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SERAP: CBN Gets 7 Days Ultimatum to Account for ‘Missing’ N100Bn Dirty Notes, other public funds

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Socio-Economic Rights and Accountability Project (SERAP) has urged Mr. Olayemi Cardoso, governor of the Central Bank of Nigeria (CBN), “to account for and explain the whereabouts of the over N100 billion ‘dirty and bad notes’ and ‘other large sum of cash awaiting examination’ which are kept in various branches of the CBN.”

SERAP, which made the call through a statement issued by its deputy director, Kolawole Oluwadare, said the allegations are documented in the latest annual report recently published by the Auditor-General of the Federation.

SERAP also urged him to “explain the whereabouts of the N7.2 billion budgeted for the construction of the CBN Dutse branch in 2010 and the N4.8 billion budgeted for the renovation of the CBN Abeokuta branch in 2009, and to publish the names of the contractors who collected the money but failed to complete the projects.”

SERAP urged him “to explain the whereabouts of the allegedly missing outstanding loan of N1.2 billion granted to the Enugu state government in 2015 and the outstanding loan of N1.9 billion granted to the Anambra state government between 2015 and 2016 and to fully recover and remit the public funds to the treasury.”

SERAP also urged him “to refer these grave violations of the Nigerian Constitution 1999 [as amended], the CBN Act and the country’s national and international anticorruption obligations to appropriate anticorruption agencies for investigation and prosecution, as appropriate, and the recovery of the public funds.”

In the letter dated 29 June 2024 and signed by SERAP deputy director Kolawole Oluwadare, the organisation said: “These grim allegations by the Auditor-General suggest grave violations of the public trust, the provisions of the Nigerian Constitution, the CBN Act, and national and international anticorruption obligations.”

SERAP said, “These grave violations also reflect a failure of CBN accountability more generally and are directly linked to the institution’s persistent failure to comply with its Act and to uphold the principles of transparency and accountability.”

According to SERAP, “These grave violations have seriously undermined the ability of the CBN to effectively discharge its statutory functions and the public trust and confidence in the bank. The CBN ought to be committed to transparency and accountability in its operations.”

The letter, read in part: “We would be grateful if the recommended measures are taken within 7 days of the receipt and/or publication of this letter. If we have not heard from you by then, SERAP shall take all appropriate legal actions to compel you and the CBN to comply with our request in the public interest.”

“Explaining the whereabouts of the missing public funds, publishing the names of those suspected to be responsible and ensuring that they are brought to justice and the full recovery of any missing public funds would serve the public interest and end the impunity of perpetrators.”

“According to the recently published 2020 audited report by the Auditor General of the Federation (AGF), the Central Bank of Nigeria (CBN) has since 2017 been keeping over N100 billion [N100,672,999,000.00] ‘dirty and bad notes’, and other large sum of cash awaiting examination in various branches of the CBN.”

The Auditor-General fears that the ‘dirty and bad notes’ initially planned to be destroyed may have been ‘be diverted and re-injected into the economy.’”

“The CBN in August 2010 also reportedly budgeted N7.2 billion [N7,286,500,476.76] for the construction of Dutse branch building. The Dutse branch was due to be completed in November 2012 but the contractors have failed to complete the project.”

“The Auditor-General is concerned that the project may have been ‘awarded to incompetent contractor,’ and wants the ‘job completed without further delay.’”

“The CBN in 2009 reportedly budgeted N4.8 billion [N4,812,608,028.10] for the renovation of the CBN Abeokuta branch. The Abeokuta branch was due to be completed in 2012 but the contractors have failed to complete the project.”

“There is no significant renovation work on the site, several years after the proposed completion date. The Auditor-General is concerned that the project may have been ‘awarded to incompetent contractor,’ and wants the ‘job completed without further delay.’”

“The CBN also reportedly failed to account for the missing outstanding loan of N1.2 billion [N1,294,453,887.83] granted to the Enugu state government in 2015 and the outstanding loan of N1.9 billion [N1,994,383,561.64] granted to the Anambra state government between 2015 and 2016.”

“The Auditor-General fears the public funds may have been diverted. He wants the money fully recovered and remitted to the treasury.”

“Paragraph 708 of the Financial Regulations 2009 provides that, ‘on no account should payment be made for services not yet performed or for goods not yet supplied.’”

“Section 35(2) of the Public Procurement Act 2007 provides that, ‘once a mobilization fee has been paid to any supplier or contractor, no further payment shall be made to the supplier or contractor without an interim performance certificate.”

“Section 16(6) of the Public Procurement Act states that ‘all bidders shall possess the necessary professional and technical qualifications to carry out particular procurements; the financial capacity and adequate personnel to perform the obligations of the procurement contracts.’”

“SERAP notes that Section 15(5) of the Nigerian Constitution requires public institutions to abolish all corrupt practices and abuse of power.” Section 13 of the Constitution imposes clear responsibility on the CBN to conform to, observe and apply the provisions of Chapter 2 of the constitution.”

“Paragraph 3112(ii) of the Financial Regulations 2009 provides that, “Where a public officer fails to account for government revenue, such officer shall be surcharged for the full amount involved and such officer shall be handled over to either the Economic and Financial Crimes Commission (EFCC) or the Independent Corrupt Practices and Other Related Offences Commission (ICPC).”

“Nigeria has made legally binding commitments under the UN Convention against Corruption to ensure accountability in the management of public resources. Articles 5 and 9 of the UN Convention against Corruption also impose legal obligations on the CBN to ensure proper management of public affairs and public funds.”

“Nigerians have the right to know the whereabouts of the public funds. Taking the recommended measures would advance the right of Nigerians to restitution, compensation and guarantee of non-repetition.”

“The Nigerian Constitution, Freedom of Information Act, and the country’s anti-corruption and human rights obligations rest on the principle that citizens should have access to information regarding their public institutions’ activities.”


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E-Financial

CitiTrust Heads to Appeal Court over Alleged Ponzi Scheme

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CitiTrust Financial Services Limited, the parent company of Osun-partly owned LivingTrust Mortgage Bank, has approached the Court of Appeal sitting in Lagos,  following the company’s conviction at the Federal High Court, Lagos, over alleged fraud and illegal financial operations.

CitiTrust Heads to Appeal Court over Alleged Ponzi Scheme

CitiTrust, is challenging the conviction and asset forfeiture order handed down by the Court in the case brought the Economic and Financial Crimes Commission (EFCC).

EFCC accused it of money laundering, illegal financial operations, and operating a Ponzi scheme.

Federal High Court, had ordered the forfeiture of the firm’s assets to the federal government of Nigeria, citing evidence of unlawful financial activities.

CitiTrust is fighting back according to the hearing notice No. CA/L/571/2025, issued on April 15, 2026, the appeal against the federal government, will be heard at the Court of Appeal complex in Tafawa Balewa Square, Lagos.

The matter, listed before Court 1, will first address a motion by the appellants seeking leave to file their appeal out of time.

Oyetola Muyiwa Atoyebi (SAN), counsel to the appellants, in a motion dated September 23, 2025, argued that procedural delays necessitated the application.

He explained that although the Record of Appeal was transmitted on May 26, 2025, the defence could not file its Brief of Argument within the stipulated 45 days due to time constraints and competing professional obligations.

Atoyebi further noted that the appellants’ brief exceeds the 35-page limit prescribed under the Court of Appeal Rules, 2021, by three pages, requiring the court’s permission for its adoption.

The appellants are therefore seeking the leave of the court to file and serve their Brief of Argument out of time, an order extending the time for filing, and an order deeming the already filed brief as properly filed.

The EFCC had earlier secured a conviction against CitiTrust and its subsidiaries, CitiTrust Asset Management Limited and CitiTrust Holding Plc, over alleged fraudulent financial operations.

It would be recalled that in a ruling delivered by Justice Friday Nemakonam Ogazi of the Federal High Court, Lagos, the judge held that there was overwhelming evidence linking the firms to unlawful activities.

The court found that one of the entities was not duly registered with regulatory authorities, including the Central Bank of Nigeria (CBN) and the Securities and Exchange Commission (SEC), describing the operations as illegal despite corporate registration.

Relying on Section 12 of the Proceeds of Crime (Recovery and Management) Act, 2022, the court ruled that the EFCC had established, on a balance of probabilities, that the assets were proceeds of unlawful activity.

Justice Ogazi also invoked provisions of the Advance Fee Fraud and Other Fraud Related Offences Act and the Companies and Allied Matters Act (CAMA), holding that the corporate veil could be lifted where fraud is alleged.

“The law is that when issues of fraud arise, the corporate veil must be lifted. Statutory provisions cannot be used as a refuge to justify illegality,” the court held.

The court subsequently ordered the final forfeiture of CitiTrust-linked assets, forfeiture of shares held in LivingTrust Mortgage Bank Plc, compensation of investors from recovered funds, and transfer of any balance to the Federal Government.

The anti-graft agency had also declared some executive directors of the firm wanted, alleging that they are currently on the run.


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Court Suspends Enforcement of FCCPC’s Reform on Loan Apps

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Federal court in Lagos has suspended the enforcement of Nigeria’s most comprehensive framework for regulating digital lending apps.

Court Suspends Enforcement of FCCPC’s Reform on Loan Apps

On April 15, Justice Ambrose Lewis-Allagoa of the Federal High Court in Lagos granted an interim injunction blocking the enforcement of the Digital, Electronic, Online, or Non-Traditional Consumer Lending Regulations 2025, better known as the DEON Regulations.

The order followed an urgent ex parte application filed the previous day by the Wireless Application Service Providers Association of Nigeria (WASPA Nigeria), the industry body representing wireless application service providers operating mainly within the telecoms ecosystem.

The suit targets twelve specific provisions of the text, covering licensing, sanctions, compliance obligations and data-handling rules, according to court documentation published by Lawyard.

Until the next hearing on April 27, 2026, the regulator cannot impose sanctions, enforce compliance directives, or issue new instructions to WASPA members.

The judge also barred the Federal Competition and Consumer Protection Commission (FCCPC) from interfering with the ongoing commercial operations of association members.

The case pits two actors whose respective mandates the Nigerian legal framework has never clearly separated.

On one side stands the FCCPC — the federal agency established in 2018 to enforce consumer protection and competition — which gazetted the DEON Regulations on July 21, 2025, under sections 17, 18 and 163 of its founding Act.

In a press statement dated September 3, 2025, Tunji Bello, executive vice chairman, FCCPC,  justified the rules by citing “a long history of complaints” involving exploitative practices, data breaches, abusive debt recovery, and harassment.

On the other side, WASPA Nigeria contests the very legitimacy of the FCCPC’s intervention, arguing that services tied to telecoms — airtime credit, data loans, mobile-financing products — fall exclusively under the Nigerian Communications Commission (NCC), the telecoms regulator created by the Nigerian Communications Act of 2003.

In the affidavit deposed by Ayo Stuffman, the association contends that the FCCPC is acting ultra vires and creating a regulatory regime parallel to the NCC’s.

A jurisdictional war that stretches far beyond a procedural dispute

The conflict is not limited to a question of legal boundaries. It strikes at the commercial core of the market: who collects the licensing fees, who sets the operational conditions, who governs the financial products embedded in telecom networks.

Nigeria’s consumer credit stock reached 3.82 trillion naira at the end of December 2024, up 21.27% on September, according to Central Bank of Nigeria (CBN) data relayed by The Cable and AFP.

In the fourth quarter of 2024 alone, personal loans disbursed amounted to approximately 470 billion naira.

A growing share flows through mobile applications and telecom-embedded lending products — including MTN’s MoMo Airtime Lending, operated by the country’s largest telecom operator.

If the court validates WASPA’s position, these products fall outside the FCCPC’s scope and come under the sole authority of the NCC, a regulator historically less active on consumer protection issues.

Available data on demand illustrate the social stakes. Between 2021 and 2023, the FCCPC recorded more than 11,000 consumer complaints for harassment, data abuse and unethical debt recovery practices, according to the agency.

The number of lending applications approved by the FCCPC rose from 269 in September 2024 to 408 in March 2025, while 47 apps were delisted and 88 were placed on the watchlist, according to data compiled by AFP and OneSafe.

The DEON Regulations were meant to introduce interest-rate caps, precontractual disclosure obligations, continuous supervision of recovery practices and fines of up to 100 million naira per violation, according to Legit.ng. The compliance deadline was set for January 5, 2026, and the FCCPC had issued written compliance notices to operators with an April 16 deadline, according to WASPA’s affidavit.

It is precisely this enforcement pressure that triggered the legal challenge.

 

 


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FG Rules Out Borrowing from IMF’s $50Bn Support Fund

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Federal government has said that Nigeria has no plans to seek a loan from the International Monetary Fund’s proposed $50 billion support package for economies hit by the Middle East crisis.

FG Rules Out Borrowing from IMF’s $50Bn Support Fund

Wale Edun, minister of Finance, who stated this, said that Nigeria’s current reliance on domestic economic reforms and fund mobilisation was working.

Edun gave these insights during the African Finance Ministers’ briefing, on Thursday, at the ongoing IMF/World Bank annual meetings, in Washington, DC.

He noted that for over two years, Nigeria’s investment in economic reforms have begun to yield results, restoring policy credibility and strengthening the country’s resilience against global economic shocks.

Edun told the global west and the rest of the world that Nigeria now prioritises market-based adjustments, avoiding administrative controls, particularly in foreign exchange and petroleum pricing mechanisms.

His assertion follows the disclosure by the IMF that a possible $50 billion support to cushion vulnerable economies against the crisis in the Middle East, was on the pipeline.

Despite clarifying Nigeria’s lack of interest in borrowing, Edun, urged the IMF to ensure faster financial assistance for African countries who will need help from the $50 billion global support package.

“Nigeria has no plans at the moment to approach the IMF or any other such body,” Edun said, emphasising that Nigeria’s reliance on market mechanisms had led to smoother economic adjustments, reduced disruptions and is sustaining the country’s macroeconomic trajectory.

“The IMF talked about $50 billion and we all know that the funding will largely go to Africa, because those are the most vulnerable countries. And the reality is that what we’re asking for in this instance, is that the funds and the support be released quickly and at scale.

 


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