In March 2026, the Central Bank of Nigeria (CBN) introduced new baseline standards requiring banks and financial institutions to adopt automated anti-money laundering systems. By April, the reality of that shift was starting to land, as institutions began grappling with what it actually means to monitor transactions in real time and tighten oversight across complex financial networks.
This isn’t happening in a vacuum. As discussed in our parallel analysis on Boko Haram, insurgent groups are expanding into illicit criminal networks and at some point, that money has to move. Whether it’s ransom payments, proceeds from trafficking, or funds flowing through informal brokers, there are moments where illicit activity brushes up against the formal financial system. The CBN’s reforms are, in part, an attempt to close those gaps.
But tightening the system in one place doesn’t necessarily remove the risk, it often just shifts it. Informal financial networks, cash-based transactions, and local intermediaries remain a big part of how money moves in parts of Nigeria, particularly in areas affected by instability. These channels are harder to track, harder to regulate, and in many cases, more resilient to formal oversight.
There’s also a practical challenge for banks themselves. Implementing more sophisticated compliance systems is one thing; doing so in regions where operations are already disrupted by insecurity is another entirely. So while the reforms mark a clear step forward from a regulatory perspective, they also highlight a familiar tension. The more robust the formal system becomes, the more likely it is that illicit activity will find alternative routes. Banks are being asked to tighten controls at precisely the moment the environment around them is becoming more fragmented and less predictable.
Taken together, we see that financial crime and security risk don’t sit neatly in separate boxes. In Nigeria, they are increasingly part of the same ecosystem and efforts to address one will inevitably shape the other.