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.

From sophisticated money-laundering networks to cyber-enabled fraud rings, criminal actors are exploiting gaps in regulation and oversight.

As traditional finance evolves, so too have the methods and opportunities for abuse, and nowhere is this more evident than in the digital asset space.

Cryptocurrency and other digital assets promised a more inclusive and efficient financial system. But without the right guardrails, innovation can inadvertently create new avenues for exploitation. Over the last several years, financial crime has grown alongside the digital economy.

According to a Chainalysis report by July 2025 over $2.17 billion were reported stolen from cryptocurrency services. But behind these numbers are real people.

Small businesses locked out of working capital after falling victim to crypto scams. Families losing savings to impersonation schemes.

Young founders forced to shut down promising ventures because a single fraud incident wiped out their liquidity. Financial crime in digital assets is not abstract. It is personal, and its impact is often irreversible.

From darknet markets moving illicit funds to ransomware groups demanding payment in digital assets, criminals increasingly leverage digital currencies because of weak oversight, inadequate identity verification, and jurisdictional gaps in enforcement.

It’s why anti-money-laundering (AML) and counter-terrorist financing (CTF) controls are not bureaucratic niceties, they are essential infrastructure for a functioning financial system.

Regulation is not a “nice-to-have”; it’s the safeguard that separates legitimate innovation from systemic risk.

The Risk Landscape Gets Sharper as Digital Assets Grow

In the absence of clear rules, digital assets have often been described as the Wild West of finance, a frontier of opportunity with little accountability.

Stories highlighting lost wallets and exchange hacks grab headlines, but the larger issue is deeper: when markets operate without enforceable standards for transparency and oversight, bad actors thrive.

The digital asset ecosystem can be a force for economic inclusion, especially in emerging markets across Africa.

But that promise will always be limited if fear of fraud, theft, or criminal misuse overshadows the potential benefits. Regulation that prioritises financial safety protects consumers and strengthens trust in the financial system, trust that is fundamental for adoption at scale.

Regulatory Momentum: Kenya and Ghana Take a Stand

Recognising these risks, several African countries have moved beyond debate and taken decisive action.

Two of the most important developments in the last year came from Kenya and Ghana, where comprehensive regulatory frameworks for digital assets were enacted.

At a time when many developed markets are still struggling to reconcile innovation with enforcement, African regulators are proving that clarity is possible. These frameworks are not reactionary. They are deliberate, consultative, and built for long-term market health.

In Kenya, a new digital asset regulatory framework was formalised in November 2025, the Virtual Asset Service Providers Bill.

This made the East African country one of the first in the region to clearly define licensing requirements, compliance expectations and supervisory oversight for Virtual Asset Service Providers (VASPs).

This law was crafted, with major input and consultation from Yellow Card’s team, enabling innovation while ensuring that operators implement strong AML and CTF safeguards.

Similarly, Ghana’s Virtual Asset Service Providers Bill, 2025, which received president assent at the end of December 2025 marked a historic shift. For years, the digital asset market in Ghana had operated in a gray area – widely used by the public but lacking legal certainty.

With the passage of the VASP Bill and receipt of presidential assent, cryptocurrency activities are now formally legalised and regulated.

This framework assigns responsibility to multiple agencies – including the central bank, securities regulator, and financial intelligence unit – to monitor transactions, enforce identity verification, and prevent illicit flows.

These laws are about more than legitimacy; they are about protecting individuals, businesses, and the broader financial system from abuse.

Why Regulation Matters: Financial Safety and Security Aren’t Optional

Financial crime isn’t just a compliance checkbox for multinational corporations – it’s a real threat that affects individuals, firms and economies.

Losses from fraud and money laundering erode consumer confidence and divert capital away from productive use. Illegal activity distorts markets and can undermine the foundational trust people place in financial systems. In the digital asset context, unregulated exchanges and opaque operations amplify these risks.

Regulatory frameworks like those in Kenya and Ghana create what we call a “safe zone” – a space where innovation can thrive under clear standards that protect participants. Mandatory Know-Your-Customer (KYC) requirements ensure identities are verified. AML and CFT protocols detect and deter illicit flows. And coordinated oversight enables regulators and operators to combine on-chain analytics with traditional compliance tools to identify suspicious behaviour in real time.

A Global Operator’s Perspective: Yellow Card’s Commitment to Safety

At Yellow Card, our operations span across 34 markets, with a footprint in 20 African countries and strategic business relationships spanning Europe and the United States.

This global reach means we interact with some of the most sophisticated regulatory regimes in the world. We don’t see financial safety and security as optional luxuries,  they are prerequisites for operating responsibly at scale.

We have built risk and financial crime programmes that adhere to the highest standards. That includes robust identity verification, transaction monitoring, and real-time risk scoring.

These systems are not theoretical; they are deployed daily to protect users and reinforce trust in the digital economy.

The Future Depends on Safe, Secure, Accountable Markets

As digital assets continue to integrate with traditional finance and everyday commerce, the stakes for financial integrity will only rise.

Countries that lead with thoughtful regulation – rooted in transparency, enforcement and international cooperation – will unlock broader economic potential.

Those that delay risk stagnating in uncertainty. The real question for policymakers is no longer whether to regulate digital assets, but how quickly and how well.

Clear rules today prevent crises tomorrow. In a global market where capital moves instantly, jurisdictions that move decisively will define the future of digital finance.

Regulation that confronts financial crime head-on doesn’t stifle innovation – it enables it by eliminating fear and establishing a foundation of trust. For Ghana, Kenya, and other forward-thinking nations, the message is clear: the future of finance must be safe to be sustainable.

And when safety is non-negotiable, everyone benefits: consumers, businesses, and the economy at large.

In doing so, the perfect climate has been created for fraud to become even more of a challenge.

A global economic crime survey has found that one in three South African respondents cite distrust as being the most significant emotional impact of fraud.

Brand damage, loss of market position, employee morale, and lost future opportunities remain unquantified. Consideration must also be paid to the availability of more sophisticated technologies such as artificial intelligence (AI), machine learning (ML), and automation that benefit organisations and criminals alike.

Technology shifts

Our recent research indicated that the pressure to safeguard against financial crime s in this connected landscape has resulted in a third of financial institutions accelerating their AI and ML adoption for anti-money laundering (AML) technology.

In the same survey, 28% of large financial institutions consider themselves to be fast adopters of AI technology while 16% of smaller financial institutions also view themselves as industry leaders in AI adoption.

The shift in consumer behaviour due to the pandemic has forced many financial institutions to move away from static, rules-based monitoring strategies as they are not accurate or adaptive to the behavioural decisioning systems required in an AI-driven landscape.

Additionally, our insurance fraud technology study has found that anti-fraud technology is flourishing due to these and other factors.

Automated red flags, predictive modelling, text mining, and reporting capability are among insurers’ most used anti-fraud technologies. They are also embracing photo analysis technology to authenticate claim damage, identify digitally altered images, and index pictures submitted in other claims.

Tying this together is how organisations are embracing financial intelligence that unite multiple information sources with analytics connecting the dots at scale to form a true, all-source-intelligence platform. For instance, sophisticated algorithms have been deployed not only to link data, but to identify the significance of a contact and predict risk of infection from malware.

Financial crime variety

Fraud and cyberattacks are just two concerns. But money laundering has become especially pervasive recently with criminals relying on legitimate businesses through which to channel their ‘dirty’ money. This is where shell companies and offshore financial transactions become part of the picture.

And then there is procurement fraud to consider with some suggesting it has become one of the most common economic crimes around the world. Because it takes so many forms, procurement fraud is very difficult to detect and investigate. Manual detection is futile with organisations requiring the right combination of advanced analytic techniques to bolster their defences against these fraudsters.

Fundamentally, today’s payment ecosystem has broadened well beyond traditional banks. Fintechs, digital banks, and payment service providers are driving new, alternative payment services.

Payments have become increasingly cashless and opened doors for new, faster payment types. But, with all the innovation comes new fraud threats – and they are emerging on different timelines in various parts of the world.

AI weaponry

For these, and other financial crime s, it has become imperative to embrace continuous monitoring solutions. These can pull millions of records from back-office systems, including purchase orders, purchase requests, invoices, payments and other accounts payable data, and supplier data.

After extracting the data, the solutions apply AI to cleanse it at scale.

The system can enhance the data by drawing on external sources, such as company registers, information about politically exposed people and transparency indexes.

Then it processes the data using alert generation processes based on mathematical algorithms and models, such as clustering and link analysis. The outcome is a real-time risk score for both transactions and vendors.

Depending on the industry and the company needs, businesses can use analytics to check for bid rigging, duplicate invoices, travel expenses, returns, fidelity cards, subscriptions, and more.

It all comes down to embracing tools like AI and ML to enhance what human experts do. Fighting financial crime is a never-ending battle. With criminals using evolving technology to bypass organisational defences, it is up to the companies to fight fire with fire.