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On 25 March 2026, the Central Bank of Nigeria (CBN) issued a circular to all Authorised Dealer Banks (ADBs) confirming that International Oil Companies (IOCs) operating in Nigeria are “hereby granted unfettered access to their repatriated export proceeds.” Under this directive, IOCs may repatriate 100% of their export proceeds through ADBs, subject to adequate documentation and the submission of monthly reports to the Director, Trade and Exchange Department. The circular, which took immediate effect, expressly supersedes all prior CBN circulars on cash pooling.
23 April 26
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In 2024, the CBN released two circulars in February and May directing IOCs operating in Nigeria and earning foreign currency revenues from crude oil exports to retain 50% of their export proceeds within Nigeria for 90 days before those funds could be transferred offshore.
Before the 2024 circulars, oil and gas export proceeds had to be repatriated to the exporter’s export domiciliary account within 90 days from the bill of lading date, as provided under the Foreign Exchange Manual 2018. In addition, holders of export proceeds domiciliary accounts had unrestricted access to their funds and could sell their export proceeds to any Nigerian financial institution or use them for their own purposes. Similarly, the CBN Monetary, Credit, Foreign Trade and Exchange Guidelines for 2010/2011 and 2012/2013 confirmed that the account holder’s instruction was sufficient to dispose of or utilise export proceeds, and that holders of domiciliary accounts had unfettered access, subject to the guidelines.
The removal of the restriction imposed by the 2024 circulars in the March 2026 circular signals, in our opinion, a pivot by the CBN from emergency liquidity controls towards a more market-oriented regulatory approach, with significant implications for IOCs, Nigerian banks, and the broader Nigerian foreign exchange market.
This article examines the legal and regulatory background underpinning the cash pooling system, analyses the three key CBN circulars (the February 2024 circular, the May 2024 circular, and the March 2026 circular), and assesses the likely effects of the new policy on IOC operations, the Nigerian banking sector, and foreign currency liquidity.
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