Central Bank of Nigeria (CBN) Launches Mystery Shopping Initiative for Bureau de Change Compliance
The Central Bank of Nigeria (CBN) has initiated mystery shopping exercises at bureau de change (BDC) outlets as part of its intensified efforts to ensure strict compliance with anti-money laundering (AML) and counter-terrorism financing (CFT) regulations. This announcement was made in a circular dated April 17, 2025, and signed by Amonia Opusunju, the Director of the Compliance Department. The new initiative aims to curb illicit financial flows and enhance regulatory oversight within Nigeria’s financial system.
In the circular, the CBN stated, “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.”
Mystery Shopping: A Strategic Approach for Compliance Monitoring
Mystery shopping is a globally recognized method employed by regulatory authorities and businesses to assess service quality, regulatory adherence, and operational standards. Under this initiative, undercover compliance officers will be deployed to evaluate BDC operators’ compliance with critical regulatory requirements, including the implementation of effective customer identification processes, Know-Your-Customer (KYC) protocols, and the reporting of suspicious transactions. The CBN has stressed that this exercise will begin immediately, underlining the urgent need for enhanced compliance within the sector.
The CBN further reminded BDC operators of their obligations under 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 and guidelines issued by the CBN and the Nigerian Financial Intelligence Unit (NFIU).
Consequences for Non-Compliance
The CBN has warned that any operator found in violation of AML/CFT regulations will face serious repercussions, including monetary fines and potential revocation of licenses. All BDC operators are expected to guarantee that their operations, staff training, transaction monitoring, and customer onboarding adhere strictly to applicable compliance frameworks. The bank made it clear that the full responsibility for compliance lies with each licensed BDC, reiterating its zero-tolerance stance on violations.
This announcement comes in light of significant regulatory changes aimed at revamping Nigeria’s foreign exchange market. In February 2024, the CBN resumed the sale of foreign exchange to BDC operators, reversing its 2021 decision that halted FX sales due to concerns over market misconduct. Additionally, in February 2025, the CBN implemented further restrictions, limiting BDC operators to a maximum purchase of $25,000 weekly from a single commercial bank.
These regulatory changes reflect the CBN’s broader strategy to strike a balance between market stability and reinforced compliance measures. The introduction of mystery shopping is a clear testament to the apex bank’s commitment to enhancing the integrity of Nigeria’s financial system and tackling illicit activities that threaten its stability.
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