A complete guide to the three pillars of AML name screening, PEP identification, sanctions list checking, and adverse media monitoring, with CBN requirements for Nigerian banks.
AML screening checks customers, beneficial owners, and transaction counterparties against watchlists to identify elevated money laundering or terrorist financing risks. CBN AML/CFT/CPF Regulations 2022 require screening at onboarding and on an ongoing basis.
PEP Screening
Identifying politically exposed persons and applying enhanced due diligence.
Sanctions Screening
Checking against UN, OFAC, EU, UK, and NFIU designated lists.
Adverse Media
Monitoring negative news about customers in financial crime-related categories.
Who qualifies as a PEP in Nigeria?
Once a PEP is identified, the bank must apply EDD: obtain senior management approval, verify source of wealth and funds, and conduct enhanced ongoing monitoring.
| Sanctions List | Issuing Authority | Mandatory? |
|---|---|---|
| UN Consolidated Sanctions List | United Nations Security Council | Yes, all Nigerian banks |
| OFAC SDN List | US Treasury Dept | Yes, for USD transactions |
| EU Consolidated List | European Union | Yes, for EUR transactions |
| UK HMT Financial Sanctions List | UK Treasury | Yes, for GBP transactions |
| NFIU Domestic Designated List | Nigerian Financial Intelligence Unit | Yes, all Nigerian banks |
⚠ Sanctions Hit Response
A confirmed sanctions match requires immediate account freeze and notification to the CBN and NFIU within 24 hours.
Adverse media screening identifies customers with negative coverage in financial crime-related categories:
AI Shield Nexus provides real-time screening against all mandatory Nigerian and international watchlists, with automated EDD workflows for PEP matches.
What sanctions lists must Nigerian banks screen against?
Nigerian banks must screen against the UN Consolidated Sanctions List, OFAC SDN List, EU Consolidated List, UK HMT Financial Sanctions List, and the NFIU Domestic Designated List.
What is a PEP in Nigerian banking?
A Politically Exposed Person (PEP) is an individual who holds or has held a prominent public function, including elected officials, senior government appointees, military officers, and state-owned enterprise executives.
How often must Nigerian banks rescreen existing customers?
At minimum annually for all customers, with real-time rescreening for wire transfers and event-triggered rescreening on material profile changes.