In February 2014 the Central Bank of Nigeria (CBN), as part of its efforts to develop “a safe reliable and efficient payments system in Nigeria”, launched its Bank Verification Number (BVN) project.

Under this initiative,

1. All bank customers must complete biometric registration (fingerprints and photographs) and obtain a BVN, through which all transactions by that particular customer may be verified.

TRANSACTIONS DEADLINE for Bank Verification Number (BVN) project.

2. In September 2014, in order to quicken the pace of registrations, the CBN directed that all bank customers must have a BVN by June 2015, and that from March 2015 only customers with BVNs will be permitted to make transactions in excess of N100 million (approximately $500,000).

3. As from June 2015, the provision of a BVN will be a requirement for every customer as part of a bank’s know-your-customer procedures.

VOTERS CARD

4. Each of Nigeria’s 60 million registered voters has also been issued with a voter’s card that includes his or her fingerprints and photograph (apparently, only 30 million cards have actually been delivered to voters, with elections scheduled for March and April).

5. Every holder of a driver’s licence must further have had his or her photograph and fingerprints taken at a licence issuing office; although despite this, individuals can still secure licences in fictitious names.

6. Every passport holder is also required to have had his or her photograph and fingerprints taken at a passport office.

7. This information may be shared internationally, but does not appear to be available to local law enforcement agencies.

MOBILE PHONES

8. At present, the Nigeria Communications Commission (NCC) requires that every single active mobile telephone number have an individual’s biometric data registered to it.

9. However, this does not appear to have assisted law enforcement agencies in apprehending kidnappers, who tend to negotiate ransoms with the use of mobile phones.

10. According to NCC statistics, there were more than 136 million active mobile phone lines in Nigeria as at November 2014.

WHAT ISSUE

11. Notwithstanding these initiatives, law enforcement agencies in Nigeria continue to experience serious challenges in dealing with fraud involving banks, as well as with other crimes.

12. Other than the general constitutional provisions relating to privacy, Nigeria has no legislation regulating how such data should be stored or accessed.

13. Towards the end of 2014, there were reports of a marked increase in fraudulent instructions for the transfer of funds to accounts held in various banks.

14. These accounts regularly turn out to be held by persons who have provided false information; and all of the information held by the banks do not appear to have been of any great assistance to those who have lost money as a result.

15. It remains to be seen whether the BVN initiative will result in any significant reduction in these types of fraud.

It is also unclear how banks will deal with accounts held in corporate names.