Services

Senior compliance, scoped to your sector and your scale.

We organise our practice by who you are. Find the card that fits, or talk to us — many engagements blend across two or three.

01 · Deposit Money Banks

For Banks and Financial Institutions

Commercial banks, mortgage banks, payment service banks, finance companies and other CBN-licensed FIs subject to the full AML/CFT/CPF Regulations 2022.

  • AML/CFT/CPF program reviews and gap assessments against the CBN Regulations 2022 and CDD Regulations 2023
  • Independent testing — the annual statutory requirement, conducted by senior practitioners
  • CBN examination readiness, including pre-inspection mock audits
  • Remediation of regulatory findings and closure of inspection points
  • Policy and procedure drafting or refresh; Board and senior management AML training
  • KYC/CDD process redesign, transaction monitoring rule tuning, sanctions screening calibration
  • Beneficial ownership data quality reviews aligned with CAMA Section 119 and the CAC BO register

02 · Microfinance Banks

For Microfinance Banks

Unit, State and National-tier MFBs — including the digital banks delivering retail financial services at scale via the MFB licence.

  • Right-sized AML programs proportionate to tier, scale and risk profile
  • Outsourced AML support and fractional Chief Compliance Officer arrangements
  • Onboarding and ongoing training for in-house compliance officers
  • Compliance function build-out for digital MFBs scaling from thousands to millions of customers
  • Tier-specific risk frameworks and policy libraries
  • Vendor selection support for automated AML tooling under the new CBN Baseline Standards

03 · Fintech & Payments

For Fintechs, MMOs & Payment Companies

PSPs, PSSPs, PTSPs, switching companies, super-agents, mobile money operators and payment service banks — at any scale, including pre-licence.

  • License application support — the AML/KYC/CDD components specifically
  • Fintech-specific AML programs designed to work at velocity, not against it
  • API-friendly compliance design so monitoring keeps pace with growth
  • Implementation guidance for the new CBN Baseline Standards: rule tuning, model governance, audit trails
  • Fraud–AML convergence frameworks for institutions where the two functions now overlap
  • Sandbox engagement support and onboarding-flow CDD reviews
  • VASP-adjacent risk assessment for fintechs offering on/off-ramps

04 · Cross-Border Remittance

For International Money Transfer Operators

IMTOs operating under the Reviewed CBN Guidelines on International Money Transfer Services 2024 and their authorised dealer partners.

  • IMTO licence application support — AML/CFT components and policy suite
  • Wire transfer information completeness reviews under FATF Recommendation 16
  • Correspondent banking AML support and de-risking response
  • Cross-border STR coordination with NFIU and counterpart FIUs
  • Sanctions screening for cross-border counterparties — UN, OFAC and Nigeria Sanctions List
  • Diaspora corridor risk assessment and typology analysis

05 · Gaming & Casinos

For Casinos and Gaming Operators

Land-based and internet casinos, sports betting operators, lottery operators and online gaming platforms — covered as DNFBPs under MLPPA 2022.

  • SCUML registration support — advisory and document preparation (SCUML registration itself is free)
  • Sector-specific AML/CFT programs aligned to FATF casino-sector guidance
  • CTR and STR submission workflows for the mandatory SCUML portal (effective 1 January 2026)
  • Player due diligence (PDD) frameworks, including high-roller source-of-funds protocols
  • Compliance officer training — and recruitment support where the role is vacant
  • Navigation across the fragmented post-Supreme-Court state-level regulatory landscape

06 · Other DNFBPs

For Other Designated Non-Financial Businesses

Real estate, legal practice, accounting, dealers in precious metals and luxury goods, hospitality, NPOs, trust & company service providers, and other SCUML-registrable businesses.

  • SCUML registration advisory and document preparation (registration is free; we charge only for our services)
  • Sector-tailored AML policies — the requirements differ markedly between real estate, legal practice and NPOs
  • Compliance officer outsourcing for SMEs that cannot justify a full-time hire
  • Annual AML training programs for staff and management
  • Suspicious transaction reporting workflow design and submission training
  • Record-keeping system reviews against the five-year statutory retention obligation

How an engagement runs

Scoped quickly. Delivered cleanly. Documented for the file.

  • Discovery (Week 1) A focused conversation with your Chief Compliance Officer, Head of Risk and — where appropriate — Internal Audit and the MLRO. We confirm the regulatory frame, scope, deliverables and timeline in writing before any fee is committed.
  • Fieldwork (Weeks 2–N) Senior practitioners on site or remote, working against an agreed test plan. Findings are surfaced as they emerge — not held back for a final read-out — so management has time to respond.
  • Reporting A written report with findings, risk ratings, regulatory references and remediation actions. The format is the one your regulator expects to see; the language is the one your Board can act on.
  • Follow-through Where the engagement is remediation, we close findings rather than list them. Where it is examination readiness, we sit with your team through the inspection. Where it is fractional CAMLO support, we are reachable.

Not sure which fits?

A 30-minute scoping conversation, at no cost, will usually tell us — and you — what the right engagement looks like.

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