CBN Reporting Requirements: STR, CTR and goAML Explained for Nigerian Banks
Regulatory reporting is one of the most scrutinised areas in CBN examinations. This guide explains exactly what Nigerian banks must file, to whom, by when, and how goAML works in practice.
What are the CBN reporting requirements for Nigerian banks?
Nigerian banks must file Suspicious Transaction Reports (STRs) within 24 hours of detecting suspicious activity, Currency Transaction Reports (CTRs) for qualifying cash transactions, and Suspicious Activity Reports (SARs) for broader behavioural concerns. All reports are submitted to the Nigerian Financial Intelligence Unit (NFIU) through the goAML digital platform.
The three core report types
Suspicious Transaction Report (STR)
Within 24 hours of detecting suspicious activity
No minimum amount, based on suspicion, not value
NFIU via goAML
Structuring, unusual patterns, PEP activity, sanctions hits
Currency Transaction Report (CTR)
For every qualifying cash transaction
Cash ≥ ₦5 million
Cash ≥ ₦10 million
NFIU via goAML
Suspicious Activity Report (SAR)
For broader suspicious behaviour not tied to a single transaction
No minimum, based on analyst judgement
NFIU via goAML
Account takeover, insider activity, customer behaviour patterns
What is goAML and how does it work?
goAML is the UNODC-developed financial intelligence platform adopted by Nigeria's NFIU as the official channel for receiving regulatory reports. All Nigerian banks must be registered on goAML and submit reports exclusively through this system.
The goAML submission process involves:
- Compliance officer reviews and approves the report within the bank's case management system
- Report is formatted to goAML's XML schema requirements
- Report is submitted via goAML's secure web portal or API
- NFIU issues a submission receipt and reference number
- Record is retained in the bank's audit trail for minimum 5 years
STR filing: what triggers a report
A Suspicious Transaction Report must be filed when a bank has reasonable grounds to suspect:
- The transaction involves proceeds of crime or unlawful activity
- The customer is engaged in structuring to avoid reporting thresholds
- The transaction is inconsistent with the customer's known business profile
- A PEP, sanctioned individual, or watchlisted entity is involved
- The transaction may be related to terrorist financing
Common CBN examination findings on reporting
- Late STR filing beyond the 24-hour window
- Failure to file CTRs for qualifying cash transactions
- Incomplete or inaccurate report fields in goAML
- No documented internal approval process before filing
- Inadequate record retention of submitted reports
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Frequently asked questions
What are the CBN reporting requirements for banks?
Nigerian banks must file STRs within 24 hours of suspicion, CTRs for cash ≥ ₦5M (individuals) / ₦10M (corporates), and SARs for broader suspicious behaviour, all via NFIU's goAML platform.
What is a Suspicious Transaction Report (STR)?
An STR is a mandatory NFIU report filed within 24 hours whenever a bank suspects a transaction may be linked to money laundering, terrorist financing, or financial crime.
What is a Currency Transaction Report (CTR)?
A CTR must be filed for cash transactions equal to or exceeding ₦5 million for individuals or ₦10 million for corporates, submitted via goAML.
What is goAML?
goAML is the UNODC-developed platform adopted by Nigeria's NFIU for receiving STRs, CTRs, and SARs from regulated financial institutions.
What happens if a Nigerian bank fails to file STRs?
Non-compliance with STR filing obligations is a serious regulatory breach. The CBN can impose fines, sanctions, and reputational penalties. Repeat failures may trigger licence review.