Procedure For Scuml Registration For Designated Non-Financial Institutions

Special Control Unit Against Money Laundering (SCUML) is charged with the responsibility of monitoring, supervising, and regulating the activities of Designated Non-Financial Institutions (DNFIs) in line with the Money Laundering (Prohibition) Act ML(P)Act 2011 and the Prevention of Terrorism Act (PTA) 2011. SCUML was established by the Federal Government in September 2005 in compliance with the Money Laundering (Prohibition) Act ML(P) Act 2011 and as a measure for the implementation of the Financial Action Task Force (FATF) Recommendations on Anti- Money Laundering /Combating the Financing.

SCUML is statutorily under the Federal Ministry of Industry, Trade and Investment but operationally works in collaboration with the Economic and Financial Crimes Commission (EFCC), as the Commission drives the operational activities of the Unit in line with Sections 6(C) and 7(2) of the EFCC Establishment Act, 2004.

Section 25 of Money Laundering (Prohibition) Act defines Designated Non-Financial Institutions (DNFIs) as dealers in Jewellery, Cars and Luxury Goods, Precious Stones and Metals, Real Estate, Estate Developers, Estate Surveyors and Valuers, Estate Agents, Chartered Accountants, Audit Firms, Tax Consultants, Clearing and Settlement Companies, Hotels, Casinos, Supermarkets, Dealers in Mechanized Farming Equipment and Machineries, Practitioners of Mechanized Farming, Non-Governmental Organizations (NGOs) or such other businesses as the Federal Ministry of Trade and Investment or appropriate regulatory authorities may from time to time designate. Subsequently, money lending firms and few other businesses have been added to the category.

Procedure for SCUML Registration

SCUML registration can be done online and all the applicant has to do is to logon to the SCUML website click, and complete the online registration form. The applicant must attach the required documents depending on the type of institution.

By and large, the following are the general requirements for SCUML registration for different categories of DNFIs:

• Business Names  
  • Certificate of Incorporation,
  • BN FORM 01, (Proprietor’s Particulars)
  • Evidence of tax registration (TIN letter) and
  • Professional certificate where applicable.
  • BVN, Bank Name, and Account Number

• Companies
  • Certificate of Incorporation
  • Memorandum and Articles of Association
  • Form CAC 1.1 (CAC 2 and CAC 7 FOR OLD REGISTRATION)
  • Evidence of tax registration (Tax Identification Number (TIN)
  • BVN, Bank Name, and Account Number

• Trust/NGO
  • Certificate of Incorporation/Registration
  • Incorporation of Trustees or CAC7 and CAC 2
  • Identification of Trustees with a valid means of identification
  • Constitution/Memorandum & Articles of Association
  • Tax Identification Number (TIN) or Tax Exemption
  • Particulars of Settlors
  • Particulars of Protector (if any)
  • Copy of Cooperation Agreement (For international NGOs)
  • Trust Deed Agreement
  • BVN, Bank Name, and Account Number

• Religious Organization
  • Certificate of Incorporation/Registration
  • Incorporation of Trustees
  • Identification of Trustees with a valid means of identification
  • Constitution

• Association /Clubs/Societies
  • Certificate of Incorporation/Registration
  • Copy of Constitution/Bye-Laws etc
  • Particulars of the trustees
  • Reliable means of Identification of at least two of the trustees
  • Tax Identification Number (TIN) or Tax Exemption
  • BVN, Bank Name, and Account Number

Notwithstanding the above general requirements, any company that has the following business objectives such as, Mining, Export, Investment and Pharmacy in their Memorandum and Article of Association must ensure that the necessary Approvals/Authorization/licences are attached to their applications while institutions who provide professional services are required to provide additional requirements, for instance, an accounting firms must also attach Professional certificate such as ICAN or ANAN or ACCA, Construction companies must attach  COREN Membership Certificate or Nigerian Society of Engineers Membership Certificate and REDAN, Estate Surveyors and Valuers must attach Certificate for Nigerian Institution of Estate Surveyors and Valuers (NIESVs), or Nigeria Institute of Quantity Surveyors Certificate (NIQS), Real estate dealers must attach REDAN Certificate, Consulting firms must attached relevant consulting certificate, Clearing and forwarding companies must attach evidence of registration with Nigerian Port Authority (NPA), Dealers in precious stones and metal must attach Exploration License or permit from the Ministry of Solid Minerals and License from a Certified Geologist.

In closing, it is important to state the failure of any DNFI to register with SCUML may not only make such an organization ineligible to maintain bank accounts with the financial institutions, but it may also lead to criminal prosecution against such entity and its officers.

Considering the above, SCUML registration is one of the important aspects of setting up a business in Nigeria which every company that has been categorized as a DNFI must comply with to successfully carry on business in Nigeria.