Guidance · EFCC · 1 Aug 2019
SCUML requires designated non-financial institutions, including law and accounting firms, to report transactions exceeding a specified threshold using a standardized template. The template mandates precise documentation of client and customer details, identification types, transaction dates, locations, payment modes, and monetary values in Naira or foreign currency. Firms must clearly distinguish between direct beneficiaries and agents while accurately recording amounts received or paid to ensure compliance with anti-money laundering reporting obligations.
EXPLANATORY NOTE ON THE REPORTING TEMPLATE FOR DESIGNATED NON-FINANCIAL INSTITUTIONS (PROFESSIONALS)
S/N: Serial Number of reporting.
DNFI (Designated Non-Financial Institution): Means the reporting entity
whose responsibility is to send/report transaction(s) above the threshold to SCUML. The name of the DNFI should be clearly written on the column.
CLIENT/SOURCE OF FUND
a. A Client is a person or legal person who gives money or valuables on trust to a law or Accounting firm. b. A client is a person or legal person who directed a law or Accounting firm to manage investment account on his/her behalf.
c. A client is a person or legal person who directed a law or Accounting firm
to manage real estate on his/her behalf d. A client is a person or legal person who directed law firm to arrange for the creation or management of company. e. A client is a person or legal person who directed a law or accounting firm to transfer money on his/her behalf f. The name of your client/source of fund should be clearly written on the column as follows: Last name/surname, First name and Middle name.
COMPANY/CUSTOMER
a. Customer/company is a person or legal person who buys property from or sells property to a DNFI. b. Customer/company is a person or legal person who pays rented property.
c. Customer/company is a person or legal person who requested for an
agreement on sales of property/item. d. Customer/company is a person or legal person who rendered service to you (DNFI) or sold an item/property to you. e. The name of a company/customer should be clearly written on the column as follows: Last name/surname, First name and Middle name.
ADDRESS
Contact address of Client/Source of fund/Company/Customer/agent which include number, street, city and state (name of a country, if other than Nigeria).
OCCUPATION
Source of living or nature of business of a Client / Source of fund / Company / Customer.
TELEPHONE NUMBER
Contact Phone Number of a Client/Source of fund/Company/Customer.
TYPE OF IDENTIFICATION
Means of identification of a Client/Source of fund/Company/Customer which include National ID card or Driver’s license or International Passport or Certificate of Incorporation in the case of company. Note that the type of ID and number of ID should be clearly stated.
DATE OF BIRTH
The client/customer’s date of birth or company’s date of incorporation.
NATIONALITY
The country of origin of a client / source of fund / company / customer.
NAME OF ITEM/SERVICE
Nature/description of the item/service rendered to or required by Client/Source of fund/company/customer/agent.
TRANSACTION DATE
The date the reported transaction took place. This should be in the following format: dd/mm/yy.
LOCATION OF TRANSACTION
Indicate where transaction took place.
MODE OF PAYMENT
Indicate mode of payment (Cash, Cheque, wire etc) for the item/service rendered or required.
AMOUNT/CURRENCY
a. The value of item/service required or rendered. b. The “IN” column is the amount received by DNFI for the service rendered or item sold.
c. The “OUT” column is the amount paid by DNFI for the service requested
or item purchased. d. The currency type (Naira, $) should be clearly indicated.
BENEFICIARY
a. The person or company who transacted a business (requested for an item or service) for his/her own benefit. b. The person or company on whose behalf a transaction is carried out by an agent.
AGENT
The person or company transacting business on behalf of another (beneficiary)
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Source: Economic and Financial Crimes Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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