transaction monitoring by regulators.

Deposit Money Banks (DMBs) emerged as the primary source of these critical reports, particularly for STRs. Banks were responsible for filing 38,715 STRs, which constitutes approximately 92 percent of all such reports received by the NFIU from diverse sectors. This substantial contribution highlights the central role of traditional banking institutions in the country's anti-money laundering and counter-terrorism financing efforts.

Beyond STRs, DMBs also largely dominated the submission of Suspicious Activity Reports, accounting for 8,313 out of the total 10,513 SARs recorded in 2025. Furthermore, banks were the overwhelming source of Currency Transaction Reports, submitting 37,214,139 CTRs, representing about 89.2 percent of the overall figure. These statistics collectively paint a clear picture of the banking sector's extensive involvement in reporting financial activities to the NFIU.

The NFIU's comprehensive reporting framework encompasses a broad spectrum of financial disclosures, including threshold-based transactions, suspicious transactions, and suspicious activities. This framework is designed to ensure robust compliance with anti-money laundering (AML), counter-terrorism financing (CTF), and counter-proliferation financing (CPF) regulations across the financial landscape. To bolster regulatory adherence, the NFIU actively collaborates with key supervisory bodies such as the Central Bank of Nigeria (CBN), the National Insurance Commission (NAICOM), the Securities and Exchange Commission (SEC), and the Special Control Unit Against Money Laundering (SCUML).

Underpinning these reporting requirements are specific provisions of the Money Laundering (Prevention and Prohibition) Act. Section 11 of the Act mandates financial institutions to report any transaction exceeding N5 million for individuals or N10 million for legal entities within a strict seven-day timeframe. Additionally, Section 3(1) of the same legislation stipulates that all incoming and outgoing international transfers surpassing $10,000 must be reported within 24 hours. These legal obligations form the bedrock of Nigeria's efforts to combat illicit financial flows.

The NFIU's 2025 report also revealed that a significant number of reports, specifically 28,133,909, involved Politically Exposed Persons (PEPs). This particular focus underscores the heightened scrutiny applied to transactions associated with individuals holding prominent public functions, reflecting international best practices in AML/CFT compliance aimed at mitigating corruption and illicit enrichment risks.

While Deposit Money Banks led in overall reporting, other financial sectors also contributed to the NFIU's intelligence gathering. Other Financial Institutions (OFIs) submitted 2,185 STRs and 1,816 SARs, alongside 4,212,466 CTRs. Designated Non-Financial Businesses and Professions (DNFBPs) accounted for 1,029 STRs, though notably, this sector recorded no SARs during the year. Capital market operators and insurance companies collectively filed 104 STRs, 295 SARs, and 289,296 CTRs.

A notable development highlighted in the report is the increasing activity from Virtual Asset Service Providers (VASPs), including businesses dealing in cryptocurrencies. Although VASPs submitted a comparatively smaller number of reports overall—49 STRs, 89 SARs, and 313 CTRs for the entire year—their reporting patterns showed a significant uptick in the latter half of 2025. For instance, VASPs filed no STRs in the first half but reported 17 in the third quarter and 32 in the fourth. Similarly, their CTR filings, which were absent in the first half, emerged with 103 reports in the third quarter and 210 in the fourth, indicating growing engagement with regulatory compliance.

Quarterly data further illustrates these trends. Bank STR filings demonstrated a steady increase throughout 2025, rising from 9,134 in the first quarter to 10,032 by the fourth quarter. Bank CTRs followed a similar upward trajectory, escalating from 7,040,493 in Q1 to 11,091,107 in Q4. While OFI STR filings fluctuated, VASP SARs were consistently reported across all quarters, with 28 in Q1, 12 in Q2, 24 in Q3, and 25 in Q4, signaling their integration into the broader financial reporting ecosystem.

The NFIU's 2025 Annual Report serves as a clear signal of heightened regulatory scrutiny on financial institutions, particularly banks, concerning their anti-money laundering and counter-terrorism financing (AML/CFT) compliance. The sheer volume of reports, especially from DMBs, underscores the critical role these institutions play in safeguarding the integrity of Nigeria's financial system. The consistent increase in STR and CTR filings by banks throughout the year further emphasizes the ongoing vigilance required.

For legal and compliance professionals within financial institutions, these findings highlight the imperative to ensure that internal reporting mechanisms for Suspicious Transaction Reports (STRs), Currency Transaction Reports (CTRs), and Suspicious Activity Reports (SARs) are not only robust but also strictly adhere to the requirements outlined in the Money Laundering (Prevention and Prohibition) Act. The NFIU's focus extends beyond traditional banking, with the report explicitly noting the emerging contributions from Virtual Asset Service Providers, signaling an expanding scope of regulatory oversight. This evolving landscape necessitates continuous adaptation and strengthening of compliance frameworks across all reporting entities.

This report signals heightened regulatory scrutiny by the NFIU on financial institutions, particularly banks, regarding AML/CFT compliance. Lawyers and compliance officers must ensure their internal reporting mechanisms for STRs, CTRs, and SARs are robust and adhere strictly to the Money Laundering Act's requirements, especially given the rising volume of reports and the NFIU's focus on various sectors including VASPs.

Source: Original reporting via Odinaka Anudu