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The Central Bank of Nigeria (CBN), pursuant to the Cybercrimes (Prohibition, Prevention etc) Act (2015) (the 'Cybercrimes Act), recently released a Circular dated 25th June, 2018 directing all Mobile Money Operators (MMOs) and other affected Payment Service Providers (PSPs) to comply with the statutory provision for the collection and remittance of the 0.005 levy imposed on electronic transactions by July 1, 2018.
Introduction
The Central Bank of Nigeria (CBN), pursuant to the Cybercrimes (Prohibition, Prevention etc) Act (2015) (the 'Cybercrimes Act), recently released a Circular dated 25th June, 2018 directing all Mobile Money Operators (MMOs) and other affected Payment Service Providers (PSPs) to comply with the statutory provision for the collection and remittance of the 0.005 levy imposed on electronic transactions by July 1, 2018. It is pertinent to note that under the Circular, electronic transactions include all financial transactions occurring in a bank or on a mobile money scheme or any other payment platform that has an accompanying service charge.
Below, is a synoptic analysis of the issues and potential impact of this Cybersecurity Levy on the operations of MMOs and PSPs.
Why is the levy being imposed?
Essentially, this is a statutorily imposed levy that accrues to the National Cyber Security Fund (NCSF) which is domiciled with the CBN and even though Section 44(5) of the Cybercrimes Act prescribes that "an amount not exceeding 40 percent of the Fund may be allocated for programs relating to countering violent extremism" there is no clarity regarding the import of the NCSF, the framework for its management or indeed the parameters for its use and deployment.
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