The Central Bank of Nigeria (CBN) has announced 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.
This was disclosed in a document titled Frequently Asked Questions (FAQ) on the Settlement of Undelivered Forward Contracts, published on the Bank’s website on Thursday.
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.”
The audit, conducted by Deloitte from September 2023, reviewed transactions under the Retail Secondary Market Intervention Sales (RSMIS) window.
These 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.
This development highlights the CBN’s attempt to restore order in the FX market following years of controversy surrounding failed forwards, opaque transactions, and alleged rent-seeking behaviour.
The Bank reiterated its commitment to honouring all valid obligations while strengthening oversight.
Naijaonpoint earlier reported 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.
This development was contained in a letter dated August 4, 2025, signed by Okey Umeano, the 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.
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.
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 Consultant.