The Central Bank of Nigeria (CBN) has concluded a sweeping forensic audit into undelivered foreign exchange (FX) forward contracts, signaling its intent to pursue civil, administrative, or criminal sanctions against individuals and institutions found guilty of breaching FX regulations.
The development was revealed in a document titled “Frequently Asked Questions (FAQ) on the Settlement of Undelivered Forward Contracts”, published Thursday on the CBN’s official website.
The audit, conducted by Deloitte between September 2023 and mid-2025, focused on transactions under the Retail Secondary Market Intervention Sales (RSMIS) window.
According to the CBN, the audit uncovered widespread irregularities, including:
Mismatched beneficiary identities
Inflated FX requests
Incomplete or falsified Form M submissions
Approvals granted for non-permissible imports
FX sale values exceeding declared cost of goods
In several cases, companies that had no authorization to import specific goods submitted requests backed by vague or fraudulent documentation. Such infractions, the Bank said, rendered many contracts legally void and ineligible for FX settlement.
“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 document stated. “The Bank will collaborate with law enforcement and regulatory agencies to pursue civil, administrative, or criminal sanctions, as necessary.”
The CBN clarified that all affected counterparties were given opportunities to explain discrepancies before their contracts were deemed invalid. For these invalid contracts, naira payments collected upfront were refunded, but no foreign exchange was disbursed.
The Bank also emphasized that the audit process—led by independent forensic experts at Deloitte—was comprehensive, transparent, and met procedural fairness standards. Authorized dealer banks were contacted during the process to provide clarity on questionable transactions.
“The case of undelivered forward contracts is now concluded and closed,” the CBN declared, adding that no appeals will be entertained.
This announcement comes months after the CBN Governor, Olayemi Cardoso, confirmed that only $4.6 billion out of the previously reported $7 billion FX backlog was valid. The remaining $2.4 billion, he stated, had been flagged as invalid after Deloitte’s review.
In a letter dated August 4, 2025, signed by Okey Umeano, Acting Director of the Financial Markets Department, the CBN formally informed all authorized dealer banks of the conclusion of the audit. It confirmed that:
All validated transactions have been fully paid.
The naira equivalent of unverified or invalid transactions has been refunded to the respective banks.
The audit is part of a broader effort by the Cardoso-led CBN to restore market confidence, strengthen transparency, and safeguard Nigeria’s FX reserves amid ongoing reforms in the financial sector.
