International standards
The FATF standards, and how this platform maps to them
The Financial Action Task Force sets the international standards that national AML/CFT regimes implement. They bind countries rather than institutions — you comply with Nigerian law, which gives effect to them — but they are the vocabulary supervisors, assessors and correspondent banks use, so it is worth knowing where a control sits in that frame.
Who sets the expectation
Financial Action Task Force (FATF)
Intergovernmental standard-setter for combating money laundering, terrorist financing and proliferation financing; assesses countries through mutual evaluation against both technical compliance and effectiveness.
Who this applies to
- Countries, directly
- The standards are addressed to jurisdictions, which implement them through national law and supervision. An institution's obligations come from that national law.
- Institutions, indirectly but consequentially
- Supervisory expectations, correspondent banking due diligence and cross-border counterparty questionnaires are all framed in the standards' vocabulary, so an institution that cannot speak it is at a practical disadvantage.
- Groups operating across borders
- Group-wide programme expectations and the treatment of higher-risk jurisdictions are where the international frame becomes an operational constraint rather than a background one.
What it requires
The obligation, stated qualitatively
Each duty below is described in substance — what it requires and what evidence it produces. Thresholds, deadlines, section numbers and penalty provisions are deliberately absent, and where a duty turns on one, the parameter you must read from the operative instrument is named beside it.
A risk-based approach, evidenced
Identify and assess risk, and apply measures proportionate to it. The standard is not permission to do less; it is a requirement to be able to explain why what you do is proportionate, which is a heavier evidential burden than applying one rule to everyone.
Evidence: A national and institutional risk assessment, and a demonstrable line from its findings to the controls in operation.
Customer due diligence and beneficial ownership transparency
Identify and verify customers, identify the natural persons who ultimately own or control them, understand the purpose of the relationship, and keep it under review. Ownership transparency has been an area of sustained revision.
Evidence: Customer files that trace ownership to natural persons, with verification evidence and a refresh history.
Read from the operative instrument: The ownership threshold and the acceptable verification measures, as implemented nationally.
Politically exposed persons
Determine whether a customer or beneficial owner holds a prominent public function, or is a family member or close associate of someone who does, and apply enhanced measures where they do.
Evidence: Screening runs with the list versions used, adjudicated outcomes, senior approval records, and source of wealth and source of funds evidence.
Read from the operative instrument: The national treatment of domestic as against foreign public functions.
Reporting of suspicious transactions, and confidentiality
Report suspicion promptly to the financial intelligence unit, and do not disclose that a report has been made or is contemplated.
Evidence: Reports with their supporting case files, and access controls over both.
Read from the operative instrument: The national deadline and the exact scope of the confidentiality prohibition.
Record keeping
Retain customer and transaction records for a prescribed period, sufficient to permit reconstruction of individual transactions.
Evidence: A retention schedule and a demonstrated reconstruction.
Read from the operative instrument: The national retention period.
Internal controls, and group-wide programmes
Compliance management arrangements, screening of staff, ongoing training, and an independent audit function; group-wide policies applied across branches and majority-owned subsidiaries.
Evidence: Programme documentation, training records, independent review findings and group application evidence.
Targeted financial sanctions
Implement designations without delay, including those relating to terrorism and to proliferation financing.
Evidence: Screening against current designations, with the list version recorded, and evidence of action on a confirmed match.
Read from the operative instrument: The national implementation route and the required response time.
Wire transfers and payment message information
Required originator and beneficiary information should accompany transfers along the chain, and institutions should have procedures for handling incomplete messages. This is an area that has been revised, so read the current text.
Evidence: Payment message completeness controls and the handling record for incomplete messages.
Read from the operative instrument: Which transfers are in scope, which elements must travel, and the treatment of intermediaries.
Designated non-financial businesses and professions
The customer due diligence, record keeping and reporting requirements extend to designated categories of non-financial business, in the circumstances the standards specify.
Evidence: Equivalent programme evidence, proportionate to the business.
Read from the operative instrument: Which categories, and which services, are designated nationally.
New technologies and new products
Assess the risks arising from new products, business practices, delivery mechanisms and technologies before launch, and mitigate them.
Evidence: A product risk assessment record predating launch, and the mitigations it produced.
How the platform supports it
Capability, and the control it traces to
Each row below describes behaviour the product documentation records, and carries the identifier of the control-register row it traces to, so a claim can be checked rather than taken on trust.
- Risk-based customer assessmentCustomer risk assessments are produced from a governed model, recorded with the triggering event and the factors that drove them, and drive due diligence tier, monitoring segment and review cycle rather than sitting beside them.Control C-07
- Ownership traced to natural personsOwnership declarations are cycle-safe, historical and independently verifiable, so a chain can be traced through intermediate entities and the position at a past date reproduced.Control C-08
- Screening with retained match evidenceSanctions, politically-exposed-person and adverse media screening retain the source, the list version and the match evidence, and clearing a hit requires appropriate clearance rather than a single click.Control C-11, C-12
- Explainable detectionDetection retains rule, version and evaluation evidence and supports deterministic replay, which is what makes a monitoring programme assessable rather than merely present.Control C-09
- Governed reporting with submission evidenceReports are generated from approved mappings and cannot be recorded as submitted without external evidence of the submission.Control C-14
- Audit, retention and legal holdAn append-only per-tenant audit chain with verifiable anchors, write-once evidence storage, and retention policy with legal holds that refuse an unlawful purge.Control C-16, C-17, C-18
- Separation of duties across sensitive actionsMaker-checker on sensitive actions, separated database privileges, and deployment that refuses unsafe defaults, missing secrets and unsigned content packs.Control C-03, C-20, C-23
What we do not claim
On a compliance product the absence of a claim is information a buyer needs as much as the presence of one.
- This is a mapping by theme, not a citation. Recommendation numbers are deliberately absent: the numbering is stable but the text is revised, and a page that cites a number while describing a superseded requirement is more misleading than one that cites nothing.
- We make no assessment of Nigeria's technical compliance or effectiveness ratings, and nothing here should be read as one.
- Compliance is with national law. The standards are the frame; they are not the obligation.
Verify before you rely on this page
This page states obligations qualitatively and carries no figures. Before acting on anything here, confirm the following against the instrument currently in force for your licence category — and record the date you checked it.
- Which Recommendation and Interpretive Note each theme above corresponds to in the FATF publication currently in force. No citation appears on this page until that mapping has been checked.
- Whether any theme above has been materially revised since this copy was written, particularly beneficial ownership transparency, wire transfer information and virtual assets.
- The Nigerian implementation of each theme, which is the obligation that actually binds the reader.
- Any current statement about Nigeria's standing in the international review process, if the page is to mention one at all.
Talk to a specialist
Talk through the mapping with someone who has implemented it
Bring your own control inventory. We will walk the themes above against what you already operate and be specific about the gaps.