Currency Transaction Reports (CTR) in Nigeria: Thresholds, Requirements, and How to File

If your financial institution handles large cash transactions in Nigeria, understanding currency transaction report requirements is essential for meeting applicable anti-money laundering and regulatory reporting obligations.

A currency transaction report in nigeria is a threshold-based regulatory report used to notify the Nigerian Financial Intelligence Unit (NFIU) of qualifying transactions. The NFIU currently states that CTRs apply to domestic transactions of ₦5 million and above for individuals and ₦10 million and above for corporate entities. It also identifies certain transfers or receipts involving foreign countries of $10,000 or more, or the equivalent, as reportable.

For financial institutions, understanding the ctr threshold nigeria, reporting timelines, required information and filing platforms is therefore an important part of an effective compliance programme.

What Is a Currency Transaction Report in Nigeria?

A currency transaction report is a regulatory report submitted to the NFIU when a transaction meets the applicable reporting threshold.

In simple terms, a currency transaction report in nigeria provides regulators with information about qualifying transactions, allowing financial intelligence authorities to receive and analyse threshold-based financial disclosures.

The NFIU lists Currency Transaction Reports among the report types that can be filed through its reporting systems. Its current FAQ states that CTRs cover domestic transactions of ₦5 million and above for individuals and ₦10 million and above for corporate entities.

The NFIU CTR process forms part of Nigeria's AML/CFT reporting framework. A CTR does not, by itself, mean that a transaction is suspicious. It is primarily triggered by the applicable reporting threshold.

If a transaction that has already been reported as a CTR is subsequently identified as suspicious, the NFIU states that an STR should also be filed.

READ ALSO: Suspicious Transaction Reports in Nigeria: When and How to File.

What Is the CTR Threshold in Nigeria?

The ctr threshold nigeria for domestic transactions is:

For CBN-regulated Other Financial Institutions (OFIs), the CBN guidance requires qualifying cash transactions of ₦5 million and above for individuals and ₦10 million and above for corporate bodies to be reported to the NFIU. The guidance covers cash deposits, withdrawals, exchanges and other cash payments or transfers.

The NFIU also identifies a separate reporting requirement for certain international transactions. A person or business that transfers or receives funds or securities from a foreign country amounting to $10,000 or more, or the equivalent in another currency, is required to report the transaction. 

Therefore, when assessing a potential currency transaction report, compliance teams should consider:

1. The type of transaction.

2. Whether it falls within the applicable reporting scope.

3. Whether the customer is an individual or corporate entity.

4. Whether the transaction meets the applicable ctr threshold nigeria.

5. Whether another reporting obligation also applies.

The CTR threshold should not be confused with the threshold for an STR. The NFIU states that STRs are not threshold-based and must be filed for suspicious transactions regardless of value. 

What transactions are covered by a CTR?

A currency transaction report in nigeria can cover qualifying cash transactions including:

• Cash deposits

• Cash withdrawals

• Cash exchanges

• Cash payments

• Cash transfers

• Other qualifying cash transactions covered by the applicable requirements

The CBN's guidance specifically states that all types of currency transactions within its scope are to be reported and that there are no exempt persons. 

The important distinction is that a CTR is threshold-based. A transaction does not have to be suspicious before it becomes reportable as a CTR.

When Should a Currency Transaction Report Be Filed in Nigeria?

For CBN-regulated OFIs, the CBN guidance states that a completed currency transaction report should be submitted to the NFIU within seven days after the date of the transaction.

The NFIU's 2023 Annual Report also states that financial institutions are required to report transactions above ₦5 million for individuals and ₦10 million for legal persons to the NFIU within seven days. 

This means institutions should identify reportable transactions promptly, validate the relevant information and complete the filing within the applicable reporting period.

For CTR reporting Nigeria, having a defined internal workflow is important because delays can occur when transaction data, customer information and compliance review are handled across separate systems.

The CBN guidance also provides for the retention of CTR records for five years in the circumstances specified by the guidance. 

What Are the Compulsory or Important Fields in a CTR?

Accurate information is central to NFIU CTR reporting. A report needs enough information for the NFIU to understand the reporting institution, the parties involved and the transaction being reported.

The NFIU's reporting specifications include information such as:

• Report information

• Reporting entity details

• Transaction date and amount

• Transaction type

• Parties involved

• Source and destination of funds

• Customer or subject information

• Other information required by the applicable reporting schema

The NFIU's XML reporting documentation provides the technical structure for these submissions, while its current goAML Enumeration Reference provides the controlled values used for fields in CTR, FTR, STR and other XML reports.

The current NFIU enumeration reference specifically identifies CTR as a report code within the goAML XML schema. 

For CTR filing requirements Nigeria, institutions should therefore work from the current NFIU schema and reporting documentation rather than relying on an old CTR form or internally created checklist.

What Platforms Do Financial Institutions Use to File CTRs?

Financial institutions use NFIU reporting platforms to submit applicable regulatory reports.

1. goAML

goAML is the main web-based reporting platform used by relevant reporting entities. The NFIU's goAML portal requires an organisation to register as a reporting entity before it can access the system. 

The NFIU also provides resources for XML reporting, including a goAML schema guide, lookup master, web guide and XML validator. 

The NFIU's video resources also specifically include guides for filing STRs and CTRs, filing web reports and filing reports through XML upload. 

For NFIU CTR reporting, institutions can therefore use the applicable goAML web reporting workflow or structured XML reporting, depending on their reporting setup.

2. RapidAML

RapidAML is a separate NFIU reporting portal developed to complement goAML. The NFIU states that it provides additional reporting features for DNFBPs, BDCs and NPOs. 

The NFIU specifically states that BDCs use RapidAML to file STRs, CTRs, Nil Reports and PEP reports, while CBN-regulated entities excluding BDCs use it for specified Nil and PEP reports.

This distinction is important for CTR reporting in Nigeria because the appropriate filing platform depends on the reporting entity and report type.

INTERESTING READ: Transaction Monitoring for Nigerian Banks and Fintechs (CBN Requirements)

How to File a Currency Transaction Report in Nigeria

The practical process for currency transaction report in nigeria filing can be broken into five steps.

1. Identify the reportable transaction

Determine whether the transaction falls within the applicable reporting scope and meets the relevant ctr threshold in Nigeria.

2. Verify the transaction and customer information

Check the customer's identity, account information, transaction amount, date, currency and other relevant information required by the applicable NFIU reporting schema.

3. Prepare the report

Prepare the currency transaction report through the appropriate NFIU reporting workflow, such as goAML web reporting or XML reporting where applicable.

4. Review the report

The compliance team should review the information for accuracy and completeness before submission.

5. Submit and retain the record

Submit the report through the applicable NFIU platform within the required timeframe and retain the relevant records.

The NFIU's goAML guidance and filing resources provide specific instructions for web and XML reporting.

This makes CTR filing requirements in Nigeria more than simply submitting a form. The process covers identification, data validation, preparation, review, submission and recordkeeping.

How Does CTR Reporting Relate to AML Regulations in Nigeria?

CTR reporting is one component of Nigeria's broader anti-money laundering and counter-terrorist financing framework.

The NFIU states that its mandate is established under the NFIU Act 2018, with its mandate further outlined under the Money Laundering (Prevention and Prohibition) Act 2022 and Terrorism (Prevention and Prohibition) Act 2022.

Financial institutions also have obligations relating to customer due diligence, suspicious transaction reporting, recordkeeping, transaction monitoring and other AML/CFT controls.

Understanding NFIU CTR reporting therefore requires looking at how threshold-based reporting fits into the institution's wider AML programme.

For a broader overview of the regulatory framework, 

See our guide to AML Regulations in Nigeria.

The distinction between CTR and STR is particularly important:
 

The NFIU confirms that where a transaction is reported as a CTR and later identified as suspicious, both reports are required. 

For institutions developing CTR filing requirements in Nigeria, this means threshold reporting should work alongside, rather than replace, broader AML monitoring and investigation processes.

What Are the CTR Filing Requirements Nigerian Financial Institutions Should Have in Place?

Effective CTR filing requirements in Nigeria should cover the full reporting process, including:

• Identifying transactions that meet applicable thresholds

• Maintaining accurate customer and transaction data

• Applying the correct customer classification

• Preparing reports using the required NFIU format

• Reviewing reports before submission

• Meeting applicable deadlines

• Monitoring submission status

• Correcting rejected or invalid reports

• Maintaining appropriate records

For institutions processing large transaction volumes, these activities can become difficult to manage manually.

A structured regulatory reporting workflow can help compliance teams identify reportable transactions, collect the relevant information and manage reviews before submission.

How Youverify Helps Financial Institutions With CTR Reporting

Managing currency transaction report obligations becomes more complex when transaction data, customer information and regulatory reporting workflows are spread across different systems.

Youverify brings these processes together, helping compliance teams identify relevant activity, organise the supporting information and streamline regulatory reporting from one workflow.

With Youverify's Regulatory Reporting solution, teams can reduce manual work around report preparation while keeping compliance professionals in control of review, validation and submission.

Vyra AI adds an intelligent layer to this workflow by helping compliance teams analyse alerts, surface relevant information and prepare case-ready investigations with the context needed for review. Instead of spending time gathering information across multiple systems, compliance officers can focus on assessing the case, making decisions and taking the appropriate regulatory action.

For institutions looking to make CTR reporting Nigeria more efficient, this means moving from identifying reportable activity to preparing the relevant information and cases with less manual effort.

Ready to simplify your regulatory reporting workflow? Speak with our compliance experts to see how Youverify can support your team.