Chairman briefing · class, not a kitchen audit · spoken S-N-I V-A-I
A compliance director should leave with one fact: we do not process or route the naira. Licensed operators keep the pipes, the ledger, and the localisation. SC-VAU is a Verification Attestation Utility on F-T-I — we stamp after their success and flush. That is legal weightlessness by construction, not a scorecard of their shop.
Choose a class · the right column does not change
Pillar 1 · Financial custody & settlement risk
They receive, hold, and move customer value. That is the licence. A reversal window after NIBSS is their liability, not a metaphor. Multi-day unwind, liquidity cover, and the switch’s own rules sit on the house that posted the book.
Speech is intent, not a debit. PIN never enters SideCar RAM. After their success ping we look at four fields, stamp a tip hash, and leave. NIBSS latency budget = 0 ms. We do not join the switch queue. If their post fails, we stamp nothing. If our ticket fails, their naira still stands.
Path A dialect = 0.000 ms · measured, never slept · SLA ≤ 12.3 ms
Pillar 2 · NDPA data-minimisation shield
A bank, a PSB, a T2 shop, or an API gateway that processes payments keeps identity, session, and transaction history because the licence and the customer require it. That warehouse is lawful. It is also the NDPA surface: purpose, security, retention, and breach notification sit on the house that stores the file.
NDPA storage limitation is not a policy paragraph on this rail. It is a clock. Working RAM, then a complete flush at 120 seconds. Residual may be a tip hash. Never a citizen file. Never a second pot. Warehouse = 0. That is the mathematical execution of minimisation: if it is not there, it cannot leak.
Idle. Nothing held. Tip hash appears only after a stamp, then the glass goes dark.
Pillar 3 · 2026 CBN localisation · January 2027
The Bank’s recent localisation line is aimed at licensed payment providers who keep transaction data: that file must sit in Nigeria by January 2027. A deposit bank, a MoMo-class PSB, a T2 warehouse, and a Paystack-class gateway each have a store to place. Migration, dual-run, and residency evidence are their cost of holding the trail. We do not inventory their racks.
Transaction data · must sit on Nigerian metal
SC-VAU holds no transaction database. Path A is a measured local attest. After 120 seconds the working set is gone. Residual may be tip_hash. There is nothing to localise, nothing to migrate, and nothing for a January 2027 residency audit to walk on our floor. This is not a waiver we asked the Bank to sign. It is the empty room.
Empty floor · no store · no server lift
One table · three pillars · class only
| Pillar | Licensed operator class | SC-VAU F-T-I |
|---|---|---|
| Custody | Hold float. Post the book. Absorb NIBSS reversal on their own rail. | Zero custody. After-T2 ticket only. NIBSS budget 0 ms. Their naira never enters our glass. |
| NDPA | Lawful warehouse of customer and transaction files. Retention is their duty. | 0-DRRU. 120-second RAM flush. Residual may be tip_hash. Warehouse = 0. |
| Localise | Licensed payment stores of transaction data sit in Nigeria by January 2027. | No database. No migration. Exemption is the empty floor, not a circular naming us. |