Regulatory Alerts2012-04-27 | FPR/DIR/CIR/AML/CFT/01/003Amendment Of Anti-Money Laundering/Combating The Financing Of Terrorism (AML/CFT) Regulation, 2009 To Align With Money Laundering (Prohibition) Act (MLPA), 2011 And Terrorism (Prevention) Act (TPA), 2011
The Nigerian Financial Intelligence Unit (NFIU) is tasked with the responsibility of collecting, collating, analyzing and disseminating financial intelligence relating to money laundering and terrorist financing. This involves receiving suspicious transaction reports from financial institutions, including banks, mobile money operators, and insurance companies, among others. Under the Nigerian Money Laundering (Prevention & Prohibition) Act 2011, there are certain categories of information that must be rendered exclusively to the NFIU, as highlighted in this appendix: 1. Failure to complete CDD: Financial institutions reporting when they have not completed the Customer Due Diligence process with a customer. 2. PEP relationships: Reporting by financial institutions on their relationship with Politically Exposed Persons (PEPs) and any unusual transactions that may arise from this relationship. 3. Complex, unusual (large), and suspicious transactions: Financial institutions reporting on complex or unusually large transactions they suspect are related to money laundering or terrorist financing. 4. Suspicious transactions relating to terrorism financing: Financial institutions are required to report suspicious transactions to the NFIU that may be associated with terrorism financing. 5. Wire transfers lacking originator information: Financial institutions reporting on wire transfers where complete originator information is missing, which could indicate a money laundering or terrorist financing activity. 6. Abnormal exercise of cancellation and cooling-off rights by investors: Financial institutions must report any suspicious patterns of cancellation or cooling-off exercises made by customers. 7. Non-face to face identification procedures: Where an institution's business is conducted electronically, it must monitor its systems for unusual transactions and report any suspicious activities to the NFIU. 8. Trust accounts and Executorship accounts: Financial institutions reporting on any suspicions about transactions carried out under trust or executorship accounts. 9. Client accounts opened by professional intermediaries: Financial institutions are required to investigate and report any suspicious activities related to client accounts managed by professional intermediaries. 10. Linked transactions suspected of money laundering: Institutions must investigate and report any linked transactions they suspect may be involved in money laundering, along with documentary evidence. Financial institutions are obligated under the Act to render these reports exclusively to the NFIU for further analysis and dissemination as needed.