Glossary

AML and CFT terminology, defined plainly

81 terms a compliance team uses daily, each defined in a sentence or two, with the distinction people most often get wrong called out and a link to where the concept is operationalised in the platform.

Definitions, not thresholds

What a suspicious transaction report is does not change when a regulation is amended. The value that triggers a cash report does. So these entries define concepts and never state a threshold, a deadline, a retention period or a penalty — where a term only has meaning once a figure is attached, the entry says so and points you at the operative instrument.

For the Nigerian obligations themselves, start with the compliance section.

A

Back to index

Adverse mediaalso: negative news

Publicly reported information suggesting that a customer or a connected person has been involved in financial crime, corruption, regulatory action or comparable conduct. It is used as an input to due diligence and to risk rating, alongside sanctions and politically-exposed-person screening.

Adverse media is a research finding, not a match against an authoritative list. It has to be adjudicated: whether the article is about this person, whether the report is credible, and whether the conduct is relevant to the risk being assessed.

In the platform: Screening and watchlistsCustomer and CDD

Alert

A single output of a detection control — a monitoring rule firing, a screening match, or a referral — indicating activity or a relationship that warrants human review. An alert is a question, not a conclusion.

In the platform: Transaction monitoringInvestigation and casework

Alert disposition

The recorded outcome of reviewing an alert, together with the reason it was reached: closed as expected activity, closed as a duplicate, closed for data quality, escalated to investigation, and so on.

Dispositions are only analytically useful if the reason comes from a closed, governed vocabulary. Free-text closure notes tell you the queue was cleared; they do not tell you which control is generating noise.

In the platform: Transaction monitoringInvestigation and casework

AMLAnti-money laundering

The set of laws, supervisory expectations, institutional policies and operational controls intended to prevent, detect and report the movement of criminal proceeds through the financial system.

Audit trail

The durable record of who did what, to which record, when, and with what result. In an AML system it is what allows a decision to be reconstructed long after the people involved have moved on.

An audit trail that can be edited or deleted by the same people whose actions it records is a log, not a control. Append-only storage and independent verifiability are what make the difference.

In the platform: Audit and privacySecurity architecture

B

Back to index

Beneficial owner

The natural person who ultimately owns or controls a customer, or on whose behalf a transaction is conducted. Control can arise through ownership, through voting rights, or through other means such as the right to appoint or remove senior management.

Ownership and control can diverge. A structure where no one meets an ownership test may still have a person who controls it, and identifying only the shareholders is an incomplete answer.

In the platform: Customer and CDD

C

Back to index

Case

The investigation record for one subject: the trigger, the evidence gathered, the analysis, the conclusion, the approval and, where applicable, the report that resulted.

One subject per case. Files that accumulate several customers because their transactions touched are difficult to review and difficult to report from, since no one can tell which evidence supports which subject.

In the platform: Investigation and casework

Cash-intensive business

A business whose ordinary operations generate large volumes of cash — retail, hospitality, transport, some agency models. The category matters because genuine cash turnover provides cover for illicit cash to be introduced alongside it.

Being cash-intensive is a risk characteristic, not a finding. The control question is whether the observed cash activity is proportionate to the business the customer actually operates.

In the platform: Customer and CDDTransaction monitoring

CDDCustomer due diligence

Identifying the customer and verifying that identity from reliable sources, identifying beneficial owners, understanding the purpose and intended nature of the relationship, and monitoring the relationship over time to check that activity remains consistent with what is known.

CDD is not an onboarding event. The ongoing element — keeping information current and comparing behaviour against it — is where most of the value and most of the failures are.

In the platform: Customer and CDD

CFTCountering the financing of terrorism

Measures aimed at detecting and disrupting the funding of terrorist acts and organisations. It sits alongside anti-money-laundering measures and shares most of the same controls.

The underlying pattern differs from money laundering: terrorist financing can involve small sums and funds of entirely legitimate origin, so value-based detection alone is a poor fit.

Correspondent banking

An arrangement where one bank provides account and payment services to another, allowing the second bank's customers to transact in a market or currency where it has no presence.

The correspondent generally has no relationship with, and no direct visibility of, the underlying customers. That indirectness is the reason the relationship attracts additional due diligence on the respondent institution and its own controls.

In the platform: Customer and CDD

CTRCurrency transaction report

A report submitted to the financial intelligence unit for a cash transaction at or above a prescribed threshold. Unlike a suspicious transaction report, it is triggered by an objective criterion rather than by suspicion — the transaction meets the definition, so it is reported.

The threshold, the aggregation rules and the timing are set by the operative regulation in each jurisdiction and change from time to time. Take them from the current instrument, not from a vendor page.

In the platform: Governed reporting

Customer risk rating

An assessment of the money laundering and terrorist financing risk a particular customer relationship presents, produced from defined factors and used to set the intensity of due diligence, monitoring and review.

The rating is only a control if something downstream changes when it changes. If due diligence, monitoring sensitivity and review frequency are identical across bands, the model is documentation.

In the platform: Customer and CDD

D

Back to index

Data minimisation

The principle that personal data collected and retained should be limited to what is necessary for the stated purpose. In AML systems it applies to what is captured at onboarding, what is copied into a case file, and what appears in an export.

It sits in tension with record keeping, which requires retention. The resolution is usually purpose-scoping and access control rather than deletion.

In the platform: Audit and privacy

DNFBPDesignated non-financial business or profession

A business outside the financial sector that is nonetheless subject to AML/CFT obligations because of the services it provides — categories internationally include real estate agents, dealers in precious metals and stones, lawyers, notaries, accountants and trust and company service providers.

Which categories are designated, and what each is required to do, is set by national law and supervisory instruction. Confirm the current designation for your business against the operative Nigerian material rather than assuming the international list applies unchanged.

In the platform: SCUML and DNFBPs

E

Back to index

EDDEnhanced due diligence

Additional due diligence measures applied where risk is assessed as higher: more information about the customer and the beneficial owners, establishing source of funds and source of wealth, senior approval to open or continue the relationship, and closer ongoing monitoring.

EDD is a set of measures, not a status. A file marked as EDD with no additional evidence in it has recorded an intention rather than performed a control.

In the platform: Customer and CDD

Enterprise-wide risk assessment

The institution's own assessment of the money laundering and terrorist financing risks inherent in its customers, products, channels and geographies, and of how effectively its controls mitigate them.

It is the document the whole risk-based approach rests on: customer risk models, monitoring coverage and due diligence tiers are supposed to be derived from it, and an assessment that nothing downstream references is an artefact rather than a foundation.

Escalation

The act of moving a matter from routine review to investigation, or from investigation to a decision-maker with authority to report or to exit a relationship.

An escalation path is only real if refusing to escalate is also recorded and reviewable. Programmes that only document escalations cannot demonstrate the quality of the decisions not to.

In the platform: Investigation and casework

F

Back to index

False negative

Activity or a relationship that should have been detected by a control but was not — a rule whose threshold sat above the behaviour, a screening configuration that missed a spelling variant, a segment no rule covered.

False negatives are invisible by nature, which is why below-the-line testing exists: you sample what a control would not have raised and check it by hand.

In the platform: Transaction monitoringScreening and watchlists

False positive

An alert that, on review, reflects activity or a match that is not what the control was looking for. A control that produces none is either perfectly calibrated or not firing.

The useful measure is not the raw rate but the rate per rule alongside what each rule contributes: a noisy rule that produces most of your reports is not the same problem as a noisy rule that has never produced one.

In the platform: Transaction monitoringScreening and watchlists

FATFFinancial Action Task Force

The intergovernmental body that sets international standards on combating money laundering, terrorist financing and proliferation financing, and that assesses countries against them through mutual evaluation.

FATF standards bind countries, not institutions. An institution complies with its own national law, which implements the standards; the two are related but they are not the same text.

In the platform: FATF Recommendations

FIUFinancial intelligence unit

The national agency that receives, analyses and disseminates reports of suspicious and threshold-based transactions submitted by reporting entities.

In the platform: Governed reporting

Fuzzy matching

Comparison that tolerates difference — spelling variants, transliteration, name order, missing components — so that a record can be matched against a list entry that is not written identically.

Tolerance is a dial with two costs. Loosen it and review volume rises; tighten it and genuine matches are missed. The setting is a risk decision, it belongs to the institution, and it should be documented and tested rather than left at a vendor default.

In the platform: Screening and watchlists

G

Back to index

goAML

An application developed by the United Nations Office on Drugs and Crime for financial intelligence units, providing the registration and reporting channel through which reporting entities submit reports in a structured format.

The specific schema version, code lists, registration procedure and submission channel are set by the receiving financial intelligence unit and are obtained from it directly. Treat the authoritative artefacts as the only source.

In the platform: Governed reportingNFIU and goAML

I

Back to index

Independent testing

Periodic review of the AML/CFT programme by a function that does not run it — internal audit, or an external party — covering design, operating effectiveness and the quality of the decisions the programme produced.

Independence is about reporting line and incentive, not job title. A review performed by people who report to the person accountable for the programme is a self-assessment.

In the platform: Audit and privacy

Integrationthird stage of money laundering

The stage at which laundered funds are returned to the legitimate economy in a form that appears to have a lawful origin — property, business investment, apparently ordinary income.

K

Back to index

KYCKnow your customer

The identification and verification component of customer due diligence: establishing who the customer is and confirming it from reliable, independent sources.

Often used loosely as a synonym for the whole due diligence obligation. It is narrower: knowing who someone is does not by itself tell you whether their activity makes sense.

In the platform: Customer and CDD

L

Back to index

Lawful basis

The ground on which personal data may lawfully be processed under data protection law. Processing carried out to meet a statutory AML/CFT obligation is generally justified on a different basis from processing carried out for commercial purposes.

Identifying the basis is a legal determination for the institution and its data protection officer. It also determines which data subject rights apply and how they interact with reporting confidentiality.

In the platform: Audit and privacyNDPA data protection

Layering

The stage of money laundering in which funds are moved through transactions, accounts, instruments or jurisdictions to obscure their origin and break the audit trail.

Legal hold

An instruction that suspends routine deletion of specified records because they are relevant to an investigation, a regulatory request or litigation.

A hold has to be able to override a retention schedule and an erasure request, and the override has to be recorded. A system where a scheduled purge can silently remove held records has a retention policy but not a hold.

In the platform: Audit and privacy

Lookback reviewalso: remediation review

A retrospective examination of a defined historical period, usually because a control was found to be defective or absent, to determine what would have been detected had it been working.

Scoping is the whole exercise: the period, the population, the criteria and the disposition standard should be agreed and documented before work starts, because they will be scrutinised afterwards.

In the platform: Investigation and caseworkTransaction monitoring

M

Back to index

Maker-checkeralso: four eyes

A control in which one person prepares an action and a different person approves it before it takes effect, with both identities and the timing recorded.

It only functions when the system enforces that the two are different people, and when refusing is a normal outcome. An approval rate at or near one hundred per cent is not evidence of quality.

In the platform: Investigation and caseworkGoverned reporting

MLROMoney laundering reporting officer

The individual designated to receive internal reports of suspicion, decide whether a report is made to the financial intelligence unit, and act as the institution's point of contact on AML/CFT matters.

Titles and the exact statutory role differ between regimes; what is consistent is that the accountability sits with a named person who must be able to act independently.

In the platform: MLROGoverned reporting

Model validation

Independent assessment of whether a detection or risk model does what it is claimed to do: that its logic is sound, its inputs are adequate, its parameters are justified, and its outputs behave as expected on real data.

It applies to rule-based monitoring and risk-scoring models as much as to statistical ones. A rule set is a model; the fact that a human wrote the arithmetic does not exempt it from testing.

In the platform: Transaction monitoring

Money laundering

The process of disguising the origin of proceeds of crime so that they can be used without attracting attention. Conventionally described in three stages: placement, layering and integration.

Mutual evaluation

A peer assessment of a country's AML/CFT regime against the international standards, examining both technical compliance — are the laws in place — and effectiveness — do they produce results.

The effectiveness half is what drives supervisory pressure on institutions, because it is measured by outcomes such as the usefulness of the reports the financial intelligence unit receives.

In the platform: FATF Recommendations

N

Back to index

Name screening

Comparing customer, beneficial owner and counterparty names against sanctions lists, politically-exposed-person data and other watchlists to identify potential matches for review.

Screening produces candidates. The control is the adjudication that follows: whether this record is that listed person, recorded with the evidence and the list version it was decided against.

In the platform: Screening and watchlists

NDPANigeria Data Protection Act

Nigeria's data protection legislation, administered by the Nigeria Data Protection Commission, governing how personal data is processed, secured, retained and transferred, and setting out the rights of data subjects.

AML/CFT processing and data protection obligations have to be reconciled rather than traded off — lawful basis, retention, subject rights and reporting confidentiality all interact. The current text, subsidiary instruments and registration requirements are matters for the institution's legal and data protection advisers.

In the platform: NDPA data protectionAudit and privacy

NFIUNigerian Financial Intelligence Unit

Nigeria's financial intelligence unit: the national agency that receives suspicious and threshold-based transaction reports from reporting entities, analyses them, and disseminates financial intelligence.

Registration, the reporting channel, the accepted formats and the operative deadlines are set by the unit itself and are obtained from it directly.

In the platform: NFIU and goAMLGoverned reporting

Nominee arrangement

An arrangement in which a person or entity holds shares, an account or an asset on behalf of another, so that the registered holder is not the beneficial owner.

Nominee arrangements are frequently legitimate. They matter to due diligence because they break the assumption that the registered owner is the person to be identified.

In the platform: Customer and CDD

Non-face-to-face relationship

A relationship established or conducted without the customer being physically present, where identity is verified remotely through documents, electronic data or biometric checks.

The risk is not the channel itself but the assurance obtained through it. A remote check with strong liveness and authoritative data verification can be stronger than a counter visit with a photocopy.

In the platform: Customer and CDD

O

Back to index

Onboarding

The process of establishing a new customer relationship: capturing and verifying identity, identifying beneficial owners, understanding the intended purpose of the relationship, screening, and producing an initial risk assessment.

In the platform: Customer and CDD

Ongoing monitoring

The continuing obligation to scrutinise transactions during a relationship to check they are consistent with what is known about the customer, and to keep the underlying customer information current.

It has two halves and programmes usually do one well. Scrutinising transactions against a customer profile that has not been refreshed in years is comparing today's behaviour with a stale expectation.

In the platform: Transaction monitoringCustomer and CDD

P

Back to index

PEPPolitically exposed person

An individual entrusted with a prominent public function, whose position may present a higher risk of involvement in bribery or corruption. Definitions commonly extend to family members and close associates.

Being a politically exposed person is not an allegation, and it is not a reason to refuse a relationship. It is a trigger for enhanced measures — establishing source of wealth and source of funds, senior approval, closer monitoring.

In the platform: Screening and watchlistsCustomer and CDD

Placement

The first stage of money laundering: introducing criminal proceeds into the financial system, typically the point at which cash is most exposed to detection.

Predicate offence

The underlying criminal conduct that generated the proceeds being laundered. Which offences qualify is defined by national law.

A report of suspicion does not require the reporting entity to identify the predicate offence, and attempting to prove one is not the reporting entity's role.

Proliferation financing

The provision of funds or financial services used for the manufacture, acquisition or movement of weapons of mass destruction and related materials, contrary to national or international obligations.

Controls are primarily sanctions-driven and turn on counterparties, goods, end use and shipping routes rather than on transaction value.

Purpose and intended nature of the relationship

What the customer says they will use the relationship for, and what activity that implies — expected products, expected turnover, expected counterparties and expected geographies.

This is the benchmark ongoing monitoring compares against. If it is captured as free text and never coded, no rule can use it, and the comparison becomes a judgement made from memory.

In the platform: Customer and CDDTransaction monitoring

Q

Back to index

Quality assurance review

Sampling completed work — alert dispositions, investigations, reports — against a defined standard, to measure and improve the quality of decisions rather than their volume.

Quality assurance measures the same decisions the maker-checker control already approved. That is the point: it tests whether the approval step is working, not just whether it happened.

In the platform: Investigation and casework

R

Back to index

RCARelative or close associate

A family member or close business or personal associate of a politically exposed person, covered by enhanced measures because such a person can be used to hold or move value on the principal's behalf.

In the platform: Screening and watchlists

Record keeping

The obligation to retain customer due diligence records, transaction records and the evidence behind reports for a prescribed period, in a form that allows them to be produced to a competent authority.

The prescribed period, when it starts running, and the acceptable format are set by the operative regulation. Retrievability matters as much as retention: records that exist but cannot be produced in a usable form within a reasonable time do not discharge the duty.

In the platform: Audit and privacy

Red flagalso: indicator

An observable characteristic of a customer, transaction or relationship that has been associated with financial crime and that warrants further enquiry.

A red flag is a prompt to look, not a finding. Treating a list of indicators as a checklist of conclusions produces both weak reports and unjustified exits.

Reliance on third parties

Meeting parts of the due diligence obligation using measures performed by another regulated party — an introducer, a group entity, an agent — rather than performing them directly.

Where reliance is permitted at all, the ultimate responsibility generally remains with the relying institution, and it must be able to obtain the underlying records without delay. Whether and how reliance is permitted is jurisdiction-specific.

In the platform: Customer and CDD

Retention schedule

The documented policy stating how long each category of record is kept, on what basis, and what happens at the end of the period.

It has to reconcile two pressures pulling in opposite directions: statutory record keeping requires retention, data protection requires that data is not kept longer than necessary. The reconciliation is a legal determination, not a system default.

In the platform: Audit and privacy

Risk appetite

The level and type of financial crime risk the institution has decided, at board level, that it is willing to accept in pursuit of its business objectives.

Appetite becomes operational only when it is expressed as decisions: which customer types are not served, which jurisdictions are out of scope, what triggers senior approval. Stated as a sentiment it changes nothing.

Risk-based approach

The principle that an institution should identify and assess the money laundering and terrorist financing risks it faces, and apply controls proportionate to them — more where risk is higher, less where it is demonstrably lower.

It is not permission to do less. It is a requirement to be able to explain why what you do is proportionate, which is a higher evidential burden than applying a uniform rule to everyone.

Rule tuning

Adjusting the parameters of a detection rule — thresholds, windows, segments, exclusions — to improve the proportion of its output that is worth reviewing, without losing the coverage it exists to provide.

Above-the-line testing shows what a change still catches; below-the-line testing samples what it would stop catching. A proposal without the second half is a volume reduction, not a tuning exercise.

In the platform: Transaction monitoring

S

Back to index

Sanctions

Restrictive measures imposed by international bodies or national authorities against named persons, entities, sectors or countries, prohibiting or restricting dealings with them.

Sanctions compliance is an absolute obligation rather than a risk-based one: a prohibited dealing is prohibited regardless of the institution's own risk assessment. This is the main respect in which it differs from the rest of the AML/CFT programme.

In the platform: Screening and watchlists

Sanctions evasion

Conduct designed to circumvent restrictive measures — using intermediaries, front companies, altered payment messages, mislabelled goods or third-country routing to obscure a designated party's involvement.

Detection generally depends on network and behavioural signals rather than name matching alone, because a successful evasion scheme is one where the designated name does not appear.

In the platform: Screening and watchlistsTransaction monitoring

SARSuspicious activity report

The term used in some regimes for a report of suspicion to the financial intelligence unit, broader in name than a transaction report because the suspicion may arise from conduct rather than from a specific transaction.

SCUMLSpecial Control Unit against Money Laundering

The Nigerian body responsible for the registration and AML/CFT supervision of designated non-financial businesses and professions.

Registration requirements, the categories in scope, reporting obligations and identifier formats are set by the operative Nigerian instruments and supervisory instruction. Confirm them directly rather than inferring from an international category list.

In the platform: SCUML and DNFBPs

SDDSimplified due diligence

A reduced set of due diligence measures applied where the institution has assessed and can demonstrate that the risk in a given category is lower.

Simplified is not absent. The identification obligation and ongoing monitoring still apply; what is reduced is the extent, timing or intensity of specific measures, and the reduction has to be justified by the risk assessment.

In the platform: Customer and CDD

Segmentation

Grouping customers into populations that behave alike — by entity type, occupation, product mix, expected turnover — so that detection thresholds and expectations can be set per population rather than across the whole book.

Poor segmentation is the largest single source of monitoring noise in most programmes, and improving it is a data exercise rather than a modelling one.

In the platform: Transaction monitoringCustomer and CDD

Segregation of duties

Splitting a sensitive process so that no single person can both initiate and complete it — the general control of which maker-checker is the most common specific form.

In the platform: Security architectureInvestigation and casework

Shell company

A company with no significant operations, employees or assets of its own, existing primarily to hold assets, receive payments or sit in an ownership chain.

Shell companies have lawful uses. What matters is whether the structure is explained by the customer's stated business, and whether the beneficial owner behind it can be established.

In the platform: Customer and CDD

Smurfing

Splitting a larger sum across multiple people acting as depositors or senders, so that no individual transaction looks notable and no single person appears to move the whole amount.

Closely related to structuring; the distinguishing feature is the use of multiple individuals rather than only multiple transactions. Detection depends on linking the participants, not on examining any one of them.

In the platform: Transaction monitoring

Source of funds

The origin of the specific money used in a particular transaction or relationship — which account it came from, and what generated it.

Frequently confused with source of wealth. Source of funds explains this money; source of wealth explains how the customer came to have money at all. A high-risk relationship generally needs both.

In the platform: Customer and CDD

Source of wealth

How the customer's overall wealth was accumulated — business ownership, employment, inheritance, investment, disposal of assets — and whether that is consistent with what is observed.

Establishing it means obtaining evidence, not recording an assertion. A file stating that wealth derives from business income, with nothing behind it, has documented the customer's answer rather than the institution's finding.

In the platform: Customer and CDD

STRSuspicious transaction report

A report made to the financial intelligence unit where the reporting entity knows, suspects or has reasonable grounds to suspect that funds are the proceeds of crime or are related to terrorist financing. In some regimes the equivalent is called a suspicious activity report.

The obligation is triggered by suspicion, not by proof, and once suspicion is formed the regime will generally impose a time limit and confidentiality restrictions. Take the trigger point, the deadline and the confidentiality rule from the operative instrument in your jurisdiction.

In the platform: Governed reportingInvestigation and casework

Structuring

Deliberately breaking a sum into smaller transactions so that no individual one meets a reporting or review threshold.

Structuring is defined by intent to evade a threshold, which is why it is detected through pattern — repeated amounts sitting just below a level, across accounts or days — rather than by examining any single transaction.

In the platform: Transaction monitoring

Suppressionalso: whitelisting

Configuring a control to stop raising a known, previously adjudicated match or alert pattern, so that reviewers are not asked the same answered question repeatedly.

A suppression is a decision that a category of activity does not need looking at. It needs an owner, a documented reason, an expiry and a review — a permanent, unreviewed suppression removes coverage as effectively as deleting the rule, and does it invisibly.

In the platform: Screening and watchlistsTransaction monitoring

T

Back to index

Threshold reporting

An obligation to report transactions meeting an objective criterion — typically a value at or above a prescribed level, sometimes with aggregation across related transactions — regardless of whether anything about them is suspicious.

Every parameter here is jurisdictional: the level, the currency, whether and how transactions aggregate, which instruments count and by when the report is due. Read them from the current operative regulation.

In the platform: Governed reporting

Tipping off

Disclosing to the subject, or to a third party, that a report of suspicion has been made or is being considered, or that an investigation is under way, in a way that may prejudice it.

Most regimes restrict this and attach serious consequences, but the precise scope — who may be told, what may be said to a customer asking why a payment is delayed — varies. Decide it from your own operative rule and institutional policy.

In the platform: Investigation and casework

Trade-based money laundering

Moving value by misrepresenting trade transactions — over- or under-invoicing, invoicing for goods never shipped, multiple invoicing of the same shipment, or misdescribing quality or quantity.

It is difficult to detect from payment data alone, because the payment can be entirely ordinary; the discrepancy sits between the payment and the trade documentation.

In the platform: Transaction monitoring

Transaction monitoring

The automated and manual scrutiny of transactions against expected customer behaviour and known typologies, producing alerts for human review.

Monitoring is a detection control, not a decision control. Its output is a question for an investigator; the quality of the programme is decided by what happens after the alert, not by how many were raised.

In the platform: Transaction monitoring

Travel rule

The requirement that specified originator and beneficiary information accompanies a transfer along the payment chain, so that each institution handling it can see who is on both sides.

Which transfers are in scope, which data elements must travel, and what an intermediary must do with an incomplete message are set by national implementation.

In the platform: IntegrationsTransaction monitoring

Typology

A documented method by which money laundering or terrorist financing is carried out — the pattern of behaviour, the roles involved and the signals it tends to leave.

Typologies are what detection rules are supposed to be derived from. A rule whose typology cannot be stated in a sentence is a rule nobody can tune, because there is no statement of what it is meant to catch.

In the platform: Transaction monitoring

U

Back to index

UBOUltimate beneficial owner

The natural person at the end of an ownership or control chain, once intermediate companies, trusts and nominees have been traced through.

The word ultimate is the operative one. Identifying the immediate shareholder of a customer is not identifying the ultimate beneficial owner unless that shareholder is a natural person.

In the platform: Customer and CDD

V

Back to index

VASPVirtual asset service provider

A business conducting activities such as exchange between virtual assets and fiat currency, transfer of virtual assets, or custody of virtual assets on behalf of others.

Whether and how virtual asset activity is licensed and supervised differs sharply between jurisdictions and changes quickly. Confirm the current Nigerian position from the operative material rather than from general guidance.

W

Back to index

Watchlist

A structured list of persons or entities that customer and counterparty records are screened against — sanctions designations, politically-exposed-person data, internal exclusion lists, law enforcement requests.

List provenance is part of the control. A screening result is only interpretable if you know which list, which version and which publication date it was decided against, and that an entry removed upstream did not disappear from your record of past decisions.

In the platform: Screening and watchlists

Missing a term?

Tell us what you looked for and did not find

This glossary grows from what people search for. If a term you needed is not here, that is useful information.

Suggest a term Read the blog

AML and CFT terminology, defined plainly

Definitions, not thresholds

A

Adverse mediaalso: negative news

Alert

Alert disposition

AMLAnti-money laundering

Audit trail

B

Beneficial owner

Blind index

C

Case

Cash-intensive business

CDDCustomer due diligence

CFTCountering the financing of terrorism

Correspondent banking

CTRCurrency transaction report

Customer risk rating

D

Data minimisation

DNFBPDesignated non-financial business or profession

E

EDDEnhanced due diligence

Enterprise-wide risk assessment

Escalation

F

False negative

False positive

FATFFinancial Action Task Force

FIUFinancial intelligence unit

Fuzzy matching

G

goAML

I

Independent testing

Integrationthird stage of money laundering

K

KYCKnow your customer

L

Lawful basis

Layering

Legal hold

Lookback reviewalso: remediation review

M

Maker-checkeralso: four eyes

MLROMoney laundering reporting officer

Model validation

Money laundering

Mutual evaluation

N

Name screening

NDPANigeria Data Protection Act

NFIUNigerian Financial Intelligence Unit

Nominee arrangement

Non-face-to-face relationship

O

Onboarding

Ongoing monitoring

P

PEPPolitically exposed person

Placement

Predicate offence

Proliferation financing

Purpose and intended nature of the relationship

Q

Quality assurance review

R

RCARelative or close associate

Record keeping

Red flagalso: indicator

Reliance on third parties

Retention schedule

Risk appetite

Risk-based approach

Rule tuning

S

Sanctions

Sanctions evasion

SARSuspicious activity report