On May 20, 2025, the Central Bank of Nigeria (CBN) issued a circular that signals a sharp pivot toward real-time, tech-driven compliance. The directive, signed by the Director of Banking Supervision, Olubukola Akinwunmi, mandates all financial institutions to implement real-time alerts for high-risk transactions. These include cross-border transfers, large cash deposits, crypto-linked activity, and any transaction previously flagged under AML guidelines.
Titled “Exposure of Draft Baseline Standards for Automated Anti-Money Laundering (AML) Solutions – Request for Comments”, the document lays the groundwork for next-generation AML compliance. The CBN’s vision is clear: modernise the way institutions detect and report suspicious activity, instantly and intelligently.
This article unpacks the new circular, explores its potential impact, and offers actionable strategies for compliance. We also highlight how Smile ID’s AML tools provide a fast, scalable path to meeting these new demands.
Key Highlights of the CBN Circular
- Mandatory Real-Time Alerts
- Institutions must trigger instant alerts for transactions involving crypto, foreign remittances, and excessive cash inflows.
- Monitoring systems must be agile enough to evaluate transactions under multiple risk scenarios in real time.
- Baseline Standards for AML Automation
- Banks must adopt configurable rule engines and customer segmentation to spot anomalies.
- Systems should allow quick updates in line with evolving typologies and local/global guidance (e.g., FATF).
- Automated Customer Onboarding & Verification
- Real-time access to CDD, KYC, and KYB data is now non-negotiable.
- Integration with BVN and NIN databases is required for instant identity validation at onboarding.
- Stress Testing & Validation
- Institutions must regularly test AML systems to reduce false positives and ensure reliability under pressure.
- Global Alignment
- These new standards aim to align Nigeria’s financial system with international AML/CFT/CPF expectations, boosting credibility and reducing systemic risk.
Why This Matters
The CBN’s latest circular is a recalibration of the risk posture expected from Nigerian financial institutions. Amidst growing concerns about terrorism financing, crypto-driven laundering, and cross-border capital flight, regulators are demanding precision, speed, and accountability.
Banks and fintechs that delay implementation may face regulatory backlash, reputational risk, and potential blacklisting on global AML rankings.
Smart Moves to Stay Ahead of Compliance Risk
To quickly meet the requirements of this directive, financial institutions should consider these immediate steps:
- Audit and Upgrade Transaction Monitoring Systems: Review existing systems for real-time capability, rule configurability, and integration readiness.
- Implement Tiered Risk Segmentation: Use customer profiles and behavior data to classify risk levels dynamically.
- Automate Onboarding with Embedded KYC/AML: Move from manual onboarding flows to digital-first identity checks and instant customer screening.
- Stress-Test Systems Proactively: Run simulations and edge-case tests to validate alert thresholds, processing speed, and false-positive rates.
- Engage a Third-Party AML Partner: Reduce development time and gain access to global best practices by integrating with proven AML tech providers.
How Smile ID’s AML Check Delivers on CBN’s Vision
Whether you're a Tier 1 bank, regional MFB, or rising fintech, the pressure to comply is real, but so is the opportunity to build trust and resilience.
Smile ID’s AML Check solution empowers institutions to meet CBN’s standards without re-inventing the wheel:
- Real-Time Watchlist Screening: Instantly screen customers and transactions against OFAC, Interpol, UN, EU, UK, and African watchlists.
- Continuous Adverse Media Monitoring: Stay ahead of evolving threats with AI-powered screening of global news and sanctions feeds.
- Smart Segmentation Tools: Tailor alerts using rule-based workflows that factor in customer behaviour, transaction patterns, and geolocation.
- Lightning-Fast ID Verification: Leverage Smile ID’s integration with BVN, NIN, and passport databases to validate identities during onboarding or transactions.
- Plug-and-Play API: Get compliant in days, not months, with minimal engineering lift and full audit trails for regulatory reporting.
Bottom Line
This new CBN circular is a signal of where Nigeria’s financial system is headed: smarter, safer, and faster. Institutions that embrace automation and intelligence will not only avoid penalties but also unlock deeper customer trust and operational efficiency.
If you’re ready to meet this new standard and future-proof your compliance infrastructure, Smile ID is here to help.
Book a demo to see how Smile ID’s AML Check can help you meet CBN’s expectations today and for your company’s future.
