Legal Question in Banking Law in Nigeria
i want to deploy and operate a service where smart cards are used to pay for food and drinks at a company cafeteria, the cards only work inside the cafeteria, i supply the server, pos terminal and smart cards, the cards cant be used to withdraw money at any ATM, their only function is to remove cash from the cafeteria, do i require a CBN license or permit to operate such a service
2 Answers from Attorneys
You will be operating as a payment service provider. You will be dealing with banks and switches. Consequently, CBN will require some certification
Ideally, you should not require a license since the service will only be restricted to the cafeteria, however I do not see how this is possible since under the relevant CBN Guidelines all POS terminals deployed in Nigeria must accept all transactions arising from any card issued by any Nigerian bank and only "licensed deposit taking banks" are authorised by CBN to issue any form of payment card in Nigeria.
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