Your monthly intelligence briefing on CBN AML/CFT enforcement, NFIU system changes, FATF follow-up actions, VASP regulatory developments, and STR quality standards.
⚠ Compliance Officer Advisory
This briefing summarises regulatory intelligence relevant to Nigerian financial institutions for April 2026. Compliance teams should review each item and assess applicability to their institution's obligations.
🚨 CBN AML Deadline: Enforcement Now Active
Following the March 2026 CBN Circular mandating automated AML/CFT systems, the CBN has confirmed enforcement examinations are now active. Institutions without adequate automated transaction monitoring face immediate sanctions including penalties up to ₦10 million and potential operating restrictions.
Penalty regime
CBN confirmed the ML(PP)A 2022 penalty framework: ₦10M per offence for institutions, ₦5M per offence for responsible officers, plus potential licence suspension for repeat non-compliance.
Examination focus areas
April examination cycles prioritise: automated transaction monitoring deployment, goAML integration, STR filing timeliness, and customer risk classification adequacy.
Microfinance banks
MFBs previously granted a transitional period are now subject to the same automated AML requirements. No further extensions will be granted.
Fintech PSBs
PSBs and mobile money operators face enhanced scrutiny on agent network monitoring, POS cash-in thresholds, and CTR filing compliance.
The NFIU issued a technical notice in April 2026 advising of upcoming goAML XML reporting schema changes, effective Q3 2026:
Enhanced transaction node structure
Additional mandatory fields including transaction channel code, device fingerprint (where applicable), and geolocation data for digital transactions.
Beneficial ownership mandatory fields
STR submissions for corporate entities must include full beneficial ownership chain to the ultimate natural person, with percentage ownership specified.
Crypto transaction reporting
A new dedicated VASP report type has been added, replacing the current workaround of using standard transaction nodes for crypto activities.
Schema validation tightening
goAML will reject submissions with missing mandatory fields from Q3 2026. Institutions must test pipelines against the updated schema before the effective date.
Nigeria remains under FATF Enhanced Follow-Up. The April 2026 report confirmed progress on key Recommendations:
| Recommendation | Previous Rating | April 2026 Status |
|---|---|---|
| R.1, Risk Assessment | Partially Compliant | Progress noted, under review |
| R.10, Customer Due Diligence | Partially Compliant | Progress noted, under review |
| R.16, Wire Transfer | Non-Compliant | Partially Compliant (upgraded) |
| R.20, STR Reporting | Partially Compliant | Largely Compliant (upgraded) |
Travel Rule Implementation
VASPs must implement FATF Travel Rule (R.16) by Q4 2026. Inter-VASP transactions of USD 1,000 equivalent or above require originator and beneficiary information.
P2P Transaction Monitoring
VASPs facilitating P2P crypto trades must implement enhanced monitoring for structuring patterns or counterparties in high-risk jurisdictions.
Bank account access
Banks are reminded the blanket ban on crypto-related accounts has been replaced by a risk-based approach. Banks may open accounts for CBN-registered VASPs following satisfactory CDD.
NFIU analysis showed significant STR quality issues across institutions:
Confirm automated transaction monitoring is operational and producing goAML-formatted STR outputs.
Review STR quality against NFIU best practice guide. Audit last 90 days of submissions for completeness and filing timeliness.
Obtain NFIU updated goAML schema and plan IT implementation for Q3 2026.
For institutions with VASP relationships, confirm CDD meets enhanced standards and Travel Rule plan is in place for Q4 2026.
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