FAQs on SCUML

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Que: What Is SCUML?

Ans:SCUML means Special Control Unit against Money Laundering Que: Where Is SCUML Located? Ans:Head office: No. 1 Obosi Street off Ladoke Akintola Boulevard beside PHCN Garki II office Abuja.
        Tel: (234) 09 7806364 Website: www.scuml.org E-mail: info@scuml.org
Lagos Zonal office: 15, Awolowo Road Ikoyi Lagos.
Kano Zonal office: GP 360 Bida Road, Civic Centre Kano.
Port Harcourt Zonal office: 8, Bank Road, off Moscow Road Port Harcourt, Rivers.
Enugu Zonal Office: Plot 106 Federal Government Collage Road Independenc Layout, Enugu,Nigeria
Gombe Zonal Office: No. 4 EFCC Street, New G.R.A, Gombe, Gombe State, Nigeria.

  Que: Scope and Role of SCUML? Ans:SCUML is charged with the responsibility of monitoring, supervising and regulating the activities of Designated Non Financial Institutions (DNFIs) in line with Financial Action Task Force (FATF) 40 recommendations. Que: What are the requirements for SCUML registration? Ans:

i. Certificate of Incorporation. ii. Article and Memorandom of Association. iii. Tax Clearance Certificate ( Not Applicable to NGOs). iv.  Audited Financial Report. v.  Authorised Operational License ( Not Applicable to NGOs). vi. Company/Organization Profile. vii. Constitution ( For NGOs Only) vii. Agreement Signed between the NGO and the National Planning Commission ( For International NGOs Only).

Que: What is Money Laundering? Ans:Money Laundering is a process by which criminals attempt to hide or disguise the true origin and ownership of their ill-gotten wealth to make it look legitimate. The purpose is to avoid prosecution, conviction and confiscation of the ill-gotten wealth. Que: Who are Designated Non Financial Institutions (DNFIs)? Ans:Section 25 of the ML (P) Act defines DNFIs as dealers in jewellery, cars and luxury goods, chartered accountants, audit firms, tax consultants, clearing and settlement companies, legal practitioners, hotels, casinos, supermarkets, or such other businesses as the Federal Ministry of Trade and Investment or appropriate regulatory authorities may from time to time designate. Que: Which Businesses And Professions Are Currently Being Regulated By SCUML? Ans:Dealers in Jewelries , Dealers in Luxury Goods, Chartered/Professional Accountants, Audit Firms, Tax Consultants, Clearing and Settlement Companies, Legal Practitioners, Trust and Company Service Providers. Estate Surveyors and Valuers, Hotels and Hospitality industry, Dealers and Miners of Precious Stones and Metals, Pool Betting, Casino and Lottery, Supermarkets,Non -Governmental Organizations, Consultants and Consulting companies, Construction Companies, Estate Agents, Dealers in Real Estate, Importers and Dealers in cars and vehicles Dealers in Mechanized farming equipment and machinery. Practitioners of mechanized farming and any other business(es) as may be designated from time to time by the Federal Ministry of Trade and Investment or SCUML
  Que: Who is the appropriate regulatory authority? Ans:Special Control Unit against Money Laundering (SCUML) and Economic Financial Crimes Commission (EFCC) are the regulatory authorities for the implementation of the AML/CFT regime in respect to the DNFI sector in Nigeria.

  Que: Does registration with SCUML attract any fee? Ans:No, the form can be downloaded on the SCUML website.
  Que: What Are Currency Transactions Reports (CTRs)/ Suspicious Transactions Reports (STRs)? Ans:CTRs: Currency Transaction Reports are reports on transactions exceeding the statutory threshold; they are to be submitted within seven days from the date of transaction.
STRs: Suspicious Transaction Reports involve a frequency which is unjustifiable or unreasonable and is surrounded by conditions of unusual or unjustified complexity which appears to have no economic justification or lawful objective.
  Que: What is the reporting threshold? Ans:The reporting threshold is $1000 or its equivalent for all transactions. Que: Can DNFIs send CTRs/STRs reports online? Ans:Yes, CTRs should be submitted in hard copy to any of the SCUML offices or electronically to info@scuml.org.
STR should be sent through the same medium but as soon as possible.
  Que: Does the rendition of statutory reports to SCUML criminalize customers? Ans:No. it is a legal requirement designed to protect legitimate businesses and professions as well as their customers. Que: Who should be a compliance officer and what are the functions of a Compliance Officer? Ans:Compliance officer is an officer at management level who coordinates AML/CFT activities within the DNFI and liaises with SCUML. Que: Should DNFIs Still Report A Suspicious Transaction Whether Or Not They Accept The Transaction From The Client? Ans:Yes, they should report for the protection of their business and sanitization of the industry and economy. Que: What activities of professionals (lawyers, accountants e.t.c.) should be regarded as transactions? Ans:All activities are regarded as transactions, provided it is service rendered and paid for, i.e. currency (cash transactions). It will not be possible to be classified since legal practitioners in Nigeria do not engage in specialized practices. Que: Should transactions be concluded without proper KYC (Know Your Customer) requirements? Ans:No, it is a requirement of the law. Que: Should DNFIs accept cash payment above the statutory threshold? Ans:No, it is illegal. Que: Why has SCUML classified NGOs as DNFI when NGO sector is not covered in the Act? Ans:This is in accordance with the powers conferred on the Minister in charge of commerce to make further designations of DNFIs subject to section 25 of the ML (P) Act 2011. Such designation is usually made where a sector is found to be vulnerable to money laundering.
  Que: Since our grants/donations are released in amounts that do not meet the reporting threshold most often, do we have the obligation to report the cumulative amount of the grant? Ans:Yes, cumulative amount of grant should be reported as soon as the agreement for the funding is signed. Que: NGOs have obligations to report to the National Planning Commission; do they have to report to SCUML? Ans:Yes, for the purpose of anti money laundering and counter-terrorist financing.