CBN AML Preparedness Evaluation
Evaluate your institution's compliance with the March 2024 CBN AML Directive. Built specifically for Nigerian financial institutions. Get your readiness score in minutes and download a tailored remediation report.
Deadline Countdown
Until 30 June 2026 deadline
Three critical metrics every Nigerian financial institution must measure this week.
Your landscape is changing faster than your policies. The new directive sets strict timelines — and the window to comply is narrowing.
Personal Liability
The March 2024 CBN AML Directive creates direct personal liability for C-suite executives, compliance officers, and board members who fail to implement required controls. Fines of up to ₦2 billion and potential criminal prosecution now apply to individuals — not just institutions.
The Shifting Fiscal Landscape
CBN has significantly tightened AML/CFT requirements since March 2024, aligning with FATF's latest standards. Institutions that delay updating their frameworks risk being flagged during the 2026 regulatory examination cycle — a cycle with unprecedented enforcement scope.
Regulatory Enforcement Posture
The CBN has adopted a markedly more aggressive enforcement posture, with a 340% increase in AML-related sanctions since 2023. The NFIU is conducting real-time monitoring of STR submissions, and institutions with gaps in their compliance frameworks are being prioritised for examination.
The CBN AML Directive — what the rules actually say.
Every figure below is sourced from primary regulatory documents. Click the source to verify.
| # | Figure | What it means | Source |
|---|---|---|---|
| 01 | ₦2 billion | Maximum institutional fine for a single AML/CFT violation under MLPPA 2022 | MLPPA 2022, S.15(1)(b) |
| 02 | 24 hours | Maximum time allowed to file a Suspicious Transaction Report (STR) with the NFIU after detection | CBN AML Directive, March 2024, Art. 7.3 |
| 03 | 5 years | Minimum record-retention period for all customer and transaction documentation | MLPPA 2022, S.8(1) |
| 04 | 30 June 2026 | Deadline for all covered institutions to submit their AML/CFT implementation roadmap to the CBN | CBN AML Directive, March 2024, Appendix A |
| 05 | 18 months | Full compliance window for Deposit Money Banks from the directive's effective date | CBN AML Directive, March 2024, Art. 12.1 |
| 06 | 3× increase | Growth in CBN AML-related enforcement actions between 2022 and 2024, signalling intensified oversight | NFIU Annual Report 2024 |
This assessment does not constitute formal legal or regulatory advice and does not replace a qualified gap analysis. Always verify figures against the primary source documents linked above.
Who Must Comply?
The CBN AML Directive expressly requires the following entities to implement full compliance frameworks before the June 2026 deadline. Failure to do so carries substantial financial and reputational consequences.
Non-compliance penalties include fines up to ₦2 billion, operating licence suspension, and personal criminal liability for directors and compliance officers.
All CBN-licensed deposit money banks, microfinance banks, primary mortgage banks, and development finance institutions.
- Deposit Money Banks (DMBs)
- Microfinance Banks (MFBs)
- Primary Mortgage Banks (PMBs)
- Development Finance Institutions
- Finance Companies
Your AML Readiness Checklist
Navigate sections using the sidebar. Questions marked ⚠ trigger are CBN deal-breakers — answering No auto-fails that section regardless of overall score.
Transaction Monitoring
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Do you have an automated transaction monitoring system in place?
Are transaction monitoring rules reviewed and updated at least quarterly?
Do you have documented procedures for investigating and resolving suspicious alerts?
Are STRs filed to the NFIU within 24 hours of detecting suspicious activity?
Is your TM system calibrated for both transaction volume and velocity thresholds?
Based on the CBN AML/CFT Directive (March 2024), MLPPA 2022, and FATF Recommendations. Does not constitute legal advice.
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