Litigation, Insights

Nigeria Cash Withdrawal Limit: Legality of the Central Bank of Nigeria (Cbn) Circular with Ref. Nos.: Bsd/Dir/Pub/Lab/015/069 And Bsd/Dir/Pub/Lab/015/073

Following the redesigning of the currency (Naira i.e. 200, 500 & 1000) of Nigeria, the Central Bank of Nigeria (CBN) issued a memo dated 6th December 2022 and referenced BSD/DIR/PUB/LAB/015/069 to all Deposit Money Banks (DMBs) and other financial institutions in furtherance to its cashless policy. It mandated that effective from 9th January 2023, there will be a limit to over-the-counter cash withdrawals.

Withdrawals in this regard by individuals would be limited to N100,000 (One Hundred Thousand Naira) per week while corporate entities would be limited to N500,000 (Five Hundred Thousand) per week. Also, the cash withdrawal per week via Automated Teller Machine (ATM) is limited to N100,000 (One Hundred Thousand Naira) subject to a maximum of N20,000 (Twenty Thousand Naira) cash withdrawal per day and the maximum cash withdrawal via Point of Sale (POS) terminal is limited to N20,000 (Twenty Thousand Naira) per day. In addition, where any individual or corporate entity is inclined to withdraw above the limit, processing fees will be payable which attracts a percentage – 5% & 10% respectively – of the cash.

The efficacy of the new CBN Policy on cash withdrawal limit has spawned many divergent views and critiques from stakeholders and the banking public including the National Assembly of Nigeria. The Policy has allegedly been described as unconstitutional and unlawful. As a result of this feedback, the CBN on 21st December 2022 made a U-turn and declared an upward review of the Policy (via a new policy contained in a circular number BSD/DIR/PUB/LAB/015/073) by increasing the cash withdrawal limits to N500, 000 and N5,000,000 (Five Million Naira) for individuals and corporate entities, respectively…



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