Regulatory Alerts2019-09-01
Guidance Note on the AML/CFT Risk-Based Approach for the Hospitality (Hotel Sub-Sector)
Issued by Nigeria’s Special Control Unit against Money Laundering (SCUML), this guidance mandates Designated Non-Financial Institutions in the hotel sub-sector to implement a structured risk-based approach for anti-money laundering and counter-terrorist financing. Hotels must systematically assess customer, geographic, product/service, and industry risk factors using a standardized scoring template to classify clients as low, medium, or high risk. The framework requires integrating these risk profiles into internal compliance controls, tailoring customer due diligence levels accordingly, and directing enhanced resources toward identifying and reporting suspicious transactions.
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