The CBN’s New AML Automation Standards: What They Require, and How Adhere Already Delivers

 



On March 10, 2026, the Central Bank of Nigeria released what may be the most consequential compliance technology directive in the country’s regulatory history. The Baseline Standards for Automated AML Solutions establish detailed minimum requirements for the technology that every financial institution must deploy to detect, prevent, and report money laundering, terrorism financing, and proliferation financing.


The standards are comprehensive, covering 12 distinct capability areas across 27 pages. The deadlines are firm: 18 months for deposit money banks, 24 months for other financial institutions, and just 3 months for every institution to submit an implementation roadmap to the CBN.


At Smartcomply, we built Adhere for this exact moment. Not because we anticipated this specific circular, but because we understood that African financial systems needed a fundamentally different approach to AML compliance technology: one built from the ground up for how institutions on this continent actually operate. Here is how Adhere maps against the CBN’s requirements:


  • Transaction Monitoring and Risk-Based Analysis

The CBN requires automated systems that support risk-based transaction and activity monitoring using predictive analytics, behavioural pattern recognition, and automated risk scoring. Adhere delivers exactly this through its AI-driven monitoring engine, which analyses transaction data in the context of each customer’s full profile, not just raw transaction feeds. This is precisely what the CBN demands when it states that AML solutions without effective linkage to CDD, KYC, and KYB information will not be regarded as compliant.


  • Customer Due Diligence and KYC Automation

The standards require end-to-end support for CDD, EDD, KYC, and KYB processes, including automated risk profiling and integration with national identity databases such as BVN and NIN. Adhere was designed for African identity infrastructure from day one, providing real-time identity verification and risk-based onboarding that adjusts dynamically based on customer risk factors.


  • Sanctions, Watchlist, and PEP Screening

The CBN requires integration with domestic and international sanctions lists, fuzzy matching logic for name variations, real-time updates, adverse media monitoring, and automated blocking of confirmed sanctions matches. Adhere provides these capabilities natively, with screening that runs continuously, not just at onboarding but throughout the entire customer lifecycle.


  • Risk Assessment

The standards call for configurable risk assessment tools that support automated scoring at onboarding, dynamic adjustment based on new data and behaviour, and enterprise-level risk identification. Adhere’s risk engine is built to do precisely this, with the transparency and explainability the CBN requires for AI-based models.


  • Case Management

The CBN requires enterprise case management with automated case creation, role-based workflows, maker-checker functionality, and complete audit trails. Adhere’s case management module delivers all of these capabilities, ensuring that every alert is tracked from creation through investigation to resolution with full documentation.


  • Regulatory Reporting

The standards require automated generation of STRs, SARs, CTRs, FTRs, and other required reports in CBN-prescribed formats. Adhere supports configurable reporting templates aligned with Nigerian regulatory requirements, including both internal management reporting and external regulatory submissions.


Customisation: What Banks Are Actually Asking For

One requirement that runs through the entire CBN framework is the expectation that AML solutions be configurable to each institution’s documented risk appetite, transaction typologies, and operational structure. This is not a secondary consideration. It is central to meeting the proportionality principle the CBN has built into these standards.


In our conversations with banking compliance teams, customisation is consistently the first requirement they raise. They want the ability to configure their own alert thresholds, define institution-specific risk scenarios, build custom escalation workflows, and adapt the platform to their unique regulatory and operational context. Adhere was built to deliver exactly this level of institutional control, because a platform that cannot be shaped to each institution’s needs cannot truly meet these standards.


What Comes Next


The 3-month deadline for the implementation roadmap submission is the immediate priority for every financial institution in Nigeria. For institutions evaluating their options, the critical question is whether the platform they choose was designed from the start to meet these specific regulatory standards, or whether it will need to be retrofitted.


Whether you are a tier-1 bank or an emerging fintech, the requirements apply to you. The CBN has been clear that proportionality guides the depth of implementation, but the baseline standards are non-negotiable. The time to start planning is now.


To learn how Adhere can support your CBN compliance roadmap, contact us at info@smartcomply.com 

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