
When Expertise Becomes a Single Point of Failure
Analysis of organisational dependencies consistently finds that key person risk exists well beyond founder or executive level.
7 Briefings · Updated regularly
Considered analysis from the front line of regulatory practice.
Short, practitioner-grade notes on the issues shaping financial crime, data, AI, cybersecurity, governance and ESG — written for boards, executives and counsel who need clarity, not column inches.

For much of the past decade, regulation and innovation have been treated as opposing forces, one that constrains and one that creates.

Within the broader registration requirements is a condition that changes the picture entirely: applicants must demonstrate that they have a functioning risk and governance framework.

The consequence of board AI illiteracy is not simply a training gap. It is a structural accountability gap. When a board cannot meaningfully challenge management's AI choices, it cannot discharge its duty of oversight.

Most firms confuse AI policy with AI readiness. Regulators are now testing whether frameworks actually function, and the gap is wider than boards realise.

The CBN's 2026 priorities raise the bar from compliance to demonstrable governance. Here is what Boards must decide before the April recapitalisation deadline.

Nigeria is off the FATF Grey List. Staying off it depends on Boards proving AML effectiveness, not just compliance on paper.