CBN Mandate

All 10 CBN AML/CFT requirements. Covered.

Vantrace is built around the CBN circular published March 2026. Every module maps directly to a specific regulatory obligation, with no gaps and no workarounds.

BSD/DIR/PUB/LAB/019/002 — Central Bank of Nigeria, March 10 2026

Requirement-by-requirement coverage

The CBN circular mandates that all deposit money banks implement automated transaction monitoring with specific capabilities. Below is a direct mapping of each requirement to the Vantrace module that fulfils it, along with current coverage status.

10/10
Requirements Covered
Full coverage
# Requirement Description Vantrace Module Status
1 Automated Transaction Monitoring Real-time or near-real-time monitoring of all transaction channels including NIBSS, mobile, POS, and USSD. Transaction Monitor Covered
2 Rule-Based Alert Generation Configurable rule engine generating alerts for structuring, velocity anomalies, and threshold breaches. Rules Engine Covered
3 ML-Powered Risk Scoring Machine learning models assigning risk scores to transactions and counterparties, updated on a rolling basis. Risk Scoring Engine Covered
4 Customer Risk Profiling Dynamic customer risk profiles incorporating behavioral patterns, PEP status, and peer-group benchmarking. Profile Engine Covered
5 Suspicious Activity Reporting (SAR) Automated generation and submission-ready formatting of Suspicious Transaction Reports (STRs) for NFIU. Reporting Engine Covered
6 Currency Transaction Reporting (CTR) Automatic identification and reporting of cash transactions above the regulatory threshold of ₦5,000,000. Reporting Engine Covered
7 Sanctions & PEP Screening Screening against OFAC, UN, EU, and local CBN/NFIU sanctions lists with configurable match thresholds. Screening Engine Covered
8 Case Management & Audit Trail Structured case management workflow with immutable audit logs, analyst notes, and disposition tracking. Case Manager Covered
9 Model Explainability Human-readable explanations for every ML-generated alert, fulfilling CBN's explainability requirements for regulated AI. Explainability Layer Covered
10 Implementation Roadmap Submission Documentation and evidence package for regulators demonstrating AML/CFT system implementation, due June 2026. Compliance Pack Covered
Reporting

Regulatory report formats

Vantrace generates every report the CBN and NFIU require, formatted to current specifications and ready for submission.

Suspicious Transaction Report (STR)

Automatically populated from flagged cases with analyst review workflow. Submitted to NFIU via the goAML platform on approval.

Format: goAML XML / NFIU v3.0

Currency Transaction Report (CTR)

Daily batch generation for all qualifying cash transactions above ₦5M threshold across all channels and branches.

Format: NFIU CTR Reporting Template

Terrorism Financing Report (TFR)

Immediate reporting triggered when a transaction matches a designated person or entity on the CBN or UN sanctions list.

Format: NFIU goAML TFR Schema

Regulatory Examination Pack

On-demand export of system logs, model documentation, and audit trails for CBN examination teams. Includes model validation records.

Format: PDF + structured data export

Management Information Report (MIR)

Monthly dashboard-ready summaries for Board Risk Committees covering alert volumes, case outcomes, and compliance KPIs.

Format: PDF / Excel / API feed

Implementation Roadmap Document

Pre-populated evidence package demonstrating AML/CFT system capabilities to meet the June 2026 CBN submission deadline.

Due: June 2026 per BSD/DIR/PUB/LAB/019/002
Data

Data residency and privacy

All customer data processed by Vantrace remains within Nigeria. There is no cross-border data transfer. The system is designed to be deployable on-premises inside your existing data centre or in a single-tenant Nigerian cloud environment.

Data handling complies with the Nigeria Data Protection Act 2023 (NDPA) and the CBN Consumer Protection Framework.

Nigeria-only data residency No data leaves Nigerian borders at any point in the processing pipeline.
Encryption at rest and in transit AES-256 at rest, TLS 1.3 in transit. Keys managed within the bank's infrastructure.
NDPA alignment Data processing agreements, consent tracking, and subject access request support built in.
Explainability

How the models explain themselves

The CBN circular explicitly requires that institutions deploying AI-driven AML systems be able to explain every alert to examiners. Vantrace's Explainability Layer is designed to satisfy this requirement.

Every ML-generated risk score comes with a plain-language rationale that an analyst, compliance officer, or CBN examiner can read and verify.

Feature attribution per alert SHAP values translated into plain-English factor summaries for each flagged transaction.
Peer-group comparison Shows how the customer's behaviour compares to similar accounts, making the deviation visible.
Examiner-ready documentation Model cards and validation reports formatted for CBN risk-based examination teams.

Ready to close every gap in your CBN compliance?

Talk to us about your June 2026 deadline and how Vantrace gets you there.

Request a Demo info@vantrace.io