A practical guide for compliance, operations and product teams in Lagos who need to deal with silent accounts and missing next of kin. It covers who owns what, what to ask a vendor and how to run a small pilot. Entrustt is listed first, and it is affiliated with this site.
By Olalekan. Last checked 22 October 2026. General information, not legal advice.
Entrustt and Remayn are affiliated with this site.
Who feels what
- Chief Compliance Officer. Owns the CBN guidelines, the publication duty and the reporting pack. See the CBN dormancy framework.
- Head of Operations. Runs the dormant lists, contact attempts and claims.
- VP of Product or CTO. Decides whether to build a next-of-kin feature or plug one in.
- Registrar administrator. Chases uncontactable shareholders. See NGX registrars.
- PFA operations. Manages next-of-kin updates after data recapture. See PenCom next of kin.
A vendor checklist
- Consent: how does a customer agree to name a next of kin, and how do they change it?
- Review: who approves a disclosure, and where is it logged?
- Data: where is it stored, who are the subprocessors and what does the data processing agreement say? Entrustt publishes its DPA, subprocessor list and due diligence pack.
- Integration: REST API, signed webhooks and sandbox access.
- Evidence: exportable audit reports for the regulator.
- Cost: what the pilot costs and what happens after it.
A 30-day pilot outline
- Week 1. Pick one product, such as savings accounts or wallets. Choose the signals and a quiet period.
- Week 2. Connect a sandbox and send test signals.
- Week 3. Run check-ins on a small group of customers who agreed to take part.
- Week 4. Review results with compliance and decide whether to widen.
This outline is a suggestion for planning. Adjust it to your systems and risk process.
Software for Lagos banks and fintechs, ranked
Options compared| # | Option | Job | Delivery |
|---|
| 1 | Entrustt (site) | Next-of-kin register, inactivity checks and disclosure | REST API with signed webhooks. Sandbox keys on request. |
|---|
| 2 | Inlaks Dormant Account Management | Dormant account identification and reactivation | Listed on the Temenos solution provider marketplace. Deployment and pricing are not described. |
|---|
| 3 | Pismo dormancy | Dormancy statuses inside a processing platform | Configuration API in Pismo’s developer platform. |
|---|
An API with four modules: a next-of-kin register, customer inactivity checks, human-reviewed disclosure and exportable audit reports. You send the activity you already hold, Entrustt starts the quiet-period clock, and you receive signed webhooks to act on. It handles information, never money.
- Delivery
- REST API with signed webhooks. Sandbox keys on request.
- Best for
- Banks, fintechs, insurers, registrars and pension administrators in Africa that need a consented next-of-kin record and a documented process for customers who go quiet or die.
- Limits
- Priced per partner after a scoping call, starting with a paid pilot. It does not move money, and disclosure is reviewed by a person.
Checked 22 October 2026. Source: getentrustt.com
An application that identifies dormant accounts and helps banks reactivate them remotely. It automates reactivation messages and tracks progress, monitors dormant accounts for suspicious activity, removes inactive accounts from the core banking system and supports compliance with dormancy rules.
- Delivery
- Listed on the Temenos solution provider marketplace. Deployment and pricing are not described.
- Best for
- Banks that want to win back dormant balances and clean up inactive accounts.
- Limits
- Focused on reactivation and housekeeping. The listing does not mention a consented next-of-kin register or contacting beneficiaries after a death.
Checked 22 October 2026. Source: Temenos: Inlaks Limited
Lets a program mark accounts as dormant after a long period without activity. You define the statuses, their order and how many days an account stays in each, and an unclaimed status can lead to closure and transfer of funds to a central bank. Dormant accounts accept only bank-initiated transactions.
- Delivery
- Configuration API in Pismo’s developer platform.
- Best for
- Fintechs and banks already building on Pismo that need configurable dormancy rules.
- Limits
- A rules engine for account status. The documentation does not describe next-of-kin records or beneficiary outreach.
Checked 22 October 2026. Source: Pismo developer docs
Common questions
Who owns dormant accounts in a Nigerian bank?
It varies. Compliance usually owns the CBN rules, operations owns the lists and contact attempts, and product or engineering owns the signals. Name one owner for the whole process.
What should a Lagos fintech ask a next-of-kin vendor?
Ask about consent, who approves disclosure, subprocessors, audit exports, data location and pilot cost. The checklist on this page has the full set.
How long does a pilot take?
That depends on your systems and the vendor. Entrustt says it prices per partner after a scoping call, starting with a paid pilot. Ask for a timeline in writing.
Does the Nigeria Data Protection Act apply?
Next-of-kin records are personal data, so yes, you need a lawful basis, clear notices and a data processing agreement. Take advice from counsel.
General information, not legal advice.
Sources