CBN AML Penalties: Fines and Sanctions for Nigerian Fintechs
Under the CBN Anti-Money Laundering and Combating the Financing of Terrorism (Administrative Sanctions) Regulations, 2018 (S.I. No. 1 of 2018), fines for AML/CFT non-compliance are set per infraction in a Schedule, tiered by institution type —minimum penalties on a bank range from ₦10,000 (small, continuing contraventions) up to ₦20 million (e.g. failing to report a suspicious transaction), with escalation to licence suspension or revocation for systemic failures. This page lists the breaches, their regulatory basis, and the corresponding minimum sanctions for a Deposit Money Bank (DMB); Other Financial Institutions (OFIs) face lower tiered minimums under the same Schedule.
Reviewed by the StackWeaver team · Published 2026-10-18 · Updated 2026-10-26 · Sources: CBN AML/CFT (Administrative Sanctions) Regulations, 2018 (S.I. No. 1 of 2018); CBN AML/CFT/CPF Regulations 2022; Money Laundering (Prevention and Prohibition) Act 2022
This page is under review and is hidden from search engines. Its figures come from the Schedule to CBN's 2018 sanctions regulations. CBN's March 2026 Baseline Standards (BSD/DIR/PUB/LAB/019/002) refer to the CBN AML, CFT and CPF (Administrative Sanctions) Regulations, 2023, which appear to replace the 2018 text. We have not yet read the 2023 schedule, so do not rely on these amounts. Confirm current figures with the CBN or a Nigerian lawyer.
All fines and sanctions below are drawn from the Schedule to the CBN AML/CFT (Administrative Sanctions) Regulations, 2018 (S.I. No. 1 of 2018), read directly against its 48-item Schedule, item by item. The CBN AML/CFT/CPF Regulations 2022 and the Money Laundering (Prevention and Prohibition) Act 2022 set the underlying compliance duties, but neither sets the fine amounts — the 2022 Regulations (§70) expressly defer penalties to "the relevant extant Administrative Sanctions Regulations." Two rows below (BVN/NIN, agent network) are governed by separate CBN circulars not contained in the 2018 Schedule and are marked accordingly. These are not StackWeaver's estimates. Use the linked source to verify current figures before making any compliance or legal decisions.
AML/CFT breach penalties table
| Breach | Regulation | Sanction | Severity |
|---|---|---|---|
| Failure to report a suspicious transaction to the NFIU | MLPPA 2022 s.7(2) (24hr duty); 2018 Sanctions Schedule, item 24 | Min. ₦20M on the DMB, +₦2.5M on the Executive Compliance Officer, +₦2M on the Chief Compliance Officer | HIGH |
| Failure to establish/apply Board-approved CDD/KYC policy and risk classification | 2018 Sanctions Schedule, items 15 & 20 | Min. ₦15M on the DMB (policy) or ₦7M (risk classification) | HIGH |
| No internal system for detecting and reporting suspicious activity | 2018 Sanctions Schedule, item 23 | Min. ₦10M on the DMB | CRITICAL |
| Failure to integrate BVN/NIN for customer accounts | CBN BVN/NIN circulars — not in the 2018 Sanctions Schedule | Not confirmed against the 2018 Schedule; verify current figure against the applicable BVN/NIN circular before citing | HIGH |
| No PEP / UN-sanctions-list screening mechanism | 2018 Sanctions Schedule, item 13 | Min. ₦15M on the DMB | CRITICAL |
| Agent network not covered by AML controls | CBN Agent Banking guidelines — not in the 2018 Sanctions Schedule | Not confirmed against the 2018 Schedule; verify current figure against the applicable agent-banking guideline before citing | HIGH |
| Inadequate record-keeping / retrieval system (< 5 years) | 2018 Sanctions Schedule, items 21 & 22 | Min. ₦10M on the DMB (5-yr records) or ₦5M (retrieval system) | MEDIUM |
| No chief AML/CFT compliance officer of appropriate status | 2018 Sanctions Schedule, item 39 | Min. ₦10M on the DMB, +₦500K per Board member | HIGH |
Source: CBN AML/CFT (Administrative Sanctions) Regulations, 2018 (S.I. No. 1 of 2018), Schedule items cited per row. Figures shown are the Schedule's minimum penalty on a Deposit Money Bank (DMB); Other Financial Institutions (OFIs) face lower tiered minimums under the same Schedule, and amounts can run higher case by case.
Beyond fines: escalation path
Financial penalties are the first-tier response. The CBN's escalation path for serious or repeated AML/CFT breaches includes:
- Formal regulatory warning — recorded in the institution's supervisory file.
- Financial penalty — a minimum penalty per the 2018 Schedule, tiered by institution type and specific breach (₦10,000 up to ₦20 million for a bank), plus restitution of any proceeds of non-compliance.
- Directed remediation — a mandatory 30–90 day remediation order with re-examination.
- Licence suspension — suspension of payment institution or mobile money operator licence pending remediation.
- Licence revocation — permanent withdrawal of the licence for systemic failures or wilful non-compliance.
- NFIU/EFCC referral — for suspected wilful facilitation of money laundering, the CBN refers the matter to the NFIU and/or EFCC for criminal investigation under the ML(PP) Act 2022.
What examiners look for
A CBN AML examination is evidence-led. Examiners are looking for three things:
Transaction monitoring that runs in real-time and produces alerts — not a system that exists on paper but has no evidence of having run in the last 30 days.
Audit trails for STR decisions, CDD completion dates, BVN/NIN verification timestamps, and sanctions screening hits and dispositions — logged, retrievable, and attributable to a named individual.
A designated MLRO, board-approved AML policy, staff training records, and a risk assessment that is less than 12 months old — signed and dated by named individuals.
Common questions
What is the CBN fine for AML non-compliance?
Under the CBN AML/CFT (Administrative Sanctions) Regulations, 2018 (S.I. No. 1 of 2018), fines for AML/CFT breaches are set per infraction in a Schedule, tiered by institution type — from ₦10,000 for a small institution's continuing breach up to ₦20 million for a bank that fails to report a suspicious transaction — plus restitution of any proceeds. Repeated or serious breaches can result in licence suspension or revocation.
Can the CBN suspend a fintech licence for AML failures?
Yes. The CBN can suspend or revoke a payment institution licence. AML/CFT failures that are systemic or repeated are escalated to licence action rather than a financial penalty alone.
What happens if a Nigerian fintech misses an STR filing deadline?
Failure to file a Suspicious Transaction Report within 24 hours exposes the institution to CBN sanctions and NFIU enforcement. The NFIU can independently refer matters to the EFCC.
How do I reduce CBN AML penalty risk?
The most effective approach is to close gaps before an examination: real-time transaction monitoring, automated STR/CTR filing to goAML, completed BVN/NIN CDD, and a documented MLRO function. StackWeaver's CBN AML Readiness Calculator scores your current posture.
CBN AML Readiness Calculator
Eight questions. A posture score, gap list, and recommended remediation scope — mapped to the CBN Baseline Standards. Free, no account required.