A member of my marketing team recently told me that we had a problem with approximately 400 contact records.
My immediate question was: 400 out of how many?
If 400 records were affected out of a database of 500, we had a crisis. If it was 400 out of 50,000, we had a data-cleaning exercise. The number had not changed, but its meaning changed completely once it had a denominator for context.
I was reminded of that conversation while reading the Nigerian Financial Intelligence Unit’s (NFIU) 2025 Annual Report.
The NFIU disclosed that it received 42,082 Suspicious Transaction Reports (STRs) and 10,513 Suspicious Activity Reports (SARs) during the year: a combined total of 52,595 suspicious reports.
Several publications reported the figure. What most did not answer was the more important question: is 52,595 actually a lot or not enough?
To answer that, we must first understand what suspicious reports are intended to achieve.
Understanding Suspicious Reports
Financial institutions in Nigeria are mandated under the Money Laundering (Prohibition and Prevention) Act 2022 to file STRs when activity gives rise to a reasonable suspicion of money laundering, fraud, terrorism financing, corruption, tax crime or another predicate offence.
Each report provides the NFIU with a piece of intelligence. One institution may see an unusual payment. Another may see funds moving through a related account. A third may identify a beneficial owner, cross-border transfer or rapid withdrawal. Individually, each event may be inconclusive. When combined with other financial information and law-enforcement intelligence, however, the pattern may become much clearer.
Suspicious reports can help authorities connect people, companies, accounts and transactions; identify criminal networks operating across several institutions; trace proceeds of crime; support investigations and prosecutions; and identify assets that may be restrained or recovered.
The overarching goal of STRs is to generate useful intelligence that helps disrupt financial crime and protect the integrity of the financial system.
Context is key
According to the Central Bank of Nigeria’s 2025 Annual Report, Nigeria had 47.8 billion electronic-payment transactions in 2025 across ATM, point-of-sale, internet or web, NEFT, USSD, mobile-app, direct-debit and RTGS channels.
When you place this beside the NFIU’s 52,595 suspicious reports, this produces approximately 1.1 suspicious reports for every one million electronic-payment transactions.
That makes 52,595 look rather different.
A quick caveat here is that a suspicious report may relate to one transaction, several transactions, an attempted transaction or a broader pattern of activity. Also, the electronic-payment figure does not capture every form of financial activity. It is simply a sense check against the scale of the financial system.
Nigeria has a large banking sector, one of Africa’s most developed digital-payments ecosystems, a rapidly growing fintech industry, expanding virtual-asset activity and a substantial cash and informal economy. It is also exposed to fraud, corruption, cybercrime, kidnapping, tax crime, terrorism financing and illicit financial flows.
Against that background, 52,595 should not automatically be described as a large number simply because it sounds large in isolation.
Similar financial systems
It is sometimes useful to compare with countries at a broadly similar stage of financial system and AML/CFT development. For that, we look to Ghana and Kenya.
According to Ghana’s Financial Intelligence Centre, as cited in the National AML/CFT/CPF Risk Assessment of Ghana, the country received 2,152 suspicious transaction reports in 2023. According to the Bank of Ghana’s Payment Systems Oversight Annual Report 2023, Ghana recorded 6.81 billion mobile-money transactions that same year – the only payment-channel figure I could independently verify, since the Bank of Ghana does not publish a single all-channel e-payments total. That works out to about 0.32 suspicious reports per million transactions.
Kenya provides another useful comparison. Kenya’s Financial Reporting Centre received 5,454 STRs and 2,482 SARs in 2024, producing 7,936 core suspicious reports. The Kenya National Bureau of Statistics recorded approximately 2.7 billion mobile-money transactions in 2024. Mobile money is technically a narrower denominator than Nigeria’s multi-channel total; however, available payment rail-level data from the Central Bank of Kenya and PesaLink indicate that mobile money accounted for approximately 94–95 per cent of Kenya’s documented payment transactions by number.
Adding the published volumes for cards, EFTs, cheques, RTGS and PesaLink produces an estimated Kenyan total of approximately 2.86 billion transactions in 2024. That equates to approximately 2.8 suspicious reports per million transactions;
So what do the numbers from Ghana and Kenya tell us in comparison? Nigeria appears to report more intensively than Ghana, but only about 40 per cent as intensively as Kenya on the available transaction-adjusted figures. Put differently, Kenya generated approximately two and a half times as many suspicious reports per million transactions as Nigeria. With that context, we can see that Nigeria’s 52,595 reports are not obviously excessive. Relative to recorded transaction activity, they sit within the regional range but below at least one comparable African financial system.
More mature systems show?
The gap, however, becomes more striking when Nigeria is placed beside three established financial-intelligence systems.
The United Kingdom’s National Crime Agency received 866,616 Suspicious Activity Reports in the year from April 2024 to March 2025. UK Finance recorded 48.8 billion payments in calendar 2024, the closest full-year payment denominator to that reporting window. That produces approximately 17.8 SARs per million payments. It is worth flagging that the UK figure carries its own distortion: a meaningful share of those SARs are defence-against-money-laundering filings driven by the consent regime, and the number is widely regarded within UK AML circles as inflated by defensive reporting rather than a clean measure of detection quality. It is cited here for the shape of the gap, not as a target to replicate.
In the United States, FinCEN received approximately 4.8 million SARs in the federal fiscal year from October 2024 to September 2025. The Federal Reserve’s latest triennial payments study estimates 236.6 billion non-cash payments in calendar 2024. Placing the two figures beside each other produces approximately 20.3 SARs per million payments.
In Canada, FINTRAC’s 2024/25 Annual Report confirms 633,882 Suspicious Transaction Reports, and Payments Canada recorded 22.5 billion retail payments in calendar year 2024. That equates to approximately 28.2 STRs per million payments.
It’s important to note that these figures do not prove that the US, UK or Canada detects financial crime seventeen or twenty or twenty-eight times better than Nigeria. Their legal obligations, reporting populations, financial sectors and payment datasets differ.
The lesson from mature systems is therefore not simply “file more”; the goal should be to build a reporting ecosystem capable of detecting more relevant activity across more sectors, while maintaining report quality and giving reporting institutions useful feedback.
The Dominance of Banks
Deposit money banks filed 47,028 of Nigeria’s 52,595 suspicious reports in 2025: approximately 89.4 per cent. Banks are central to the financial system and should be major reporters. But when almost nine out of every ten reports originate from one segment, it raises questions about detection maturity elsewhere.
Are payment businesses, capital-market operators, insurers, virtual-asset service providers and designated non-financial businesses seeing genuinely little suspicious activity? Or are their systems identifying and escalating too little of what they see?
The answer should not be a reporting quota. Quotas create defensive filings and low-quality narratives. The solution is more sophisticated monitoring: better customer-risk models, reliable beneficial-ownership information, transaction monitoring designed around each institution’s products, cross-channel and linked-account analysis, well-tuned typologies, effective alert investigation and continuous testing for the suspicious activity that existing rules may be missing.
This is also why the CBN’s Baseline Standards for Automated AML/CFT/CPF Solutions matter. The standards establish minimum expectations for automated systems capable of detecting, analysing and reporting suspicious activity. They reflect a basic reality: at the scale at which Nigerian finance now operates, manual reviews and isolated rules cannot provide adequate coverage.
I should disclose an obvious conflict of interest here: I run a company that builds this kind of technology. But even after applying a healthy discount to my enthusiasm for automation, the arithmetic remains difficult to argue with. A system processing tens of billions of electronic payments cannot depend principally on spreadsheets, fragmented data and analysts manually searching for suspicious patterns after the event.
So, is 52,595 a lot?
It is a substantial number in isolation. It is higher than Ghana’s reporting intensity on the available transaction-based measure. But it is materially lower than Kenya’s estimated 2.8 reports per million transactions and far below the roughly 17.8 to 28.2 reports per million recorded across the UK, US and Canada on their closest available payment denominators. Above all, it remains modest beside the 47.8 billion electronic-payment transactions recorded in Nigeria during the year.
The fairest conclusion is that Nigeria is not producing too many suspicious reports. The more credible concern is whether it is producing enough high-quality reports, from a sufficiently broad range of institutions, for the size, complexity and risk of its financial system.
That question cannot be answered by the headline number alone. It requires information about active and nil filers, filing concentration, report quality, regulatory feedback and measurable law-enforcement outcomes.
Concretely, the NFIU’s next annual report would tell us far more if it disclosed five things: the number of active versus nil-filing reporting entities by sector; report volumes broken down by institution type rather than dominated by a single deposit-money-bank figure; a quality or actionability metric, meaning the share of reports that meaningfully advanced an investigation rather than simply the number filed; turnaround and feedback rates to reporting institutions; and downstream outcomes, such as prosecutions, convictions or assets restrained, that trace back to STR and SAR intelligence.
Context does not diminish the importance of 52,595 reports. It tells us what the number is really saying.
And what it appears to be saying is this: Nigeria’s financial-intelligence system has progressed, but its detection capability still has considerable room to mature.
.Ibidapo-Obe is the co-founder and CEO of Regfyl, an AML, transaction monitoring, and fraud-prevention technology company. He writes on financial crime, compliance and regulatory technology.
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