Every time significant sums of money move between banks in Nigeria, oversight is supposed to follow. That responsibility rests with the Nigerian Financial Intelligence Unit (NFIU), which receives reports from banks, fintechs, insurance companies, cryptocurrency platforms, and other entities handling large financial transactions. The agency uses this information to track money laundering, terrorist financing, and other financial crimes. The unit has operated independently since the 2018 NFIU Act separated it from the Economic and Financial Crimes Commission (EFCC), and it exchanges intelligence with foreign counterparts through the Egmont Group of financial intelligence units.

Suspicious reports down, currency reports up

In 2025, the NFIU received 42,082 Suspicious Transaction Reports (STRs) from financial institutions across the country. The figure appears substantial until set against the previous year, when institutions filed 82,143 reports. In a single year, the volume of suspicious transaction reports filed by Nigerian financial institutions dropped by nearly 49%.

Over the same period, Currency Transaction Reports — routine disclosures triggered when banks report transactions exceeding a certain amount — rose dramatically, by 61.6%. These reports increased from 25.8 million in 2024 to 41.7 million in 2025.

Taken together, the trend points to an increase in the amount of money being monitored but a decline in the number of transactions flagged as suspicious. That combination could be very encouraging — or it could raise important questions that need to be addressed.

What each report actually measures

To understand why these figures matter, it helps to know what each type of report represents.

A Currency Transaction Report (CTR) is generated automatically whenever an individual moves more than ₦5 million, or a company moves more than ₦10 million. It is essentially a record of large transactions, and its volume reflects trends such as inflation and currency depreciation — both pronounced in Nigeria since the naira was floated in mid-2023 and weakened sharply. Because the reporting thresholds are fixed in naira terms, inflation alone can push more transactions past them even with no change in underlying activity. The rise to 41.7 million CTRs in 2025 indicates more large transactions taking place in Nigeria.

A Suspicious Transaction Report (STR), by contrast, requires a human or an automated system to evaluate a transaction and determine whether something seems off — unusual patterns, unexplained transfers, or similar anomalies. It involves judgment and is more complex to produce.

Why the STR decline?

The sharp decline in STRs from 2024 to 2025 could mean several things. There may be genuinely fewer suspicious activities, though that is hard to believe given the financial crimes already known. It could also mean institutions are underreporting, whether because of insufficient compliance systems or a desire to avoid the hassle of flagging suspicious transactions. Alternatively, the shift could reflect regulatory changes that influence what institutions feel they need to report.

The NFIU suggests the drop in STRs is the result of improved compliance measures and reforms. Those reforms have an external backdrop: in February 2023, the Financial Action Task Force (FATF), the intergovernmental body that sets global anti-money laundering standards, placed Nigeria on its 'grey list' of jurisdictions under increased monitoring — a status tied to an agreed action plan and periodic assessments of progress. The Central Bank of Nigeria's new framework, issued in May 2025, proposed using artificial intelligence for better transaction monitoring — a change that might have enhanced detection quality even as the number of reports decreased. In effect, the argument is better targeting rather than less scrutiny.

How accurate that explanation is will only become clear once financial crime prosecution data is updated alongside the reporting data.

Who filed the reports

The breakdown of who filed what tells its own story.

In 2025, Deposit Money Banks — institutions such as GTBank and Access Bank — filed 92% of all Suspicious Transaction Reports, amounting to 38,715 out of 42,082. The figure indicates both strong compliance systems and significant regulatory pressure.

Fintech companies and other financial institutions, in contrast, filed only 2,185 STRs — a number that seems low given the sector's transaction volume. Opay alone handles more than 100 million transactions each day, raising the question of whether fintech compliance is keeping up.

Crypto platforms filed just 49 STRs for the entire year, a surprisingly small figure given the government's efforts to regulate the industry. That regulatory timeline has moved quickly: the Central Bank of Nigeria barred banks from servicing crypto operators in February 2021, reversed the prohibition in December 2023, and issued guidelines for virtual asset service providers in May 2024. The data also shows that crypto platforms only began submitting Currency Transaction Reports in the latter half of 2025, suggesting their compliance efforts remain at an early stage despite the Central Bank of Nigeria's focus on crypto regulations.

The 28 million PEP disclosures

One overlooked aspect of the report is the count of Politically Exposed Persons (PEP) disclosures. In 2025, Nigerian financial institutions filed 28.1 million PEP reports, a 31% increase from 21.5 million the previous year.

A PEP is someone who holds, or has held, a prominent public position, as well as certain family members and close associates. Financial institutions are required to apply enhanced scrutiny to their financial activity because of the higher corruption and money-laundering risks associated with some public positions.

These 28 million reports show Nigerian banks flagging a large number of transactions tied to politically connected individuals. Whether that volume reflects true vigilance or simply a routine exercise is unclear. Set against Nigeria's population of around 220 million, however, it suggests a substantial proportion of financial activity is linked to these individuals. This detail, more than anything else in the report, merits discussion — yet it is largely absent from the conversation.

An AI-driven AML framework ahead

The Central Bank of Nigeria's proposed AI-driven anti-money laundering (AML) framework aims to enhance real-time transaction monitoring, behavioural pattern recognition, risk scoring, and automated reporting of suspicious transactions. If implemented effectively, it could replace or support human judgment in identifying potentially suspicious activities, allowing better detection of anomalies that might otherwise be overlooked.

The shift carries broader implications. It could make it increasingly difficult to conceal financial crimes within the volume of legitimate transactions — assuming the systems are used correctly and the data they produce is acted upon.

The unanswered question

With 42,082 suspicious transactions flagged, 41.7 million currency reports filed, and 28 million PEP disclosures made, it is clear that Nigeria's financial surveillance system is operational. In practice, the pipeline is meant to continue past the NFIU, which disseminates analyzed reports as intelligence to law enforcement agencies such as the EFCC for investigation and possible prosecution. Yet the NFIU's annual report leaves a crucial question unanswered: what becomes of the transactions that were identified but not flagged? That missing information is what truly matters.