# CBN/NCS Import FX and Customs Documentation Controls

This evidence note consolidates relevant provisions from official Central Bank of Nigeria (CBN) and Nigeria Customs Service (NCS) sources for retrieval in the Regence demonstration. It does not create a universal USD transaction ceiling. Transaction value is controlled by the amount supported by the accepted Form M, invoice and related import documents.

## Section 1 — Form M is required for imports irrespective of value

Nigeria Customs Service import guidance states that a person intending to import physical goods into Nigeria must first process Form M through an Authorised Dealer Bank, irrespective of the value and whether or not payment is involved. The Authorised Dealer must confirm acceptance of Form M before other import processes proceed.

Primary source: Nigeria Customs Service, Destination Inspection guidance, Guidelines 1 and 6. https://customs.gov.ng/wp-content/uploads/2019/07/NCS-Destination-Inspection.pdf

## Section 2 — Pre-import documents submitted with Form M

Official import guidelines require a completed e-Form M to be submitted electronically to an Authorised Dealer Bank with a pro-forma invoice, insurance certificate and applicable regulatory certificates or permits. The bank is to ensure Form M is complete, compare attached documents with originals, perform KYC, satisfy itself that relevant documents are genuine, and validate and transmit Form M to Nigeria Customs Service.

Primary source: Nigeria Customs Service, Import Guidelines 2013, Part B, paragraphs 1–3. https://customs.gov.ng/wp-content/uploads/2019/07/Import_Guidelines_2013.pdf

## Section 3 — Form M and invoice value consistency

CBN published reasons why foreign-exchange forward claims may be invalid. These include where approved FX sales are higher than the demand, where no Forex Form number is indicated, where Form M is blank, and where the approved sales value is higher than the cost of the import item on the Form M portal. Therefore, an Authorised Dealer should not treat an unsupported difference between an FX payment instruction and the accepted import value as a valid entitlement to FX settlement.

Primary source: Central Bank of Nigeria, Frequently Asked Questions, response concerning invalid undelivered forward contracts. https://www.cbn.gov.ng/FAQS/

## Section 4 — Form M product and invoice particulars

Form M and the relevant pro-forma invoice must contain a proper description of the goods for price verification, including the generic product name, brand where applicable, model or reference number where applicable, quality or specification, quantity, and packaging. Supporting documents must be marked Valid for Forex or Not Valid for Forex as appropriate.

Primary source: Nigeria Customs Service, Destination Inspection guidance, Guidelines 3 and 5. https://customs.gov.ng/wp-content/uploads/2019/07/NCS-Destination-Inspection.pdf

## Section 5 — Documents required for PAAR

Nigeria Customs Service service standards list the documents required for a Pre-Arrival Assessment Report (PAAR): registered Form M, applicable regulatory certificates, bill of lading/airwaybill/waybill, commercial invoice, packing list and certificate of origin. Pre-shipment documents support Form M and PAAR, Customs declaration and duty calculation.

Primary source: Nigeria Customs Service, Restructured Service Level Agreement, Import Procedure: PAAR. https://customs.gov.ng/wp-content/uploads/2025/08/NCS-Restructured-SLA_Rev.docx.pdf

## Section 6 — Import shipment and origin documents

Official NCS guidance requires imports to be accompanied by relevant shipment and origin documentation. The file may include the Combined Certificate of Value and Origin with the Form M number and goods details, a packing list, and a shipped/clean-on-board bill of lading, airway bill, waybill or road waybill. The applicable documentation depends on the goods and transport route.

Primary source: Nigeria Customs Service, Destination Inspection guidance, Guideline 15. https://customs.gov.ng/wp-content/uploads/2019/07/NCS-Destination-Inspection.pdf

## Section 7 — Demonstration control for the Iroko/Blue Ribbon case

For the fictional Iroko Industries Ltd payment to Blue Ribbon Ltd, a USD 2,000,000 instruction supported by a USD 200,000 invoice leaves USD 1,800,000 unsupported. This arithmetic is a case fact, not a universal CBN USD limit. The payment should remain on hold until the full amount is reconciled to genuine commercial documents, an accepted Form M and the applicable Customs/PAAR records. Any suspicion and regulatory reporting decision requires human compliance review.

Demonstration application derived from Sections 1–6; not an additional regulatory source.