BANKING AND PAYMENTS SYSTEM DEPARTMENT
BPS/DIR/GEN/CIR/02/007 CENTRAL BANK OF NIGERIA Central Business District P.M.B. 0187, Garki, Abuja.

+234 - 0946238445 July 29, 2015 TO:
ALL DEPOSIT MONEY BANKS, MICROFINANCE BANKS AND PRIMARY MORTGAGE INSTITUTIONS, MOBILE MONEY OPERATIONS, SWITCHES AND OTHER PAYMENTS SYSTEM SERVICE PROVIDERS SANCTIONS ON ERRING BANKS/e-PAYMENT SERVICE PROVIDERS FOR INFRACTIONS OF PAYMENTS SYSTEM RULES AND REGULATION Further to the provisions of S.47 (3) of the CBN Act 2007, requiring the Central Bank of Nigeria to "prescribe rules and regulations for the efficient operations of clearing and settlement systems", the Bank hereby stipulates the following applicable sanctions to erring banks and payments system service providers for infringements of extant Guidelines, Circulars, Rules and Regulations issued by the Bank on all forms of electronic payments system:

1. ATM

S/No.	INFRACTIONS	PENALTY
1.	Non-compliance with Payment	N250,000 as fine and a follow-up of penalty charge of N50,000
Card Industry Data Security	per week, for as long as non-compliance persists
Standards (PCIDSS).
2.	Non-compliance of ATM	N200,000 as fine and additional penalty charge of N50,000 per
terminals with EMV level 1 & 2	week, for as long as non-compliance persists
3.	Non-compliance with	N250,000 as fine and penal charge of N50,000 per week, for as
migration to EMV after	long as non-compliance persists
September 30, 2010
4.	Failure to provide audit trails	Fine of N50,000 with a full refund to the customer
and journals for ATM
transactions
5.	Failure to have 2% of ATMs	Fine of N100,000
deployed with tactile graphic
symbol for the use of visually
impaired customers
6.	Down time of ATM for more	Fine of N100,000
than 72 hours without cogent
reasons
7.	Non availability or nen-	Fine of N100,000 and penal charge of N50,000 per week, for
functional help desk contacts	as long as non-compliance exists
8.	Non-disclosure of ATM	Fine of N50,000 daily

S/No.
1.

S/No.	INFRACTIONS	PENALTY
surcharge to customers
9.	Lack of online monitoring	Penal fee of N100,000, with immediate compliance. Graduated
mechanism for ATMs	fine of at least N150,000, if exception is picked again
10	Lack of back-up power	Penal fee of N50,000, with immediate compliance. Graduated
(inverter) for ATM	fine of at least N100,000 per week, if exception is picked again
11	Failure to have camera at	Penal fee of N250,000 and a follow-up charge of N50,000 per
ATM	day, until a camera is installed
12	Failure to provide footages on	The bank would pay a penalty equal to the amount refunded, to
ATM transactions when	serve as a deterrent
required
13	Failure to respond to the	Fine of N100,000 per day
customer/CBN on ATM
complaints within 72 hours
14	Failure of Acquirer to initiate	The bank to refund the total amount involved in the dispute and
automatic reversal of failed	a penal fine of N50,000 per day
customer ATM transaction

2. Transaction Switching Services

S/No.	INFRACTION	PENALTY
1.	Failure to apply funds to customer's	Penalty stipulated on the "Guidelines on Electronic Payments
account within stipulated timelines	of Salaries, Pensions, Suppliers and Taxes in Nigeria" applies
on the Guidelines on Electronic
Payments of Salaries, Pensions,
Suppliers and Taxes in Nigeria
2.	Non return of unapplied funds within	Penalty stipulated on the "Guidelines on Electronic Payments
24 hours	of Salaries, Pensions, Suppliers and Taxes in Nigeria" applies
3.	Non-compliance with third party	10% of the amount in excess of limit or N100,000, whichever is
cheque cap of N150,000 OTC	higher
withdrawal

1.

S/No.	INFRACTION	PENALTY
1.	Issuance of Mag-stripe cards	Bank to be fully liable for any fraud arising from the use of the card
2.	Enabling use of Mag-stripe of	Bank to be fully liable for any fraud arising from the use of the card
Nigerian issued cards in non	2

INFRACTION	PENALTY
Any	infraction	of	the	Initial fine of N100,000 and full liability for compromise due to non-
Guidelines	compliance

3. Bulk Payments And Ach 4. Card Issuance (Stored Value/Prepaid Cards And Debit Cards)

S/No.	INFRACTION	PENALTY
EMV	environment without
customer's request
3.	Issuance of Card without	Bank to be fully liable for any fraud arising from the use of the card
application from Account
holder
4.	Card fraud on an Account	Bank to be fully liable for any fraud arising from the use of the card.
while card is still in custody	Disciplinary action on the bank staff found culpable.
of bank
5.	Card frauds that exceed the	Bank to be fully liable for amount of fraud involved
limit set on the card by the
card holder
6	Card fraud on Corporate	Bank to be fully liable for amount of fraud involved
Accounts
7	Card Issuance without proper	Bank to be fully liable for amount of fraud involved
KYC
8	Loading of Cash on Cards	Bank to be fully liable for amount of fraud involved
without proper KYC

S/No.	INFRACTION	PENALTY
1.	Fraud arising from non-compliance with	Scheme operator liable for amount above set limit
transaction value limit
2.	Lack of inter-operability and	Directive to operator to disable the PoS
interconnectivity to other systems

INFRACTION	PENALTY
Late submission of monthly returns	Fine of N50,000 per day of delay.

S/No.	INFRACTION	PENALTY
1.	e-payment	operations	without	Close down of the operations and prosecution of the offender
obtaining CBN approval or license	(individual/company promoters)
2.	Patronage of unlicensed payment	Fine of N50,000 per day of continued patronage.
system operator by a Bank
3.	Non-compliance with any other	Fine of N50,000 per week of non-compliance and full liability for
CBN	e-payment	directive	or	any fraud arising from non-compliance
circular

S/No.
1.

5. Point-Of Sale (Pos) 6. Rendition Of Returns 7. Others

Non Monetary Sanctions For Violator Of Regulations

1. Name and shame of responsible officers and the entity 2.

Blacklisting of operator or service providers 3.

Removal from office of principal officers of operators and service providers 'Dipo Fatokun Director, Banking and Payments System Department 4