In a conversation with Brad Levy, chief executive of ThetaRay, a company focused on the “wiring” of trust through AI-powered monitoring that helps banks and fintechs scale safely while detecting and reporting financial crime, we examined what this speed means for risk, regulation, and trust in the financial system. 

Levy argues that old ways of tracking money flows no longer hold up.

Nigeria’s banking and fintech sector has expanded, almost faster than the systems built to regulate it. Payments now move in seconds, and fraud patterns move just as quickly. 

Regulators are responding with stronger policies and expectations.

For Levy, the transition is apparent. Systems built for manual checks cannot keep pace with today’s transaction volumes or the complexity of digital crime networks. He describes a system under stress, where scale has exposed the limits of human-led monitoring.

Across banks and fintechs, the gap in readiness varies. Some institutions are already adopting artificial intelligence and real-time oversight. Others still rely on older compliance models that struggle to connect customer data with live transaction behaviour.

The Central Bank of Nigeria’s recent direction on automated anti-money laundering (AML) systems sets a firm line, forcing the industry to move from gradual improvement to immediate action. Institutions now have to rethink how they see compliance, not as a back-office task, but as core infrastructure.

In this interview, Levy, who has spent his career building the plumbing of the global financial markets, first with nearly two decades at Goldman Sachs, then leading Symphony and MarkitSERV, explains what has changed, what still slips through the cracks, and why Nigeria’s approach may affect how digital finance is policed far beyond its borders.

TE: The Central Bank’s move makes automated AML systems effectively non-negotiable. From your vantage point, what changed in the risk sector to push regulators from guidance to outright mandates? 

Brad Levy (BL): The math simply stopped working for manual oversight. Nigeria has one of the most vibrant digital payment ecosystems in the world. You can’t monitor millions of instant transactions using spreadsheets and human eyes. 

The CBN’s March 2026 mandate recognises that guidance doesn’t stop automated, bot-driven crime. By mandating these systems, Nigeria is making a strategic move to protect the integrity of the Naira and ensure the country stays effectively connected to the global financial map.

TE: You’ve worked closely with financial institutions in Nigeria, where do most banks and fintechs actually stand today in terms of AML capability, and how wide is the gap? 

BL: The divide is significant, though it’s closing fast. We see forward-leaning institutions like Sterling Bank already moving toward a future-proof posture by putting AI at the centre of their monitoring. On the other hand, plenty of firms are still stuck in a “box-ticking” mindset.

The gap is most obvious when you look at the CBN’s anti-money laundering automation mandate. Most legacy systems can’t provide a unified view of the customer or link KYC/KYB data to transaction behaviour. 

The 18-month window for banks is tight, but the real pressure is the three-month requirement to submit a roadmap. If financial institutions haven’t started their gap analysis yet, they’re already behind.

TE: There’s a lot of talk about AI in compliance, but in practical terms, what kinds of financial crime patterns are still slipping through traditional monitoring systems that AI is better at catching? 

BL: Traditional systems are built on rules. They look for what we already know, like whether a transfer is over a certain dollar amount. Modern criminals have moved past that. They use smurfing or complex networks of mules to make illicit flows look like normal, low-value activity. AI catches the anomalies. 

It identifies patterns that look wrong even if we haven’t seen that specific tactic before. For a bank, it’s the difference between chasing 5,000 false alarms and actually finding the criminal network hidden in the noise.

TE: For Nigerian institutions, this goes beyond a tech upgrade to an operational shift. What are the biggest implementation challenges you’re seeing on the ground, especially around data quality, cost, and internal expertise? 

BL: The biggest hurdle is fragmented data. AI is only as good as what you feed it, and many institutions have their KYC data sitting in a different silo than their transaction logs. There is also a lingering perception that compliance is just a “tax” on doing business. 

I argue it’s a strategic asset. When you use AI to reduce false positives by 90%, you aren’t just satisfying the CBN; you’re making the entire bank more efficient. Your investigators can finally focus on real risks instead of low-value busywork.

TE: Do you see this directive as a Nigeria-specific response or part of a regulatory change across Africa? And how might it reshape expectations for cross-border transactions over the next few years? 

BL: Nigeria is the blueprint for the continent. We’re seeing similar shifts everywhere, from the EU’s new AML Authority to tightening rules in the US. This is Nigeria’s “mobile phone” moment. Just as the continent skipped landlines to go straight to mobile, Nigeria is leapfrogging the failing, manual era of compliance. 

By hard-coding AI and transparency into the banking system, Nigeria is making itself a much safer destination for global capital. This mandate turns compliance into a bridge for international trade rather than a barrier.

This ecosystem is supported by the innovative efforts of both financial institutions and fintechs, which have expanded access to financial services, driven adoption, and empowered millions of Nigerians. Innovations such as the Central Bank of Nigeria’s (CBN) eNaira, Africa’s first central bank digital currency, highlight how regulators are fostering groundbreaking solutions to enhance financial inclusion and modernize the economy.

One consistent theme in Nigeria’s financial services sector has been its unwavering focus on innovation and collaboration. From the early 2000s, when pioneers like Interswitch and NIBSS laid the groundwork, to the rise of fintech giants such as Paystack, Flutterwave, and PiggyVest in the 2010s, players in the ecosystem have consistently sought new ways to deliver value.

Today, blockchain is at the forefront of this evolution, with institutions adopting these technologies to improve efficiency and customer experiences. Zone, a trailblazer in regulated blockchain technology, is at the center of this shift, uniting banks and fintechs under a decentralized payment network.

In this exclusive interview, Sunday Agbi, vice president of Operations at Zone Payment Network, delves into how Zone is reshaping Nigeria’s payment landscape with its innovative infrastructure and partnerships.

TE: Zone has been described as a game-changer in the payments space. Can you give us an overview of what sets Zone’s infrastructure apart from existing payment systems in Africa?

Sunday Agbi: Zone’s infrastructure is Africa’s first regulated blockchain network for payments, and that alone marks a significant departure from conventional systems. Unlike traditional centralized systems, our decentralized network allows financial institutions to connect directly, eliminating the gaps experienced with centralized payment networks. This means faster transaction times, reduced costs, and increased security.

What truly sets us apart is how we’ve seamlessly integrated innovation with regulatory compliance. Zone was designed to address the unique challenges of Africa’s payment ecosystem while adhering to the highest standards of governance. By enabling direct, real-time interactions between financial institutions, our network ensures full transparency, making payments not only more reliable and secure but also more resilient.

This approach has earned the trust of leading financial institutions and regulators alike. By embedding compliance into the core of our infrastructure, Zone offers an interoperable system that empowers banks and fintechs to innovate without compromising security or regulatory standards.

TE: Collaboration with commercial banks and fintechs seems central to your strategy. How does Zone enable such partnerships, and what value do they bring?

Sunday Agbi: Collaboration is central to our mission because the future of payments depends on the synergy between traditional financial institutions and innovative fintechs. B

anks bring scale, trust, and deep customer relationships, while fintechs introduce agility, creativity, and new ways to engage users. Zone bridges these worlds, creating a unified infrastructure where both can thrive.

Our decentralized payment network enables seamless, real-time interactions between financial institutions on our network (both banks and fintechs alike).

For example, through our ZonePOS payment gateway,  financial institutions using ZonePOS can process transactions directly with the other, bypassing traditional intermediaries.

This not only reduces operational costs but also delivers a faster, more seamless experience for end-users.

Beyond technology, our partnerships are built on trust. By aligning with the regulatory frameworks of institutions like the Central Bank of Nigeria (CBN), we create an environment where both banks and fintechs can confidently innovate. This collaboration ultimately benefits merchants and consumers, strengthening Nigeria’s payment ecosystem.

TE: Zone operates in a highly regulated industry. How do you navigate compliance while staying innovative?

Sunday Agbi: Navigating regulatory compliance is non-negotiable in our space, and Zone prioritizes this at every level.

Our regulated blockchain infrastructure is not only innovative but also fully aligned with the requirements set by regulators like the Central Bank of Nigeria.

We actively engage with regulators to ensure our solutions meet and even exceed compliance standards. This involves building transparency into our system—such as ensuring full traceability of transactions—and using technology to enhance anti-money laundering (AML) and fraud prevention measures.

Ultimately, our commitment to compliance ensures that the ecosystem we’re building is both sustainable and trusted by all stakeholders.

TE: How is Zone preparing for the future of payments in Africa, given the rapid evolution of technology and customer expectations?

Sunday Agbi: The future of payments in Africa lies in scalability, accessibility, and trust. At Zone, we’re focused on expanding the capacity of our decentralized network to accommodate increasing transaction volumes while reducing latency to near-zero levels.

Furthermore, we continuously invest in our R&D to anticipate customer needs, ensuring our infrastructure is future-proof.

TE: Looking ahead, what does success look like for Zone in the next five years?

Sunday Agbi: Success for Zone is rooted in creating a payment ecosystem that transcends borders while continuing to redefine what’s possible within regulated blockchain technology.

Over the next five years, we aim to expand our network to connect financial institutions and fintechs not only across Africa but also on a global scale. By enabling seamless local and cross-border payments, Zone will become an essential bridge for financial services between emerging and developed markets.

We also envision Zone as the definitive example of what regulated blockchain can achieve—a concept championed by our CEO & Co-founder Obi Emetarom.

By demonstrating how decentralization and regulation can work in harmony, we aspire to set a global standard for innovation in payments.

In addition, we’re committed to evolving our network’s capabilities to support a broader range of use cases.

From powering regulated DeFi protocols to providing a platform for advanced financial products, Zone will continue to push the boundaries of what blockchain can do in a compliant, secure, and scalable manner.

Ultimately, success means building a financial infrastructure that empowers institutions, businesses, and individuals—enabling payments that are faster, more reliable, and inclusive, and ensuring that Africa remains a leader in the global financial innovation landscape.

The ever-changing regulatory climate necessitates the need for prudent risk management and compliance, particularly within the fintech ecosystem where the regulatory picture continues to evolve to protect both businesses and consumers.

The Central Bank of Nigeria (CBN) which is the apex regulator of all financial services, continues to establish more licenses and frameworks for operating across several areas of fintech.

Therefore, entrepreneurs need to stay abreast of these regulations to avoid compliance issues and ensure proper risk management.

These days, fintech companies operate across several jurisdictions, each with peculiar risk and compliance expectations. In addition, each subsector of fintech such as payments, switching & processing, mobile money operation (MMO) and blockchain, to name a few, comes with its own set of rules and regulations. Nonetheless, there are six key risks that all fintechs must consider in spite of sector or geographical location.

These are fraud risks, merchant and third-party risks, anti-money laundering (AML) and terrorist financing risks, consumer risks, credit risk and operational risks, and finally, cybersecurity and data privacy risks.

The great news is that management of these set of risks can be achieved through a combination of risk management and compliance tactics. Because these risks can be cumbersome for budding fintechs that just want to focus on perfecting their products, it is critical to onboard a competent Chief Compliance Officer (CCO), an experienced Chief Risk Officer (CRO) and Chief Administrative Officer (CAO). The CCO is responsible for ensuring that the organisation complies with all applicable laws, regulations, policies and procedures, while the CRO focuses on the identification and mitigation of all risks that could be a threat to profitability and productivity.

The CAO has a more general role of managing day-to-day operations which encompasses government relations, human resources, finance, compliance and more. A culture of compliance within the organisation must be built from the top down.

Auditors also have a key role to play when it comes to risk and compliance. Internal auditors investigate potential risks and weak points within the company’s systems and processes, while external auditors inspect financial statements to rule out fraud. Internal audit reports are used by management, while external audit reports are used by external stakeholders such as investors, creditors and the public.

The two roles are complementary as both are essential for the effective risk governance of an organisation. However, it is vital that the two functions maintain clear boundaries and preserve their independence.

The diagram below serves as a guide for risk management and compliance within the fintech space:

The compliance and risk management frameworks in a fintech firm should outline the control and oversight structures to manage multiple stakeholders present in evolving fintech operating models. The framework should take into cognizance, the compliance requirements at each stage of product development and the customer life cycle. 

Similarly, risk management frameworks should address the potential exposures created by fintech disruption, innovation, partnerships and ongoing regulatory and financial market developments.

Early last year, United Services Automobile Association (USAA) bank was fined a whopping $60 million by the United States Treasury Department for not complying with the agency’s Bank Secrecy Act regulations. The USAA bank failed to submit reports on suspicious banking transactions in a timely manner, which exposed the inadequate risk management framework of the bank.

In addition to the fine, USAA was issued a cease-and-desist order and required to take immediate corrective actions.

This occurrence supports the notion that without robust risk management and compliance practices, organisations will fall short in predicting potential risks, and therefore would not be able to take the appropriate steps to address them on time.

Information Security is one aspect of risk management which is often ignored but has an almost immediate impact on survival. In plain terms, information security refers to the technologies, procedures and methods designed and operated by organisations in order to prevent their networks, devices and data from security breaches such as unauthorized access, malware, data thefts or hacking. Information Security Risk Management is important because it helps to easily identify any vulnerabilities that could lead to data breaches or other security incidents. It also serves to prioritize the severity of each vulnerability based on its likelihood and impact.

Fortunately, there are many ways by which fintechs can improve their posture in Information Security Risk Management. Some of these are regular password change for customers and employees, regular IT security audit, the use of Artificial Intelligence (AI) and Machine Learning (ML) to track suspicious transactions, safety-oriented application testing, and so much more.

This comes at a crucial time as a 2022 study by Statista revealed that the average cost per data breach in financial services is now as high as US$ 5.97 million per breach.

Fintech start-ups face a higher risk of data breaches than legacy banks because their human and capital resources are not as robust as incumbents. Therefore, fintechs need to take extra steps for risk mitigation.

To succeed, regulators must perceive that risk management is part of the fintech company’s self-governing mechanisms. This means that the fintech must have identified risk, taken measures to assess it and mitigate against it.

The cost of non-compliance is not limited to monetary fines alone – often, it also results in the depletion of consumer trust which can be detrimental to start-up growth. With a robust risk management and compliance framework in place, fintechs can better navigate through occasionally ambiguous regulations, rather than waste productive time and resources dealing with all sorts of risk and compliance issues.

In your opinion, what are the greatest risks facing the fintech industry? How can the compliance culture of fintechs be built further? Comment below and let’s keep the conversation going.

Some existing regulations are: Risk-Based Cybersecurity Framework and Guidelines for Deposit Money Banks and Payment Service Providers by the Central Bank of Nigeria (CBN), Guidelines on Minimum Requirements for Data Protection in the Nigerian Telecommunications Industry by Nigerian Communications Commission (NCC), Guidelines for Data Protection Compliance in Nigeria by National Information Technology Development Agency (NITDA), Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Regulations by Nigerian Financial Intelligence Unit (NFIU).

In our next series on Building Resilience in Fintech Business, we will take a closer look at Ethics, Values and Accountability.

…Continue Reading HERE.

The Forrester Wave: Anti-Money-Laundering Solutions, Q3 2022 evaluates the industry’s 15 most significant anti-money laundering (AML) technology providers, assessing and ranking them based on 26 evaluation criteria.

As criminals grow more sophisticated in their money laundering methods, financial services organisations like banks and insurers rely on ever-more advanced AML solutions to detect financial crime.

Notably, SAS Anti-Money Laundering attained the highest score of any evaluated vendor in the “current offering” category.

The AI-powered anti-money laundering software solution scored 4.85 out of 5 overall and received the highest possible score in 12 of the category’s 13 criteria, including:

• Users and roles
• Watchlist management and screening
• Rules-based scoring and alerting
• AI/machine learning-based scoring and alerting
• Internationalisation, currencies, and reporting
• Scale

The influential research and advisory firm’s assessment of SAS’ current AML offering notes that it “provides an overall robust solution.”

“Key management for encrypting data is explicitly configurable,” the report continues. “Rules-based and AI/ML based risk scoring is nice and functional. The solution can also provide rule recommendations. Workflow for model building is also functional and intuitive. Case management screen customisation and usability is superior.”

According to a global AML study by SAS, KPMG and the Association of Certified Anti-Money Laundering Specialists (ACAMS), one-third of financial institutions have accelerated their adoption of AI and machine learning for AML compliance since the COVID-19 pandemic began. Moreover, those that have deployed these advanced AML capabilities are seeing tremendous benefits.

“While anti-money laundering compliance expectations have increased due to more complex regulatory priorities, AI and machine learning are delivering on their promise of making AML programs more automated, efficient and effective,” said David Stewart, Director of Financial Crimes and Compliance at SAS. “It’s not hype or hyperbole. SAS has helped financial institutions achieve more than 90% model accuracy, reduce false positives by up to 80% and realise a twofold improvement on their SAR conversion rate.”

Financial services sectors have a crucial role to play in the ongoing development of African countries and are priority sectors on African Continental Free Trade Area (AfCFTA) Trade in Services agenda. In support of this, each country needs to ensure that it has strong regulation in place and in line with best practice principles set out by the global watchdog.

Stephan Wessels, SAS Head of Customer Advisory for South Africa, said: “The cost and consequences of financial crimes and illicit finance is a plight that emerging economies in Africa cannot afford – and especially as markets become increasingly globalised in the digital era.”

Earlier this month the head of South Africa’s National Treasury expressed that the country is taking the global anti-money laundering regime seriously – and that the country intends to have addressed any regulatory weaknesses in its money laundering controls by the end of the year.

“This is certainly a great step forward for the country – and financial services providers will need to ensure that their business and practices are in keeping with updates to the regulation,” said Wessels.

“We are very proud to be names a Leader in anti-money laundering solutions by Forrester. This is a testament to our advanced market solutions that are built to fight against money laundering and illicit finance with AI, machine learning, intelligent automation and advanced network visualisation – and to meet the challenges and risks in an ever-changing operating environment.”