Responses to Information Requests

Research Directorate, Immigration and Refugee Board of Canada, Ottawa

1. Overview

According to sources, the BVN is a "centralized biometric identification system" launched by the Central Bank of Nigeria (CBN) in February 2014 (Nigeria n.d.a; NIBSS n.d.a). The Nigeria Inter-Bank Settlement System (NIBSS), a company owned by the CBN and all licensed banks in Nigeria (NIBSS n.d.b), reports the following regarding BVN's objectives:

• The purpose of the project is to use biometric information as a means of first identifying and verifying all individuals that have account(s) in any Nigerian bank and consequently, as a means of authenticating customer’s identity at point of transactions.
• To provide a uniform industrially accepted unique identity for [b]ank [c]ustomers.
• To authenticate transactions without the use of cards using only biometric features and PIN.
• Identification of blacklisted customers. (NIBSS n.d.a)

The CBN explains that the BVN "is neither a payment instrument nor an account number and therefore could not be used to access any account by unauthorized users" (Nigeria 5 Nov. 2015). In October 2017, the CBN released the Regulatory Framework for Bank Verification Number (BVN) Operations and Watch-List for the Nigerian Banking Industry (The CBN Framework) (Nigeria 18 Oct. 2017). The CBN Framework states that it guides the activities, in the context of the BVN operations, of the CBN, the NIBSS, the Deposit Money Banks (DMBs) [1], Other Financial Institutions (OFIs) [2] and bank customers (Nigeria 18 Oct. 2017, 4). In correspondence with the Research Directorate, a lecturer at the University of Nigeria's Department of Economics who specializes in public finance and monetary economics explained that the BVN is implemented by all banks in Nigeria (Lecturer 26 Apr. 2018).

2. Requirements and Procedures to Obtain a BVN

Sources report that the BVN is associated with customers' biometric details, including fingerprint of all ten fingers and facial image (NIBSS n.d.a; NGEX n.d.a). Other sources similarly indicate that during the BVN registration process, fingerprint and facial image are captured (Buzz Nigeria n.d.; UBA 6 July 2015). The United Bank for Africa (UBA), a financial institution with branches in Nigeria, explains that a "customer's biometric and personal data is attached to all bank accounts he or she operates whether personal or corporate" (UBA 6 July 2015). In a telephone interview with the Research Directorate, the President of the Nigerian Canadian Association Ottawa (NCAO) [3] explained that all the accounts held by an individual are linked to their BVN (NCAO 26 Apr. 2018).

The CBN Framework provides the following regarding BVN operational processes and procedures:

1. Enrollment: The enrolment is the process where individuals have their biometric and demographic data captured in the BVN central database system and a unique ID, the Bank Verification Number (BVN), generated for the customer.
2. Identification: This refers to the comparison of a person's biometrics to the biometrics of all enrolled customers, to confirm if the person is already enrolled or not, before issuing the BVN.
3. Verification: This refers to the process of verifying the customer by matching his/her biometric template with what has been captured in the database.
4. Linking of Customer’s Unique ID to all related bank accounts: This is a process of using the customer’s unique ID generated after his/her enrolment to link all his or her bank accounts, irrespective of which bank the account is domiciled. This ensures that the customer would not be able to enroll twice and that the customer’s activities in other banks (especially suspicious ones) can be easily made available to all banks where the customer has account(s).
5. Fraud Management: This is a process aimed at using a traceable Unique Customer Identity to deter, prevent, detect and mitigate the risks of fraud in the banking industry.
6. Customer Information Update: This is the process by which the customer updates his/her information on the central identity database. (Nigeria 18 Oct. 2017, 8)

NIBSS explains that "[o]ffline verification will authenticate the customer by comparing the fingerprint or the facial image with the data stored on the BVN card" (NIBSS n.d.c). The Lecturer explained that all banks, as well as other licensed and authorized institutions, have access to "a BVN registration and verification portal, synchronized and hosted by the CBN" and that they can verify a customer's BVN through this portal (Lecturer 26 Apr. 2018). The CBN Framework provides that the NIBSS is responsible for maintaining the BVN database and "an on-line real-time [w]atch-list [p]ortal," as well as to ensure adequate security of the BVN information (Nigeria 18 Oct. 2017, 5-6). The NIBSS states that customers' details "are encrypted and stored in a secure database" (NIBSS n.d.c). According to the CBN Framework, access to the BVN database requires the payment of fees (Nigeria 18 Oct. 2017, 9).

An article by the Sun, a newspaper in Nigeria, cites a director of the CBN as stating that "records as [of] December 2017 showed that more than 31 million BVN[s] had been linked with over 43 million bank accounts" (The Sun 26 Apr. 2018). NIBSS reports that as of 7 April 2018, 32,678,676 BVNs had been issued (NIBSS n.d.a).

2.1 Enrolment

According to sources, bank customers must have a BVN (NIBSS n.d.c; NGEX n.d.a; Buzz Nigeria n.d.). The Lecturer said that all opened accounts, and future accounts, require "BVN registration and verification in Nigeria" (Lecturer 26 Apr. 2018).

According to sources, the BVNs of signatories to corporate accounts are linked to the corporate account by the bank (NIBSS n.d.c; Buzz Nigeria n.d.). Buzz Nigeria, a news website, explains that "[t]here is no 'corporate enrollment' for corporate accounts" and that the signatories have to enrol individually (Buzz Nigeria n.d.). NIBSS mentions that, in the case of a joint account, "[a]ll signatories of the accoun[t] shall be linked [to it]" (NIBSS n.d.c).

2.1.1 In Nigeria

Sources indicate that the BVN registration can be made at any bank in Nigeria (UBA 6 July 2015; NIBSS n.d.a). NIBSS provides the following steps for the BVN enrolment in Nigeria:

1. Walk into any branch of your [b]ank.
2. Fill and submit the BVN [e]nrolment form.
3. Present yourself for data capturing (such as [f]ingerprint, facial [i]mage[,] etc[.]).
4. An acknowledgment slip with the transaction ID is issued to you.
5. Within 24 hours the system confirms your application, your BVN is generated, and you receive an SMS for pickup. (NIBSS n.d.a)

NIBSS explains that the identification required for the BVN enrolment "depends on the level of account the customer wants to open" and that applicants should contact their bank on this matter (NIBSS n.d.c). On their website, the First Bank of Nigeria (FirstBank) explains that to enrol for the BVN, customers need to go to any FirstBank branch with a valid ID (international passport, driver's license, voter's registration card or national ID card) and fill out the enrolment form (available at the bank or on the bank's website) (FirstBank n.d.). On their website, the Zenith Bank (Zenith), headquartered in Lagos, indicates that customers enrolling for the BVN in Nigeria should go to any Zenith branch and fill out the enrolment form, present themselves for the biometric data capture (a ticket ID will then be issued) and the BVN will be sent by SMS after 48 hours (Zenith n.d.).

2.1.2 From Abroad

In August 2015, the CBN issued a Circular on the Framework for the Enrolment of Nigerian Banks' Customers in Diaspora for Bank Verification Number (BVN) Issuance that provides the two following options for the BVN enrolment of customers in diaspora:

1. Use of Foreign Based Nigerian Banks
   
   The first option is for the customers of Nigerian banks to present themselves to the offshore branches/subsidiaries of any Nigerian Deposit Money Bank (where such facilities have been made available) for the enrolment for the BVN. The deployment of scanners and other devices to these locations have started in earnest.
   
   Nigerian banks abroad are expected to capture necessary data, generate a BVN and communicate same to the customers. Thereafter, the [c]ustomers are expected to forward the assigned BVN to their banks, for linkage with their accounts. A web portal to achieve this linkage to bank accounts has been developed and deployed, while the process of such linkage will be made available by NIBSS to all those enrolled abroad.
   
   All Deposit Money Banks (DMBs) with branches/subsidiaries abroad, are by this Circular enjoined to work with NIBSS to ensure a seamless implementation of this option.
   
   
2. Use of a Consultant - Online Integrated Solutions (OIS)
   
   The above mentioned company has been engaged to establish stations for data capture and generation of BVN at a fee of [30 British pounds (GBP)] (thirty pounds or its equivalent) [approximately C$52] per transaction, payable by the customer. The company is expected to capture necessary data for online transmission to NIBSS, who would thereafter generate the BVN and communicate same to the customers. The customer may approach OIS for the BVN, where the communication from NIBSS is not received within 48 hours after the enrolment. Thereafter, Nigerian [b]anks' [c]ustomers in diaspora are expected to forward their BVN to their banks for linkage with their accounts, as in option 1 above.
   
   The plan is to rollout this operation in twelve … locations in the first phase. These locations are: London, Leicester, New York, Atlanta, Washington DC, Houston, Johannesburg, Beijing, Shanghai, Guangzhou, Dubai and New Delhi. The second phase will include locations with a high demand for service, based on online feedback, while remote locations with lower concentrations of Nigerians will be accommodated through scheduled sessions for defined periods. (Nigeria 18 Aug. 2015)

NGEX [4] mentions that for Toronto, New Jersey, Dallas, Dar Es Salaam, Manila and Schenzen, the BVN registration provider is Avante Global Services, and that for Al Khobar, Jeddah, Cape Town, Melbourne, Riyadh, Sao Paulo, and Nairobi, the BVN registration provider is VFS Global Services (NGEX n.d.b). According to the OIS website, there are also enrolment centers in Amsterdam, Ankara, Beirut, Kuala Lumpur, Los Angeles, Mumbai, Paris and Rome (OIS n.d.). The same source states that in order to enrol for a BVN, the applicant has to book an appointment online and present the following documents at the enrolment center: a valid ID (Nigerian international passport, Nigerian national ID card, Nigerian driver's license or international passport for non-Nigerian); a recent passport photograph; the BVN enrolment form (available at the enrolment center or on the OIS website); the enrolment fee (required at the enrolment center); and the appointment slip (OIS n.d.).

The information in the following paragraph was provided by the President of the NCAO:

There was a "grace period" for Nigerians in diaspora to enrol for the BVN. A corporation was mandated to come to Canada (in Ottawa, Calgary, Toronto, Montreal, etc.) for the BVN enrolment. It was in Ottawa for the last time in November 2017. The applicants' information was captured and the BVNs were issued within 24 hours. A fee had to be paid for the enrolment (NCAO 26 Apr. 2017). Corroborating information could not be found among the sources consulted by the Research Directorate within the time constraints of this Response.

2.2 Features

According to sources, the BVN is a number composed of 11 digits (Buzz Nigeria n.d.; Phonecorridor 23 Sept. 2017; GTBank Dec. 2015). Sources mention that the BVN expires after 10 years (NIBSS n.d.c; NGEX n.d.b; Buzz Nigeria n.d.), but the BVN remains the same after the re-enrolment (NIBSS n.d.c; Buzz Nigeria n.d.). According to sources, the Managing Director of NIBSS explained that BVN cards will be issued to customers after their BVN registration (InvestAdvocate 30 Mar. 2015; Independent 31 Mar. 2015).

According to sources, to retrieve their BVN, individuals have to dial *565*0# on their mobile phone used to enrol for their BVN (Diamond Bank n.d.; NB 30 Nov. 2015); "[t]his retrieval method is only available to Airtel, Etisalat and MTN [telecommunication companies] subscribers" (NB 30 Nov. 2015). NIBSS states that to retrieve their BVN, customers should contact the bank where they enrolled (NIBSS n.d.c).

2.3 Customers Without a BVN

Sources mention that customers who have not enrolled for the BVN after the deadline will not be able to operate their bank accounts (NIBSS n.d.a; NCAO 26 Apr. 2018). According to the OIS, customers who have not completed the BVN registration process would not be able to transact in Nigerian banks and that would affect their Automated Teller Machine (ATM) use and Internet banking access (OIS n.d.). The Zenith Bank indicates that "no withdrawal shall be made on accounts without validated BVN" (Zenith n.d.). On their website, the First City Monument Bank (FCMB), a Nigerian bank, mentions that for online account opening, the BVN is not necessary, but that the account "will not be fully operational" until the customer provides their BVN (FCMB n.d.).

In a letter addressed to all the OFIs, the CBN states that, effective 1 August 2017, customers without a BVN will not be allowed to withdraw money from their account (Nigeria 21 Apr. 2017). In another letter addressed to the OFIs, the CBN states that the deadline for the BVN enrolment was extended to 31 December 2017, and that effective 2 January 2018, OFIs "are required to place all accounts without BVN on a 'post no debit' status," and to remove this status only when a BVN has been obtained and submitted to the financial institution by the customer (Nigeria 2 Jan. 2018).

3. Uses of BVNs

The President of the NCAO explained that every transaction requires that a BVN is linked to the account's holder, otherwise the transaction will not be authorized (NCAO 26 Apr. 2018). The same source indicated that for "daily transactions," only the BVN registration is required and there is no verification of the biometric data (NCAO 26 Apr. 2018). According to sources, ATM transactions do not require biometric identification (Esoimeme Jan. 2015; NCAO 26 Apr. 2018). An undated NIBSS webpage indicates that the biometric verification will be implemented on Point-of-Sale (POS) systems and ATM terminals "at a later stage" (NIBSS n.d.c).

According to the CBN, customers are required to provide their BVN when purchasing foreign currency in banks and Bureaux de Change (BDCs) in Nigeria (Nigeria 5 Nov. 2015). Similarly, Newsverge, a news portal with "a Nigerian-African perspective" (Newsverge n.d.), reports that BVNs must be validated by the authorized BDCs "through the NIBSS portal" before a foreign exchange transaction takes place, and that the portal was made available on NIBSS website "to facilitate access for the confirmation/validation of the BVN number of the BDCs' customers" (Newsverge 31 Oct. 2017).

According to NIBSS, applications for a loan require the verification of the customer's biometric features through the central database (NIBSS n.d.a). Similarly, Ehi Eric Esoimeme, a lawyer in Nigeria who specializes in the field of money laundering, indicates that the "BVN project requires individuals performing banking transactions (e.g., applying for loans) to identify themselves using their biometric features which will be matched against information in the central database" (Esoimeme Jan. 2015).

4. Prevalence of Fraud

NIBSS explains that if an individual steals a customer's BVN, their fingerprint will not match the customer's recorded fingerprint (NIBSS n.d.c). The Lecturer explained that, to his knowledge, there are no instances of bank accounts being opened using fraudulently obtained BVNs in Nigeria, as it would require a high level of collusion, compromise and system breakdown for this to take place (Lecturer 26 Apr. 2018).

A press release by the CBN warns the general public that messages "about deactivation or suspension of their bank accounts due to uncompleted [BVN] registration process" are being sent "to lure bank account holders to reveal their personal details" such as passwords, card details or PINs (Nigeria 30 Oct. 2015). The Daily Post, a news website in Nigeria, reports that two "fraud experts" specialized in "duping innocent people by obtaining their [BVNs] using the trick that their accounts had been closed due to BVN issues" were arrested by the Economic and Financial Crimes Commission (EFCC) in March 2017 (Daily Post 24 Mar. 2017). Similarly, an article by Vanguard, a newspaper in Nigeria, indicates that fraudsters offer "seemingly easier registration options" for bank customers and threaten that their accounts will be closed if their details are not provided (Vanguard 12 Mar. 2015).

A 2018 article by the same source mentions that the Lagos State Police Command arrested "a syndicate that specialised in dispossessing victims' phones for the purpose of getting their account details and making withdrawals without the account holder's knowledge" (Vanguard 20 Jan. 2018). According to the same source, this was done by obtaining the victim's BVN with the stolen SIM card (Vanguard 20 Jan. 2018). Similarly, a 2018 article by Nigerian newspaper The Nation reports cases of people whose money was transferred from their bank account to another bank account, after their phone was stolen (The Nation 2 Mar. 2018). The same source states the following about the robbers' mode of operation:

"I do not need to know the victim's password on the phone or Personal Identification Number for me to have access to victims' accounts and transfer money to my account or buy recharge cards. Most victims password their phones not [their] Sim cards. So once I removed the Sim [card] and put it in my own phone, I would have easy access to the Sim [card]. I do not also need to know the PIN of my victim; all I need is the last digits of the victim's [BVN], which I can easily obtain by dialing *556*0# and it would be revealed on the phone," said one of the suspects involved in [a case].

Also, syndicates who specialise in robbing people of their mobile phones and emptying their bank accounts also use computer applications to generate the BVN and bank details of their custome[r]s working in concert with fraudulent bankers.

…

[Members of a gang] said they were responsible for stealing phones and Sim cards, which they handed over their gang leader … [The leader] said he normally sent short codes to the service providers through the stolen Sim cards to generate the [BVN] and the account numbers of the owners.

He said: "Once it is the number registered with the bank, the details will appear on the phone and we would use it to hack into the person's account. We generate PIN … and do instant transfers." (The Nation 2 Mar. 2018)

4.1 Watch-List for Customers Involved in Fraudulent Activity

According to the CBN Framework, there is a watch-list, consisting of a database with the BVNs of customers "involved in confirmed fraudulent activity in the banking industry in Nigeria," such as "forgery, compromise, complicity, fraudulent duplicate enrolment[,] [a]ny fraudulent infraction without monetary value [and] [c]onfirmed successful fraud with monetary value" (Nigeria 18 Oct. 2017, 4, 10). According to the same source, banks have to enlist customers involved in fraudulent activity on the watch-list and the following penalties apply for these customers:

1. A watch-listed individual shall not be allowed to enter into new relationship with any bank.
2. A bank may choose not to continue business relationship with account holder on the watch-list. Where a bank chooses to continue an existing business relationship with holders of account on the watch-list, the account holder shall be prohibited from all e-channels, such as ATM, POS, Internet Banking, Mobile Banking, including issuance of third-party cheques. A watch-listed customer shall not provide reference to another customer, neither shall he/she be allowed access to credit facility or guarantee credit facilities.
3. A watch-listed individual shall remain in the watch-list for a period as specified in the penalty table. In the event of a reoccurrence, the tenure shall begin to count from year one.
4. Penalties that applied to watch-listed customers shall apply to all accounts that he or she is a signatory to. (Nigeria 18 Oct. 2017, 11)

An article by Punch, a Nigerian news website, indicates that "[a]s a result of the [F]ramework, a number of the DBMs have written to their customers, informing them of the development and their readiness to suspend any account linked to any fraudulent activity" (Punch 14 Jan. 2018). NIBSS mentions that banks "shall be prompted" during account openings or credit checks if customers have been "blacklisted" (NIBSS n.d.a). A 2016 report by the Nigeria Electronic Fraud Forum (NeFF) [5] indicates the following:

[I]t is quite unfortunate that despite several awareness and tips about BVN watchlist, some institutions still refuse to send BVNs of their customers who have been involved in fraudulent acts for watch-listing, thereby leaving these fraudsters free in our ecosystem and subsequently perpetrating more fraud. Out of the 1,020 unique individuals who were beneficiaries of fraudulent transactions in 2016 across listed channels, only 217 BVNs were sent to NIBSS for watch-listing. Obviously, this is just about 21% of supposed watchlisted BVNs. (Nigeria 5 July 2017, 23)

Corroborating information could not be found among the sources consulted by the Research Directorate within the time constraints of this Response.

4.2 Payroll and Pension Audits

According to the website of the Nigerian State House [office of the President], the government used the BVN for payroll and pension audits, which led to the "detection of more than 50,000 erroneous payroll entries" (Nigeria n.d.b). Similarly, an article by Nigeria CommunicationsWeek (Comms Week), a Nigerian news website, indicates that the Akwa Ibom state government found "1,458 cases of [BVN-]related frauds involving civil servants and pensioners in the public service"; according to the Finance Commissioner, cases of one BVN being linked to more than one person were discovered (Comms Week 19 Apr. 2016).

This Response was prepared after researching publicly accessible information currently available to the Research Directorate within time constraints. This Response is not, and does not purport to be, conclusive as to the merit of any particular claim for refugee protection. Please find below the list of sources consulted in researching this Information Request.

Notes

[1] A Deposit Money Bank (DMB) is "[a] financial institution licensed by the regulatory authority to mobilize deposits from the surplus unit and channel the funds through loans to the deficit unit and perfor[m] other financial services activities" (Nigeria n.d.c).

[2] Other Financial Institution (OFI) "means "means any individual, body, association or group of persons; whether corporate or unincorporated, other than the banks licensed under th[e] [Nigeria Banks and Other Fiancial Institutions Act] which carries on the business of a discount house finance company and money brokerage and whose principal object include factoring, project financing, equipment leasing, debt administration, fund management, private ledger services, investment management, local purchases order financing, export finance, project consultancy, financial consultancy, pension fund management and such other business as the Bank may from time to time designate" (Nigeria 1991, art. 66).

[3] The Nigerian Canadian Association Ottawa (NCAO) is a non-profit organization that works "for the progress and the betterment of the members of the Nigerian community and the furtherance of … relations between the peoples of Nigeria and Canada" (Black Ottawa Scene [2016]).

[4] "NGEX provides data-driven marketing solutions that help businesses reach, engage and understand their desired audience in Nigeria and the Nigerian [d]iaspora" (NGEX n.d.c).

[5] The CBN website states that the Nigeria Electronic Fraud Forum (NeFF) is a forum created for "all relevant stakeholders to actively and proactively react to th[e] challenge" of safeguarding the integrity of the e-payment channels in the context of a "heightened incidence of fraud" (Nigeria n.d.d).

References

Black Ottawa Scene. [2016]. John Adeyefa. "Community Profile: Nigerian-Canadian Association Ottawa." [Accessed 30 Apr. 2018]

Buzz Nigeria. N.d. Nwadinobi Ugochukwu. "Bank Verification Number: 15 Facts, and How to Check BVN Online or on Mobile." [Accessed 13 Apr. 2018]

Daily Post. 24 March 2017. Wale Odunsi. "Court Jails Two BVN Fraud Experts." [Accessed 26 Apr. 2018]

Diamond Bank. N.d. "How Do I Retrieve My BVN?" [Accessed 1 May 2018]

Esoimeme, Ehi Eric. January 2015. "A Critical Analysis of the Bank Verification Number Project Introduced by the Central Bank of Nigeria." Regulation of Financial Institutions eJournal, 17. [Accessed 25 Apr. 2017]

First Bank of Nigeria (FirstBank). N.d. "Biometric." [Accessed 25 Apr. 2018]

First City Monument Bank (FCMB). N.d. "Knowledge Centre/FAQs." [Accessed 27 Apr. 2018]

Guaranty Trust Bank (GTBank). December 2015. "GTBank Commences Bank Verification Number (BVN) Enrolment for Nigerians." [Accessed 30 Apr. 2018]

Independent. 31 March 2015. Bamidele Ogunwusi. "Banks not Charging Customers for BVN Cards - NIBSS." [Accessed 7 May 2018]

InvestAdvocate. 30 March 2015. "Banks to Distribute Free BVN Cards to Customers - NIBSS." [Accessed 7 May 2018]

Lecturer, Department of Economics, University of Nigeria. 26 April 2018. Correspondence with the Research Directorate.

The Nation. 2 March 2018. "How Telephone Robbers Now Steal Millions from Bank Customers' Accounts." (Factiva) [Accessed 26 Apr. 2018]

Newsverge. 31 October 2017. Oriyomi Olamiposi. "ABCON, NIBSS, Sensitise BDC Operators on BVN Validation." [Accessed 30 Apr. 2018]

Newsverge. N.d. "About Us." [Accessed 30 Apr. 2018]

NGEX. N.d.a. "Understanding Bank Verification Number (BVN) in Nigeria." [Accessed 13 Apr. 2018]

NGEX. N.d.b. "Getting Your Bank Verification Number (BVN) Outside Nigeria." [Accessed 13 Apr. 2018]

NGEX. N.d.c. "Data-Driven Marketing Solutions." [Accessed 25 Apr. 2018]

Nigeria. 2 January 2018. Central Bank of Nigeria (CBN). "Letter to Other Financial Institutions (OFIs): The Bank Verification Number (BVN) Enrollment for OFIs' Customers - Directive to Place Accounts Without BVN on 'Post No Debit'." [Accessed 24 Apr. 2018]

Nigeria. 18 October 2017. Central Bank of Nigeria (CBN). Regulatory Framework for Bank Verification Number (BVN) Operations and Watch-List for the Nigerian Banking Industry. [Accessed 24 Apr. 2018]

Nigeria. 5 July 2017. Central Bank of Nigeria (CBN), Nigerian Electronic Fraud Forum (NeFF). A Changing Payments Ecosystem: The Security Challenge. Annual Report 2016. [Accessed 30 Apr. 2018]

Nigeria. 21 April 2017. Central Bank of Nigeria (CBN). "Letter to All Other Financial Institutions (OFIs): Bank Verification Number (BVN) Enrollment for Customers." [Accessed 24 Apr. 2018]

Nigeria. 5 November 2015. Central Bank of Nigeria (CBN). "Press Release on Use of BVN for FOREX Transactions." [Accessed 13 Apr. 2018]

Nigeria. 30 October 2015. Central Bank of Nigeria (CBN). "Press Release on BVN: Bank Customers Beware." [Accessed 13 Apr. 2018]

Nigeria. 18 August 2015. Central Bank of Nigeria (CBN). Circular on the Framework for the Enrolment of Nigerian Banks' Customers in Diaspora for Bank Verification Number (BVN) Issuance. [Accessed 24 Apr. 2018]

Nigeria. 1991 [amended 2002]. Banks and Other Financial Institutions Act. [Accessed 26 Apr. 2018]

Nigeria. N.d.a. Central Bank of Nigeria (CBN). "Bank Verification Number (BVN)." [Accessed 13 Apr. 2018]

Nigeria. N.d.b. State House. "Transparency & Anti-Corruption." [Accessed 1 May 2018]

Nigeria. N.d.c. Central Bank of Nigeria (CBN). "Other Related Institutions." [Accessed 26 Apr. 2018]

Nigeria. N.d.d. Central Bank of Nigeria (CBN). "Nigeria Electronic Fraud Forum." [Accessed 30 Apr. 2018]

Nigeria CommunicationsWeek (Comms Week). 19 April 2016. "Civil Servants, Pensioners Defraud Govt with BVN." [Accessed 1 May 2018]

Nigeria Inter-Bank Settlement Systems (NIBSS). N.d.a. "About BVN." [Accessed 13 Apr. 2018]

Nigeria Inter-Bank Settlement Systems (NIBSS). N.d.b. "About NIBSS." [Accessed 13 Apr. 2018]

Nigeria Inter-Bank Settlement Systems (NIBSS). N.d.c. "FAQs." [Accessed 13 Apr. 2018]

Nigerian Bulletin (NB). 30 November 2015. "How to Retrieve Your BVN Free of Charge." [Accessed 1 May 2018]

Nigerian Canadian Association Ottawa (NCAO). 26 April 2018. Telephone interview with the President.

Online Integrated Solutions (OIS). N.d. "BVN Enrolment." [Accessed 13 Apr. 2018]

Phonecorridor. 23 September 2017. "How You Can Easily Check Your BVN Number on Your Phone." [Accessed 8 May 2018]

Punch. 14 January 2018. Oyetunji Abioye. "CBN Orders Banks to Suspend Accounts Linked with Fraud." [Accessed 17 Apr. 2018]

The Sun. 26 April 2018. Magnus Eze. "500,000 Agent Banks to Be Established in Rural Areas." (Factiva) [Accessed 26 Apr. 2018]

United Bank for Africa (UBA). 6 July 2015. "UBA Introduces Simplified Process for BVN Registration." [Accessed 27 Apr. 2018]

Vanguard. 20 January 2018. Evelyn Usman. "How We Extract Bank Details from Stolen Phones to Withdraw Money - Suspects." [Accessed 7 May 2018]

Vanguard. 12 March 2015. "Importance of Bank Verification Number." [Accessed 13 Apr. 2018]

Zenith Bank (Zenith). N.d. "Bank Verification Number." [Accessed 27 Apr. 2018]

Additional Sources Consulted

Oral sources: Fidelity Bank; First Bank of Nigeria; First City Monument Bank; Nigeria – Central Bank, Consulates in Atlanta and New York, High Commission in Ottawa; Nigeria Inter-Bank Settlement System; Nigerian-Canada Business Association; Nigerian Canadian Association of Calgary; Policy and Legal Advocay Centre; Zenith Bank.

Internet sites, including: Access Bank; BBC; Ecobank Nigeria; Fidelity Bank; The Guardian; News Agency of Nigeria; Nigeria – Consulates in Atlanta and New York, Embassy in Washington DC, High Commission in Ottawa; The Nigerian Voice; Premium Times; Pulse NG; Tribune Online; UN – Refworld; World Bank Group.