Recently, the Central Bank of Nigeria ("CBN" or the "Apex Bank") restricted and placed a bar on the activities of some 'unlicensed' companies providing international money transfer services to Nigeria. In the wake of this development, it was unclear what the intention of the regulator was. Some claimed that the Apex Bank has shut the door on intending and prospective players. In this regard, and to clear the seeming confusion, the CBN issued the statement below:
“The CBN wishes to state unequivocally that it has not foreclosed the licensing of interested players in the International Money Transfer Organisation ("IMTO") space in Nigeria. Therefore, interested applicants are required to forward their requests for licensing to the Director, Trade and Exchange Department of the CBN, in line with the CBN guidelines on International Money Transfer Services in Nigeria (2014), which, among other things, specify the minimum technical and business requirements for various participants in the international money transfer services industry in Nigeria.”
The statement added that the apex bank would continue to provide an enabling environment for international money transfer services in Nigeria." @finiancialwatch
Lic
From the above, every company desirous of providing an international money transfer services in Nigeria is required to obtain a licence from the CBN. The CBN Guidelines on International Money Transfer Services in Nigeria states thus:
"No person or institution shall provide international money transfer services unless such person/institution has been duly licensed by the CBN. Application for a licence to carry on the business of International money transfer services shall be submitted to the office of the Director, Trade & Exchange Department, Central Bank of Nigeria, Abuja."
Documentary Requirements
All applications shall be accompanied with the following:
- Board of director’s approval to offer International money transfer services.
- Copy of the applicant’s certificate of incorporation
- Memorandum & Articles of Association (certified copy), of which the primary object clause shall indicate provision of Money Transfer Services.
- Shareholding structure of the Company
- Forms C02 (Return on Allotment of shares) and C07 (Particulars of Directors)
- Profiles of the Board and Management of the Company to include: CVs, functional contact e-mails and telephone numbers, ownership, governance and management structure;
- Organogram of the company
- Business Plan, to include:
- Nature of the Business
- Features of the scheme
- Internal control systems and monitoring procedures
- Security features that will be put in place
- 3 years Financial projections/Market analysis for the Company
- Transaction and other charges that will be borne by customers;
- Profit sharing agreement among the parties;
- Diagrammatic illustration of transaction flows;
- Consumer Protection and Dispute Resolution Mechanism
- Information Technology Policy of the Company including:
- Privacy Policy;
- Information Ownership/Disclosure/Loss Policy;
- Backup and Restore Policy;
- Network Security Policy;
- Encryption Policy;
- Confidential Data Policy;
- Password Policy;
- Third Party Connection Policy;
- Incidence Response Policy; and
- Physical Security Policy.
- Enterprise Risk Management Framework;
- Contingency and Disaster Recovery Plan (business continuity plan)
- Draft agreements with the participating parties
- Tax Clearance Certificate for three (3) years
- Project Deployment Plan (time, location, operation, etc.)
- Credit reports from a licensed credit bureau for the shareholders and key officers of the money transfer services operator;
- Any other information as may be required by the CBN from time to time
- A non-refundable application fee of N500,000 (Five Hundred Thousand Naira) or such other amount that the Bank may specify from time to time, payable to the “Central Bank of Nigeria” by electronic transfer.
- Evidence of meeting the minimum paid up share capital of:
- N2,000,000,000 (Two Billion Naira) for Nigerian companies; and
- N50,000,000 (fifty million Naira) or its equivalent for Foreign companies, plus the guarantee of the parent company.
- Presence in at least seven (7) different countries.
For more information on the Guidelines, please visit https://www.cbn.gov.ng/Out/2014/BPSD/Guidelines%20on%20International%20Money%20Transfer%20Services%20in%20Nigeria%20Approved%20d.pdf
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