CBN Mandatory Rules - Verifow

These 9 rules implement the Central Bank of Nigeria AML/CFT Act requirements. They are always active and cannot be disabled.

Rule	Trigger	Score	Auto-Actions
CBN-001 Cash Threshold	Cash deposit/withdrawal ≥ ₦5,000,000	60	Generate CTR, Notify Officer
CBN-002 Transfer Threshold	Electronic transfer ≥ ₦10,000,000	50	Generate CTR, Notify Officer
CBN-003 Structuring Detection	Single txn ≥ 80% of threshold, OR 3+ txns in 24h exceeding threshold cumulatively	80	Generate SAR, Create Case, Notify Officer
CBN-004 PEP Screening	Sender identified as Politically Exposed Person (from global watchlists)	70	Create Case, Enhanced Due Diligence, Notify Officer
CBN-005 Foreign Transfer	International transfer or receiver country ≠ NG	40	Generate FTR, Notify Officer
CBN-006 Dormant Account	No transaction activity for ≥ 180 days	65	Create Case, Enhanced Due Diligence, Notify Officer
CBN-007 Rapid Succession	≥ 5 transactions within 60 minutes from same account	75	Create Case, Notify Officer
CBN-008 KYC Tier Limit	Transaction exceeds sender’s KYC tier limit (Tier 1: ₦20k, Tier 2: ₦500k)	100	Block, Notify Officer, Prompt Tier Upgrade
CBN-009 Near Tier Limit	Transaction at ≥80% of sender’s KYC tier limit	30	Review, Notify Officer

Structuring Detection Logic (CBN-003)

threshold = (isCash ? ₦5,000,000 : ₦10,000,000)
structuring_line = threshold × 0.80

Trigger A: single_amount ≥ structuring_line AND < threshold
    → "Just-below-threshold" pattern

Trigger B: count(24h_txns) ≥ 3 AND sum(24h_amounts) ≥ threshold
    → Cumulative structuring