AML Compliance for Betting Companies and Casinos in Nigeria: SCUML, STRs and the ₦5m/₦10m Rules (2026)
What Nigerian pools betting companies, online and land-based casinos must do under the MLPPA 2022: SCUML registration and supervision, the casino transaction register, 24-hour STRs, ₦5m and ₦10m reports, PEPs, sanctions and five-year records.
Short answer: Pools betting companies and casinos, including internet casinos, are designated non-financial businesses and professions (DNFBPs) under Nigeria's Money Laundering (Prevention and Prohibition) Act, 2022 (MLPPA). They register with and are supervised by the Special Control Unit Against Money Laundering (SCUML), a department of the EFCC. Casinos must identify customers and keep a register of all transactions for SCUML; every DNFBP reports suspicious transactions within 24 hours and single transactions above ₦5 million (individuals) or ₦10 million (companies) to SCUML within seven days, and keeps records for at least five years.
This guide is for compliance officers and managers at Nigerian sports-betting and pools operators, online and land-based casinos and gaming firms. It is a practical guide, not legal advice: check the Act, SCUML's regulations and your licensing authority's rules.
Why betting and casinos are covered
The MLPPA's definition of DNFBPs names casinos and pools betting, alongside dealers, real estate firms, lawyers, accountants and other businesses. For the Act's casino duties, "casino" includes internet casinos and ship-based casinos (section 5(3)), so online operators cannot treat the rules as written for land-based halls only.
SCUML registers, certifies, monitors and supervises DNFBPs (section 17). A DNFBP whose business involves cash must also submit a declaration of its activities to SCUML, before it starts business if it is new (section 6).
The duties, in order
| Duty | What the Act requires | Section |
|---|---|---|
| Register with SCUML | Registration and certification by SCUML; a declaration of activities for cash-based businesses | 17, 6 |
| Identify customers | Casinos verify the identity of customers carrying out financial transactions, from a valid original document with name and address; cash-based DNFBPs identify customers before any transaction above US$1,000 | 5, 6 |
| Keep a transaction register | Casinos record all such transactions in chronological order, with the nature and amount and each customer's name and address, in a register forwarded to SCUML and kept for at least five years after the last entry | 5 |
| Report suspicious transactions | Immediately, and within 24 hours after the transaction, whatever the amount and whether or not it was completed | 7 |
| Report large transactions | Single transactions, lodgments or transfers above ₦5 million (individuals) or ₦10 million (companies), to SCUML in writing within seven days | 11 |
| Keep records | At least five years after the transaction, and five years after the end of the relationship for due-diligence records | 8 |
A DNFBP that fails to identify customers or submit returns within seven days of the transaction commits an offence: a fine of ₦250,000 for each day the offence continues, and suspension, revocation or withdrawal of its licence (section 6(3)).
Where reports go
For DNFBPs the routes differ from banks':
- Currency transaction reports go to SCUML, not the NFIU (section 11).
- Suspicious transaction reports go to the NFIU. The NFIU's RapidAML portal, which complements goAML, is the channel it names for STRs from SCUML-supervised DNFBPs, and it also handles nil reports and PEP reports.
Check your registration covers both, and that your staff know which report goes where.
PEPs, sanctions and structuring
- Politically exposed persons: for a foreign PEP, senior-management approval, source-of-wealth and source-of-funds checks and enhanced ongoing monitoring; the same for domestic PEPs where the relationship is higher risk (section 4).
- Sanctions: screen customers against UN lists and the Nigeria Sanctions List published by the Nigeria Sanctions Committee (NIGSAC).
- Structuring: splitting transactions to avoid a reporting duty is prohibited (section 2(2)), and cash payments above ₦5 million (individuals) or ₦10 million (companies) may only go through a financial institution (section 2(1)). Watch for players who fund accounts in amounts that stay just under the lines, or through many accounts.
A compliance checklist for betting and casino operators
- Registered and certified with SCUML, with a declaration of activities on file
- Customer identification at onboarding, and before any transaction above US$1,000 for cash-based products
- A chronological transaction register for SCUML (casinos), kept at least five years
- STRs within 24 hours, whatever the amount, filed through the NFIU's channel for DNFBPs
- Transactions above ₦5 million (individuals) or ₦10 million (companies) reported to SCUML within seven days
- PEP checks and screening against the Nigeria Sanctions List
- Monitoring for deposits and withdrawals split to stay under the reporting lines
- Records kept for at least five years
How software helps
A betting or casino operator handles high volumes of small, fast transactions across online wallets, agents and shops, so the controls have to run automatically: screening at onboarding, risk ratings that change with behaviour, monitoring rules for structuring and unusual deposit-and-withdraw patterns, and cases that reach a report inside 24 hours. Creodata's AML compliance software in Nigeria covers screening, customer risk rating, transaction monitoring and case management, and our transaction monitoring runs on streaming data as well as batches. For choosing a system, see our buyer's guide to AML software in Nigeria.
Frequently asked questions
Do betting companies in Nigeria need to register with SCUML?
Yes. Pools betting and casinos are DNFBPs under the MLPPA 2022, and SCUML registers, certifies and supervises DNFBPs. A business that deals in cash must also file a declaration of its activities with SCUML.
Are online casinos covered?
Yes. For the Act's casino duties, a casino includes internet casinos and ship-based casinos (section 5(3)).
What must a betting company report, and to whom?
Suspicious transactions, within 24 hours and whatever the amount, to the NFIU; and single transactions above ₦5 million for an individual or ₦10 million for a company to SCUML within seven days.
What happens if a DNFBP does not identify customers or file returns?
A DNFBP that fails to identify customers or submit returns within seven days of the transaction commits an offence, with a fine of ₦250,000 for each day it continues and suspension, revocation or withdrawal of its licence (section 6(3) of the MLPPA 2022).
See how Creodata's AML compliance software in Nigeria handles screening, monitoring and reporting: book a demo.
