Cross-Examining Settlement Accounts In Nigeria’s Mobile Money System

6 Pages Posted: 8 Sep 2022 Last revised: 9 Sep 2022

Date Written: August 27, 2022


Settlement banks in Nigeria's mobile money system impose charges on settlement accounts contrary to the plain letters of regulation 9.0 of the Guidelines on Mobile Money Services in Nigeria 2021. R.9.0(c)(iv) prohibits any form of charges on settlement accounts in Nigeria. We know that deposit money banks that act as settlement banks for mobile money operators in Nigeria impose transaction charges on settlement accounts. Admittedly, the white-label business model, and licence leverage business model that the CBN implicitly permits may contribute to unlawful actions of the settlement banks. DMBs may consider other benefits of available funds in the settlement accounts and its inherent duty not to stampede mobile money services in Nigeria. In cross-examining the settlement account in the mobile money system, we demonstrated how settlement accounts are to be negotiated and operated in Nigeria. The CBN's disposition to mid-wife financial technology services in Nigeria is laudable.

Keywords: Settlement account, mobile money services settlement banks, non-bank-led model, mobile money system, and financial technology

JEL Classification: K2

Suggested Citation

Enwe, Osita, Cross-Examining Settlement Accounts In Nigeria’s Mobile Money System (August 27, 2022). Available at SSRN: or

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