Required Documents for SCUML Registration in Nigeria

Some Time ago, I set out to open a corporate account for my business. I later received an account number but was unable to perform any transaction on the account. Why? A dedicated account manager told me I needed to complete SCUML registration.

That was the first time I heard about the SCUML certificate and why my business had to obtain it.

“After review by the compliance unit, it was discovered that you need a SCUML registration because of your business type,” my account manager told me.

You will definitely cross the hurdle if you plan to open a corporate account for your business in Nigeria.

So, in this post, I will tell you all you need to know about SCUML registration in Nigeria, including its purpose, businesses that are required by law to obtain it, and the penalties that may apply for non-compliance.  

What is SCUML?

SCUML means Special Control Unit against Money Laundering which is designed for Designated Non-Financial Institutions (DNFIs) or Designated Non-Financial Businesses and Professions (DNFBPs) for them to declare financial transactions from their customers which involves cash in excess of NGN10,000 (for limited liabilities) or excess of NGN5,000,000 (for business name).

Purpose of SCUML registration

Businesses that register for the SCUML certificate make an obligation that their organizations or businesses will not be used as a channel to receive illegal cash.

Of course, it also means such organizations or businesses make promises to the anti-graft body EFCC and Nigeria’s government never to involve themselves in illegal or illicit financial transactions from their customers or to their customers.

Obtaining SCUML certificate means DNFIs consented to the provisions of EFCC regulations 2022 and allow the SCUML diligently carries out its roles by monitoring their financial activities.

Today, no individual or body can operate a corporate account without submitting an evidence of the SCUML registration number.

Penalties for failure to register with SCUML

There are penalties for violating Money Laundering (Prohibition) Act, 2011. Entities or individuals that violate the act may have their certificate of registration revoked and may be fined or sent to jail, depending on the gravity of the violation.

Businesses that should get SCUML Certificate

Wondering if your business needs to register for SCUML? Or don’t even know if your company is one of the entities classified as Designated Non-Financial Businesses and Professions (DNFBPs) by the EFCC?

If your company or business type is capable of handling NGN10,000,000 or NGN5,000,000 or more in future, you are classified as DNFBPs by the Act establishing the anti-money laundering Act.

As such, you are expected to apply and obtain a SCUML certificate from the Economic and Financial Crimes Commission.

In case you didn’t know, here is a full list of businesses that are designated as DNFBPs. They are the businesses or professions that need SCUML registration in Nigeria.

1. Law Firms
2. Supermarket
3. Audit Firms
4. Tax Consultants
5. Digital agencies
6. Mortgage brokers
7. Lottery Businesses
8. Dealers In Jewelry
9. Automobile dealers
10. Accounting firms
11. Mechanized farming
12. Real estate companies
13. Consulting companies
14. Construction companies
15. Casinos and Pool Betting
16. Non-Profit Organizations
17. Dealers In Luxury Goods
18. Real estate dealers/brokers
19. Estate Surveyors and Valuers
20. Clearing and forwarding firms
21. Hotels and hospitality business
22. Businesses that buy and sell precious stones and metals

Sample of SCUML certificate

Here is a sample of SCUML certificate according to Section 17(2) (a) of the Money Laundering (Prevention and Prohibition) Act, 2022 and any other Law or Regulation.

Required Documents for SCUML Registration

1) Certificate of Incorporation (limited liabilities)

2) Memorandum and Articles of Association

3) Form CAC 1.1 (CAC 2 and CAC 7 FOR OLD REGISTRATION)

4) Form BN-01 (Proprietor’s Particulars for BN)

5) Tax Identification Number (TIN)

6) BVN

7) Bank Name

8) Account Number

Additional requirements

1) Evidence of Registration with the Association of Motor Dealers of Nigeria (AMDON) for auto dealers

2) Evidence of registration with Hotel Owners Forum Abuja (HOFA) or Nigeria Tourism Development Corporation (NTDC) for those who are in the hotel and hospitality business.

3) Obtain license from either the National Lottery Commission/ State Lotteries Board if you are in the Casinos, Pool Betting & Lottery Business.

4) Evidence of professional certificate with ICAN or ANAN or ACCA for auditing firms.

5) Tax consultants must present a professional certificate with ICAN or ANAN or ACCA or CITN.

6) Estate surveyors and valuers need Nigerian Institution of Estate Surveyors and Valuers (NIESVs), or Nigeria Institute of Quantity Surveyors Certificate (NIQS).

7) Real estate dealers need a REDAN Certificate.

8) Accounting firms need a professional certificate with ICAN or ANAN or ACCA.

9) COREN Membership Certificate or Nigerian Society of Engineers Membership Certificate or relevant construction certification for those in the construction sector.

10) Evidence of registration with Council For The Regulation Of Freight Forwarding In Nigeria (CRFFN) for those in the clearing and forwarding business.

11) Law firms need Legal Practicing certificates

12) Any company that their business objective contains Mining, oil/Gas, Export, Investment and Pharmacy will be required to have Approvals/Authorization/licenses from relevant agencies.

For instance license from Nigerian Export Promotion Council (NEPC) for exporters; Nigerian Investment Promotion Commission (NIPC) for importers of such precious stones, and Exploration License/permit from the Ministry of Solid Minerals.

NOTE: Some of the additional requirements or professional licence may be waived.

Non-Profit Organizations

• Non-Profit Organizations (NPOs) need to present the Identification of Trustees with a valid means of identification
• Constitution/Memorandum & Articles of Association
• Certificate of Incorporation/Registration
• Incorporation of Trustees or CAC7 and CAC 2
• Tax Identification Number (TIN) or Tax Exemption
• Particulars of Settlors
• Trust Deed Agreement
• Copy of cooperation Agreement (For international NGOs)

Requirements for SCUML registration for Religious Organizations

• Certificate of Incorporation/Registration
• Incorporation of Trustees
• Identification of Trustees with a valid means of identification
• Constitution
• Tax Identification Number (TIN) or Tax Exemption
• Letter of Authority from the General Overseer of the church
• Details of other activities engaged in (Charities/Humanitarian activities)
• BVN, Bank Name and Account Number

Cost of registering for SCUML certificate

SCUML registration is between NGN50,000 to NGN60,000, depending on the agent that is handling the registration process for you. Although the registration was designed to be free, this is not always the case in a situation whereby business owners can’t handle registration themselves.

Procedure for SCUML Registration

• To begin the registration process, head over to SCUML registration portal at: https://portal1.scuml.net/mhatabz.php to sign up
• Fill out the registration form
• Upload required documents
• Click next to fill other required spaces.

Note: The SCUML registration form has the following info which you are required to fill in:

• Category (DNFBPs or NPO)
• CAC registration type (RN for companies; BN for Business Name; NEPZA for Nigeria Export Processing Zones Authority)
• Sector (supermarket, tax consultants, construction firm etc)
• Business objective
• Incorporate number
• Registered name
• Date of incorporation
• Tax ID (TIN)
• Office address
• State
• Bank
• Account number
• Account name
• Preferred location to pick up your certificate when it’s ready
• Company’s phone number
• Company’s email address
• Company’s director details
• National Identity Number (NIN)

Opening a corporate account without a SCUML certificate

Interestingly, you can open a corporate account without a SCUML certificate, however, your business account will not be active until you present your SCUML registration number.

Both have been designed in such a way that you can perform transactions on your corporate account without presenting evidence of SCUML registration.

Also, if you submitted an application for SCUML registration without your corporate account number, your application would be rejected by the SCUML registration team.

This means that you need to begin the process of business registration, get an account number before proceeding to the SCUML registration process.

Conclusion

If your business or profession is classified as DNFBPs, you will need a SCUML registration number to open a corporate bank account or business account 

After registration, you will have to send evidence of registration to your bank for validation and activation of your bank account.