Central Bank of Nigeria (CBN) has said that it plans to pursue civil, administrative, or criminal sanctions against parties found to have breached foreign exchange (FX) rules, following the conclusion of a forensic audit into undelivered forward contracts.

A document titled Frequently Asked Questions (FAQ) on the Settlement of Undelivered Forward Contracts, published on the Bank’s website on Thursday, revealed the development.

The audit, conducted by Deloitte from September 2023, reviewed transactions under the Retail Secondary Market Intervention Sales (RSMIS) window.

The document read, “The Central Bank of Nigeria is reviewing appropriate legal action against parties found to have violated applicable rules and regulations, based on the findings of the forensic audit. The Bank will collaborate with law enforcement and regulatory agencies to pursue civil, administrative, or criminal sanctions, as necessary.”

According to the apex bank, the contracts involved upfront naira payments in exchange for promised US dollar delivery on future dates—many of which went unfulfilled.

The CBN said the audit was necessary to verify the legitimacy of these contracts, protect FX reserves, and uphold regulatory standards.

The findings revealed extensive irregularities, including mismatches in beneficiary identities, exaggerated FX requests, use of incorrect or blank Form M submissions, and approvals for non-permissible imports.

The CBN noted that certain transactions were based on vague or false documentation, while others involved companies that lacked authorisation for the items they sought to import.

In several cases, the approved FX sale value exceeded the declared cost of the imported goods, raising questions of misrepresentation.

According to the CBN, such infractions rendered the contracts void under Nigerian law and ineligible for FX settlement.

Only verified and compliant contracts were honoured.

The Bank clarified that the affected counterparties had been given the opportunity to respond during the audit process before any contract was invalidated.

For those deemed invalid, the naira previously collected was refunded, but no FX was disbursed.

The CBN has declared the audit process closed and not open to appeal, citing the independence and procedural fairness of the review.

“The audit conclusions were based on a rigorous process carried out by an independent forensic expert (Deloitte), acting pursuant to a transparent mandate.

“The auditor contacted the authorized dealer banks concerning those contracts to get their explanations of the infractions before reaching conclusions on them. The findings have therefore met procedural fairness standards. The case of undelivered forward contracts is now concluded and closed,” the document stated.

Earlier in March 2024, the CBN announced the complete clearance of the valid foreign exchange backlog.

This was after Olayemi Cardoso, governor, CBN,  in February, disclosed that about $2.4 billion foreign exchange backlog is not valid for settlement.

Cardoso clarified that out of the initially reported $7 billion FX liabilities of the federal government, about $2.4 billion were identified as invalid following a forensic audit by Deloitte Management Consultants.

Earlier report showed that CBN officially concluded the forensic audit into undelivered forward foreign exchange (FX) transactions and refunded the value of all unfulfilled and unvalidated deals to banks in naira.

The development was contained in a letter dated August 4, 2025, signed by Okey Umeano, acting director of the Financial Markets Department, and addressed to all authorised dealer banks.

The letter noted that all validated transactions had been paid, while the local currency equivalent of outstanding and unverified transactions had been returned to the banks.

A High Court in Abuja has awarded a fine of N85 million against Zenith Bank Plc for freezing a customer’s bank account by relying on an invalid court order.

Justice S. U. Bature, in a judgment, also ordered the bank to immediately unfreeze the account domicile in its branch at 63, Usuma Street, Maitama, opposite Transcorp Hilton Hotel, Abuja.

Justice Bature directed the bank to publish a public apology to the customer, Abhulimen & Co, in two national newspapers and on its website.

The judge held that the bank acted on an invalid order made by a Magistrate Court that lacked the requisite jurisdiction.

Justice Bature further held that the decision of the bank and the Nigeria Police Force (NPF), the 2nd defendant in the suit, to freeze the customer’s account, based on a supposed order by the Magistrate Court, without notifying the said customer, was illogical and a betrayal of the banker-customers’ relationship between parties.

The judge said it was unfortunate that a major financial institution like Zenith Bank, with a Legal Department, supposedly manned by lawyers, would claim to have acted based on an invalid order by a Magistrate Court that lacked the jurisdiction to entertain any banking related case, including issuing orders for the freezing of a bank account.

The judgement was delivered on July 16 but its certified true copy (CTC) made available to newsmen on Thursday in Abuja.

Paulyn O. Abhulimen, SAN, trading under the name and style of Abhulimen & Co, had, in the suit marked: FCT/HC/CV/2194/2024, sued the Zenith Bank and NPF as 1st and 2nd defendants.

Abhulimen sued through the law firm of Kehinde & Partners LP, claiming that, in early 2024, after being unable to access the account of her firm, Abhulimen & Co, and make transactions with it, she discovered that the bank placed a post-no-debt (PND) on it.

She claimed to have subsequently contacted an official of the bank, who is in charge of the account, Obi Okafor.

She said Okafor told her about the development, following which the bank, in March 13, 2024 claimed to have frozen the account based on an order obtained by the NPF from a Chief Magistrates Court in Mararaba Gurku, Nasarawa State.

Delivering the judgment, Justice Bature said: “The said account was opened at the first defendant’s (Zenith Bank’s) Transcorp Hilton branch, here in Abuja, and the 2nd defendant (NPF) is also domiciled in Abuja.

“The rationale behind seeking the said order at a Magistrate Court under the Nasarawa State jurisdiction cannot be understood, and the 2nd defendant did not appear, to be able to give any explanation or reason as to why they decided to follow this line of action.

“The said Magistrate Court lacked the territorial jurisdiction to entertain the application.

“Regarding the substantive jurisdiction of the court to make the order, it is clear from the provisions of Section 251 of the Constitution of the Federal Republic of Nigeria (1999 as amended), that matters relating to banks and banking transactions are within the exclusive jurisdiction of the Federal High Court, and matters relating to banker-customer disputes are jointly under the jurisdiction of the Federal High Court, State High Courts and High Court of the FCT,” Justice Bature said.

According to the judge, from the foregoing, it is clear that Magistrate Courts lack the jurisdiction to entertain an application for an order to freeze a bank account of a person, and should not have entertained the said application in its entirety.

“The legal department of the first defendant (Zenith Bank), being lawyers, should have been aware of this position of the law and taken the appropriate action in this situation, as they ought not to have obeyed the court order in the first place.

“Thus, the 1st defendant was wrong to have placed a PND on the account of the claimant based on the order of a court lacking the requisite jurisdiction to do so. I so hold,” the judge held.

The judge faulted the failure of the bank to inform the claimant about its decision to freeze her company’s account, describing it as a breach of the duty of care it owed to its customers.

Justice Bature said: “It is the humble opinion of this honourable court that, the first defendant owed the claimant a duty of care of duly informing her that her account had been frozen.

“The 1st defendant placed a post-no-debit on the account of the claimant’s firm, but same was not communicated to the claimant until she encountered difficulties in the use of the said account.

“It is the humble opinion of this honourable court that, the 1st defendant owed the claimant a duty of care of duly informing her that her account had been frozen

“The failure of the 1st defendant to inform the claimant of the state of affairs on her account amounts to negligence on the part of the 1st defendant and hence, a breach of duty of care and due diligence owed to the claimant. I so hold,” Justice Bature said.

Having found that the bank and the NPF acted unlawfully, the judge proceeded to declare among others, that an order to freeze a bank account cannot validly be granted ex-parte to last indefinitely.

He also declared that the Chief Magistrate Court of Nasarawa State, sitting at Mararaba Gurku, lacked the requisite jurisdiction to make an order to freeze the claimant’s Zenith Bank Plc’s account number: 1012272348, based on an ex-parte application.

“The defendants are hereby ordered to jointly and severally pay the sum of N60 million to the claimant as general damages for the embarrassment, psychological trauma, financial distress, emotional stress and grave inconveniences suffered by the claimant due to the defendants’ actions.

“The defendants are hereby ordered to jointly and severally pay the sum of N25 million to the claimant as cost of this action,” Justice Bature declared.

Bank Verification Number (BVN) database rose to a new high in July 2025, with total enrollments climbing to 66.23 million, a 4.3 per cent increase within the first seven months of the year, as Nigerians residing outside the country enrolled through the Non-Resident BVN (NRBVN) initiative.

The Central Bank of Nigeria (CBN) had, earlier this year, introduced the NRBVN, alongside the Non-Resident Nigerian Ordinary Account (NRNOA) and the Non-Resident Nigerian Investment Account (NRNIA), to attract diaspora investments into the country.

Subsequently, commercial banks with international licences took up the challenge, launching roadshows to help Nigerians abroad open accounts and enrol in the biometric identity system.

This effort drove up the number of enrollments from the 63.48 million recorded as of December 2024.

According to the latest figures from the Nigeria Inter-Bank Settlement System (NIBSS), 2025 is shaping up to be one of the most active years for BVN registration since 2021.

Over the past four years, BVN growth has maintained a steady upward trend: from 51.9 million in 2021, enrollments rose by 7.9 per cent to 56 million in 2022, followed by a 7.4 per cent increase to 60.1 million in 2023.

Growth moderated slightly in 2024, with a 5.6 per cent rise, but the 4.3 per cent increase already recorded by mid-2025 suggests this year could surpass last year’s total by December.

The NRBVN enables Nigerians living abroad to enroll for BVNs remotely, eliminating the need to visit bank branches in Nigeria.

At a cost of $50, the initiative has significantly broadened the system’s reach and strengthened diaspora engagement with the country’s formal financial services.

The spike in non-resident enrollments has also been supported by stricter Know Your Customer (KYC) requirements across the banking sector and deeper collaboration with fintechs that streamline the onboarding process.

Together, these efforts have reinforced the BVN’s role as a cornerstone of digital identity and financial inclusion in Nigeria.

Alongside the rise in BVN registrations, the banking sector is witnessing increased account activity.

As of March 2025, the number of active bank accounts reached an all-time high of 320.053 million.

Dormant accounts stood at 33.4 million, while 29.4 million accounts had been closed.

This compares to slightly lower figures in February, which recorded 316.8 million active accounts, 19.9 million dormant accounts, and 33.3 million closures.

The rebound in March points to a growing number of Nigerians re-engaging with the formal banking system, aligning with broader efforts by financial institutions and regulators to promote access, trust, and compliance within the financial sector.