Overview

The Central Bank of Nigeria (CBN) issued a circular on March 31, 2026, requiring all financial institutions (banks, mobile money operators, international money transfer operators, other financial institutions, and payment service providers) to implement the Baseline Standards for Automated AML/CFT/CPF Solutions. The CBN observed increased industry engagement but noted risks of misinterpretation, particularly regarding compliance being viewed solely through system features or vendor capabilities. To address this, a Guidance Note was issued clarifying CBN expectations. Financial institutions must submit implementation plans within three months (by June 10, 2026) using a provided template. Plans must cover all requirements, define current/target states, actions, timelines, ownership, and governance, demonstrating effectiveness, integration, and defensibility. Submissions will be assessed for adequacy, governance robustness, and solution effectiveness. Incomplete or inconsistent submissions may attract supervisory action. The CBN will continue engagement to support implementation.

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