On 24th May 2021, the Central Bank of Nigeria (“CBN”) released a new circular titled “New License Requirements for Payment System” (the “Circular”). The Circular effectively introduces new license categorization requirements for payments systems in Nigeria (the “Sector”).

Key Highlights of the Circular

Whilst the Circular retains the same classification scheme of Payment System Providers (PSP) as provided under the CBN circular on “New License Categorizations for the Nigerian Payments System” dated 9th December 2020 (the “Previous Circular”), this Circular specifically provides for the capital requirements, documentation requirements and the applicable licensing fees applicable to all the relevant players in the Sector.

Mobile Money Operators

The Circular requires all Mobile Money Operators (“MMO”) to maintain a N2,000,000,000 (Two Billion Naira) shareholders’ funds unimpaired by losses. The CBN also prescribes that a refundable deposit of N2,000,000,000 (Two Billion Naira) be made by prospective MMO licensees into an escrow account created for that purpose and the escrowed funds can be invested into treasury bills, subject to the availability of treasury instruments.

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