MLPPA 2022
Market regime · Money Laundering (Prevention and Prohibition) Act 2022
Federal Republic of Nigeria
Nigeria
2022, replacing the 2011 Act
Enforced through the EFCC, NFIU, SCUML and sector supervisors
Financial institutions and designated non-financial businesses in Nigeria
Curated, versioned & cross-mapped
The obligation, plainly.
The MLPPA 2022 is the statute beneath the supervisory regime: it defines the money-laundering offences, sets the due-diligence and record-keeping duties, limits cash transactions, and extends obligations to designated non-financial businesses through SCUML.
For a compliance programme it is the anchor authority: circulars interpret it, examiners cite it, and the penalties that make AML a board matter live here.
Where programmes are tested.
Statutory CDD and records
Customer identification and record-keeping duties as legal obligations, not just supervisory expectations.
Cash and transaction limits
Statutory thresholds respected and monitored.
Scope beyond banking
DNFBP obligations through SCUML for the businesses the Act designates.
Curated once, evidenced continuously.
- The Act's obligations are curated and cross-referenced to the CBN and NFIU requirements they underpin, one mapping across statute and circular.
- Requirements resolve to shared controls: implement a control once and it counts toward every framework it maps to.
- Status is evidence-gated: a requirement can't be marked implemented without valid, in-date evidence behind it.
- Every attestation carries maker/checker, and every action lands in an append-only audit trail.
MLPPA 2022, asked plainly.
The questions compliance teams actually ask before an adoption decision or an audit.
What did the MLPPA 2022 change from the 2011 Act?
It rebuilt the statute: wider offences, sharper customer-due-diligence and beneficial-ownership duties, explicit coverage of designated non-financial businesses through SCUML, and stronger penalties. Most supervisory circulars issued since trace their authority to it.
What are the cash transaction limits?
The Act prohibits cash payments above ₦5 million for individuals and ₦10 million for corporate bodies outside a financial institution, which both restricts conduct and feeds the threshold-reporting regime.
Who are DNFBPs under the Act?
Designated non-financial businesses and professions: real estate, dealers in jewellery and cars, casinos, legal and accounting practitioners and similar, supervised through SCUML. If the Act designates you, AML duties apply even though the CBN does not license you.
How long must records be kept?
At least five years after the transaction or the end of the relationship, retrievable on demand. Retention is a statutory duty here, not just a supervisory expectation.
Where it connects.
The full catalogCompliance you can prove.
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