Currency Transaction Reports in Nigeria: The ₦5m and ₦10m Rule, Cash Limits and Foreign Transfers (2026)
Short answer: Under section 11 of the Money Laundering (Prevention and Prohibition) Act, 2022 (MLPPA), a financial institution reports to the Nigerian Financial Intelligence Unit (NFIU), and a designated non-financial business or profession (DNFBP) to the Special Control Unit Against Money Laundering (SCUML), in writing within seven days, any single transaction, lodgment or transfer of funds above ₦5,000,000 for an individual or ₦10,000,000 for a body corporate. Separately, nobody may make or accept a cash payment above those amounts except through a financial institution (section 2), and transfers to or from a foreign country above US$10,000 are reported within one day (section 3). For software that detects these transactions and files them, see goAML reporting software for Nigeria.
This guide is for compliance officers and operations teams at Nigerian banks, microfinance banks, payment service providers, bureaux de change, insurers, capital-market operators and DNFBPs. It is a practical guide to the Act, not legal advice.
The currency transaction report (section 11)
| Question | The answer in the Act |
|---|---|
| What is reported? | Any single transaction, lodgment or transfer of funds above the threshold, "or its equivalent" in another currency |
| Threshold | ₦5,000,000 for an individual; ₦10,000,000 for a body corporate |
| Who reports, and to whom? | Financial institutions to the NFIU; DNFBPs to SCUML |
| Deadline | In writing within seven days |
| Penalty | A fine of at least ₦250,000 and not more than ₦1,000,000 for each day the contravention continues (section 11(3)) |
Two operational points follow. The threshold depends on the customer type, so every customer record must say reliably whether the customer is a natural person or a body corporate; a misclassified company is reported against the wrong line. And the Act's words cover transfers and lodgments as well as cash withdrawals and deposits, so the rule belongs in the system that sees every channel, not in a teller's checklist.
A person other than a financial institution may also report voluntarily any transaction above ₦1,000,000 for an individual or ₦5,000,000 for a body corporate (section 11(2)).
Where the report goes
Financial institutions file on the NFIU's goAML portal. Bureaux de change file their currency transaction reports on the NFIU's RapidAML portal, and DNFBPs report to SCUML. Our NFIU goAML registration guide explains which portal each institution uses.
The cash payment limit (section 2)
No person or body corporate may make or accept a cash payment above ₦5,000,000 (individual) or ₦10,000,000 (body corporate) except in a transaction through a financial institution (section 2(1)). Making or accepting a cash payment above the authorised amount is an offence (section 19(1)).
The same section prohibits structuring: a person may not conduct two or more transactions separately, with one or more financial institutions or DNFBPs, to avoid a reporting duty (section 2(2)). A customer who deposits ₦4.9 million on three consecutive days is therefore a monitoring question, and possibly a suspicious transaction report within 24 hours under section 7. See our NFIU STR guide.
Foreign transfers above US$10,000 (section 3)
A transfer to or from a foreign country of funds or securities by a person or body corporate, including a money service business, of more than US$10,000 or its equivalent "shall be reported to the Unit, Central Bank of Nigeria and Securities and Exchange Commission in writing within one day from the date of the transaction" (section 3(1)). The report states the nature and amount of the transfer and the names and addresses of the sender and the receiver (section 3(2)). Failing to report an international transfer is an offence (section 19(1)).
Cash or negotiable instruments above US$10,000 carried into or out of Nigeria by an individual are declared to the Nigeria Customs Service, which reports the declarations to the Central Bank and the NFIU (section 3(3)–(4)).
DNFBPs and casinos
A DNFBP whose business involves cash identifies the customer before any transaction above US$1,000, using a standard data form and photo identification, and records transactions in a numbered register for SCUML, kept for at least five years (section 6). Failing to identify customers or submit returns within seven days of the transaction carries ₦250,000 for each day and possible suspension or loss of licence. Casinos, including internet and ship-based casinos, verify customers' identity and keep a chronological register of transactions for SCUML (section 5). See AML compliance for betting companies and casinos in Nigeria.
Getting the data right
- Customer type. The ₦5 million and ₦10 million lines follow the customer type, so the natural-person and body-corporate flag must be complete and correct.
- Currency conversion. "Or its equivalent" means foreign-currency transactions are tested against the naira lines, and foreign transfers against US$10,000, at a documented rate.
- Linked transactions. The Act prohibits splitting transactions to avoid a report. Monitor for deposits and withdrawals kept just under the lines.
- Identifiers. Carry the Bank Verification Number and National Identification Number for individuals, and registration details for companies, into every report.
- Records. Keep transaction records for at least five years after completion (section 8).
Checklist
- Flag every customer as an individual or a body corporate.
- Detect transactions, lodgments and transfers above ₦5 million or ₦10 million, in any channel and currency.
- File within seven days: to the NFIU on goAML (or RapidAML for bureaux de change), or to SCUML for DNFBPs.
- Report foreign transfers above US$10,000 within one day to the NFIU, the CBN and the SEC.
- Refuse cash payments above the section 2 limits outside a financial institution.
- Monitor for structuring, and consider an STR when you find it.
- Keep records for at least five years.
Frequently asked questions
What is the currency transaction report threshold in Nigeria?
Any single transaction, lodgment or transfer of funds above ₦5,000,000 for an individual or ₦10,000,000 for a body corporate, or the equivalent in another currency, under section 11 of the MLPPA 2022.
When must a currency transaction report be filed in Nigeria?
In writing within seven days: financial institutions report to the NFIU, and DNFBPs to SCUML.
What is the cash limit in Nigeria?
Cash payments above ₦5,000,000 for an individual or ₦10,000,000 for a body corporate may only be made or accepted through a financial institution (section 2 of the MLPPA 2022).
Are foreign transfers reported in Nigeria?
Yes. Transfers to or from a foreign country of funds or securities above US$10,000 or its equivalent are reported in writing within one day to the NFIU, the Central Bank of Nigeria and the Securities and Exchange Commission (section 3).
What is the penalty for not filing a currency transaction report?
A fine of at least ₦250,000 and not more than ₦1,000,000 for each day the contravention continues (section 11(3)).
Currency transaction reporting with Creodata
Creodata's goAML Reporting Platform detects transactions above the ₦5 million and ₦10 million lines and assembles them for filing within the seven-day window, so the thresholds are never checked by eye in a spreadsheet. It generates schema-valid goAML XML, validates every report against the schema and business rules before upload, and keeps an immutable record of every filing. See goAML reporting software for Nigeria, our Nigeria NFIU goAML reporting guide, and AML compliance software in Nigeria for the monitoring that catches structuring.
See it on your own report types — request a demo.