Legal basis for STR filing
Section 6 of the Money Laundering (Prevention and Prohibition) Act 2022 (MLPPA) requires all financial institutions to file an STR with the NFIU within 24 hours of a transaction giving rise to suspicion. The NFIU receives STRs through the goAML platform. Failure to file, late filing, or filing with materially incomplete data is a criminal offence under the MLPPA 2022.
What triggers an STR?
An STR must be filed when a transaction, attempted transaction, or pattern of transactions raises reasonable suspicion of money laundering, terrorism financing, or proliferation financing. There is no minimum transaction amount. Common triggers include:
- Transactions inconsistent with a customer's known business or profile
- Structuring — splitting transactions to stay below CTR thresholds (NGN 5M for individuals)
- Rapid movement of funds through multiple accounts with no apparent business purpose
- Customers who are reluctant to provide identification or beneficial ownership information
- Transactions involving parties on sanctions lists or known PEPs without adequate justification
- Large cash deposits followed immediately by international wire transfers
- Transactions linked to geographic areas or sectors flagged as high risk by the NFIU
STR report categories on goAML
As of the February 2026 goAML platform upgrade, STRs are filed under six specific categories rather than a single general type. Selecting the wrong category is one of the most common reasons for rejection:
| STR category | When to use |
|---|
| STR — Terrorism Financing | Suspicion of financing terrorist activities or organisations |
| STR — Kidnapping for Ransom | Transactions linked to kidnapping or ransom payments |
| STR — Corruption | Suspicion of public corruption or bribery |
| STR — Fraud | Fraud-related suspicious activity |
| STR — Drug Trafficking | Transactions linked to narcotics |
| STR — General | Residual category — only use when no specific category applies |
Mandatory fields in an STR
- Report type (correct STR category — not STR General if a specific category applies)
- At least one predicate offense from the NFIU's 21 defined categories
- At least one indicator linked to the selected predicate offense
- Complete party data: full name, BVN or NIN, nationality, full address (street, LGA, state, country)
- Transaction data: amount, date in YYYY-MM-DD format, currency as ISO 4217 code (NGN, USD)
- Narrative describing the basis for suspicion
Filing deadlines and the correction window
STRs must be filed within 96 hours of detecting suspicious activity. The clock starts from detection — not from when the case is closed or internally approved. If the NFIU rejects the STR, a 24-hour correction window opens. The STR must be corrected and resubmitted using the same reference number within this window. Missing the correction window means the filing must be escalated as a fresh report.
Frequently asked questions
What is the difference between an STR and a CTR in Nigeria?
An STR (Suspicious Transaction Report) is filed when a transaction raises suspicion of financial crime. There is no minimum amount. A CTR (Currency Transaction Report) is filed automatically when cash transactions exceed NGN 5 million for individuals or NGN 10 million for corporates. CTRs are threshold-based and mandatory — STRs are suspicion-based and judgment-driven.
Can an STR be filed for a transaction that was not completed?
Yes. The MLPPA 2022 requires reporting of both completed and attempted transactions that raise suspicion. An attempted transaction that a customer abandoned after being asked for identification, for example, must be reported if it raised suspicion of financial crime.
What happens after an STR is filed with the NFIU?
The NFIU analyses the STR and may request additional information from the reporting institution. If the analysis indicates criminal activity, the NFIU may refer the case to the EFCC, ICPC, or other law enforcement bodies for investigation. The reporting institution is not notified of the outcome of the investigation.
What are the most common reasons NFIU rejects an STR?
The most common rejection reasons are: selecting the wrong report type (STR General instead of a specific category), missing or incorrect predicate offense, incomplete party data (missing BVN, NIN, or full address), transaction data formatting errors (wrong date format or currency code), and filing outside the 96-hour submission window.