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.

The guidelines, issued in March 2026, formally recognise artificial intelligence and machine learning as tools banks and payment companies can use to monitor suspicious transactions.

They also require financial institutions to deploy automated anti-money laundering systems capable of detecting unusual activity and reporting it to regulators.

Under the directive, banks, mobile money operators, international money transfer operators and other regulated financial institutions must implement systems that support customer risk profiling, sanctions screening, transaction monitoring and case management.

“As financial services become increasingly digitised and complex, manual AML/CFT/CPF controls are no longer sufficient to manage evolving risks,” the central bank said in the framework.

For years, many compliance processes in Nigeria’s financial sector relied heavily on manual reviews and rule-based systems. The new standards shift the focus toward technology-driven monitoring.

Banks will now be expected to deploy automated platforms that can track customer behaviour, flag unusual transaction patterns and support real-time reporting of suspicious activity to regulators, including the Nigerian Financial Intelligence Unit.

These systems must integrate with core banking platforms and customer onboarding systems so institutions can analyse transactions in the context of a customer’s profile rather than isolated payment data.

The framework also encourages the use of tools such as anomaly detection, behavioural pattern recognition and automated risk scoring. Systems should be capable of identifying name variations during sanctions checks and screening customers against politically exposed persons lists.

However, the central bank insists technology cannot operate without oversight. Financial institutions that deploy machine-learning models must validate those systems regularly and ensure investigators can understand why alerts were triggered.

Real-time fraud monitoring becomes a requirement

The new standards don’t just focus on money laundering, as banks must also deploy automated fraud monitoring tools that track transactions across cards, electronic channels, deposits and lending platforms.

The systems are expected to operate in real time or near real time so institutions can stop suspicious transactions before funds leave an account.

Fraud monitoring tools may operate on the same platform as anti-money laundering systems, but the regulator requires institutions to maintain separate management and governance structures for each function.

Data from the Financial Institutions Training Centre shows fraud losses climbed to ₦3.29 billion in the first quarter of 2025, representing a 603% increase year-on-year, with 12,347 cases reported across the banking sector.

Regulators say the growing use of digital payment platforms, instant transfers and online banking has created new opportunities for organised financial crime.

Aligning Nigeria with global compliance trends

Nigeria’s new regulations also place the country within a bigger global shift toward technology-based compliance.

Industry estimates suggest that about 90 per cent of financial institutions worldwide will use artificial intelligence or machine learning in anti-money laundering programmes by 2026, up from roughly 62% in 2024.

Regulators in other jurisdictions are already seeing similar adoption. Data from the UK’s Financial Conduct Authority shows about 75% of financial firms already use AI in compliance operations, with another 10% planning deployment within three years.

These technologies can reduce false alerts by as much as 40%, allowing compliance teams to focus on genuinely suspicious transactions rather than reviewing thousands of routine alerts.

The regulatory technology market is also expanding. Analysts estimate the global RegTech market could reach $19.5 billion by 2026, driven largely by demand for AI-powered compliance systems.

Implementation timeline for banks and fintechs

The central bank has given financial institutions a phased timeline to implement the new framework.

Banks classified as deposit money institutions must fully comply within 18 months, while other financial institutions have up to 24 months to deploy compliant systems.

Each institution must also submit a detailed implementation roadmap to the regulator within three months of the circular’s issuance.

Supervisory teams will monitor compliance through inspections and regulatory reviews. Institutions that fail to meet the requirements risk sanctions under existing banking regulations.

Part of a clean-up of Nigeria’s financial system

The new CBN AI anti-money laundering (AML) standards follow several regulatory movements aimed at strengthening financial oversight in Nigeria.

In recent years, the central bank strengthened customer verification regulations, requiring new account holders to provide a Bank Verification Number or National Identification Number. Authorities also introduced stronger reporting requirements for fraudulent transactions and refund investigations.

These reforms were important in Nigeria’s removal from the grey list of the Financial Action Task Force in 2025, after the country improved transparency in its financial system.

Regulators are now pushing banks and fintech companies toward a more integrated financial crime monitoring system where fraud detection and anti-money laundering management share data and analytics.

Officials say the goal is to detect suspicious activity faster and close the gaps criminals use to move money through the financial system.

Even so, a new AML technology study from data and AI leader SAS, featuring contributions from SAS partner KPMG, finds that interest in AI continues to outpace its full implementation.

Based on a global survey of 850 members of the Association of Certified Anti-Money Laundering Specialists (ACAMS), the study reveals:

• Adoption of AI and machine learning (ML) remains modest. Only 18% of survey respondents report having AI/ML solutions in production. Another 18% are piloting AI/ML solutions, while 25% plan to implement AI/ML in the next 12-18 months; 40% have no current plans to adopt AI/ML.
• Interest in generative AI (GenAI) technology is robust but seemingly cautious. Nearly half of respondents say they are currently piloting GenAI (10%) or are in the discovery phase (35%) – no small amount for an emerging technology. Still, that leaves 55% with no plans to adopt GenAI.

The road to integration: The state of AI and machine learning adoption in anti-money laundering compliance, a follow-up to a similar survey published in 2021, explores the current state of AI/ML adoption for anti-money laundering. SAS has also published a data dashboard that allows users to explore, visualise and filter survey insights by region and institution size.

“The survey indicates that AML practitioners believe regulators have cooled on AI,” said Kieran Beer, Chief Analyst and Director of Editorial Content at ACAMS. “Fifty-one percent said their regulator promotes or encourages AI/ML innovation – a 15-point drop from 2021. Those who said regulators are apprehensive or cautious about AI/ML adoption rose from 28% to 36%, and those describing regulators as ‘resistant to change’ more than doubled from 6% to 13%.”

“AI and machine learning aren’t a magic fix for every financial crime challenge. But they are showing to be increasingly effective in certain areas – especially those involving large amounts of data,” said Timo Purkott, Global Fraud and Financial Crime Transformation Lead at KPMG International and Partner at KPMG in Germany. “That includes automating alerts from transaction monitoring, generating enterprise-wide risk assessments, reporting suspicious activities, AML checks, striving to reduce false positives and more. It all depends on data. Organisations must invest in their data management infrastructure to maximise the value of AI and ML and stay ahead of financial criminals.”

AI and ML are producing value – when fully implemented

The survey produced a number of insights on how AI technology is being used in anti-money laundering and why companies may be slow to fully integrate it into their operations:

• Organisations are identifying more uses for AI/ML. In the first edition of the survey in 2021, 78% of respondents cited either improving the quality of investigations and regulatory findings (40%) or reducing false positives (38%) as their primary reason for AI/ML adoption. This year, the answers to that question were more diverse. Those top two answers were still the same, but the combined percentage dropped by 11 points to 67%. Meanwhile, detecting complex risks rose from 17% to 21%, and “none of the above” jumped from 5% to 13%.
• Reasons for notadopting AI/ML have also evolved. In 2021, the top obstacle for passing on AI was budget constraints, at 39%. That slipped to 34% in this survey and was overtaken by the lack of a regulatory imperative, up slightly to 37%. Lack of available skills is also becoming less of a concern, with the percentage falling by nearly half to 11%. However, the “Other” category saw a significant rise from 5% to 19%.
• Reducing false positives is a growing priority. When asked about their priorities for AI/ML deployment, AML experts cited the reduction of false positives in existing surveillance systems at 38% (an 8% increase since 2021). Automating data enrichment for investigations and due diligence (25%) and detecting new risks with advanced modeling techniques (23%) also remained popular responses, though both dropped by several points from the previous survey. The remaining 13% of respondents cited customer segmentation for behavioural analysis.

Reducing false positives and negatives was also the top answer for which area offers the most value from AI/ML, at 38%. However, the other two available choices – better and faster investigations (34%) and triaging high- and low-risk alerts (28%) – weren’t far behind.

Machine learning is making a big impact – but don’t sleep on NLP. When asked to rank three technologies based on their impact, machine learning was once again the top choice by far at 58%, up 6% since 2021. Robotic process automation saw a corresponding drop to 28%, while natural language processing (NLP) was the last choice at 14%.

While machine learning’s ability to identify patterns in large amounts of data is certainly impactful, might the low response for NLP indicate that compliance teams are missing early warning signs due to underdeveloped capabilities?

Laying the groundwork for a competitive advantage

“The key to unlocking the full potential of AI and machine learning is integration of data sources, teams and technology.  The first step toward that integration is establishing a data ecosystem that combines data from all sources,” said Stu Bradley, Senior Vice President of Risk, Fraud and Compliance Solutions at SAS. “In this ACAMS survey, 86% of respondents reported doing some form of integration between AML, fraud and information security processes. Nearly a third have a fully integrated case management capability across those functions. Another third collaborate through cross-functional teams to deploy controls to prevent financial crimes exposure.

“Some organisations may be waiting on regulatory guidance. Firms that press ahead with integrating data and operations with governance in mind are laying the groundwork for responsible innovation in AI and ML and will enjoy a competitive advantage over those who hesitate.”

[Featured Image Credit]

Flip to January 2025, the Nigerian government, through the efforts of the National Information Technology Development Agency, (NITDA) and the Nigerian Financial Intelligence Unit, (NFIU) have kick-started an initiative that would ensure the exclusion of the country from the FATF Grey List by May 2025.

This initiative was a directive of the President to the request of the NFIU to develop and implement an Anti-Money Laundering/Counter Financial Terrorism/Counter Proliferation of Firearms Data Management Framework and Platform in collaboration with NITDA.

A fintech expert who is familiar with the FAFT grey list told Techeconomy that Nigeria had late last year submitted over 50 per cent of the list required to exit the list.

At the inaugural technical session to kick start the process at the NITDA Headquarters in Abuja, on Friday, Kashifu Inuwa, the director general of NITDA, disclosed that the technical session meeting would mark a “remarkable mile in the country’s journey to exit from the From the Financial Action Task Force Grey List the nation has been enlisted into since February 2013.

He said the enlistment of the country into the Grey List was occasioned by seven issues among which are the rising capital inflows into the country, the shortcomings in combating money laundering, the shortcomings in combating arms financing and the shortcomings in combating terrorism financing.

According to him other factors include “the nation’s deficiencies in anti-money laundering regime, counter-terrorism financing regime and counter arms proliferation financing regime.”

He noted that the desire of the President to combat corruption and financial crime through innovation and technology necessitated his directive to NITDA to work with NIFU to build a system that would help NFIU to better manage financial data and compliance in the country.

He said,

“Today we are kick starting a meeting to start that project that will take us out of the Grey List and build that robust system. The main objective of the system is to help us with global compliance; to help Nigeria position itself as a key player in the global effort to combat financial terrorism and other crimes. This will help us to create visibility in Nigeria as well as improve our global reputation and relationship in the financial market.”

While maintaining that the initiative will help in improving national security because of its capability to see any financial transaction inflow into the country, NITDA boss maintained that it will also help to “track any illicit flow as well as empower us to highlight or identify criminal network in our financial sector.”

Inuwa averred that the system will strengthen the nation’s law enforcement and the economy because it will tame crime in the economy which will encourage investment into the country.

In her remarks, the NFIU Chief Executive Officer, Barrister Hafsat Abubakar Bakari described the project as a “game changer” because it will not only help the country to exit the grey list as directed by the president but improve the Data Integration Management System for Anti-Money Laundering and Combating the Financing of Terrorism, (AMLCFT.)

While acknowledging the introduction of technology in the way things are now being done at the NFIU, she called on Nigerians to support the initiative of not only the exiting of the grey list but to sustain the gains that the country has made from it.

She said,

“The Grey List is not just a one-off project, it is a continuous project. The next cycle of evaluation will be done in the year 2027 and we do not want a situation where we exit from the Grey List and another evaluation is conducted by the FITF, and we find ourselves back on the grey list again.”

Barrister Bakari added that “this is why we have decided that the use of technology will give credibility to every statistic that we have, not just to our domestic stakeholders, but also to our international partners. Everything should be done in real time and accessible, credible, and factual, and that is the project that we are doing today.”

While expressing her gratitude to NITDA and the Director General for their contributions to the project and other national service, she noted that she believes in local content initiative and that was why the NFIU made submission to Mr. President that NITDA should drive the process which he “graciously approved.”

“So, congratulations, NITDA, for the confidence that the NFIU has in you, and for the confidence that Mr. President has in you to drive this project,” she noted.

Adedeji Olajide, the chairman, House Committee on Information and Communication technology and Cyber Security, who also graced the event assured both NITDA and NFIU of legislative support in their quest to secure the country against illicit financial flow and other vices.

While acknowledging that it was a welcome development to see the executive and the legislator working together to achieve common goals in our country Honourable Olajide said “You can be sure of it that you have all of the legislative support to get whatever you need done, and we will make sure there are no stumbling blocks in your way.”

He said it has become imperative to “change the narrative” and position Nigeria to its rightful place among the comity of nation, adding that he understood all the benefits and values the introduction of technology will bring to NFIU operations.

He said,

“Nigeria is going to take its rightful place as the giant of Africa. We are going to lead the way in cutting-edge technologies to make sure that Nigeria has all of the right people, the right processes, and the right technology to move the country to the next level which is also in line with the agenda of Mr. President Ahmed Bola, who is also a technology person.”

The objective of the AML/CFT/CPF Data Management Framework/Platform are; to achieve FATF compliance, to enable Nigeria’s removal from the Grey List and restore international confidence, to enhance NFIU’s operational capacity through automation, intelligence integration, and scalability, establish a robust and sustainable framework to ensure long-term operational and financial independence and to position Nigeria as a global leader in financial intelligence and AML/CFT practices, setting benchmarks for other nations

The development and implementation of this platform are imperative to addressing the identified gaps, strengthening Nigeria’s financial integrity, and securing its place as a trusted partner in the global financial ecosystem.

It can take many forms, including embezzlement, bribery, and kickbacks. These practices have the potential to raise the costs of government projects and contracts, as well as divert public funds to personal accounts.

The Human Environmental Development Agenda (HEDA) Resource Centre reported over the weekend that Nigeria lost N1,623,584,000,000 and $825,679,500,000 to corrupt officials between 1999 and 2022.

The shocking revelation was made during a press conference following the public presentation of a publication titled “Impunity Galore: A chronicle of some unresolved high-profile corruption cases in Nigeria.”

Its Chairman told reporters that the title was coined after extensive research on recent events revealed that impunity has continued unabated.

He said: “In many of the cases, it is either investigation was not completed, committee report not made public, white-paper not released or there is clear sabotage within and or outside government.

“It is also noteworthy that the cases listed in this chronicle are not exhaustive and the selection has not been discriminated in any manner.
We have only done our best to report on such high-profile cases as much as we can find stories about. So, even if we overlooked some, we should be able to update them in the near future.

However, we have done our best to cover the majority of the ground.”

According to Suraju, the document is a compilation of corruption cases being investigated by the Economic Financial Crimes Commission (EFCC), the Independent Corrupt Practices and other Related Offences Commission (ICPC), and relevant National Assembly committees.

“The collection is centered on cases between 1999 and 2022,” he clarified.

The Executive Secretary, Sulaimon Arigbabu, observed that the petitions and legal action being executed by the organization were to help to keep these humongous cases of graft evergreen in the memories of Nigerians.

“So, we try to keep a public view on the issues of corruption that had either suffered in the legal process or with this latest work, we are doing those issues that didn’t make it through the court process and some that didn’t go there,” he explained.

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.”