The sanction is contained in the fourth edition of the Foreign Exchange Manual recently released by the apex bank. Under the section detailing offences and penalties, the CBN stated that, “Authorised dealers shall pay N100m in addition to N10m per transaction” for consummating foreign exchange transactions with inadequate documentation.
The revised manual, released by the CBN’s Trade and Exchange Department in May 2026, represents the first major review of the framework since 2017. It provides updated guidelines for banks, authorised dealers, exporters, investors and other participants in the foreign exchange market.
According to the apex bank, the new framework is designed to improve transparency in foreign exchange transactions, strengthen compliance, enhance reporting standards, and ensure that foreign exchange resources are directed toward productive sectors of the economy.
Apart from the N100 million sanction, the manual outlines several penalties for breaches of foreign exchange regulations by authorised dealers and market participants.
For banks that exceed approved Net Open Position limits, penalties will be applied progressively. A first violation will attract a warning letter, while a second offence will result in a 10-working-day suspension from the foreign exchange market. A third breach will lead to a 90-day suspension.
The CBN also introduced stricter reporting requirements for authorised dealers. Banks must submit daily returns on foreign exchange transactions by 10 a.m. the following day and file monthly returns within five working days after the end of each month.
Failure to meet these obligations will attract sanctions. Late submission of returns carries a N500,000 fine, while failure to render returns attracts a minimum penalty of N5 million, in addition to N500,000 for every day the violation remains unresolved.
The apex bank further warned against the reallocation of foreign exchange funds without approval, stating that offenders could face financial penalties, suspension of their authorised dealer licence for at least six months, or complete revocation of the licence, depending on the severity of the offence.
Import-related transactions also feature prominently in the updated framework. Importers are now required to submit Exchange Control Documents within 90 days after negotiating shipping documents with overseas correspondent banks.
Those who fail to comply will be restricted from participating in both valid and non-valid foreign exchange transactions, including the processing of Form M applications. The restrictions increase with repeated violations, beginning with a 90-day suspension for first-time offenders, 180 days for a second offence, and 360 days for a third. A fourth violation will result in a total ban from the foreign exchange market.
Banks that fail to report such defaults could face penalties, including warnings and a N10 million fine for every affected transaction.
The revised manual also places greater responsibility on exporters. Under the new rules, proceeds from non-oil exports must be repatriated and credited into domiciliary accounts within 180 days of shipment, while oil and gas export proceeds must be received within 90 days.
Exporters that fail to meet these timelines will be sanctioned with a penalty equal to one per cent of the naira value of the outstanding proceeds. Banks that fail to enforce compliance will be fined 0.5 per cent of the outstanding amount.
In addition, the CBN reserved the right to sanction banks for delays in approving export documentation, failure to remit export supervision levies, and non-submission of returns relating to export proceeds.
Alongside the sanctions, the manual introduces several reforms intended to improve efficiency within the foreign exchange market.
Among the key changes are the increase in allowable advance payments for imports from 15 per cent to 30 per cent, the introduction of an acceptable import shortfall or excess margin of plus or minus 10 per cent of the Cost and Freight value on Form M, and the removal of processing fees for Form NXP used in export transactions.
The framework also includes provisions covering service exports, technology-related remittances, transactions under the Pan-African Payment and Settlement System, non-resident investment accounts, and tuition fee remittances of up to $25,000 per semester for undergraduate and postgraduate studies abroad.
Furthermore, the CBN removed the mandatory requirement for Form A for remittances funded through ordinary domiciliary accounts, although banks are still expected to verify the legitimacy and purpose of such transactions.
The apex bank said the revised manual was developed following extensive consultations with banks, exporters, corporate organisations, regulators and development partners, with the objective of creating a more transparent and market-driven foreign exchange system.