Industries we serve
Six sectors. Each with its own regulator, risk profile and reporting rhythm.
We do not pretend that one AML program fits every business. The CBN's expectations of a commercial bank are not the same as SCUML's expectations of a casino. Find your sector — and what we deliver inside it.
Deposit money banks & financial institutions
Commercial banks, mortgage banks, finance companies and payment service banks — institutions under the full weight of the CBN AML/CFT/CPF Regulations 2022.
Regulatory frame: CBN AML Regulations 2022, CDD Regulations 2023, BOFIA 2020, MLPPA 2022, TPPA 2022, the new Baseline Standards for Automated AML Solutions (March 2026), and NDIC joint supervision.
What we deliver: Program reviews and gap assessments, annual independent testing, examination readiness, post-inspection remediation, KYC/CDD process redesign, transaction monitoring rule tuning, sanctions screening calibration, beneficial ownership data quality reviews, Board and senior-management training.
Engagement length: 4–12 weeks for a program review; 2–4 weeks for examination readiness; ongoing for fractional support.
Microfinance banks
Unit, State and National-tier MFBs — including the digital banks delivering retail financial services at scale via the MFB licence.
Regulatory frame: CBN AML Regulations 2022, MFB-specific licensing guidelines, MLPPA 2022, the new Baseline Standards for Automated AML Solutions.
What we deliver: Right-sized AML programs proportionate to tier and scale, fractional Chief Compliance Officer arrangements, in-house compliance officer training, build-out of compliance functions for digital MFBs scaling rapidly, vendor selection support for automated AML tooling.
Engagement length: 6–10 weeks to stand up a program; fractional CAMLO retainers from one quarter onward.
Fintech, MMOs & payment companies
PSPs, PSSPs, PTSPs, switching companies, super-agents, mobile money operators and payment service banks — at any scale, including pre-licence.
Regulatory frame: Multiple CBN licence categories, the new Baseline Standards for Automated AML Solutions, MLPPA 2022, TPPA 2022, Nigeria Data Protection Act 2023 (intersecting with KYC), and EFCC scrutiny of "Post No Debit" actions during fraud investigations.
What we deliver: License application support (AML/KYC/CDD components), fintech-specific AML programs that work at velocity, API-friendly compliance design, implementation guidance for the CBN Baseline Standards, fraud–AML convergence frameworks, onboarding-flow CDD reviews, sandbox engagement support.
Engagement length: 3–6 weeks for licence-stage support; 8–16 weeks for full program build; ongoing for scale-up support.
International money transfer operators
IMTOs operating under the Reviewed CBN Guidelines on International Money Transfer Services 2024 and their authorised dealer partners.
Regulatory frame: Reviewed CBN IMTS Guidelines 2024 (₦2bn capital for Nigerian-owned / USD 1m for foreign-owned), MLPPA 2022, TPPA 2022, FATF Recommendation 16 on cross-border wire transfers, and correspondent banking expectations.
What we deliver: IMTO licence application support, wire transfer information completeness reviews under FATF R.16, correspondent banking AML support, cross-border STR coordination with NFIU, sanctions screening for cross-border counterparties, diaspora corridor risk assessment.
Engagement length: 4–8 weeks for licence-stage advisory; 6–12 weeks for end-to-end program review.
Casinos & gaming operators
Land-based and internet casinos, sports betting operators, lottery operators and online gaming platforms — designated non-financial businesses and professions under MLPPA 2022.
Regulatory frame: MLPPA 2022 (extended in 2022 to internet and ship-based casinos), EFCC DNFBP Regulations 2022 administered by SCUML, FATF casino-sector guidance, and the fragmented post-Supreme-Court state-level landscape (NLRC, Lagos LSLB, FSGRN, others).
What we deliver: SCUML registration support (advisory and document preparation — SCUML registration itself is free), sector-specific AML/CFT programs, CTR and STR submission workflows for the mandatory SCUML portal (effective 1 January 2026), player due diligence (PDD) frameworks, high-roller source-of-funds protocols, compliance officer training and recruitment support.
Engagement length: 4–6 weeks for SCUML registration and initial program; ongoing training and compliance support thereafter.
Real estate, legal, accounting & other DNFBPs
Real estate, legal practice, accounting and audit, dealers in precious metals and stones, dealers in luxury goods and cars, hospitality, NPOs (including churches, mosques, charities and foundations), trust & company service providers, and other SCUML-registrable businesses.
Regulatory frame: MLPPA 2022, EFCC DNFBP Regulations 2022, SCUML oversight, sector-specific thresholds (real estate: identify all parties; precious metals/stones: identify customers for any cash transaction ≥ USD 1,000).
What we deliver: SCUML registration advisory and document preparation, sector-tailored AML policies (real estate vs. legal practice vs. NPO frameworks differ markedly), compliance officer outsourcing for SMEs, annual AML training for staff and management, suspicious transaction reporting workflows, record-keeping system reviews against the five-year statutory retention obligation.
Engagement length: 2–4 weeks for SCUML and policy work; annual retainers for training and reporting support.
Not sure which sector or service fits?
Many institutions hold more than one licence and fall across categories. A short scoping conversation usually clarifies what you need — and what you don't.
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