The Central Bank of Nigeria (CBN) issued the Guidelines on International Money Transfer Services in Nigeria (2014) for the maintenance of adequate and reasonable financial services to the public and specifically for the regulation of International Money Transfer Operators (IMTO) services in Nigeria. The CBN has licensed several IMTOs and continues to receive applications from foreign-registered IMTO extending operations into Nigeria and prospective domestic ones.

Requirements for MTO Licence in Nigeria

Application for a license to carry on the business of international money transfer services is submitted to the office of the Director, Trade & Exchange Department, Central Bank of Nigeria, Abuja. No person or institution shall provide international money transfer services unless such person/institution has been duly licensed by the CBN.

The applications must be accompanied with the followings:

i.       Board of director’s approval to offer International money transfer services.

ii.      Copy of the applicant’s certificate of incorporation

iii.     Memorandum & Articles of Association (certified copy), of which the primary object clause shall indicate provision of Money Transfer Services.

iv.     Shareholding structure of the Company

v.      Forms C02 (Return on Allotment of shares) and C07 (Particulars of Directors)

vi.     Profiles of the Board and Management of the Company to include: CVs, functional contact e-mails and telephone numbers, ownership, governance and management structure;

vii.    Organogram of the company

viii.   Business Plan, to include:

  1. Nature of the Business
  2. Features of the scheme
  3. Internal control systems and monitoring procedures
  4. Security features that will be put in place
  5. 3 years Financial projections/Market analysis for the Company
  6. Transaction and other charges that will be borne by customers
  7. Profit-sharing agreement among the parties
  8. Diagrammatic illustration of transaction flows
  9. Consumer Protection and Dispute Resolution Mechanism

ix.     Information Technology Policy of the Company including:

  1. 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
    • Physical Security Policy

x.      Enterprise Risk Management Framework

xi.     Contingency and Disaster Recovery Plan (business continuity plan)

xii.    Draft agreements with the participating parties

xiii.   Tax Clearance Certificate for three (3) years

xiv.   Project Deployment Plan (time, location, operation, etc.)

xv.    Credit reports from a licensed credit bureau for the shareholders and key officers of the money transfer services operator;

xvi.   Any other information as may be required by the CBN from time to time

xvii.  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.

xviii. Evidence of meeting the minimum paid-up share capital of:

  1. N2,000,000,000 (Two Billion Naira) for Nigerian companies; and
    1. N50,000,000 (Fifty Million Naira) or its equivalent for Foreign companies, plus the guarantee of the parent company

xix.  Presence in at least seven (7) different countries.

Registration of Foreign IMTO in Nigeria

An international money Transfer Operator already licensed in a foreign jurisdiction can apply for a similar license in Nigeria based on its foreign registration. However, it is important that such foreign-registered IMTO nominate a local company, preferably a bank for coordination and taking responsibility.

The CBN guideline addresses the business rules governing the operation of international money transfer services in Nigeria, and it equally sets the basis for the regulation of the services offered at different levels and by the operators.

By Resolution Law Firm