The Central Bank of Nigeria (CBN)'s Guidelines on International Money Transfer Services provide the regulatory foundation for cross-border remittances and international payment flows into and out of Nigeria. These guidelines, though framed in the context of consumer protection and operational integrity, include multiple elements that align with the Financial Action Task Force (FATF) Travel Rule (WTR), which mandates the transmission of originator and beneficiary information alongside wire transfers.

Application of the Travel Rule

While the guidelines do not explicitly use the term "Travel Rule," their provisions incorporate its key requirements. Section 3.10 mandates that money transfer operators (MTOs) maintain comprehensive records of each transaction, including full names, addresses, contact numbers of both sender and beneficiary, acceptable means of identification, occupation of the sender, source of funds, transaction type and purpose. These data elements are consistent with the FATF’s Recommendation 16 on wire transfers. Inbound transfers can only be disbursed through bank accounts or mobile wallets, with stringent documentation for exceptions. Outbound transfers are capped at USD $2,000 per transaction and must be denominated in naira at initiation, ensuring traceability and adherence to regulatory reporting thresholds.

Responsibilities of Money Transfer Operators & Agents

MTOs are required to establish robust information systems to support audit trails and to retain transaction data for regulatory inspection. They must ensure agents meet specified suitability criteria and execute detailed contracts defining operational responsibilities. These contracts include clauses on AML controls, data ownership, oversight rights of the CBN, and clear limits on permissible services. The guidelines emphasize that all data collected by agents is ultimately the property of the MTO, reinforcing the need for end-to-end visibility and control over transfer data, as mandated by the Travel Rule.

Compliance & Risk Mitigation

MTOs must comply with the 2013 CBN Regulations on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT), and other relevant legal frameworks. They are also prohibited from allowing or processing split transactions intended to circumvent reporting requirements.

Records must be accurate, updated daily, and accessible to regulators. Payment must not proceed without dual-level authentication. Disclosure requirements obligate MTOs to inform customers of all applicable charges, exchange rates, and transaction timelines, ensuring transparency.

Recordkeeping & Regulatory Oversight

The guidelines establish clear reporting obligations to the CBN's Trade & Exchange Department and require MTOs to provide monthly returns on transaction activities and complaint handling. All inward transfers must be paid in Nigerian currency at the prevailing exchange rate and cannot be disbursed in foreign currency. Acceptable identification methods are specified to ensure verification, and operators must retain contracts and transaction records for seven years or as otherwise directed by the CBN.

Enforcement & Sanctions

Non-compliance with the guidelines can result in corrective actions, financial penalties, suspension from operations, or license revocation. The CBN retains extensive oversight rights and may intervene in both operator and agent conduct. Operators must allow the Bank unfettered access to premises, systems, and personnel for compliance audits.

Conclusion

Nigeria’s regulatory framework for international money transfer services, while primarily constructed around licensing, consumer protection, and financial integrity, incorporates the operational spirit of the FATF Travel Rule. The requirements for transaction data retention, disbursement controls, AML compliance, and agent oversight collectively ensure that originator and beneficiary information is preserved and auditable. These measures contribute to Nigeria’s broader effort to align with international standards on anti-money laundering and counter-terrorist financing in the realm of cross-border payments.