BLAECWOOD

Financial Regulation

Know where your controls stand before CBN asks to see them.

Blaecwood assesses your current controls against the Central Bank of Nigeria's Open Banking framework and its proposed rules on authorised push payment fraud, documents the gaps in priority order, and assembles the evidence in one reviewed pack.

Book a Call Compliance that gets you somewhere.

The requirement

Supervision is tightening faster than most control documentation is.

The Central Bank of Nigeria is supervising more closely across Open Banking participation, and has issued proposed rules on authorised push payment fraud that remain at exposure draft stage. Approval and renewal timelines are tightening with it.

Firms that cannot show documented, operating controls lose weeks to back and forth over evidence that should already have existed. The work is rarely the controls themselves. It is the record of them.

Blaecwood assesses and documents. Your team executes the remediation, because your team owns the systems. We then validate what has been put in place and record it.

Who this is for

  • Payment service providers, switches and payment-infrastructure firms
  • Open Banking participants, both providers and consumers of APIs
  • Fintechs approaching an examination, renewal or remediation milestone
  • Firms whose control documentation has fallen behind the product

Engage when

  • An examination, renewal or remediation deadline is approaching
  • You are joining or expanding participation in Open Banking
  • The proposed APP fraud rules could reach your product
  • A bank or partner has asked for evidence you cannot currently produce
  • Control documentation was written once and never revisited
  • A new payment product changes what you need to be able to show

What Blaecwood does

  1. 01
    Regulatory Gap Assessment
    We map your current controls against CBN's Open Banking framework and its proposed fraud rules, and document each exposure with the evidence behind it, ranked so your team knows what to address first.
  2. 02
    Open Banking Readiness
    We assess and document your API participation, consent and data-sharing controls against CBN's Open Banking framework. Your team executes the remediation. We then validate what has been put in place and record the result.
  3. 03
    APP Fraud Rule Readiness
    We map your fraud controls against CBN's proposed rules on authorised push payment fraud. Those rules are at exposure draft stage, so the mapping is directional and is revisited when the final rules are issued.
  4. 04
    Examination Evidence Pack
    We assemble the policies, control descriptions and supporting records your assessment referenced into one reviewed pack, so the evidence sits in one place and in one format when it is requested.

What this engagement does not cover

Blaecwood does not act as your regulatory representative. We do not prepare or submit licence applications, and we do not correspond with the regulator on your behalf.

We do not build or operate your controls. We assess them, document them, and validate what your team has put in place.

CBN's rules on authorised push payment fraud are at exposure draft stage. Any mapping against them is readiness work against a draft, not compliance with a final rule.

Find out what an examiner would find, before one does.

Book a Call

Why Blaecwood

  • Licensed Data Protection Compliance Organisation · NDPC/DPCO/17469
  • Assessment of controls as they actually operate, not policy-only consulting
  • Privacy, cloud security and assurance-readiness capability in one delivery model
  • Human review for every material security and compliance conclusion
  • Findings written in the order your team can act on them

Assurance note

Readiness work does not guarantee a licence, certification, audit result or partner decision. Blaecwood's advisory and readiness work is separate from its DPCO assurance work.

The formal NDPA compliance audit, DPCO Verification Statement and Compliance Audit Return filing are contracted separately, with separate scope and review. SOC 2 examinations are performed by an eligible independent CPA or equivalent. PCI DSS validation follows the applicable SAQ, ASV or QSA route.