Registering with SCUML is the start of a DNFBP's duties, not the end. Reporting certain transactions comes next.
Two different reports, two different triggers
A currency transaction report, or CTR, covers a cash deposit, purchase, sale or payment above a set amount. A currency-based transaction report, or CBTR, covers cash dealings measured in dollar terms rather than naira.
Both exist to flag transactions large enough to matter for anti-money laundering purposes. Neither report accuses the customer of wrongdoing on its own.
The naira thresholds for a CTR
A CTR applies to a transaction above ₦10 million where the customer is a corporate body. For an individual customer, the threshold drops to ₦5 million.
The customer must also be identified before a transaction like this goes ahead, under the Money Laundering (Prevention and Prohibition) Act 2022. A DNFBP that cannot identify who it is dealing with has a bigger problem than a missed report.
The dollar threshold for a CBTR
A CBTR applies to cash dealings more than $1,000 or its equivalent. This sits apart from the naira-based CTR thresholds, and covers cross-border or foreign currency cash movements a DNFBP might handle.
If your business regularly deals in foreign currency cash, both thresholds are worth checking against the same transaction before deciding which report, if any, applies. When a transaction is close to either line, treat it as reportable rather than guessing it falls just under.
Reports now go through the portal only
Until the end of 2025, some DNFBPs filed these reports by email. That changed on 1 Jan 2026. CTRs and CBTRs sent by email stopped being accepted, and every report now goes through scuml.efcc.gov.ng.
A DNFBP without portal log-in details needs to request them from SCUML directly. Waiting until a report is due to sort this out is the wrong time to discover you cannot log in.
What missing a report costs
The 2024 regulations set a ₦100,000 fine for each unreported transaction, with reports due within seven days of completion. That is a per-transaction figure, not a one-off penalty for the year.
Common mistakes
- Confusing the CTR and CBTR thresholds. One is naira-based and varies by customer type; the other is a dollar figure for cash dealings.
- Still trying to email a report. The portal is the only accepted channel since the 2026 change, regardless of what worked in previous years.
- Not requesting portal access early. A business that only discovers it has no log-in when a report is due risks missing the seven-day window.
- Assuming reporting duties end once you have a certificate. Registering with SCUML is the start of these duties, not a one-time box to tick.
Keep reporting deadlines on the compliance calendar alongside your other filings, and see the SME regulators hub for the rest of this series.