Nigeria AML for Accountants: MLPPA 2022 and SCUML Guide

Nigeria's anti-money laundering framework applies directly to accountants. The Money Laundering (Prevention and Prohibition) Act 2022 treats licensed professional accountants as designated non-financial businesses and professions (DNFBPs), and places them under the supervision of the Special Control Unit against Money Laundering (SCUML), a department of the Economic and Financial Crimes Commission (EFCC). This guide summarises what the Act says about due diligence, record keeping, reporting, cash limits and penalties. It is based on the text of the Act as published in the Federal Government Gazette, as reproduced by a legal publisher, together with SCUML's own mandate page and the Financial Action Task Force (FATF) plenary statement of October 2025. It is general information, not legal advice, and amendments or regulations made after 2022 should be checked.

The legal framework and who supervises accountants

PwC Nigeria's overview records that the President assented to the Act on 13 May 2022 and that it repealed the Money Laundering (Prohibition) Act 2011. Section 30 of the Act defines DNFBPs. The list in the text we reviewed includes licensed professional accountants, tax consultants, legal practitioners and notaries, trust and company service providers, real estate dealers and agents, and dealers in precious metals and stones. Auditors are not named separately, so licensed professional accountants are the closest category. Section 17 makes SCUML the supervisor of DNFBPs.

SCUML's mandate page says its functions include registering and certifying DNFBPs, sensitising them to their obligations, monitoring and supervision through off-site, on-site and spot-check inspections, enforcement, and collecting cash-based transaction reports and currency transaction reports for the Nigerian Financial Intelligence Unit (NFIU). The page cites both the 2011 and 2022 Acts in different places, which is a reminder to check which text SCUML is applying.

Customer due diligence

Section 4 of the Act requires institutions to identify and verify customers, beneficial owners and anyone acting for a customer. According to the text, due diligence applies when establishing a business relationship, on occasional transactions above a threshold set by regulators (including linked transactions), on occasional wire transfers, where there is suspicion of money laundering or terrorist financing, and where earlier identification data is doubtful. The Act also requires ongoing monitoring and periodic updating of records, and enhanced measures for politically exposed persons. For casual customers it sets a figure of US$1,000 (section 4(5)). The definition of beneficial owner in section 30 covers the natural person who ultimately owns or controls a customer, the person on whose behalf a transaction is conducted, and anyone exercising ultimate effective control over a legal person or arrangement.

For the underlying process, our guide to customer due diligence for accountancy practices sets out the steps in a general way.

Record keeping and internal controls

Under section 8, transaction records must be kept for at least five years after completion, and customer due diligence records for at least five years after the relationship ends or the occasional transaction takes place. Section 10 requires anti-money-laundering programmes, including compliance officers at management level, regular staff training, centralised information and an internal audit unit, and section 13 requires risks from new products and technologies to be assessed before launch.

Reporting duties and cash limits

The Act sets several different reporting duties, and accountants should keep them apart:

• Suspicious transactions (section 7). Transactions meeting the listed suspicion criteria must be reported immediately, and a written report must be prepared and filed within 24 hours. The duty applies whether or not the transaction is completed. The text we reviewed does not make entirely clear whether DNFBP reports go directly to the NFIU or through SCUML, so confirm the current route with SCUML.
• Large transactions (section 11). A single transaction above ₦5 million for an individual or ₦10 million for a body corporate must be reported within seven days, to SCUML in the case of DNFBPs.
• Cash payments (section 2). Cash payments above those same amounts are prohibited unless made through a financial institution.
• Cross-border transfers (section 3). Transfers above US$10,000 to or from another country must be reported within one day, and cash or negotiable instruments above that amount carried across the border must be declared to Customs.

The tipping off offence is in section 19. Staff acting in good faith under the Act are protected from civil and criminal liability to customers. Section 11(4) also provides that professional privilege and client confidentiality do not apply to listed activities such as property transactions, the management of client money or assets, and the creation or operation of companies and trusts.

Penalties

The Act sets out financial penalties and criminal sanctions. For DNFBPs it provides a penalty of ₦250,000 per day for failing identification or return duties, with possible licence suspension or revocation (section 6(3)), and ₦1 million per day for failing suspicious reporting duties (section 7(10)). Directors or employees who breach sections 3 to 15 face a fine of ₦10 million or three years' imprisonment, or both, and professional bans of up to five years or indefinitely (section 19). Money laundering itself carries imprisonment of four to fourteen years, a fine of at least five times the proceeds, or both (section 18(3)). A body corporate convicted of an offence may be wound up and its assets forfeited (section 22).

Nigeria and the FATF

At its plenary of 22 to 24 October 2025, FATF said that Burkina Faso, Mozambique, Nigeria and South Africa had completed their action plans within agreed timeframes and would no longer be subject to its increased monitoring process, following successful on-site visits. It said Nigeria and Burkina Faso would continue to work with their FATF-style regional body, GIABA, to sustain improvements. Leaving increased monitoring does not remove any legal duty. For a comparable case, see our guide to South Africa's AML framework after its grey list exit, and for a different regional model, our guide to AML obligations in the UAE.

Practical steps for Nigerian practices

These are our suggestions, not requirements in the Act:

• Confirm that your practice is registered and certified with SCUML and that the certificate is current.
• Build the ₦5 million and ₦10 million thresholds, and the seven-day reporting window, into your cash and transaction procedures.
• Record your risk assessment for new services and technology before you offer them, as section 13 requires.
• Keep client due diligence and transaction records for the five-year periods in section 8.
• Agree who is responsible for suspicious transaction reports, and confirm the filing route with SCUML.
• Re-check the current text of the Act and any SCUML regulations or guidance, because later changes are not covered here.

Frequently asked questions

Are accountants covered by the Act?

Yes. Section 30 lists licensed professional accountants among the DNFBPs, and section 17 makes SCUML their supervisor.

Are auditors covered?

The Act does not name auditors separately in the list we reviewed. Check with SCUML how audit work is treated for registration and reporting.

Does leaving the FATF grey list change my obligations?

No. The Act's duties apply regardless. The change reflects FATF's view of the country's progress.