CTR Filing Requirements Nigeria — Currency Transaction Report Guide

Legal basis for CTR filing

The Money Laundering (Prevention and Prohibition) Act 2022 (MLPPA) requires all financial institutions to file a Currency Transaction Report with the NFIU when cash transactions meet or exceed the prescribed thresholds. The obligation applies regardless of whether the transaction raises suspicion. Failure to file, late filing, or filing with materially incomplete data is a criminal offence under the MLPPA 2022.

CTRs are submitted through the NFIU's goAML platform. Financial institutions must be registered and active on goAML to meet this obligation.

CTR thresholds

Customer type	Cash transaction threshold	Filing deadline
Individual	NGN 5,000,000 and above (single transaction or series of related transactions)	Within 7 days
Corporate / legal entity	NGN 10,000,000 and above	Within 7 days

The thresholds apply to cash — physical currency received or paid out. They do not apply to electronic transfers, which have separate reporting obligations under the Foreign Transfer Report (FTR) regime if they involve international transactions above USD 10,000.

Structuring — splitting transactions to avoid thresholds

Structuring, also known as smurfing, is the practice of splitting cash transactions into smaller amounts to avoid triggering the CTR threshold. The MLPPA 2022 criminalises structuring. If a financial institution identifies that a customer is conducting multiple smaller cash transactions that together exceed the threshold, or that appear designed to avoid it, an STR must be filed in addition to any applicable CTR. Structuring is explicitly listed as a money laundering indicator in the NFIU's typologies guidance.

Mandatory fields in a CTR

Report type: CTR (individual or corporate, as applicable)
Full customer name as it appears on the verified ID on file
BVN and/or NIN — mandatory for all Nigerian nationals and residents
Account number and bank branch where the transaction occurred
Transaction date in YYYY-MM-DD format
Transaction amount and currency code (NGN as ISO 4217 code)
Transaction type: cash deposit or cash withdrawal
Customer address: full street address, LGA, state, and country
For corporate accounts: registered business name, RC number, and beneficial owner details

CTR vs STR — key differences

Feature	CTR	STR
Trigger	Cash transaction meets or exceeds threshold	Transaction raises suspicion of financial crime
Minimum amount	NGN 5M (individual), NGN 10M (corporate)	None — any amount can trigger an STR
Filing deadline	7 days from transaction date	96 hours from detection of suspicion
Discretion required	No — threshold-based, automatic obligation	Yes — compliance officer judgment required
Can both apply?	Yes — a large cash transaction that also raises suspicion requires both a CTR and an STR

Frequently asked questions

Does the NGN 5 million threshold apply per transaction or per day?

The threshold applies to any single cash transaction or series of related transactions. If a customer makes multiple cash deposits in a single day or across a short period that together exceed NGN 5 million, a CTR is required. Institutions must have systems that aggregate cash transactions to identify when the combined total meets the threshold.

Do electronic transfers trigger a CTR?

No. CTRs apply only to physical cash transactions — currency received or paid out over the counter. Electronic transfers, including NIP, NEFT, and RTGS transactions, are not subject to CTR reporting. International electronic transfers above USD 10,000 are subject to the Foreign Transfer Report (FTR) regime instead.

What happens if a CTR is filed late?

Late CTR filing is a regulatory breach under the MLPPA 2022. The CBN can levy fines on the institution and hold individual compliance officers accountable. The NFIU may flag the institution for examination. Persistent late filing is treated as a systemic compliance failure and attracts enhanced supervisory scrutiny.

Is a CTR required for transactions between financial institutions?

Inter-bank cash transactions are generally not subject to CTR reporting in the same way as retail customer transactions. However, if a customer deposits large amounts of cash at a correspondent bank branch for credit to their account at another institution, the receiving institution has the reporting obligation for the physical cash it received.