CBN Steps Up Anti-Money Laundering Enforcement with New Mystery Shopping Drive

The Central Bank of Nigeria (CBN) has commenced mystery shopping exercises across Bureau De Change (BDC) outlets nationwide as part of a renewed crackdown on money laundering and terrorism financing in the country’s financial sector.

The move, announced via a circular dated 17 April 2025 and signed by Amonia Opusunju, Director of the Compliance Department, forms part of the apex bank’s strategy to bolster adherence to anti-money laundering (AML) and counter-terrorism financing (CFT) regulations.

“As part of its enhanced effort to combat money laundering, the financing of terrorism, proliferation financing, and other illicit financial activities, the Central Bank of Nigeria (CBN) hereby notifies all Bureau de Change (BDC) operators in Nigeria that it will commence mystery shopping exercises with immediate effect,” the statement read.

Mystery shopping—a globally recognised regulatory tool—will see undercover compliance officers deployed to BDC outlets to evaluate how well they adhere to AML/CFT protocols. These assessments will cover key areas such as customer identification, Know-Your-Customer (KYC) procedures, and reporting of suspicious transactions.

The CBN noted that this approach would provide real-time insights into the operational behaviour of BDCs and help identify gaps in compliance, signalling a shift from reactive enforcement to proactive monitoring.

The circular reminded operators of their obligations under several legislative and regulatory frameworks, including 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. These are further reinforced by directives issued by the CBN and the Nigerian Financial Intelligence Unit (NFIU).

The central bank warned of stringent penalties for any BDC operators found to be in violation of regulatory standards. Sanctions may include monetary fines and, in severe cases, revocation of operational licences.

CBN Steps Up Anti-Money Laundering Enforcement with New Mystery Shopping Drive

Operators have also been instructed to ensure comprehensive internal compliance structures, including staff training, transaction monitoring, and customer onboarding processes, are consistently aligned with national and international best practices.

“For the avoidance of doubt, full responsibility for compliance rests with each licensed BDC,” the CBN reiterated, reaffirming its zero-tolerance policy for breaches.

This development follows a series of regulatory adjustments aimed at reforming Nigeria’s foreign exchange (FX) market.

In February 2024, the CBN reinstated FX sales to BDCs, reversing a 2021 suspension caused by concerns over market malpractice. By February 2025, further measures were introduced, capping BDCs’ weekly FX purchases at $25,000 from a single commercial bank.

These reforms are part of the CBN’s broader agenda to stabilise the forex market while enhancing transparency and accountability in the sector.

The mystery shopping initiative underscores the CBN’s commitment to protecting the integrity of Nigeria’s financial system. By reinforcing compliance in the BDC segment, the central bank aims to combat illicit financial flows, restore market confidence, and position Nigeria in alignment with global AML/CFT standards.