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How Importers and Exporters Are Adapting to CBN’s New Policies

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Nigeria’s trade players are adjusting fast to a stricter, more transparent foreign-exchange (FX) and trade regime. 

The Central Bank of Nigeria (CBN) has removed the old Price Verification System (PVS) for Form M, tightened timelines for bringing export dollars home, and introduced a formal FX conduct code for banks and market participants, alongside broader market reforms. 

Here’s how importers and exporters are adapting to the changes:

1) Faster cash-back on exports

CBN no longer grants time extensions for repatriating export proceeds. Exporters must bring home and credit their domiciliary accounts within 180 days for non-oil shipments and 90 days for oil & gas, counted from the bill-of-lading date. 

Companies are rewriting contracts to match these hard deadlines, tightening production and logistics schedules, and choosing routes with fewer delays so funds land on time. They’re also using milestone tracking with their banks to avoid breaches.

2) Form M without the old PVS—more bank-side scrutiny

With the PVS scrapped, Form M applications no longer need a PVS report. But importers aren’t relaxing: banks are leaning into detailed invoice support, comparable pricing, and supplier due diligence before approving Form M and FX. 

Firms are building stronger paper trails,factory proforma invoices, freight quotes, insurance, and product specs,to speed bank validation.

3) Cleaner FX behaviour under the Nigeria FX Code

CBN’s Nigeria FX Code sets standards for ethics, execution, information sharing, risk management, and settlement. Importers and exporters now expect clearer quotes, documented mark-ups by dealers, better trade confirmations, and tighter internal controls. 

Many are setting internal SOPs, including who requests quotes, how many quotes to collect, and how to record approvals, so audits are painless and bank relationships remain strong.

4) Tactics to handle FX timing and price swings

  • Align cash cycles to rules: exporters schedule shipments so receipts land well within the 90/180-day clocks; importers align deposit dates and LC terms to realistic vessel arrivals.
  • Use letters of credit (LCs), and confirmed LCs on riskier lanes to lock delivery and payment terms and cut disputes.
  • Create natural hedges: firms that both import and export match dollar inflows to outflows to lower net exposure.
  • Add price-adjustment clauses so contracts reflect naira moves at shipment or delivery.
  • Build operational buffers in lead times to avoid missing repatriation or Form M validity windows.

5) Documentation discipline is a moat

Even with PVS gone, documentation standards matter more than ever. Best-in-class importers keep verified supplier KYC, signed proformas, packing lists, and third-party freight and insurance quotes. 

They maintain end-to-end shipment evidence (BL/AWB, terminal receipts, inspection reports) and a clear mapping between Form M, LC or remittance, and the final goods received. 

This speeds bank approvals and protects against future queries, especially under the FX Code’s settlement and conduct principles.

6) Route and port choices that de-risk the clock

Exporters are picking routes with fewer trans-shipments and using more reliable carriers to protect the 90/180-day timelines. Some are moving to earlier bookings, bonded warehousing, and stronger export documentation support to cut hold-ups that could push receipts past CBN limits.

7) Working with banks—earlier and more transparently

Because banks carry compliance risk, traders now loop relationship managers in earlier—before placing orders or confirming cargo,so the right structuring (Form M setup, LC type, tenor, settlement method) is in place. 

Many firms request pre-clearance checklists from their banks and keep a central repository of trade files, which helps as FX automation and post-trade checks tighten further.

8) Cash-flow planning around repatriation and access rules

With stricter repatriation timelines, exporters forecast dollar inflows more precisely and link them to naira working-capital needs. 

Importers plan deposits and LC maturities against realistic ETAs. Companies avoid practices that trip compliance while they strengthen local banking lines and improve inventory turns.

9) Governance upgrades inside trading teams

To live up to the FX Code, CFOs are tightening who can request FX quotes, sign trade documents, approve rates, and submit forms. 

Many now require dual controls on rate acceptance, standard email templates for quote requests, and a daily “FX blotter” that logs quotes received, dealer chosen, and final rate,so internal and regulator reviews are straightforward.

10) What this means for costs—and competitiveness

In the short term, stricter timelines and tighter bank checks feel like extra admin. But the medium-term effect is positive: fewer delays, clearer rates, and better working relationships with banks. 

Companies that adapt early by fixing documentation, syncing logistics with cash, and embedding FX discipline turn compliance into an advantage, win faster approvals, and quote customers more confidently.

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