Further to a circular issued by the Central Bank of Nigeria (“CBN”) to Nigerian banks in June 2016 directing that all physical CCIs in respect of which the funds have not been completely repatriated are to be migrated to e-CCIs, the CBN has now set a deadline of Friday 19th May for submission of original physical CCIs to the Nigerian banks which issued them. Following submission, the relevant details will be uploaded and captured electronically as e-CCIs. From the go-live date of the e-CCI platform (15th May 2017), physical CCIs will no longer be issued for foreign exchange inflows.
On 12 May 2017, the CBN confirmed at a meeting with Nigerian Banks that the window for banks and authorized dealers to migrate relevant data from the physical CCIs to e-CCIs will be open from Friday 12 May 2017 to Friday 19 May 2017. Exceptions for data migration will be considered from 22 May 2017 to 26 May 2017. Any CCI not returned to the relevant issuing bank by such date will require CBN approval before it can be used. The CBN may also impose a fine as penalty for non-submission.
It is important to note however, that the deadline is for submission of the physical CCI and not for confirmation of registration of the e- CCI, and that given the short window, there is a possibility that the deadline for submission may be extended by the CBN.
The e-CCI initiative of the CBN is said to be intended to create a central electronic database for all CCIs in issue with the objective of facilitating tracking by banks, investee companies and in-bound investors; eliminating the risk of loss, fraud or forgery and in general providing for a more efficient administration of the CCI regime by the issuing banks (licensed by the CBN as Authorized Dealers of FX) and the CBN.
The new platform is expected to support all inbound foreign investment transactions evidenced by a CCI including issuance, markup in the event of an increase in investment, markdown upon a partial sale or transfer, complete divestment, reinvestment, cancellation, amendment, and transfer – as well as in relation to mass investments involving master CCIs such as in the case of such cross-border capital markets transactions, and the creation of global depository receipts.