Setting Up International Money Transfer Services in Nigeria

*Seun Timi-Koleolu and Olawale Atanda

Companies desirous of providing International Money Transfer Operator (IMTO) services in Nigeria are required to be licensed by the Central bank of Nigeria (CBN) as provided by the Guidelines for the Operation of International Money Transfer Services in Nigeria, 2014 (“IMTO Guidelines”).

What activities can IMTOs Provide?

IMTOs may accept monies for the purpose of transmitting to persons resident in Nigeria or another country. They may also carry out cross-border transfer services for personal purposes such as money transfer services towards family maintenance and money transfer services for foreign tourists visiting Nigeria.

However, IMTOs are not permitted to accept deposits or carry out money lending services (as there are separate licensing requirements for these services). They may also not buy foreign exchange from the domestic foreign exchange market for settlement purposes.

What are the requirements for an IMTO license?

The IMTO Guidelines provide requirements for both local and foreign companies wishing to acquire an IMTO license.

Local companies must have a minimum share capital of ₦2 billion and submit relevant document such as their incorporation documents and business plan. Foreign companies on the other hand, are required to show evidence of being licensed as IMTOs in their home country and have a minimum share capital of $1 million. They must also have authorized forex dealers (banks) to serve as local agents and pay an application fee of ₦500,000.

Is there any regulatory update concerning International Money Transfer?

The CBN issued two circulars (the “Circulars”) on November 30, 2020 announcing a new policy initiative on diaspora remittances through IMTOs. The Circulars clarified the CBN’s position on the operation of domiciliary accounts and the procedure for receipt of diaspora remittances.

What do the Circulars say?

The Circulars state that recipients of diaspora remittances through IMTOs shall now receive such inflows in foreign currency (US Dollars) through the agent bank of the IMTO.

The Circulars provide for recipients of remittances to have the option of receiving these funds over the counter in foreign currency cash (US Dollars) or have it transferred into their ordinary domiciliary accounts.

Conclusion

The CBN seeks to deepen the foreign exchange market by ensuring the availability of more foreign currency in the market and creating more transparency in the administration of diaspora remittances into Nigeria as provided in the Circulars.

The CBN has so far licensed about 60 IMTOs with many foreign based IMTOs looking to debut in the Nigerian market alongside local ones. It is important that these IMTOs understand the regulations around IMTO licensing and compliance.

*Seun Timi-Koleolu is the Managing Partner at Pavestones Legal and Olawale Atanda is an Associate at the firm.