FTR Filing Requirements Nigeria — Foreign Transfer Report Guide

Legal basis for FTR filing

The Money Laundering (Prevention and Prohibition) Act 2022 (MLPPA) requires all financial institutions to report international transfers that meet or exceed the prescribed threshold to the NFIU. The FTR obligation is separate from both the STR and CTR regimes. It captures international capital flows that may not involve cash and may not raise immediate suspicion, but which represent a risk vector for money laundering through cross-border layering.

All FTRs are submitted through the NFIU's goAML platform. The obligation applies to all CBN-licensed institutions that process international payments, including commercial banks, microfinance banks, licensed international money transfer operators (IMTOs), and payment service providers handling cross-border transactions.

FTR threshold and scope

Transfer direction	Threshold	Filing deadline
Outbound (Nigeria to foreign country)	USD 10,000 or equivalent in any currency	24 hours from transaction date
Inbound (foreign country to Nigeria)	USD 10,000 or equivalent in any currency	24 hours from transaction date

The USD 10,000 threshold applies to the USD equivalent of the transfer amount, regardless of the transaction currency. An institution must maintain current exchange rates for converting non-USD amounts to determine whether a transaction meets the threshold. The threshold is not indexed to inflation and applies per transaction — it does not aggregate multiple transactions.

Who has the FTR obligation

For outbound transfers, the obligation rests with the sending institution in Nigeria. For inbound transfers, the obligation rests with the Nigerian institution that receives and credits the funds to a customer account. In correspondent banking arrangements where a Nigerian bank processes the payment on behalf of a foreign institution, the Nigerian bank has the reporting obligation for its role in the transaction chain.

Mandatory fields in an FTR

Report type: FTR — outbound or inbound as applicable
Sending institution and receiving institution, including SWIFT/BIC codes where applicable
Originating party: full name, BVN/NIN (for Nigerian nationals), nationality, full address
Beneficiary party: full name, nationality, country, and account details
Transaction date in YYYY-MM-DD format
Transaction amount and ISO 4217 currency code (e.g. USD, GBP, EUR, NGN)
Purpose of transfer, as declared by the originating customer
Correspondent bank details if applicable

FTR and STR — when both apply

An international transfer that meets the FTR threshold and also raises suspicion requires both an FTR and an STR to be filed. The FTR satisfies the mandatory threshold-reporting obligation. The STR separately captures the suspicion. Filing one does not discharge the obligation to file the other. In practice, the FTR should be filed within its 24-hour window even while the STR investigation is still in progress — do not wait for the STR to be complete before filing the FTR.

Frequently asked questions

Does the FTR apply to diaspora remittances received in Nigeria?

Yes. Inbound remittances from overseas that meet or exceed the USD 10,000 equivalent threshold require an FTR. This applies regardless of whether the remittance is for personal, business, or investment purposes. IMTOs and banks processing diaspora inflows must have systems to identify qualifying remittances and file FTRs within 24 hours.

What exchange rate should be used to determine the FTR threshold?

Institutions should use the CBN official exchange rate applicable on the date of the transaction to determine whether a non-USD transfer meets the USD 10,000 equivalent threshold. The rate used should be documented in the institution's records. The FTR itself must also record the original transaction currency and amount alongside the USD equivalent.

Does the FTR obligation apply to fintechs and payment service providers?

Yes. Any CBN-licensed institution that processes international transfers is subject to the FTR obligation. This includes fintechs and PSPs that have obtained licences for cross-border payment services. Given the 24-hour filing window and the potential volume of qualifying transactions, fintechs handling international payments need automated FTR identification and submission processes from the outset.