How to File a Currency Transaction Report (CTR) in Nigeria

In Nigeria, financial institutions (FIs) and designated non financial professions and businesses (DNFPBs) are legally required to file Currency Transaction Reports (CTRs) for cash transactions exceeding N5 million for individuals and N10 million for corporate entities. This obligation is set out in Section 11 of the Money Laundering (Prevention and Prohibition) Act 2022 and is part of the country’s broader efforts to combat money laundering, terrorist financing, and other financial crimes.

Failure to comply can result in regulatory penalties, reputational damage, and potential criminal liability. However, many compliance teams struggle with manual reporting processes, data formatting requirements, and ensuring accuracy in submissions.

This article provides a step-by-step guide on how to file a CTR in Nigeria.

What is a Currency Transaction Report (CTR)?

A Currency Transaction Report (CTR) is a mandatory regulatory filing that notifies the NFIU of large cash transactions above a specific threshold. These reports help the government track suspicious activities and deter illicit financial flows.

Who Needs to File a CTR?

• Financial Institutions

Financial Institutions (FIs) include banks, microfinance banks, payment service providers, insurance companies, capital market operators, and other entities that handle financial transactions. They are strictly regulated by bodies like the Central Bank of Nigeria (CBN), the Nigerian Financial Intelligence Unit (NFIU), and the Securities and Exchange Commission (SEC) to ensure compliance with AML/CFT regulations. 

• Designated Non Finnacial Professions and Bs

Designated Non-Financial Businesses and Professions (DNFBPs)  encompass businesses and professions that are vulnerable to financial crimes but are not traditional financial institutions. These include law firms, real estate agents, casinos, luxury goods dealers, trust and company service providers, and accountants, among others. The Special Control Unit Against Money Laundering (SCUML), under the Economic and Financial Crimes Commission (EFCC), is responsible for overseeing their compliance with AML/CFT obligations in Nigeria.

How to submit a Currency Transaction Report (CTR)

The Nigerian Financial Intelligence Unit (NFIU) serves as Nigeria's central agency for collecting and analysing financial data. It is responsible for generating and disseminating actionable intelligence to combat money laundering, terrorism financing, and the proliferation of illicit activities. It is also responsible for receiving CTRs through its GoAML Reporting and RapidAML reporting platforms.

FIs are required to submit their CTRs through the GoAML platform, while the RapidAML platform is for the following CTR submissions: Bureau De Change (BDCs), Designated Non-Financial Businesses and Professions (DNFBPs), and Non-Profit Organizations (NPOs).

This guide outlines the step-by-step process for FIs to submit a CTR on the goAML Web portal, based on the official user guide. 

Step 1: Register and Log In to the goAML Portal

A. Register for Access

Before submitting a CTR, the Nigerian financial institution must be registered on the goAML Web portal. The registration process includes:

1. Navigating to the goAML Web portal (https://goaml.nfiu.gov.ng)

2. Selecting “Register” on the homepage

3. Choosing the registration type (Individual User or Reporting Entity)

4. Completing the registration form, including:

   • Organization details (for reporting entities)

   • Personal details (for individual users)

   • Contact information and reporting obligations

5. Submitting the registration request

6. Receiving approval from the NFIU, after verification

B. Logging In to goAML

Once registered, users can log in by:

1. Clicking on “Login” on the goAML homepage

2. Entering their credentials (Username & Password)

3. Completing the CAPTCHA verification

4. Clicking “Login” to access the portal

Step 2: Preparing the CTR for Submission

There are two ways to submit a CTR:

1. Uploading an XML report file (automated, for institutions with AML software)

2. Manually entering the report via the Web Report form

A. Uploading an XML Report File

If the Nigerian financial institution has AML software that generates reports in the NFIU-compliant XML format, follow these steps:

1. Go to New Reports > XML Upload

2. Click “Browse” and select the XML file (the file size must be less than 10MB)

3. Click “Upload” to submit the report

4. Check the XML Upload List to confirm submission status

Common Issues faced:

• Failed uploads: Errors may be due to incorrect XML formatting

• Validation errors: Reports may require corrections before acceptance

B. Manually Creating a Web Report (Without XML)

For institutions that don’t use automated AML software, reports can be manually created:

1. Go to New Reports > Web Reports

2. Select “CTR” from the Report Type dropdown

3. Fill out the required information:

   • Transaction details: Amount, date, currency, transaction mode

   • Involved parties: Sender, receiver, financial institutions

   • Customer details: Name, ID, address, nationality

4. Click “Save Report” before proceeding

5. Attach supporting documents, if required

6. Review all entered data for accuracy

7. Click “Submit Report” to finalize the submission

Step 3: Tracking and Managing Submitted Reports

Once a CTR has been submitted, compliance officers should monitor the report status in the Submitted Reports section.

A. Checking Submitted Reports

1. Go to Submitted Reports > Web Reports

2. Apply filters to track specific reports:

   • Date range

   • Report type

   • Submission status

3. Review status updates:

   • Accepted: Successfully processed

   • Failed Validation: Requires corrections

   • Rejected: Not approved due to missing/inaccurate information

B. Correcting and Resubmitting Reports

1. Identify rejected or failed reports

2. Edit the report to correct errors

3. Re-upload (for XML) or update details (for Web reports)

4. Re-submit the report

Penalties for Non-Submission of Currency Transaction Reports in Nigeria

Failure to submit Currency Transaction Reports (CTRs) to the Nigerian Financial Intelligence Unit (NFIU) within the required timeframe attracts significant financial penalties for responsible officers and institutions. These penalties vary depending on the type of financial institution and the officer responsible.

1. Deposit Money Banks (DMBs)

• Executive Compliance Officer (ECO): N1.25 million

• Chief Compliance Officer (CCO): N1 million

• DMB (Institution): N15 million

2. Payment Service Banks (PSBs)

• CCO: N500,000

• PSB (Institution): N10 million

3. Bureau De Change (BDC)

• CCO: N100,000

• BDC (Institution): N1 million

4. Microfinance Banks (MFBs)

• CCO: N100,000

• OFI (Institution) Penalties Based on Tier:

  • Tier 1 Unit MFB: N500,000

  • Tier 2 Unit MFB: N300,000

  • State MFB: N1 million

  • National MFB: N2 million

5. Finance Company (FC)

• CCO: N200,000

• FC (Institution): N1 million

6. Primary Mortgage Banks (PMBs)

• CCO: N500,000

• OFI (Institution) Penalties Based on Tier:

  • State PMB: N2 million

  • National PMB: N5 million

7. Development Finance Institutions (DFIs)

• CCO: N1 million

• Institutional Penalties:

  • Regional DFI (RDFI): N5 million

  • Wholesale DFI (WDFI): N10 million

8. Mobile Money Operator (MMO)

• CCO: N500,000

• MMO (Institution): N5million

9. Payment Solution Service Providers (PSSPs)

• CCO: N500,000

• PSSP (Institution): N5 million

10. Switching and Processing Provider (SP)

• CCO: Between N300,000

• SP (Institution): N2 million

11. Super Agent (SA)

• CCO: N500,000

• SA (Institution): N3 million

How Regfyl Can Help Institutions Avoid CTR Penalties

Regfyl provides an automated regulatory reporting solution that ensures financial institutions remain compliant with NFIU reporting requirements.

Key Benefits:

• Real-time transaction monitoring to automatically detect reportable transactions

• Automated CTR generation, eliminating manual data entry

• Error-free XML reports, ensuring compliance with NFIU requirements

• Dashboard tracking, providing instant status updates

• Audit-Ready Documentation – Stores records for regulatory review

With Regfyl, compliance teams can save time and reduce errors, ensure full regulatory compliance, and avoid costly regulatory fines and penalties.

Interested in streamlining your CTR filing? Schedule a no obligation discovery call with Regfyl today.