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Purpose overviewInsight
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Insight overviewAnalysis
Nigeria AML Intensive · Microfinance
Lagos, December 2026
Your proportionality argument is only as good as the document behind it. A working clinic for Nigerian microfinance banks that produces that document, and the eight institutional outputs that follow from it.
Applications open. Admission is by institution and confirmed in writing.
Applications open. Admission is by institution and confirmed in writing.
Why this, and why now
The Central Bank of Nigeria issued the Baseline Standards for Automated AML, CFT and CPF Solutions on 10 March 2026. Implementation roadmaps were due by 10 June 2026. Other Financial Institutions, which includes microfinance banks, must reach full compliance twenty-four months from issuance.
That leaves roughly twenty months. It is more time than deposit money banks have, and it is not as much as it sounds. Procurement, independent validation and board approval cycles all run on calendars an institution does not control.
The three positions
| The position | What the Standards say | Why it matters |
|---|---|---|
| The proportionality trap | Section 4 permits calibration to observable characteristics. One of those characteristics is the institution’s own documented risk assessment. | An institution without one does not have a proportionality argument. It has a budget constraint, and the Standards do not recognise that. |
| The elevated risk limit | Institutions in business lines with elevated inherent risk must apply enhanced monitoring commensurate with that profile, regardless of institutional size. | Agent banking and a cash-intensive customer base are the two triggers most microfinance banks do not recognise as applying to them. |
| The shared services route | Section 5.10(c) permits shared services and centralised arrangements with prior CBN approval, provided responsibilities are clearly allocated and documented. | This changes the economics of compliance for a smaller institution. Very few have explored it, and no single institution will convene it alone. |
What this is
General education belongs only where it supports an institutional decision. Every session produces or improves a defined work product. Your institution arrives with its own documentation and leaves with eight outputs it owns.
The unit of participation is the institution, not the delegate. Admission requires an executive sponsor, a defined institutional problem, completed pre-work and the authority to make implementation decisions.
What you leave with
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Two formats
The one-day Sector Clinic runs only where a sponsor underwrites the cohort. If you lead an association, a development finance institution or an apex body, see Sponsorship.
Two days · 9 and 10 December 2026
One day · 8 December 2026, subject to sponsorship
Boundaries
NAMLI is not provided by, endorsed by or conducted on behalf of the Central Bank of Nigeria. The programme is not a regulatory examination, an assurance opinion, a legal opinion, a certification, a vendor recommendation or a confirmation of compliance.
Your institution remains responsible for its regulatory interpretation, its submissions, its implementation decisions and its evidence. NAMLI does not rank or endorse vendors.
Inside the programme
Nine modules, eight outputs, the two formats and the week in Lagos.
Who should apply, how admission works, what to bring and the fees.
Underwrite a cohort of state and unit microfinance banks.
A former CBN supervisory lens and a methodological lens, working together.
Speak with the Programme Office. We respond within one working day.
The institutional application. About fifteen minutes, and confidential.
Places are confirmed in writing. Name an executive sponsor and the institutional problem you want the clinic to work on, and we will tell you within one working day whether the format fits.
