SJULTRA Sentinel is a Nigerian compliance consultancy. We write your CBN AML roadmap document in four weeks, so you file before June 10 — then support your institution through the full 18-month implementation.
The Sprint is a live consulting engagement available now. The Sentinel compliance platform is in development, with pilot testing targeted for November 2026.
On March 10, 2026, the CBN issued a 27-page circular mandating every licensed financial institution deploy a fully automated AML/CFT system — covering 12 specific technical capabilities. This is not guidance. It carries personal liability for senior executives.
CBN Circular BSD/DIR/PUB/LAB/019/002 took effect on March 10, 2026. Every licensed DMB, PSP, MMO, and fintech must comply. Non-compliance results in administrative sanctions and financial penalties — affecting both the institution and accountable individuals including the CCO and MD personally.
Personal LiabilityDMBs have 18 months for full compliance (September 2027). PSPs, MMOs and fintechs have 24 months (March 2028). But every institution — regardless of type — must submit a formal implementation roadmap to the CBN Compliance Department by June 10, 2026.
86 Days AwayThe CBN explicitly applies a proportionality principle: institutions must calibrate solutions to their size, transaction volume, risk profile, and business model. SJULTRA's tiered consulting service is structured around this — your institution does not need an Oracle FCCM deployment to be compliant.
Calibrated SolutionsThe CBN circular mandates 12 distinct technical capability areas. SJULTRA's Sprint covers all 12 — delivering your roadmap, governance framework, and gap remediation plan against every standard. The Sentinel compliance platform, currently in development with pilot testing targeted for November 2026, will automate the ongoing execution of these standards once live. Every Sprint deliverable maps directly to specific standards.
Every Sentinel Sprint follows a structured, four-phase process. Your institution provides the data. SJULTRA runs a comprehensive cyber asset discovery across your entire IT and compliance environment, generates a structured report, designs the CBN roadmap from that report, and delivers a polished first draft for your review — before any CBN deadline pressure sets in.
The network agent installed in Phase 1 does not need to be removed after the Sprint. Keeping it active provides your institution with continuous, live visibility of every asset across your network — automatically surfacing new devices, unmanaged endpoints, and emerging data flow risks as your infrastructure evolves during the 18-month CBN implementation period. This directly supports CBN Standard 7 (tamper-proof audit trails) and Standard 9 (data protection and NDPA compliance) on an ongoing basis. SJULTRA can provide a costed continuous monitoring licence proposal as part of your Sprint deliverables package — available to all Sprint clients at a preferential rate.
Before SJULTRA begins the cyber asset discovery, your institution submits the information below. This is the foundation of the entire Sprint — the quality of your discovery report and roadmap depends directly on the completeness of what you provide here. Most of this information is already in your CCO's or CTO's files. The average institution completes all three categories of intake in under two hours. The table below shows every item organised by data type.
All information provided to SJULTRA is subject to a Non-Disclosure Agreement signed before the Sprint begins. No institutional data, transaction information, or gap assessment findings will be disclosed to any third party. SJULTRA holds Professional Indemnity Insurance covering all consulting engagements. A Data Processing Agreement (NDPA-compliant) is executed with every client before any data is shared.
The CBN's proportionality principle means institutions are not all measured by the same ruler. SJULTRA's Sprint is calibrated to each segment's specific risk profile, technical infrastructure, and internal capacity.
Foreign AML vendors offer powerful platforms built for European and North American banks. They cannot offer Nigerian data residency by architecture, knowledge of the CBN examiner's process, or a team that picks up a Lagos phone number when your CCO needs support on June 9.
Sentinel was designed from the language of Circular BSD/DIR/PUB/LAB/019/002 — not adapted from a generic AML framework. Every feature, every rule, every reporting format maps to a specific CBN requirement.
SJULTRA deploys on AWS af-south-1 (Cape Town). All customer PII, transaction records, and case data are processed and stored within Nigeria. The Sentinel screening engine processes only the signals required for compliance checks — no customer names, BVNs, or account numbers leave Nigeria.
A compliance transformation of this scope typically takes six to twelve months just to plan — vendor selection, architecture design, board approvals, and document drafting all running in sequence. The Sprint compresses that planning into four structured weeks, delivering a submission-quality CBN roadmap before most institutions have finished their RFP process.
Sentinel's sanctions, PEP, and adverse media screening is powered by an enterprise-grade intelligence engine covering 200+ global watchlists, 1M+ monitored entities, and a response time under 300ms — the same calibre of infrastructure used by global Tier 1 banks and fintechs.
The Sprint is a standalone consulting engagement. You do not need to commit to any software to receive your CBN roadmap. The Early Access Agreement is optional — but those who sign receive 20% off the Sprint fee, applied immediately, and priority access to Sentinel's usage-based pilot licence when the platform launches in November 2026.
Sentinel will operate on a usage-based licence model — institutions are licensed for access and consume tokens as they use the platform. Pricing is calibrated to transaction volume and screening activity, not a fixed monthly flat fee. Pilot pricing details will be confirmed to Early Access Agreement holders ahead of the November 2026 pilot launch.
This brochure uses regulation and technology terminology throughout. Here is a plain-English reference for every term that appears more than once.
The Nigeria Financial Intelligence Unit's official online portal where all financial institutions must file Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs). Every licensed institution must be registered.
A dual-control process where one analyst (the Maker) raises or flags an AML alert, and a second independent analyst (the Checker) reviews and approves or dismisses it. Required by the CBN to prevent single points of failure in compliance decisions.
The primary software system a bank or fintech uses to manage accounts, process transactions, and record customer data. Common Nigerian examples include Finacle, T24, and Flexcube. All AML monitoring systems must integrate with the CBS to access transaction data.
A Letter of Intent signed before the Sprint begins. No payment is required to sign. Signing the EAA immediately unlocks a 20% discount on your Sprint fee and secures priority access to the Sentinel platform pilot in November 2026. No financial obligation arises until the pilot phase.
Mandatory reports that financial institutions must file with the NFIU whenever a transaction or pattern of activity is suspected to be linked to money laundering, terrorist financing, or other financial crime. Filing must be done via the goAML portal in XML 3.1 format.
Nigeria's primary data protection legislation, enacted 2023. Requires that Nigerian citizens' personal data be stored and processed within Nigeria unless specific cross-border transfer conditions are met. Directly relevant to where AML platform data is hosted — which is why Nigerian data residency is a CBN requirement, not just a preference.