Compliance teams need a traceable path from customer onboarding to investigation and reporting. We engineer CDD, sanctions screening, transaction monitoring and case workflows around your data, risk policies and Nigerian regulatory obligations.
AML engineering that connects customer risk, alerts and reporting evidence
Service overview
AML & compliance engineering connects customer records, beneficial ownership, sanctions screening and transaction monitoring with investigation and reporting workflows. Sparkr Digitals helps compliance and engineering teams turn risk policies into tested rules, accountable decisions and retrievable audit trails.
We map controls to the CBN AML/CFT/CPF Regulations 2022 and your licence-specific obligations. Your MLRO retains responsibility for suspicion decisions, reporting and control approvals.
The final CBN Baseline Standards for Automated AML Solutions were issued on 10 March 2026. Implementation starts on issuance: full compliance is due within 18 months for DMBs and 24 months for OFIs, with roadmaps within three months. We help map integration gaps, ownership and delivery milestones.
The problem
An alert queue is not a compliance decision.
Why AML queues lose their evidence
Fragmented customer records, untested thresholds and disconnected case notes make investigations harder to reconstruct. We connect source data, rule versions and decision records so analysts can explain an alert, its disposition and any resulting report.
The traps
Trap 0101 / 05
CDD before scoring
Customer risk without context
Incomplete KYC and beneficial ownership records weaken customer risk assessments. We define required evidence, review triggers and escalation paths so onboarding decisions can be explained and revisited.
Trap 0202 / 05
Resolve, then record
Screening without match review
A name match is not a confirmed sanctions hit. We connect screening results to review queues, record list versions and supporting evidence, and define approval routes for potential matches.
Trap 0303 / 05
Tune with evidence
Rules that never get reviewed
Static thresholds create noise and leave coverage gaps. We test monitoring scenarios against data quality and typologies, document tuning decisions and require approval before rule or model changes reach production.
Trap 0404 / 05
Evidence with decisions
Cases detached from source data
A case note without transaction lineage is hard to defend. We link customer risk, transactions, alerts and analyst actions, with role-based approvals and an audit trail of decisions, changes and supporting evidence.
Trap 0505 / 05
Track through to receipt
Reports without submission proof
Preparing a report is not the same as completing submission. We build validation, approval, goAML submission tracking and receipt reconciliation, with escalation for errors and deadlines.
The process
How we deliver the programme
We agree scope, access and accountable owners before delivery. Each stage has review points and documented decisions, so security, compliance and operations can see what has been tested, what remains open and who owns the next action.
Step 01
Map duties
Map CBN requirements, customer risk and reporting duties to systems, owners and gaps. Define the baseline-standards implementation roadmap.
Step 02
Connect data
Integrate customer, beneficial ownership and transaction records. Test completeness, identifiers and source-to-case lineage.
Step 03
Set rules
Configure sanctions screening and monitoring scenarios. Test thresholds, segmentation and escalation with compliance owners.
Step 04
Tune & approve
Validate scenarios and models, review false positives and document tuning, version control and approvals.
Step 05
Operate
Test case handling, goAML reporting, receipts and audit trails. Hand over review schedules and accountable owners.
What you get
Defined controls, documented decisions, clear owners.
Control gap map
Requirements, system gaps, accountable owners and implementation roadmap milestones.
CDD & KYC workflows
Customer risk, beneficial ownership, enhanced review triggers and approval records.
Screening configuration
Sanctions match review, list-version evidence and documented escalation routes.
Monitoring rulebook
Scenarios, thresholds, test results, tuning rationale and rule-version history.
Case & reporting flows
Investigation records, approvals, goAML validation, submission receipts and reconciliation.
Governance pack
Audit trails, access roles, model validation, change control and periodic review responsibilities.
Which Nigerian AML rules apply?
The CBN AML/CFT/CPF Regulations 2022 apply to banks, OFIs and PSPs. We assess licence-specific duties and map CDD/KYC, beneficial ownership, monitoring, sanctions screening, records and reporting into controls. We do not promise regulatory approval or guaranteed compliance.
What changed in March 2026?
The CBN issued final Baseline Standards for Automated AML Solutions on 10 March 2026. Implementation starts on issuance, with full compliance within 18 months for DMBs and 24 months for OFIs. Roadmaps are required within three months. The May 2025 text was an exposure draft.
When must an STR be reported?
Report an STR within 24 hours of identifying suspicion, regardless of transaction value. We support NFIU goAML workflows with schema validation, approvals, submission receipts and reconciliation. The MLRO owns the reporting decision; an automated alert alone is not an STR.
What are the CTR thresholds?
CTR reporting covers transactions above ₦5 million for individuals and ₦10 million for bodies corporate, within seven days under the 2022 regime. We support NFIU goAML reporting and distinguish these thresholds from cash-payment restrictions.
How do you tune monitoring rules?
We test scenarios, segmentation and thresholds against your data and risk assessment. Tuning records include the rationale, validation results, approvals and version history. Model governance adds documented limitations, change control and periodic review.
Is Nigeria still on the FATF grey list?
No. Nigeria left FATF increased monitoring on 24 October 2025. Removal does not abolish AML obligations: institutions still need effective CDD, screening, monitoring, reporting and evidence of internal controls.
Can you integrate existing systems?
We assess customer, ledger, screening and case-system interfaces first, then scope integrations and data-quality checks.
How is delivery priced?
Pricing depends on source systems, transaction volumes, screening tools, case workflows and reporting scope. We separate licence, integration and ongoing support costs in the proposal.
The 72-hour clock: what NDPA and the GAID demand of your systems
6 min read
How breach assessment, incident records and escalation support risk-based notification under the NDPA 2023 and GAID 2025.
Sophos or Fortinet? Choosing the security stack for a Nigerian enterprise
6 min read
Compare endpoint, firewall and management requirements before choosing products, licences and operational responsibilities.
What a regulator-ready VAPT report contains
6 min read
Scope, evidence, severity and remediation owners: the records that turn a technical assessment into an accountable action plan.
What the CBN's baseline standards for automated AML mean for your stack
6 min read
The final March 2026 standards: implementation windows, integration requirements and auditable workflows for compliance teams.
Designing internal tools people actually use
6 min read
Lessons from Relix, Victora and Interoly: clear queues, permissions and task flows that help teams complete their daily work.
Other services
