AML/CFT Compliance — The Operating Standard

The regulation in brief

Nigerian AML/CFT obligations flow from several converging sources: the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, NFIU reporting requirements, FATF Recommendations as adopted into Nigerian practice, and CBN-specific guidance for regulated institutions. The framework requires risk-based customer due diligence, ongoing transaction monitoring, sanctions screening against multiple lists, beneficial-ownership identification (CAMA 5% UBO disclosure), and structured reporting (CTR, STR, SAR, TFR).

For most institutions, AML/CFT is the single largest source of recurring compliance work outside loan administration.

How FinovaMax handles it

• Customer risk profiling. Every customer is risk-scored at onboarding and dynamically as their transaction behaviour evolves. Risk score modulates KYC depth, transaction monitoring sensitivity, and reporting thresholds.
• PEP (Politically Exposed Person) detection. Built-in screening against PEP databases at onboarding and on transaction patterns; PEP status escalates the customer's risk profile and surfaces in compliance dashboards.
• CAMA 5% UBO tracking. Beneficial ownership is captured for every corporate customer, with the 5% threshold from the Companies and Allied Matters Act as the default reporting trigger. The ownership chain is structured data, not a PDF.
• Sanctions screening across multiple lists. Every transaction is screened against OFAC (US), UN consolidated, EU, ECOWAS, and Nigeria's Terrorism Sanctions List (TSL). Lists are updated automatically.
• Eight transaction-monitoring scenarios. Structuring, layering, geographic anomaly, frequency anomaly, customer-tier-vs-transaction-volume mismatch, and other typology-driven detections run in real time.
• Case management. Every flagged event becomes a compliance case with assignee, SLA, evidence capture, escalation path, and audit trail.
• Bi-annual NFIU compliance returns. Aggregated from the same case-management data.

Practical implication for your institution

AML/CFT stops being a parallel manual workflow that lives outside the core banking system. It is the core banking system, with the compliance work integrated into the transaction flow. The Head of Compliance manages by exception, not by daily transaction-blotter review. Examination evidence is the same data the team uses every day, not an export specifically rebuilt for the examiner.