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Money Transfer License in Nigeria: A Comprehensive Guide to IMTO Regulations

Introduction

The Central Bank of Nigeria (CBN) recently introduced a revised regulatory framework for International Money Transfer Operators (IMTOs) in the country. Released on January 31, 2024, these guidelines outline the requirements, operational scope, ownership structures, compliance obligations, and governance standards for companies engaged in international money transfer in Nigeria.

This regulatory update reflects the CBN’s commitment to boosting forex liquidity, increasing diaspora remittances, and improving the ease of doing business for IMTOs. The new framework also brings stricter licensing conditions, clearer compliance requirements, and enhanced customer protections.

For anyone interested in starting a money transfer business in Nigeria, this guide provides a detailed breakdown of the Money Transfer License in Nigeria, including eligibility criteria, required documentation, compliance rules, and best practices.

Understanding IMTOs in Nigeria

An International Money Transfer Operator (IMTO) is a CBN-licensed company that facilitates the inbound transfer of foreign currency from individuals or businesses abroad to beneficiaries in Nigeria. IMTOs serve as intermediaries, ensuring that remittances are efficiently received and disbursed in line with CBN regulations.

Key Changes in the 2024 IMTO Guidelines

The new IMTO framework introduces several changes that impact both new and existing players in the industry.

Aspect Previous Regulation (2014) Updated Regulation (2024)
Who Can Operate? Fintechs, banks, and IMTOs Only IMTOs (Fintechs & banks prohibited)
Transaction Scope Inbound & outbound transfers Inbound-only transactions
Allowed Transaction Types Person-to-person (P2P) only Expanded to include Business-to-Person (B2P) & Business-to-Business (B2B)
Foreign Exchange Sourcing IMTOs could buy forex domestically IMTOs prohibited from buying forex from local markets
Settlement Methods Bank transfer & cash pickup Amounts above $200 must be settled via bank transfer
Annual License Renewal Not strictly enforced Mandatory renewal by January 31st each year
Collaboration with Agents No specific rules CBN approval required before appointing agents

These changes indicate stricter control over IMTO operations, ensuring that only compliant businesses are allowed to operate in the money transfer sector.

Who Can Apply for a Money Transfer License in Nigeria?

Eligibility Criteria

To obtain an IMTO license, the applicant must be a registered company that meets the CBN’s financial, legal, and operational requirements.

Who is NOT Eligible?

  • Banks (They may act as agents but cannot operate their own IMTO business).
  • Fintech companies (Previously allowed, now strictly prohibited).
  • Unregistered entities or individuals

Requirements for Obtaining an IMTO License

To apply for an IMTO license, a company must submit an application to the Director, Trade & Exchange Department of the CBN, along with the following documents:

Required Documents

  1. 1. Proof of approval to operate internationally (For foreign IMTOs)
  2. 2. Certificate of incorporation & tax clearance (For Nigerian companies)
  3. 3. Ownership structure & board approval
  4. 4. Company profile, including CVs of key executives
  5. 5. Credit reports of shareholders & management
  6. 6. Details of technical partners (if applicable)

Upon successful review, the CBN grants an Approval-in-Principle (AIP), allowing the applicant to set up its operations. However, the final license is only granted once all compliance conditions are met.

Annual Renewal Requirement

  • IMTO licenses must be renewed annually by January 31st
  • The renewal fee is ₦10,000,000.
  • Failure to renew on time may result in suspension or revocation.

Forms of Money Transfers in Nigeria

IMTOs facilitate different types of money transfers to accommodate varying customer needs.

Type of Money Transfer Description
Bank Transfer Transfers money between bank accounts via Bacs, CHAPS, SEPA, or SWIFT.
Wire Transfer Direct international transfers between unlinked bank accounts.
In-Person Transfer Western Union-style transfers where recipients collect cash at agent locations.
Mobile Money Transfer Transfers funds directly to a recipient’s mobile wallet.
Payment Apps Digital platforms like PayPal, WorldRemit, and Wise allow seamless online transfers.

How Money Remittance Can Be Executed

Remittances can be carried out through several channels, depending on convenience, cost, and recipient access.

1. Through Banks & Financial Institutions

  • Transfers made via online banking, mobile banking apps, or branch visits.
  • International transfers require IBAN or SWIFT/BIC codes.

2. Through Specialized Money Transfer Companies

  • IMTOs provide online & in-person services.
  • Recipients may need a government-issued ID for verification.

3. Through Payment Apps

  • Customers can send money using debit/credit cards.
  • Funds can be transferred to a bank account or cash pickup location.

4. Directly to Mobile Wallets

  • Funds can be sent to a recipient’s mobile wallet for instant access.
  • Popular in Africa & Asia due to widespread mobile banking adoption.

Compliance & Regulatory Obligations for IMTOs

1. Anti-Money Laundering (AML) & Compliance

IMTOs must establish strong AML & Counter-Terrorism Financing (CTF) measures to prevent illicit transactions

AML Compliance Requirement Details
Customer Due Diligence (CDD) Verification of sender & recipient details.
Transaction Monitoring Detection of suspicious activities.
Suspicious Transaction Reporting (STR) Reports must be submitted to authorities within 24 hours.
Record Keeping Maintain transaction records for at least 5 years.

2. Transparency & Disclosure

IMTOs must clearly disclose:

  • Exchange rates & transaction fees
  • Applicable charges
  • Terms & conditions in simple language

3. Collaboration with Agents

  • IMTOs can work with local agents, but CBN approval is required.
  • The IMTO is responsible for any misconduct by its agents.

Penalties for Non-Compliance

The CBN has strict enforcement policies for IMTOs that violate its guidelines.

Offense Possible Sanction
AML violations Heavy fines or license revocation
Late renewal Suspension of IMTO operations
Misrepresentation of fees & rates Fines & penalties
Unauthorized outbound transactions Immediate suspension

Your IMTO Licensing Questions, Answered

1. What is an IMTO in Nigeria?

An International Money Transfer Operator (IMTO) is a CBN-licensed company that facilitates inbound remittances from individuals and businesses abroad to recipients in Nigeria.

2. Can fintech companies apply for an IMTO license in Nigeria?

No, the 2024 CBN guidelines prohibit fintech companies from obtaining an IMTO license. However, they can partner with licensed IMTOs to offer money transfer services.

3. What is the cost of an IMTO license in Nigeria?

  • The initial license fee is ₦10,000,000.
  • The annual renewal fee is also ₦10,000,000, due before January 31st each year.

4. Can an IMTO operate outbound transfers from Nigeria?

No, the updated guidelines restrict IMTOs to inbound transactions only. Outbound transfers must be handled through other financial institutions.

5. What are the permitted money transfer methods in Nigeria?

IMTOs can facilitate transfers via:

  • Bank transfers
  • Wire transfers
  • In-person cash pickups
  • Mobile money & digital wallets

6. How long does it take to get an IMTO license in Nigeria?

The licensing process includes:

  • 1. Application submission
  • 2. Approval-in-Principle (AIP) issuance
  • 3. Final approval within 3 months (if all conditions are met).

7. Can banks operate as IMTOs in Nigeria?

No, banks cannot obtain an IMTO license, but they can act as agents for licensed IMTOs.

8. How are beneficiaries paid in Nigeria?

Beneficiaries receive payments in Naira via:

  • Bank deposits (mandatory for amounts exceeding $200)
  • Cash pickup at authorized locations

9. Are IMTOs allowed to buy foreign exchange in Nigeria?

No, IMTOs cannot purchase forex from the domestic foreign exchange market for settlement purposes.

10. How can I start a money transfer business in Nigeria?

To start a money transfer business in Nigeria, you must:

  • Register a company with the Corporate Affairs Commission (CAC)
  • Meet the capital requirement ($1 million or naira equivalent)
  • Apply for an IMTO license from the CBN
  • Comply with AML, KYC, and other financial regulations

Conclusion

The new IMTO framework reflects CBN’s ongoing efforts to strengthen the international remittance industry and ensure compliance with global financial standards. For businesses interested in starting a money transfer business in Nigeria, understanding the new licensing requirements, compliance rules, and transaction regulations is critical to success.

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