The Central Bank of Nigeria issued a regulatory circular on 10 March 2026 requiring all deposit money banks, fintechs, mobile money operators, and international money transfer operators to deploy automated anti-money laundering systems capable of monitoring transactions in real time or near real time to detect suspicious activity. The directive establishes differentiated compliance deadlines based on institutional category: deposit money banks must achieve full implementation within 18 months from the date the circular was issued, while other regulated financial institutions — including fintechs, mobile money operators, and international money transfer operators — have a 24-month compliance window. All institutions across both categories are required to submit detailed implementation roadmaps to the CBN within three months of the circular's issuance.
The directive follows Nigeria's removal from the Financial Action Task Force Grey List in October 2025. The CBN's March 2026 circular, which the bank said aligns with Financial Action Task Force recommendations, sets out the baseline technical, governance, and procedural standards that individual regulated entities are now expected to meet and sustain.
SCOPE AND TECHNICAL REQUIREMENTS
The circular applies beyond deposit money banks to the fintech and payment services sector. Mobile money operators and international money transfer operators are also in scope. The baseline standards specified in the directive span technical architecture, operational procedures, and governance frameworks.
A core technical requirement is that automated systems must monitor transactions in real time or near real time to detect unusual patterns. The CBN has indicated that the systems must satisfy defined baseline technical specifications covering monitoring algorithms, data integration, alert generation, and reporting protocols, while allowing individual institutions flexibility in their choice of technology vendor and implementation approach, provided the solution satisfies the stipulated performance requirements. Governance expectations embedded in the directive include documented processes for alert investigation, escalation, and reporting to the Nigerian Financial Intelligence Unit.
SANCTIONS
The circular states that institutions that fail to comply may be subject to remedial directives, administrative sanctions and penalties in line with extant laws and regulations.
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