A Nigerian operating company usually needs a naira account for local receipts and payments and may require domiciliary accounts for permitted foreign-currency transactions. Account opening is controlled by each bank’s onboarding standards, Central Bank of Nigeria requirements and risk assessment. There is no reliable universal document list that overrides a bank’s own lawful KYC requests.

Prepare a complete corporate KYC file

Banks commonly require CAC incorporation evidence and current status information, memorandum and articles, directors’ and shareholders’ particulars, beneficial-owner information, tax identification, registered and operating addresses, board resolutions, account mandates and identity and address evidence for relevant individuals. A regulated business may need its licence or evidence of approval. A foreign parent may be asked for certified corporate documents and ownership information through to natural persons.

CBN guidance requires financial institutions to establish the existence of a corporate customer and take reasonable measures to identify directors and ultimate beneficial owners. The CBN’s BVN framework supports customer identification in the banking system. Banks may require BVN or other identifiers for directors, signatories and beneficial owners according to the applicable framework and the customer’s circumstances.

Design the account mandate before onboarding

The board resolution should specify the account type, authorised signatories, transaction limits, digital-banking users and whether signatures are joint or individual. The mandate should align with the articles, shareholders’ agreement and delegated authorities. A two-person approval process that cannot operate when one expatriate is travelling can paralyse the business; an unrestricted single signatory can create governance risk.

The company should decide who can create beneficiaries, initiate payments, approve payments and download statements. Separate user credentials and dual control are preferable to shared access. Reconcile the bank mandate after director or role changes.

Coordinate banking with foreign capital

Discuss the proposed equity or loan inflow with the authorised dealer before funds are sent. The remitter, investor, Nigerian beneficiary, currency, purpose and supporting corporate documents should be consistent with the intended electronic Certificate of Capital Importation. Funds sent before the bank confirms its documentation requirements can create avoidable difficulty.

Account opening does not itself guarantee access to foreign currency or approval of a cross-border remittance. Each payment may require underlying contracts, invoices, tax evidence, regulatory approval or NOTAP documentation. Build those requirements into commercial timetables.

Key risks

• Corporate records do not match the ownership information given to the bank.

• Funds arrive from an entity other than the documented investor or lender.

• The business description includes a regulated activity without the relevant approval.

• A bank mandate conflicts with the shareholders’ agreement.

• Online-banking permissions are not separated by role.

• Changes in directors, PSCs, address or licence status are not reported promptly.