Application received
Identity form, documents and consent
01A coordinated set of agents collects evidence, verifies identity and ownership, screens risk, and routes exceptions to a human reviewer.
Regence compares Iroko Industries' USD 2m instruction with Blue Ribbon's USD 200k invoice, pauses on each control failure and preserves every human resolution for the MLRO.
Identity form, documents and consent
01OCR, tamper checks and field matching
02ID, liveness and address corroboration
03Directors, UBOs and control structure
04PEP, sanctions, adverse media and risk
05Analyst decision with full evidence trail
06USD 2m instruction and supporting invoice
01Instruction USD 2m · invoice USD 200k
02USD 1.8m is unsupported by the invoice
03Blue Ribbon ownership and account unverified
04Contract, purchase order and delivery absent
05Maintain hold, escalate and retain audit trail
06Compare a customer payment instruction with its supporting invoice, run three focused compliance checks and preserve the recommended action.
REF · MB/PI/2026/0831
32 Greystone Drive · Sandton · Johannesburg · SA
The payment instruction is ten times the value of the supporting invoice.
Compare the instructed value with the invoice total and quantify any unsupported difference.
USD 2,000,000 instructed versus USD 200,000 invoiced. USD 1,800,000 is unsupported.
ACTION 01Block release and require an amended instruction or corrected invoice that reconciles the full amount.
Confirm Iroko as customer, buyer and payer; then verify Blue Ribbon as supplier, invoice issuer and payee.
The buyer-supplier roles are consistent, but Blue Ribbon's identity, ownership and payee account have not been independently verified.
ACTION 02Verify Blue Ribbon Ltd, its beneficial owners, South African address and NorthEast Bank payee account through independent sources.
Test whether the submitted commercial evidence reasonably supports the full payment instruction.
The invoice supports only 10% of the requested transfer. The economic purpose of the remaining value is undocumented.
ACTION 03Obtain the purchase order, underlying contract, delivery evidence and a written explanation from Iroko Industries Ltd.
Block release. Require an amended instruction or corrected invoice accounting for the USD 1,800,000 difference.
Complete KYC and beneficial-ownership verification for Blue Ribbon Ltd and confirm its bank account outside the submitted records.
Collect the contract, purchase order, delivery evidence and Iroko Industries Ltd's written explanation of the economic purpose.
DECISION: Keep the transfer on hold and escalate the combined findings to the MLRO. Consider an STR only after human review of the facts and applicable reporting obligations.
Fictional demonstration only · Human compliance approval is required before any action.
The same Iroko-to-Blue Ribbon transaction is tested against official import-FX and Customs documentation requirements. No arbitrary CBN-wide USD ceiling is asserted: the control limit is the USD value supported by the invoice and accepted trade documents.
REF · MB/PI/2026/0831
SUPPLIER · 32 GREYSTONE DRIVE · SANDTON · SA
The USD 2,000,000 instruction exceeds the USD 200,000 evidenced trade value, and the required import documentation is absent.
Compare the USD amount requested with the invoice and the value recorded in the applicable trade documentation.
Only USD 200,000 is evidenced. The remaining USD 1,800,000 cannot be processed without valid documentation reconciling the full request.
ACTION 01Hold the USD 2,000,000 request. Require corrected or additional commercial documents and ensure any FX sale does not exceed the accepted Form M/import value.
Confirm that the import was initiated through an accepted Form M and that its details agree with the supplier invoice.
Imports of physical goods require Form M through an Authorised Dealer Bank irrespective of value; the bank must confirm acceptance before proceeding.
ACTION 02Do not remit. Obtain and validate the accepted Form M, pro-forma invoice, insurance and applicable regulatory certificates.
Check the PAAR and shipment evidence needed to support Customs declaration and the commercial payment.
The file lacks PAAR and supporting shipment documents, including the bill of lading, packing list and certificate of origin.
ACTION 03Keep the transaction on hold until the registered Form M, PAAR and applicable shipping/origin documents are independently validated.
Reject or amend the instruction unless valid trade evidence supports the additional USD 1,800,000.
Obtain the accepted Form M and verify that its parties, goods and value agree with the payment and invoice.
Validate PAAR, bill of lading, packing list, certificate of origin and other applicable regulatory documents.
DECISION: Maintain a documentary hold, preserve the submitted records and escalate the unexplained USD 1,800,000 difference to Trade Operations and Compliance.
Fictional scenario · Requirements are grounded in cited official CBN and Nigeria Customs sources · Confirm current transaction-specific requirements before operational use.
Regence extracts financial data, computes ratios, identifies reconciliation gaps and structures the analyst's decision record. It does not approve the facility.
Sources: management accounts · sales ledger · 12-month bank statements · owner schedule
Sales ledger reports NGN 1.92bn while identifiable bank inflows total NGN 1.71bn. The difference requires explanation and supporting evidence.
Regulatory evidence: CBN Prudential Guidelines, CRMS and Bank of Ghana risk governance.
This fictional Nigeria–Ghana transaction separates preferential-trade eligibility, PAPSS customer payment speed, settlement mechanics, fees and UCP 600 document compliance.
Confirm HS classification, the applicable tariff schedule, product-specific rule of origin and valid proof of origin for the Nigeria–Ghana corridor.
PAPSS states that customer payments can process within 120 seconds. Pre-funding and inter-participant net settlement are separate controls.
Check the operative credit and licensed UCP 600 text before issuing a refusal or seeking waiver.
Ask a question about the current CBN AML baseline corpus. Regence separates its analysis from the regulatory evidence supporting it.
Meridian Bank is a fictional Nigerian bank with operations in Ghana. Explore its fictional Ghana liquidity scenario using internal policy, its contingency plan, Basel III summary, ALCO memo and Treasury data.
TimesFM 2.5 analyses 24 fictional GHS-denominated rolling observations for Meridian’s Ghana operation. The selected Regence language adviser then explains the forecast against its liquidity position, retrieved policy evidence and internal limits.
The adviser retrieves from the Meridian Bank corpus and uses the answer model selected in the sidebar.
Liquidity Policy · Contingency Plan · Basel III LCR/NSFR Summary · ALCO Memo · Treasury POC Data
Run a focused review of governance, accountability and evidence controls against the current regulatory baseline.
Responsibilities, reporting cadence and documented challenge.
Named owners, decision rights and escalation pathways.
Source records, approvals, testing and audit traceability.
Five fictional Meridian Bank governance documents are indexed on the private retrieval service. Findings cite the internal documents used; no real bank information is included.
Regence connects transaction chronology, related-party indicators and missing evidence without treating an alert as proof of wrongdoing.
Arise Commodities Ltd · “Haulage advance”
Dockside Supplies Ltd · “Equipment”
Blue Harrier Trading · “Services”
Dockside Supplies Ltd · “Invoice”
Three NGN 6m transfers · Cedar Bridge Consulting
Customer · Director: Ada Nwosu
Beneficiary · Owner: Emeka Nwosu
Beneficiary · nominee director
No relationship is treated as proven until identifiers, ownership records and economic purpose are independently verified.
Separates observed facts, indicators, evidence gaps and human decisions.
Draft ICAAP narratives, credit portfolio summaries and supervisory-return packs with every case fact labelled and every regulatory claim source-cited.
Explain capital position, all material risks, stress assumptions, management actions, limitations and evidence of Board challenge.
Reconcile controlled sources, explain asset-quality movement, concentrations, coverage, exceptions and accountable remediation owners.
Capital assessment, material risks, stress outcomes, deficiencies and corrective measures.
Draft · review requiredBorrower identity, facilities, performance status, reconciliations and authorised sign-off.
Data validation pendingNamed preparer/reviewer, source reconciliation, approval and immutable receipt.
Evidence checklistRegence prepares a draft; authorised officers remain responsible for approval and submission.
Review the authority, verification state and available citation locations for the current CBN corpus.
9 December 2025 · FPR/LAD/INT/001/002
1 December 2025 · FPRD/PRD/INT/CCD/005/003
24 November 2025 · FPR/DIR/PUB/CIR/001/008
17 December 2024 · PSM/DIR/PUB/CIR/001/057
3 October 2024 · Exposure draft
9 August 2024 · CBN Retail Dutch Auction System sales report
26 July 2024 · FPR/DIR/PUB/CIR/002/012
19 July 2024 · FPR/DIR/PUB/CIR/002/011
30 June 2024 · FPR/DIR/PUB/CIR/001/003 · Banks and other financial institutions
22 May 2024 · FPR/DIR/PUB/CIR/002/010
7 May 2024 · Institutions listed as at 26 April 2024
28 March 2024 · FPR/DIR/PUB/CIR/002/009
8 March 2024 · BSD/DIR/PUB/LAB/017/002
23 February 2024 · FPR/DIR/PUB/CIR/002/006
2 January 2024 · FPR/DIR/PUB/CIR/002/003
10 March 2026 · Issuance circular and controlled regulatory transcription
31 March 2026 · Implementation guidance and roadmap requirements
18 January 2013 · Circular FPR/DIR/CIR/GEN/02/001
Official CBN and Nigeria Customs provisions for Form M, supported FX value, PAAR and shipment documents
Credit policy, ratio analysis, repayment capacity, credit information and concentration governance
Corridor eligibility, PAPSS processing and settlement, fees and UCP 600 article areas
Transaction chronology, related-party indicators, evidence gaps, escalation and quality assurance
Board ownership, annual ICAAP, material risks, portfolio reporting, CRMS and return controls
31 August 2026 · Fictional internal control standard for the demonstration case
Margins and interest cover are positive, but the ratios depend on management records containing an unresolved NGN 210m sales-to-bank-inflow difference. Stress the ratios using verified cash receipts before relying on repayment capacity.