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What next after Business Registration? SCUML Registration

What next after Business Registration? SCUML Registration


SCUML being an acronym for Special Control Unit against Money Laundering, was established in 2005 in furtherance of the combat against the funding of terrorism in Nigeria. It is statutorily under the Federal Ministry of Industry, Trade and Investment but operationally domiciled within the Economic and Financial Crimes Commission (EFCC) since the commission ordinarily oversees its operations. SCUML enforces every law relating to Anti Money Laundering and Combating the Financing of Terrorism with regards to Jewelry, Cars and Luxury Goods, Precious Stones and Metals, Real Estate, Estate Developers, Estate Surveyors and Valuers, Estate Agents, Chartered Accountants, Audit Firms, Tax Consultants, Clearance and Settling Companies, Hotels, Casinos, Supermarkets, Dealers in Merchandized Farming Equipment's, Non-Governmental Organizations, Money Lending Firms and other businesses the Ministry may designate.


The following functions are performed by SCUML:

  1. Registration and Certification of Designated Non-Financial Institutions (DNFIs) in Nigeria.

  2. Sensitization of DNFIs on their compliance obligations and the implementation guidelines.

  3. Monitoring and supervision of the acivities of DNFIs as it relates to Anti Money Laundering and Countering Financing of Terrorism (AML/CFT).

  4. Conducting off-site, on-site and spot checks inspections of DNFIs.

  5. Taking necessary enforcement action to ensure compliance with the AML/CFT Laws and Regulations.

  6. Collaboration with stakeholders  to ensure compliance with the AML/CFT measures within the DNFIs sector in Nigeria.

  7. Establishment and maintenance of a comprehensive database of DNFIs and their  financial transactions to support tactical, operational and strategic analysis as well as policy options in combating money laundering and financing terrorism.

  8. Carrying out strategic analysis using available data to identify emerging trends and patterns in money laundering and terrorist financing.

  9. Collection of statutory reports such as Cash Based Transaction Reports (CBTRs), Currency Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) for forwarding to the Nigerian Financial Intelligence Unit (NFIU) being the national repository of financial disclosures of these reports.

  10. Provision of vital information relating to DNFIs money trails to assist criminal investigation by Law Enforcement Agencies in order to boost the fight against economic and financial crimes within the DNFIs sector in Nigeria.   


  1. To register with SCUML.

  2. To make Currency Transaction Reports (CTRs) of any single cash transaction, lodgment or transfer of funds in excess of  N5,000,000 or its equivalent in the case of an individual or N10,000,000 in the case of a body corporate within seven days from the date of transaction via SCUML online reporting platform on the SCUML website.

  3. To make Cash Based Transaction Reports (CBTRs) to SCUML on any single transaction in excess of $10,000 or its equivalent within 7 days from the date of the transaction via SCUML online reporting platform on the SCUML website.

  4. To make report of any transfer of funds or securities to or from a foreign country including a Money Service by a person or body corporate including a Money Service Business of a sum exceeding $10,000 or its equivalent to the Central Bank of Nigeria, Securities and Exchange Commission or the Commission in writing within 7 days from the date of the transaction.

  5. To report suspicious transaction relating to terrorism. A Financial Institution or DNFI shall within a period not more than 72 hours, forward reports of suspicious transactions relating to terrorism to the Nigerian Financial Intelligence Unit which shall process such information and forward it to the relevant law enforcement agency.

  6. To identify and verify customers. Identification is done by taking note of the customer's name, address, occupation or nature of business, Telephone Number, Date of Birth or Date of Incorporation, Nationality etc. Verification is done via IDs - driver’s license, international passport, national identity card and voter’s card.

  7. To keep records of all transactions conducted with your customers for a period of 5 years before discarding same.

  8. To appoint a compliance officer that will be liaising with SCUML and would be responsible for ensuring compliance with obligations as stipulated by law. SCUML shall be notified officially in writing with the details of the officer.

  9. To train employees on anti-money laundering obligations.

  10. To ensure that all transactions with customers in the branch offices are forwarded to the headquarters for onward forwarding to SCUML within 7 days.

  11. To establish an internal auditing system that ensures all transactions are conducted based on anti-money laundering measures.     


Whilst carrying out SCUML Registration online, the necessary documents to be filed would depend on the type of DNFI. The following documents are filed based on the following categories:

  • Business Names

    • Certificate of Incorporation


    • Evidence of tax registration (TIN Letter)

    • BVN, Bank name and Account Number

    • Professional certificates where applicable

  • Companies

    • Certificate of Incorporation

    • Memorandum and Articles of Association

    • Form CAC 1.1

    • Evidence of tax registration (TIN Letter)

    • BVN, Bank Name and Account Number

    • Licenses or permits where applicable

  • Trust or NGO

    • Certificate of Incorporation or Registration

    • Incorporation of Trustees

    • Identification of Trustees with a valid means of Identification

    • Constitution or Memorandum and Articles of Association

    • Tax Identification Number (TIN) or Tax Exemption

    • Particulars of Settlors

    • Particulars of Protector (if any)

    • Copy of Cooperation Agreement (For International NGOs)

    • Trust Deed Agreement

    • BVN, Bank Name and Account Number

  • Religious Organization

    • Certificate of Incorporation or Registration

    • Incorporation of Trustees

    • Identification of Trustees with a valid means of at least two of the trustees

    • Constitution 

  • Association or Clubs or Societies

    • Certification of Incorporation or Registration

    • Copy of constitution or Bye-Laws

    • Particulars of the trustees

    • Tax Identification Number (TIN) or Tax Exemption

    • BVN, Bank Name and Account Number    


Dealers in Jewelry - Evidence of registration with Jewelry Marketers Association of Nigeria (JMAN).

Car Dealers - Evidence of registration with Association of Motor Dealers of Nigeria (AMDON)

Hotels and Hospitality Business - Registration with Hotel Owners Forum Abuja (HOFA) or Nigeria Tourism Development Corporation (NTDC).

Casinos, Pool Betting and Lottery Businesses - License from either the National Lottery Commission or State Lotteries Board.

Audit Firms/Accounting Firms/Tax Consultants - Professional Certificate with ICAN or ANAN or ACCA.

Estate Surveyors and Valuers - Nigerian Institution of Estate Surveyors and Valuers (NIESVs) or Nigeria Institute of Quantity Surveyors Certificates (NIQS)

Real Estate Dealers - REDAN Certificate

Construction Companies - COREN Membership Certificate or Nigerian Society of Engineers Membership Certificate etc. REDAN Certificate

Consulting Companies - Relevant consulting certificates

Clearing and Forwarding Companies - Evidence of registration with Council for the Regulation of Freight Forwarding in Nigeria (CRFFN)

Dealers in Precious Stones and Metals - Exploration License/permits (Ministry of Solid Minerals), License from a Certified Geologist; For Exporting: Nigerian Export Promotion Council (NEPC); For Importing: Nigerian Investment Promotion Commission (NIPC).

Law Firms - Call to Bar Certificate or Legal Practicing Certificate  


It is compulsory that (Special Control Unit against Money Laundering) SCUML registration be carried out by businesses that fall within DNFIs in order to successfully carry out business in Nigeria. As a matter of fact, failure to do this may make such a business unable to maintain a bank account with financial institutions, as well as lead to criminal prosecution of the business. 

For more insights on steps to take after business registration, check out our series of articles on WHAT NEXT AFTER BUSINESS REGISTRATION? and What Next After Business Registration? Registering Your Trademark.