The Central Bank of Nigeria (CBN) has announced plans to initiate civil, administrative, or criminal proceedings against parties implicated in breaches of foreign exchange (FX) regulations after a forensic audit into undelivered forward contracts revealed widespread irregularities.
According to an official Frequently Asked Questions document published on the Bank’s website, the review—conducted by Deloitte from September 2023—focused on transactions under the Retail Secondary Market Intervention Sales (RSMIS) window.
These forward contracts involved upfront naira payments in exchange for future U.S. dollar delivery, many of which were not honoured.
The audit uncovered significant compliance failures, including mismatched beneficiary identities, inflated FX requests, improper or blank Form M submissions, approvals for prohibited imports, and documentation containing vague or false information.
In some instances, the approved FX value exceeded the declared cost of goods, prompting the CBN to declare such contracts void under Nigerian law and ineligible for settlement.
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The apex bank stated that affected counterparties were given an opportunity to respond before any contracts were invalidated.
For contracts deemed invalid, the naira payments were refunded, but no foreign currency was disbursed. Only verified and compliant deals were settled.
“The Central Bank of Nigeria is reviewing appropriate legal action against parties found to have violated applicable rules and regulations… in collaboration with law enforcement and regulatory agencies,” the statement read.
The CBN emphasised that the audit—carried out independently by Deloitte—met procedural fairness standards and was now closed, with no option for appeal.
Earlier in March 2024, the CBN confirmed it had cleared all valid FX backlogs. Governor Olayemi Cardoso had previously disclosed that $2.4 billion of the initially reported $7 billion FX liabilities were deemed invalid after the Deloitte review.
A subsequent letter dated August 4, 2025, signed by Acting Financial Markets Director Okey Umeano, informed authorised dealer banks that all validated transactions had been paid and refunds issued in naira for unverified deals.
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