The Nation Newspaper

Tag: cbn

  • CBN resisted pressure to float the Naira – Okoroafor

    The acting Director of Corporate Communications, Central Bank of Nigeria (CBN), Mr. Isaac Okoroafor, said on Wednesday the apex bank resisted suggestions to float the Naira when the country was battling with economic recession.

    Okoroafor spoke at the Capital Chapter Congress/Dinner of the Nigerian Institute of Public Relations (NIPR) in Abuja.

    Delivering a lecture titled: “Managing Public Confidence in a Period of Economic Challenge -The Role of Public Relations,” the CBN spokesman said the bank was vindicated afterwards for rejecting the suggestion.

    A floating exchange rate is a regime where the currency price is set by the forex market based on supply and demand compared with other currencies.

    This is in contrast to a fixed exchange rate, in which the government entirely or predominantly determines the rate.

    He said: “Several people both local and international made the suggestions that we float the Naira but we said no.

    “We resisted the option because we felt it was a wrong option and dangerous to the economy and we are very happy we proved them wrong.

    “We believe we succeeded and what are doing now in to consolidate on the successes and address our failures.”

    NAN

     

  • CBN sustains forex intervention with $210m injection

    The Central Bank of Nigeria (CBN), yesterday sustained foreign exchange  supply in the inter-bank Foreign Exchange market with the sum of $210 million.

    The bank offered $100 million to authorised dealers in the wholesale segment of the market while interests in the Small and Medium Enterprises (SMEs) segment received the sum of $55 million. Also, the sum of $55 million was apportioned to invisibles such as tuition fees, medical payments and Basic Travel Allowance (BTA).

    Confirming the figures, the CBN’s Acting Director, Corporate Communications Department, Isaac Okorafor, said the Bank’s continued intervention forex market is to ensure the availability of foreign exchange to genuine customers.

    He urged the Deposit Money Banks (DMBs) to continue to comply with the Bank’s directive to sell forex over the counter to customers with legitimate needs so as to sustain the confidence in the foreign exchange market.

    It will be recalled that the CBN had recently ordered banks not to deny genuine travelers Personal Travel Allowance (PTA) and Business Travel Allowance (BTA) as there are enough dollar supplies to meet the demand. This was followed by the CBN Governor, Godwin Emefiele leading Bank Examiners to conduct on-the-spot assessment of forex sales in the DMBs on Monday, May 28.

    Meanwhile, the naira yesterday, exchanged at an average of N363/$1 in the BDC segment of the market.

  • BDCs reject CBN’s dollar purchase order

    Bureaux de Change (BDCs) operators yesterday rejected Central Bank of Nigeria’s (CBN’s) directive that operators make at least three dollar purchases weekly or be sanctioned.

    The apex had also threatened to punish banks that fail to instantly sell foreign exchange (forex) to eligible travelers and boost dollar liquidity in the market.

    The new CBN’s moves followed last week’s depreciation of the naira against dollar, which saw the local currency closing at N366/$1 at the parallel market on Friday from N361/$1 sustained in nearly one year. The naira remained flat at the parallel market trading at N364/$1 for the first three trading sessions in last week before losing one naira on Thursday and Friday respectively to close the week at N366/$1 despite $310 million injected into the interbank foreign exchange market by the CBN.

    But when contacted, the Association of Bureaux De Change Operators of Nigeria (ABCON) rejected CBN’s mandatory dollar purchase order to BDCs. The group rather, asked the regulator to review BDC’s dollar purchasing rate to align with rate commercial banks’ buying rate.

    ABCON President, Aminu Gwadabe, said in a statement that CBN’s directive on BDCs should be put on hold. He said: “The CBN’s directive at this time of our operational difficulties is no doubt precarious and vague and was intended to emasculate a sector that has helped the system to stabilize and thus unacceptable”.

    The CBN had directed in a statement signed by its Acting Director, Corporate Communications, Isaac Okorafor, that: “All BDCs shall henceforth access forex from the CBN on Mondays, Wednesdays and Fridays. It is compulsory that all BDCs access forex at least three times weekly. Any BDC that fails to access the forex window at least three times weekly shall have its licence reviewed by the CBN”.

    The CBN’s goal, Okorafor said, is to ensure that eligible travelers are able to access foreign exchange for the Business Travel Allowances (BTA), Personal Travel Allowances (PTA), school fees payment and medical bills payment. It is also in line with its plan to deepen foreign exchange liquidity available in the market.

    Finding by The Nation also showed that CBN Governor, Godwin Emefiele and key CBN officials are expected to within this week, go on spot-checks in some unspecified branches of commercial banks to monitor compliance with directive on immediate dollar sale to travelers.

    Gwadabe insisted that the regulator should firstly, merge BDC dollar buying rate with that of commercial banks and also pay ABCON disbursement fees as it is practiced globally. For instance, Travelex also collects forex disbursement fees from the CBN.

    The ABCON leader urged BDC operators to remain calm and focused, ahead of and executive engagements with the CBN and ‘further communication soon’.

    Gwadabe therefore recommended that the CBN cuts the three market days for buying dollars to two at $30,000 per market day. He said: “The rate between the banks and BDCs should be merged for uniformity and fairness. A situation where the banks buy dollar from the CBN at lower rate than the BDCs is no helping the market stability drive. Besides, ABCON should be considered for disbursement fees like Travelex in the collection centres to ameliorate the new assignments”.

    BDC operators insisted that making Fridays a market day for dollar purchase and funding done same day will be difficult to achieve and therefore should be discouraged. Gwadabe assured the CBN of BDCs’ continuous support in enabling the regulator achieve its core mandate of ensuring exchange rate stability and liquidity access.

    He added that: “The BDC sector is confronted with many challenges such as multiple exchange rate,  abnormal bank charges, Value Added Tax (VAT) and Commission on Turnover (COT), parallel market operators and illegal International Money Transfer Operators (IMTOs), porous international boarders, complex documentation requirements and poor capacity/ skills of operators”.

    Continuing, he said: “For instance, the increasing difficulties arising from over regulation and complex documentation requirements that licensed BDC operators are facing in carrying out their daily legitimate operation remain worrisome. These hitches have negative impact on BDCs’ efforts toward compliance to statutory and regulatory requirements. For instance, six units within the CBN are involved with BDC regulations, supervision, licensing, monitoring, saying this  constitutes multiple regulation of a unit of the financial sub-sector that is only involved as a small market player”.

    He said a BDC operator is expected to render daily, monthly, quarterly, half yearly and annual returns to these various departments of the same corporate body, which could be very cumbersome, repetitive and time consuming for both the operator and the regulator.

    “ABCON is therefore using this opportunity to appeal to the CBN to take urgent steps to review the rate at which the dollar is sold to BDCs in order to boost ongoing recovery of the naira against dollar. Obviously, the BDC business has been badly affected by “uncompetitive rate as the CBN sells dollars to BDCs at higher rate compared to what it sells to commercial banks, yet both institutions target the same market segment and customers. The BDCs buy dollar from the International Money Transfer Operators (IMTOs) at N360/$1 and sell to end users at N361.5/$1 while the CBN sells to commercial banks at N357/$1 and the banks sell to end users at N360/$1,” he said. He urged the CBN to review BDC rate to align with that of the banks since both sectors serve the same customers.

    The ABCON boss also want the apex bank to make BDC transactions Value Added Tax (VAT) and Commission on Turnover (COT) exempt and reduce BDCs licence renewal payments.

  • E-payment promotes efficiency in resource allocation, says CBN

    Channeling of payment through the e-payment leads to efficiency in allocation of resources, especially in an emerging market like Nigeria, Central Bank of Nigeria (CBN) Deputy Governor, Operations, Adebayo Adelabu has said.

    Speaking at the Electronic Payments Incentive Scheme Efficiency Awards held in Lagos, he said e-payment leads to increased consumption,  more production and employment.

    “We have seen the growth in volume and value, but I believe we are still scratching the surface, as the potential growth in the payment ecosystem is heaps.

    ‘’Furthermore, the payments system has been a harbinger of hope for the economy as operators in the payments system have been attracting foreign direct investment notwithstanding the challenges. Also, you have made the country proud and our payment system a bench mark in our sub-region, through your innovations, hard work and collaboration,” he said.

    Adelabu lauded the successful turnout of the Bank Verification Number project and implore all stakeholders to ensure that we maintain the integrity of the platform to derive the maximum benefit.

    “Let me thank you most importantly on the collaborative spirit, work done on integrating the Fintech Start-ups, as I regularly receive briefings on how you continuously collaborate with the Central Bank of Nigeria to ensure that the country gets it right. We will continue to count on you in the years ahead as we partner to greater heights in delivering exceptional electronic payments services that will further extend beyond the  borders and spread more vigorously across whole of Africa,” he said.

    He said banks have continued to make life easier for Nigerians, with electronic payments innovations and extending the reach of financial services to reduce cash intensity in our economy.

    “Let me thank Nigeria Interbank Settlement Systems (NIBSS) Plc and members of the Electronic Payments Incentive Scheme Committee for creating this relaxed atmosphere in which we play down the intense competition and nerve-racking daily efforts to ensure availability and efficiency of electronic payments system at all times: twenty-four hours a day, seven days a week. It is my hope that the systems will behave for the few hours we are here so we can fully let down our guards and relish this moment of celebration of our efforts in 2017,” he said.

    He said stakeholders project deserved to be comendation for braving infrastructural limitations, increasing and worrying cyber security challenges, needs for sensitisation of Nigerians to accept electronic payments and regulatory requirements. ‘’You have been unrelenting and because of your activities, Nigeria continues to be celebrated as a trail blazer on the continent in electronic payments services.

  • CBN mandates banks to sell forex to customers over the counter

    • Asks banks to access dollars from CBN thrice a week

    Nigerians travel-ling overseas can now heave a sigh of relief following the release of new Central Bank of Nigeria (CBN) directives that make it much easier for people in this category to access foreign exchange for their travelling needs.

    A statement Saturday night by the apex bank’s Acting Director, Corporate Communications, Isaac Okoroafor, stated that in a bid to ensure that eligible travelers are able to access foreign currency and make liquidity available in the market, the CBN had issued the following instructions to banks:

    “All Deposit Money Banks are mandated to buy and sell foreign currency to travelers (both customers and non-customers) upon presentation of relevant valid travel documents such as visa and tickets over the counter. All travelers shall be attended to immediately at the bank’s counters. Any contravention will be sanctioned by the CBN.

    “All Bureaux de Change (BDCs) shall henceforth access dollars from the CBN on Monday’s, Wednesdays and Fridays. It is compulsory that all BDCs access currency at least three times weekly.”

    The statement warned that BDCs that failed to access the FX window at least three times weekly would have their licenses reviewed by the CBN – emphasizing that compliance with the new directive was compulsory.

  • CBN injects $100m into interbank market

    The Central Bank of Nigeria (CBN) yesterday released  $100 million into the Nigerian Forex market to boost liquidity in the market.

    The move was also in line with the regulator’s determination to safeguard the interest of customers seeking to purchase foreign exchange for personal obligations and checkmate any attempt at causing panic in the market.

    The release, which is coming barely 24 hours after the Bank injected $210 million into the wholesale segment of the market, is aimed at accommodating the spike in the seasonal demand for foreign exchange to meet various personal obligations, particularly pilgrimage.

    Furthermore, it was learnt that the CBN plans to inject more United States Dollars into the foreign exchange market in the coming days, to checkmate any attempt to trigger artificial scarcity of the greenback.

    Confirming the release, the Bank’s Acting Director, Corporate Communications, Isaac Okorafor said the move had become necessary in order to protect customers from the activities of speculators who might want to capitalize on the increase in demand for foreign exchange at this time to make brisk gains.

    While noting that the CBN had sufficient foreign exchange to meet genuine needs, Okorafor cautioned dealers against speculation, warning that they stood to lose much if they chose to hoard currencies in anticipation of a spike and a depreciation in the value of the naira.

     

  • CBN to stop naira slide, inflation with election spending monitoring

    With election spending looming and the late passage of the 2018 budget, the Central Bank of Nigeria (CBN) has vowed to monitor and control spending in the coming months to save the economy from the adverse consequences of expansionary fiscal measures.

    CBN Governor Godwin Emefiele told reporters at the end of the Monetary Policy Committee (MPC) meeting in Abuja: “We will be in control and monitor these activities and ensure that as these activities begin to unfold we, as monetary policy authority, will take action that will make sure that the adverse consequences that will arise from these expansionary activities will not impede our activities of bringing inflation down and achieve a stable exchange rate.”

    That is why the MPC decided to retain the Monetary Policy Rate (MPR) at 14%, the CBN boss said.

    The CBN Governor noted that “there are expansionary fiscal activities that we see, beginning from around May or June, this year; the fact that at this time we are still spending on 2017 budget; 2018 budget will hopefully kick in around June/July.  There will be an acceleration to the rate of spending and we also expect that there will be a lot of election spending.”

    According to Emefiele, the MPC was worried over the potential effects of expansionary fiscal budget of 2018 and the liquidity impact of rising FAAC distribution, following increase in the prices of crude oil as well as the build- up in election related spending towards the 2019 general elections.

    These, he said,  “expectedly, are meant to expand the economy and spur growth, which is commendable, but because price and monetary stability is our strong mandate, we do know that those expansionary fiscal measures will eventually lead to inflationary tendencies and, if that happens, may reverse the course of inflation upwards and put pressure on the foreign exchange market.”

    As a result of these  findings and scary scenarios, the MPC, Emefiele said, “strongly deliberated and thought there was a need to tighten in anticipation of the occurrence  of these expansionary activities”.

    On the Nigeria/China currency swap, the CBN Governor said the details of the framework would be released next week.

    As a first step, he said, “the settlement banks have been chosen; they will be Standard Chartered Bank, and Stanbic Bank that has its own affiliate bank ICBC that is the Investment and Commercial Bank of China that will be the correspondent at the Chinese end”.

    Emefiele assured Nigerians that the deal “can never be negative to Nigeria”. According to him, “how it works is that it will just operate the way normal Form M or LC (Letters of Credit) transactions happen”,

    “Under the China-Nigeria deal, what we are saying is that Form M or whatever name it will be called by the time the framework is released, we will begin to see that Chinese suppliers will begin, based on the negotiations with their Nigerian importers, to issue invoices in Reminbi and if you consider that China is Nigeria’s largest trading partner, controlling close to a market share of about 25%,  what that means is that all things being equal, by the time we conclude the framework, we should see invoices more in Reminbi rather than in the traditional dollar.”

    In Emefiele’s view, “it is going to be strongly positive for Nigerian imports and also for Nigerians; that is what we expect and we will ensure that we achieve that”.

    The CBN chief maintained that “this was a negotiation that was painstakingly drawn, and I am optimistic that Nigeria will reap a positive impact from this and we do expect that by the time the framework is released, that Nigeria will end up being the Reminbi trade hub in the West African sub-region” .

    His optimism  is based on the fact that “there are only three countries in Africa that are currently enjoying the swap deal between China and themselves (South Africa, Egypt and Nigeria); so, there is a lot of scope to go through it and for Nigeria to benefit from this arrangement and particularly not just in Nigeria but also West African sub-region.”

    Asked how the apex bank hopes to creatively boost credit to the real sector, the CBN governor said that one of the creative ways to encourage Deposit Money Banks (DMBs) to increase credit to the real sector of the economy, will be to “come up with some prudentials that will relate loan/deposit ratio with the level of cash reserve that a bank pools so as to direct a bank or compensate the bank that has done a lot of work in boosting its loan/deposit ratio through compensating them”.

    The compensation, he said, will come in the form of Cash Reserve Ratio (CRR) benefits to the DMB.

    “Those who prefer to keep liquidity and trade in government securities or direct those to the FX market rather than grant a loan to the real sector will be penalised,” he added.

    At the end of the MPC meeting, it was decided that MPR will be retained at 14 per cent, with one member voting for a reduction; CRR was also retained at 22.5 per cent and the liquidity ratio of 30 per cent; Asymmetric corridor at +200 and -500 basis points around the MPR.

    According to the meeting’s  communique, foreign reserve stood at $47.79 billion as at May 18, 2018.

    The MPC urged the CBN to sustain this momentum and continue to boost investor confidence in the economy.

    The Committee believes that growth remains largely fragile and could benefit from further reforms and stimulus.

    In this regard, the MPC urged the various levels of government to accelerate the settlement of contractors’ debts and salary arrears as well as facilitate the quick implementation of the 2018 Federal Government budget.

  • ATCON rejects CBN’s 0.005% cyber security levy

    • Group advises subscribers to brace for tariff increase

    The Association of Telecommunications Companies of Nigeria (ATCON) has rejected the move of the Central Bank of Nigeria (CBN) to start the implementation of a certain section of the Cybercrime Act 2015. The section provides for the collection of ‘0.005’ levy on all electronic transactions into a National Cyber Security Fund account with the CBN.

    Its National President, Mr. Olusola Teniola, warned yesterday in Lagos that the collection of the levy would inevitably lead to a sharp increase in ‘charges paid by customers’ for telecoms services.  He said tariff on voice calls and data cost would certainly go up because the impact of the levy would be passed on to the end user of telecoms services.

    The businesses which are to be affected by the levy include telcos, Internet Service Providers (ISPs); banks and other financial institutions; insurance companies and Nigerian Stock Exchange.

    Teniola said the CBN has written to the group to brace for the collection of 0.005 per cent levy. He lamented that the industry was already heavily burdened by 39 different taxes, charges and levies imposed on it by the three tiers of government and their ministries, departments and agencies (MDAs).

    He warned that private sector efforts to speed up broadband penetration in the country would affected as investors would choose not to invest in the sector, adding that the $70billion foreign direct investment (FDI) that has come to the industry came from investors and not from government.

    He said the association has a mandate to protect the investment in the telecom industry from undue pressure from the government in the form of yet additional burden on our members that are already overtaxed by all tiers of governments.

    He said: “The Cybercrime (Prohibition, Prevention etc) Act 2015, Section 44 that the CBN seeks to implement, states in Section 44 an establishment of a National Cyber Security Fund.

    “In Section 44.2 (a) a Levy of 0.005 of all electronic transactions by the businesses specified in the second schedule to this Act. Where in the Schedule five categories including GSM service providers and all telecommunication companies and Internet Service Providers are to apply this charge.”

     

    “ATCON believes any premeditated actions that are capable of killing the telecoms industry must be eschewed by all tiers of governments in Nigeria as the perceived benefits of imposing this levy on aforementioned businesses have the direct capability to erase if not destroy the achievements that have been made since the telecoms sector was liberated.

    “We therefore advise government review this directive as it would affect some macro-economic elements such as loss of employment and we as Industry will have to increase prices to cover the collection, processing and pass on these costs to the 150million subscribers,” ATCON said.

    Inconsistent and defective policy formulation

    He said the group is of the opinion that formulation and implementation of policies are not properly coordinated in the sense that while some government agencies are working towards migrating all government services online, some others are working towards discouraging people from making use of electronic channels via this obnoxious levy.

    “It should be stated for the purpose of records that government should not think that the elasticity of demand for the use of electronic channels is inelastic as this move can stop people from transacting their businesses via available electronic channels,” Teniola warned.

  • CBN lifts retail SMIS with $293m foreign exchange injection

    The Central Bank of Nigeria (CBN) at the weekend lifted the Retail Secondary Market Intervention Sales (SMIS) of the inter-bank Foreign Exchange Market with the sum of $293 million.

    A statement from the bank’s Acting Director, Corporate Communications Department, Isaac Okorafor, confirming the figures, indicated that the sum, as in previous interventions, was in favour of interests in the agriculture, airlines, petroleum products, raw materials and machinery sectors.

    He reiterated that the objective of the CBN intervention in the foreign exchange market has remained ensuring liquidity in the foreign exchange market and enhance production activities.

    He explained that the CBN will continue to ensure liquidity in the interbank sector of the market as well as sustain its interventions in order to drive economic growth and guarantee market stability.

    Meanwhile, the naira remained stable and exchanged for N361/$1 in the BDC segment of the market on Friday, May 18.

    The naira had been relatively stable at 360 to the dollar for months after the CBN in April 2017 liberalised trade in the currency for investors as it emerged from a currency crisis and recession brought on by low oil prices that also slashed government revenues.

    The CBN then introduced a multiple exchange rate regime to closely manage dollar demand as a way to alleviate chronic dollar shortages. Part of the latest shortage of dollars was due to offshore funds dumping Nigerian bonds following a fall in yields and multinationals repatriating their dividends.

    Forex traders also said the CBN has reduced its issuance of open market bills and lowered the interest rates it offered, signaling a more dovish stance on interest rates that nevertheless makes the currency less attractive for foreign investors.

    This shift at the CBN comes after the government paid off some of its treasury bills rather than rolling them over as it has done in the past, in a move to lower its borrowing costs. This has made investors pull funds away from Nigerian fixed income securities, which coupled with firms repatriating dividends abroad, put pressure on the currency market.

     

    In one example of the currency pressure from dividends, the Nigerian unit of South Africa’s MTN declared a dividend of 50 billion naira in 2017 and paid a further dividend in the first quarter, which it said it would repatriate to offshore investors – meaning it would sell that amount of naira.

     

    On the official market the naira is quoted at around 305 per dollar, where it has been for over a year, supported by regular central bank interventions. One lender traded the currency at 314.50 naira on Thursday.

     

  • Money laundering: CBN goes hard on banks

    • Non-compliant bank’s Boards may be removed

    The Central Bank of Nigeria (CBN) and the Office of the Attorney General of the Federation (OAGF) have approved new administrative sanctions regime against banks and their staff who fail to comply with anti-money laundering and terrorist financing regulations.

    The new rule, signed by CBN Director, Financial Policy and Regulations, Kelvin Amugo, requires that where the Board of a financial institution, a director or officer responsible for ensuring anti-money laundering compliance with any relevant provision of these regulations has been penalised in three consecutive examination cycles and the breach continues, the CBN may suspend or remove the Board, director, or officer of that institution.

    The framework released at the weekend also spelt out dissuasive monetary sanctions against Banks and Other Financial Institutions as well as their staff and Boards that fail to comply with the set rules.

    The new rule, the CBN said, is in line with the requirements of the Financial Action Task Force (FATF) Recommendations 35 on effective, proportionate and dissuasive sanctions and the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) 2007 Mutual Evaluation recommendation that Nigeria’s Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) sanctions regime should be reviewed and made to be proportionate and dissuasive.

    The administrative sanctions regime has been gazetted to give it legal effect and ensure compliance with FATF and GIABA requirements. The gazetted regulation was signed by the Attorney-General of the Federation and Minister of Justice, Abubakar Malami.

    The action also aligns with the powers conferred on OAGF by Section 23 (2) (e) of the Money Laundering (Prohibition) and are made  in  furtherance  of  the  Money Laundering (Prohibition) Act, 2011 (as amended) and Central Bank of Nigeria (Anti-Money Laundering and Combating the Financing of Terrorism for Banks and Other Financial Institutions in Nigeria) Regulations, 2013.

    Amugo said the sanctions given to any bank that violates anti-money laundering regulations will depend on how quickly, efficiently and effectively the financial institution or person  concerned  in  its management  brought  the  contravention  to  the attention of the CBN or any other relevant regulatory authority to the crime.

    It will also depend on the degree of co-operation with CBN examiners or other supervisory agency during the examination;  any  remedial  step  taken  when  the  contravention  was  identified, including  disciplinary  action taken against the staff involved, where appropriate, addressing any systemic failure and taking action designed to ensure that similar problem do not arise in the future and the likelihood that the same type of contravention will reoccur where no administrative sanction is imposed  and whether the contravention was admitted or denied.

    The new rule also requires that any bank that fails to establish written AML/CFT policies and procedures will attract N20 million fine; failure to approve the AML/CFT policies and procedures will attract N1 million fine on each member of the board and N20 million for the bank.

    Also, failure to review/update the AML/CFT policies and procedures at least every three years will attract N750,000 fine on the Executive Compliance Officer in the first instance and N750,000 for each year that the contravention continues.

    It will also attract N500,000 on the Chief Compliance Officer in the first instance and N500,000 for each year that the contravention continues and N5million on the bank in the first instance and N1,000,000 for each year that the contravention continues.

    Also, failure by a bank to communicate the AML/CFT programme of the organisation to employees will attract N750,000 fine on the Executive Compliance Officer and N500,000 on the Chief Compliance Officer as well as N10 million on the bank.

    Failure of the Board or its Committee to supervise and ensure the effective implementation of the AML/CFT programme will attract N500,000 on each member of the Board and N10 million on the bank, among other sanctions.

    The regulation requires that the Central Bank of Nigeria (Anti-Money Laundering and Combating the Financing of Terrorism for Banks and Other Financial Institutions in Nigeria) Regulations, 2013 will include administrative sanctions and penalties as listed out under the Schedule to these Regulations. Also, the administrative sanctions will be imposed after the  examination  of  a  financial  institution  and  observance  of contraventions by CBN Examiners or the recommendation of relevant agencies.

    In determining the sanctions to apply, all the circumstances of the case, including the nature and seriousness of the contravention, conduct of the regulated financial institution or person concerned in its management after the contravention, previous record of the financial institution or person concerned, shall be considered.