CBN Dormant Account Compliance Checklist for Banks and Fintechs

Entrustt covers steps 2 to 4 below, where most teams work by hand. It runs the quiet-period clock from activity you already hold, keeps a consented next-of-kin register and puts a person in the loop before anything is disclosed. It handles information, never money.

Use this with our summary of the CBN dormancy rules. [Rule] items come from the guidelines or circulars as reported in the press. [Practice] items are our suggestions.

1. Ownership and policy

• Name one accountable owner for dormant accounts and unclaimed balances. [Practice]
• Record the dormancy definition you apply to each account type, and the CBN text it comes from. [Rule]
• List exempt accounts, such as those under litigation or pledged as collateral, and who approves an exemption. [Rule]

2. Data and signals

• List every signal you hold: logins, transactions, card use, replies, repayments. [Practice]
• Decide which signal resets the clock for each product. A wallet, a current account and a mortgage do not behave alike. [Practice]
• Find accounts with no phone, email or named beneficiary. You cannot warn these. [Practice]

3. Warn before dormancy

• Send a warning before an account turns dormant. [Rule]
• Use more than one channel, in your own name, and never ask for a PIN, password or money. [Practice]
• Log each attempt with date, channel and result. [Rule]

4. Reach the holder or beneficiary

• Try to reach the holder and, where the customer agreed, the named beneficiary or next of kin. [Rule]
• Have a staff member approve anything that goes to a third party. [Practice]
• Verify identity before any reactivation. [Rule]

5. Publish

• Prepare the website list of dormant accounts and unclaimed balances: authorised operators, account type, bank and branch. [Rule]
• Prepare the annual press publication, or the premises notice for State and Unit microfinance banks. [Rule]

6. Transfer and reactivation

• Track balances nearing ten years of dormancy, when they move to the Unclaimed Balances Trust Fund pool. [Rule]
• Update reactivation for the March 2026 affidavit change, and keep the affidavit step for funds already transferred. [Rule]
• Keep a claims log: who claimed, what proof, who approved. [Practice]

7. Evidence pack

• Keep one folder an examiner can read in an hour: policy, signal list, warning templates, attempt logs, approvals, publication proofs, transfer records. [Practice]

What to read next

• On Entrustt: the guide to managing deceased customers, pricing and the contact page
• CBN dormancy rules and a pre-dormancy framework
• How an inactivity tracking API works, for the engineers who will build or integrate step 2
• Next-of-kin API providers compared
• PenCom next of kin for pension administrators