📅 Monthly UpdateApril 27, 2026

Nigeria AML & CBN Regulatory Update, April 2026

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 Enforcement: April 2026

🚨 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.

NFIU goAML Schema Changes

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.

FATF Follow-Up Status, Nigeria

Nigeria remains under FATF Enhanced Follow-Up. The April 2026 report confirmed progress on key Recommendations:

RecommendationPrevious RatingApril 2026 Status
R.1, Risk AssessmentPartially CompliantProgress noted, under review
R.10, Customer Due DiligencePartially CompliantProgress noted, under review
R.16, Wire TransferNon-CompliantPartially Compliant (upgraded)
R.20, STR ReportingPartially CompliantLargely Compliant (upgraded)

CBN VASP Circular Update

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.

STR Quality Drive

NFIU analysis showed significant STR quality issues across institutions:

⚠46% of STRs lacked adequate transaction narrative explaining why the activity is suspicious
⚠38% of STRs contained incomplete customer identification data
⚠29% of STRs were filed outside the mandatory 24-hour window
⚠Institutions with manual STR processes had significantly higher deficiency rates

Required Compliance Actions, April 2026

URGENT

Confirm automated transaction monitoring is operational and producing goAML-formatted STR outputs.

HIGH

Review STR quality against NFIU best practice guide. Audit last 90 days of submissions for completeness and filing timeliness.

HIGH

Obtain NFIU updated goAML schema and plan IT implementation for Q3 2026.

MEDIUM

For institutions with VASP relationships, confirm CDD meets enhanced standards and Travel Rule plan is in place for Q4 2026.

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