The Central Bank of Nigeria (CBN) has initiated mystery shopping activities

The Central Bank of Nigeria (CBN) has initiated mystery shopping activities at bureau de change (BDC) outlets as part of its ongoing efforts to ensure strict compliance with anti-money laundering (AML) and counter-terrorism financing (CFT) regulations.

Outlined in a circular dated April 17, 2025, and signed by Amonia Opusunju, the Director of the Compliance Department, this initiative aims to combat illicit financial flows and strengthen oversight within Nigeria's financial system.
"In its heightened commitment to addressing money laundering, terrorism financing, and other illegal financial activities, the Central Bank of Nigeria (CBN) notifies all Bureau de Change (BDC) operators that it will commence mystery shopping exercises immediately." **Mystery Shopping: An Innovative Compliance Monitoring Approach** Mystery shopping – a widely adopted method by regulatory entities and private organizations – is now the CBN's strategy to evaluate service quality, regulatory compliance, and operational standards of BDCs. This process involves sending undercover compliance agents to evaluate the adherence of BDC operators to essential regulatory requirements, such as effective customer identification, Know-Your-Customer (KYC) protocols, and the reporting of suspicious transactions. The CBN has emphasized that these mystery shopping activities will begin without delay, underscoring the urgency of enhancing compliance in the BDC sector. "BDC operators are reminded of their obligation to comply fully with the Money Laundering (Prevention and Prohibition) Act, 2022, the Terrorism (Prevention and Prohibition) Act, 2022, and the Regulatory and Supervisory Guidelines for Bureau De Change Operators in Nigeria, 2024, along with other pertinent laws, regulations, and guidelines established by the CBN and the Nigerian Financial Intelligence Unit (NFIU)," the circular stated. Consequences for Non-Compliance: The CBN has cautioned that BDC operators who fail to adhere to AML/CFT regulations will face serious repercussions, including financial penalties and the potential revocation of their licenses. Moreover, all BDC operators must ensure that their operations, staff training, transaction monitoring, and customer onboarding processes are in complete alignment with relevant compliance frameworks.
"To clarify, the responsibility for compliance lies solely with each licensed BDC," the CBN emphasized, reaffirming its zero-tolerance stance on violations. Key Takeaways: This announcement follows recent regulatory changes aimed at transforming Nigeria's foreign exchange market. In February 2024, the CBN reinstated foreign exchange (FX) sales to BDC operators, reversing its previous decision in 2021 to halt FX sales due to market malpractice concerns. By February 2025, the CBN imposed additional restrictions, limiting BDC operators to a maximum purchase of $25,000 weekly from a single commercial bank.
These regulatory adjustments reflect the CBN's overarching strategy to balance market stability with enhanced compliance measures. The introduction of mystery shopping underscores the CBN's commitment to reinforcing Nigeria's financial integrity and tackling illicit activities that could jeopardize its financial stability.