The Statutory Pillars (AML / CFT / CPF)
The statutory pillars of an AML/CFT/CPF (Anti-Money Laundering / Combating the Financing of Terrorism / Counter-Proliferation Financing) framework are the mandatory, globally recognized layers of legal and operational compliance that financial and designated non-financial businesses implement to prevent economic crime
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Failure to Report / Defensive Concealment (MLPPA 2022)
Corporate entities: Heavy financial penalties, potential license revocation
Individuals (CCO, executing directors): Minimum 4 years imprisonment, substantial fine, or both
Directors/employees who tip off: Fine of at least ₦10,000,000 or imprisonment of at least 2 years (Section 19(2)(a))
The Tipping-Off Offense
Legal Basis: Section 12 of the NFIU framework + Section 19 of MLPPA 2022
Definition: Alerting a customer that an alert has been generated, an internal investigation is active, or an STR has been filed
Consequence: Direct criminal offense resulting in heavy personal fines and prison terms
Key Principle: Even an unintentional disclosure during "fishing" for information constitutes tipping off
Structuring (Smurfing)
Definition: Splitting transactions intentionally to stay below statutory thresholds (e.g., executing multiple ₦4,900,000 transfers to avoid the ₦5M limit)
Legal Basis: MLPPA 2022, Section 2(2) — prohibits conducting two or more transactions separately with intent to avoid reporting duties
Consequence: Severe compliance violation triggering mandatory reporting and potential criminal prosecution