The Central Bank of Nigeria imposed total fines of ₦15.427 billion on Zenith Bank for contraventions identified during the 2024 period, making it the largest penalty levied on a single institution in the regulator's enforcement sweep of that year. Of that total, ₦14.647 billion was specifically attributable to foreign exchange infractions uncovered during a CBN examination of the bank's operations.

The fine formed part of a broader regulatory action in which CBN penalised six lenders — Zenith Bank, Stanbic IBTC, First HoldCo, GTCO, UBA and Wema — for FX and other violations. Collectively, those six institutions paid ₦16.45 billion in CBN-imposed fines as at year-end 2024, with Zenith Bank's share representing the overwhelming majority of that total and underscoring the scale of the infractions identified at the bank.

FX VIOLATIONS DRAW HEAVIEST PENALTIES

The concentration of Zenith Bank's penalty in the foreign exchange category reflects the CBN's intensifying focus on compliance with Nigeria's foreign exchange rules, a priority that has sharpened as the naira has come under sustained pressure and the regulator has sought to bring greater transparency and discipline to the FX market. The bank's ₦14.647 billion FX fine dwarfs the amounts paid by other institutions in the same enforcement period: Stanbic IBTC Bank paid ₦579 million, while Wema Bank paid ₦2 million for violations in the same reporting window.

The CBN's examination process, which triggered the Zenith Bank fine, involves a structured review of a bank's books and transactions. When examiners identify breaches of FX regulations — which can include unauthorised transactions, misreporting of positions or failure to comply with market conduct rules — the findings are referred for penalty determination. The size of the fine imposed on Zenith Bank indicates that examiners identified violations of considerable magnitude or frequency.

Zenith Bank is one of Nigeria's largest commercial banks by assets and deposits, and its public profile as a consistently well-capitalised institution makes the scale of the penalty all the more notable. The bank had not, at the time of the announcement, provided detailed public commentary on the specific nature of the infractions identified.

CARDOSO WARNING SIGNALS TOUGHER ENFORCEMENT

The enforcement action fits within a broader regulatory posture that CBN Governor Olayemi Cardoso had been signalling. In January 2025, Cardoso issued an explicit warning that violations of the new Nigeria Foreign Exchange Code would attract severe sanctions — a statement that reinforced the message that the era of limited consequences for FX non-compliance was drawing to a close. The January warning came before the public disclosure of the Zenith Bank fine, but together the two events paint a consistent picture of a regulator determined to tighten standards.

The Nigeria Foreign Exchange Code was introduced to impose clearer obligations on authorised dealers and market participants, with the aim of deepening liquidity, reducing speculative behaviour and aligning Nigeria's FX market practices with international standards. Whether the enforcement actions announced in early 2025 will prompt a broader reassessment of compliance frameworks across the Nigerian banking sector is likely to be a focus of regulatory observers and bank compliance teams in the period ahead.