goAML submission windows — filing deadlines for Nigerian institutions

Submission deadlines at a glance

When the STR clock starts

The 96-hour STR window begins from the point at which the compliance function detects or identifies suspicious activity — not from when the transaction occurred. This is an important distinction. A transaction may have occurred days or weeks earlier. The submission clock starts when the institution, through its transaction monitoring or case management process, identifies that a transaction gives rise to reasonable suspicion.

Internal escalation steps — such as obtaining senior officer approval before filing — do not pause the clock. Institutions must ensure their internal escalation procedures can be completed well within the 96-hour window, not at the end of it.

When the CTR clock starts

The 7-day CTR window runs from the date of the transaction. It does not depend on any internal escalation or decision — the obligation is automatic once the cash threshold is met. Institutions must have systems that identify threshold-crossing transactions promptly so that the 7 days are not consumed by delayed internal identification. A batch process that identifies CTR-eligible transactions once per week will routinely miss the deadline for transactions that occur early in that window.

When the FTR clock starts

The 1-day FTR window is the tightest of the three. It starts from the date of the international transfer. Given that FTR is a volume-based, non-discretionary report (like CTR), institutions with significant international payment volumes need automated FTR identification and submission processes. Manual FTR filing at this turnaround is not viable for any institution with more than a handful of qualifying transactions per day.

The correction window

When the NFIU rejects a report, a 24-hour correction window opens from the time the rejection notice is issued. This window applies to all three report types. The institution must correct the identified errors and resubmit the report under the original reference number within this 24-hour period. The correction window does not extend the original submission window — if a report is rejected after the original deadline has already passed, the correction still creates a late-filing record.

Consequences of missing a window

• Late STR filing is a criminal offence under the MLPPA 2022 — it is not merely a regulatory breach
• The CBN records late filing patterns during on-site AML examinations
• Persistent late filing is treated as evidence of a systemic compliance programme failure
• Late CTR filings may indicate a failure to monitor transactions in near-real time
• Missed FTR windows can trigger enhanced scrutiny of the institution's international payments controls
• Individual compliance officers carry personal regulatory exposure under the CBN's 2026 circular