Introduction

With the 2004 increase of the minimum share capital requirement, the Nigerian banks that survived the exercise realised that they had excess capital at their disposal. This encouraged them to aggressively expand their operations and services abroad in search of economic opportunities. While the provision of cross-border banking services by Nigerian multinational banks was welcome in several jurisdictions, especially in Africa, it raised serious regulatory concerns. In 2008, for instance, a cbn Circular asserted that the “Central Bank of Nigeria has observed with serious concern the aggressive expansion of banks, particularly cross border, in the recent past. These involve additional risks.” The circular went on to argue that while the cbn appreciates the need for Deposit Money Banks (dmbs) to grow their bank and improve profitability as they seek to deliver value to stakeholders, “it is imperative to have in place guidelines that would further strengthen the system and ensure safety and soundness of the financial institutions, both at home and offshore” (cbn Circular 2008). Key areas of regulatory concern include the potential of such rapid expansion to create opportunity and incentive for regulatory arbitrage, money laundering, and financial contagion in the host countries of these Nigerian multinational banks (Cf. uche 2014).

The objective of this paper is to critique the rise of these Nigerian multinational banks and to explore the operational challenges and risks associated with the emergence of such banks. To achieve its aim, this chapter is divided into four parts. Part 1 critiques the various theories that explain the practice of multinational banking while Part 2 explores the structure and history of Nigerian banking up until the 2004 bank capital increase. Part 3 analyses the emergence of Nigerian multinational banks in the context of various theories of multinational banking and critiques the regulatory risks and challenges associated with the practices of such banks. Part 4 concludes the paper.

Why Do Banks Go Abroad?

Attempts to explain why banks go abroad to provide services is entwined with the history of international banking. The practice of cross-border banking operations, which has been linked to the emergence of international trade, commenced several centuries ago. It has for instance, been noted that “Italian bankers of the late middle ages sometimes established branches in foreign countries to assist their cross-border lending and trade finance activities” (Jones 1990: 2).

Although the us now play an important role in the promotion of multinational banking, this is a relatively recent development. By 1913, for instance, only six us banks had branches abroad while most of the us banks, including national banks had no branches at all. By 1960, very little had changed as only “eight us banks had foreign branches, and most us banks including those in New York, still could not branch freely throughout their home state, much less across the country” (Heurtas 1990: 249–250).

Domestic banking regulation therefore prevented us banks from participating in the first phase of multinational banking. This was so despite the fact that by 1872, the size of the us economy had surpassed that of uk and by 1915, us exports had also surpassed that of the uk (Chinn and Frankel 2008, 2007). All this changed in the 1960s when the us led the second wave of multinational banking. The reason for the emergence of this second phase of international banking, which has been termed as the “golden era”, has been linked to several factors, including growth in international trade, foreign direct investments, and the Eurodollar market. ² Another important factor for the rapid increase in us multinational banks during this “golden era” period of multinational banking was because from the 1960s, the us began to change its banking laws thus encouraging such multinational banking. In 1962, for instance, us amended its banking rules to enable “foreign branches of national banks to compete more effectively in foreign markets” (Brimmer and Dahl, 1975: 343). In 1970, it also amended its Bank Holding Companies Act to provide a regulatory framework for the international activities of the us bank holding companies. Proactively promoting cross-border us banking services was grounded in the belief that “the establishment of overseas facilities by us banks would generally promote the foreign commerce of the United States” (Ibid.).

It was as a consequence of the above changes that the scope and range of products offered by multinational banks was extensively expanded during the period. ³ Based on the histories and experiences of banks and countries that played an active part across all periods of multinational banking (medieval, first wave, and second wave eras), various theories, which sometimes overlap, have emerged in an attempt to explain the main causative factors of multinational banking in the world.

The most pervasive explanation for the emergence of multinational banks is that banks normally follow their clients abroad (Williams 2002). This theory, which is also known as “customer-driven internationalization” (Engwall and Wallenstal 1988: 148) is so widespread that it has been referred to as the conventional hypothesis (Cf. Williams 2002). In the nineteenth century, the assumption was that domestic banks that operated in host economies of multinational firms were poorly equipped to service the local finance needs of multinational businesses (Aliber 1984). This theory made sense especially during the colonial period when British banks, for example, followed the expansion of British trade and government across the colonies. This was at least in part because there was a dearth of institutions that provided banking services in such colonies. The fact that the foreign branches of British multinational banks were overwhelmingly concentrated in developing economies during the first wave of multinational banking further validate this point (Jones 1990).

The above theory has, however, since been modified to suggest that the main incentive why banks follow their customers abroad is to ensure that they do not lose such customers to other banks. In other words, the “modified rationale is that banks follow their domestic customers abroad to reduce the likelihood that they might lose their business to host country banks” (Aliber 1984: 664). This modification has been characterised as “defensive expansion” (Williams 2002: 127).

A second reason why banks go abroad is to exploit new market opportunities. In the us, for instance, it has been noted that the sheer size of the economy and its attendant investment opportunities constitute major attractions for foreign banks eager to expand their services abroad (Cf. Goldberg and Saunders 1981). This theory is also supported by banking developments during the colonial era. This explains why some of the banks that were established in the developing economies did not have operations in the uk although they were registered there. Adapting the concept developed by Mira Wilkins (1988), such banks can be referred to as “free standing multinational banks.” The main focus of such banks was simply to explore opportunities of introducing banks in localities where such banks did not exist and thus facilitate trade in and with such jurisdictions. As early as 1879, for instance, colonial business interests had identified such opportunities in British West Africa. Along these lines, the proposal for the Bank of West Africa (which never commenced operations) noted that no country at the time offered a better opportunity for establishing a highly profitable Banking business than the British West African Colonies, “where the benefits of a Bank are wholly wanting, and the facilities of trade are restricted to a few large merchants whose interests are naturally adverse to each other, but who will gladly avail themselves of its advantages when established” (Quoted in Uche, 1999: 671).

A third reason that explains the expansion of banks abroad is home and host country regulation of the banking environment. As explained above, home country restrictive regulations prevented American banks from participating in the first wave of international banking which occurred before World War i. Examples of countries, aside from the us, that have in the past restricted their banks’ expansion abroad are Sweden and Japan (Cf. Hultman and McGee 1989). At another level, it has also been argued that “in part, the rapid growth of offshore banking results from efforts to circumvent the costs of national regulation” (Aliber 1976: 6).

Another reason why banks go abroad is to find and exploit additional financial resources. This has been referred to as “provider driven internationalization.” Proponents of this theory argue that banks are likely to concentrate their foreign entries in cities that are well known for their intensive financial activity in order to gain access to capital (Hellman 1994). In other words, decisions on where banks open offices abroad are likely to be influenced by the level of financial activity in such cities (Engwall and Wallenstal 1988). The emergence of this theory has been facilitated by the popularity of major financial centers like New York and London as places for the establishment of overseas offices and affiliates of foreign multinational banks.

In general, however, the experiences of various jurisdictions with respect to the development of international banking is based on their various specificities and local histories. Historically, too, the reasoning behind the provision of banking services outside the home country of multinational banks is not static and thus it can change over time. Irrespective of whatever may have motivated a bank to establish subsidiaries abroad, such subsidiaries are always at liberty to explore the possibilities for expanding their services to host country firms and businesses. In other words, multinational banking subsidiaries established to service the interests of their home country businesses abroad may over time begin to provide banking services to host country businesses. With respect to the dynamic strategies of non-us banks operating in the us, this has been asserted that initially “these us based offices of foreign banks served primarily the credit and other banking needs of us affiliates of their home country customers.” This gradually changed over time. In “recent years, many foreign banks have expanded their customer base by actively soliciting business from us companies, competing in terms of price and quality of service” (Terrell 1993: 913). In the next section, we will critique the origins and structure of the Nigerian banking system prior to the 2004 consolidation exercise.

The Origins and Structure of the Nigerian Banking System

It is an established historical fact that British businesses played an important role in the establishment of British colonies across the world (Cf. Tignor 1998: 18, 1987: 479; Cain and Hopkins 1980: 463–465). Based on the above, it is not surprising that the conventional theory of multinational banking, which suggests that banks follow their customer abroad, can, at least to some extent, be applied to the establishment of pioneer British multinational banks in Nigeria ⁴ like the Bank of British West Africa (bbwa) and Barclays Bank (Dominion, Colonial, and Overseas). ⁵ This explains why such British multinational banks seldom established operations in territories without British commercial interests.

The international business focus of the British banks, however, led to complaints and protests of discrimination by Africans and culminated in the establishment of indigenous banks (Cf. Newlyn and Rowan 1954; Ayida 1960; Ajibola 1986; Brown 1966; Onoh 1982). These indigenous banks were, however, poorly capitalised, poorly staffed, and poorly managed and were thus no match for the foreign banks. Despite this, however, the first indigenous bank to be established in Nigeria, the Industrial and Commercial Bank Limited, which was established in 1929 became the first Nigerian international bank. It was established by some Nigerian and Gold Coast (Ghanaian) businessmen and formally opened for business in Lagos in 1929. The bank subsequently set up a branch in Accra (Hopkins 1966). It is instructive that, at the time, the 1906 Gold Coast Companies Act prevented the establishment of any local company to carry out any form of banking operations (Uche 1997). It was therefore plausible that the Industrial and Commercial Bank opened a branch in Accra, as opposed to registering a local bank, in order to circumvent existing regulations in the Gold Coast at the time, which prevented indigenous companies from establishing banks and providing banking services in the colony. The Industrial and Commercial Bank was, however, short lived and collapsed in 1931 (Azikiwe 1956).

Several indigenous banks were subsequently established. The enactment of the 1952 banking Ordinance, however, ensured that most of these indigenous banks failed. Between 1952 and 1953, for instance, 17 of such indigenous banks collapsed (Nwankwo 1986, 1990). Despite the establishment of the indigenous banks in Nigeria, foreign banks continued to dominate the Nigerian banking space (Cf. Rowan 1952). This began to change with the promulgation of the Companies Decree of 1968, which specifically required foreign companies, including banks to be incorporated and registered in Nigeria. The consequence of this was that Nigerian branches of foreign banks had to be incorporated in Nigeria as distinct legal entities. The main objective of the decree was to “bring under the control of the Nigerian government ‘local’ subsidiaries of foreign firms” (Ogbuagu 1983: 248). Prior to this requirement, the issue of foreign banks in Nigeria having branches or subsidiaries abroad did not arise. Even with the requirement for such banks to be registered in Nigeria as distinct legal entities, there was also little need for such banks to operate branches/representative offices abroad. This was because they were fully integrated in the business strategy of their parent multinational banks. This explains, as would be seen later, why the emergence of Nigerian multinational banks has been championed by locally owned and controlled banks rather than foreign banks.

In 1972, the Nigerian Government promulgated the Indigenization Decree. This enabled the Nigerian Government to acquire 40 per cent of the shareholding of foreign banks operating in the country. All the foreign banks agreed to this proposal, except for First National City Bank (usa), which decided to withdraw from the Nigerian market (Uche 2012). The government subsequently amended the Indigenisation Decree in 1977. This enabled it to increase its shareholding in such foreign banks to 60 per cent. The consequence of the above policy was that control of these foreign banks was effectively put into the hands of the Nigerian Government. This weakened the relationship between the foreign banks and their Nigerian affiliates. Some of the concerned foreign banks reacted to this loss of control by changing the names of their Nigerian operations. For example, Barclays Bank changed its name to Union Bank in 1979 (Cf. Uche 2012).

The indigenisation strategy of the Nigerian Government however began to change with the downturn in the economy, which was caused by dwindling oil prices and sub-optimal use of the country’s resources. Under pressure from the International Monetary Fund, the Babangida administration in 1986 adopted the Structural Adjustment Programme (sap). Specifically, sap was designed to achieve balance of payment viability by altering and restructuring the production and consumption patterns of the economy, eliminating price distortions, reducing the heavy dependence on consumer goods imports and crude oil exports, enhancing the non-oil export base, rationalise the role of the public sector, accelerate the growth potential of the private sector, and achieve sustainable growth. To achieve the above objectives, the main strategies of the programme were the adoption of a market-determined exchange rate for the Naira, the deregulation of external trade and payments arrangements, reductions in price and administrative controls and more reliance on market forces as a major determinant of economic activity (cbn Briefs 95/03).

The adoption of sap therefore meant that the government had to relinquish its controlling interest in most banks. Furthermore, the licensing process for new banks was liberalised leading to increased competition in the industry. This new spirit of competition meant that the decision as to whether banks should fail or not was now to be determined by market forces.

Despite the laudable objectives of sap, the government was unable to adopt a single market determined exchange rate for the Naira. This was mainly because it was unwilling to totally leave the fate of its currency to the forces of demand and supply. Most of the managed foreign exchange rate systems the government experimented with resulted in a dual exchange rates: the official rate and the parallel market (black market) rate. This positioned banks, the agents of the managed exchange rate system, to make illegal arbitrage profits simply by buying foreign exchange at the official rate and selling at black market rate. This defective government policy was mistaken by many as proof of banking profitability. This further opened the floodgate of applications for banking licences. Between 1985 and 1993, for instance, the number of licensed banks operating in Nigeria rose from 41 to 120. Most of these new banks were no more than currency exchange centres. The deregulation of the economy coupled with loopholes and, sometimes, outright evasion of the law, made it possible for some of these banks to survive simply by buying and selling foreign exchange (Uche and Ehikwe 2001).

Clearly, such banks, which were essentially focused on exploiting arbitrage opportunities that arose from government policies, had no need to expand their services to overseas territories. The government, however, subsequently removed most of the distortions in the foreign exchange market. This greatly reduced the arbitrage opportunities available to banks in currency trading. The financial well-being of these new banks was further complicated by the government decision, in 1995, to relax the investment laws for foreigners. With this development, foreigners were allowed to wholly own financial institutions in Nigeria. Some of the foreign banks that dominated the pre-indigenisation banking arena in Nigeria have now returned in full force. For instance, Barclays Bank, which used to be part of what is now Union Bank, is back in the country as a distinct bank that is 100 percent foreign owned. Standard Chartered Bank, which was part of what is now First Bank Plc, has also returned, as a distinct, wholly foreign-owned institution. Even Citi Bank, which, prior to the 1995 liberalisation, owned 40 per cent shares in the Nigerian International Bank, has since taken up majority interest in the bank and renamed it Citi Bank Nigeria. These fully owned foreign banks have little need for expanding their operations abroad. As subsidiaries of big multinational banks they are content with servicing the local interests of the multinational companies that are allied with their parent bank. In some cases, Nigerian businesses aspiring to internationalise their operations also find the services of such international banks attractive. The consequence of this increased competition from the strengthened foreign banks and the unstable macroeconomic environment sometimes coupled with poor service rendition by these indigenous banks was the collapse of several of the newly established indigenous banks. In 1998 alone, for instance, 26 banks were liquidated (Beck et al. 2005).

The New Era of Nigerian Multinational Banks

As already mentioned, in July 2004, the cbn announced the intention to radically increase the minimum share capital of Nigerian banks from N2 billion to N25 billion. The main essence of this increase was to encourage mergers and acquisitions in the Nigerian banking arena in order to create mega banks capable of competing in the provision of banking services in the global arena. The immediate consequence of the above policy was the shrinking in the number of Nigerian banks from 89 to 24 (Table 17.1). It was not surprising that all foreign owned banks survived this new policy without merging with other banks. This is because they “relied on capital injections from the parent company to meet the capital requirements” (Barros and Caporale 2012: 244).

View Table

Unlike the foreign banks, most of the indigenous banks were forced into mergers and acquisitions in order to meet the new capital requirement. A few of the indigenous banks like Zenith Bank and Guarantee Trust Bank were, however, able to meet the new capital requirement by raising funds internally or though the Nigerian Capital Market. These banks therefore did not need to merge with other banks (Cf. Table 17.1).

Despite the dramatic increase in share capital requirement, most foreign banks continued to focus solely on the Nigerian market. As already explained, integration into their parent bank international strategy ensured this. The scenario for Nigerian banks was however different. Prior to 2004, only five Nigerian banks had branches, representative offices or affiliates abroad. These were Afribank (Republic of Ireland 1988); Finbank (Gambia 1997); First Bank (uk 2002); Guarantee Trust Bank (Gambia 2000; Liberia 2002; and Sierra Leone 2002), United Bank for Africa (New York 1984) and Union Bank (South Africa 1996) (Cf. Table 17.2). The 2004 increase in the share capital of banks, however, encouraged such banks to aggressively seek opportunities for the expansion of their services abroad.

View Table

The result is that 11 Nigerian banks currently have 60 subsidiaries, one branch and three representative offices abroad (Cf. Table 17.2). Most of these subsidiaries are based in Africa. Only eight Nigerian banks have subsidiaries outside Africa, of which, seven are in the United Kingdom. These include: Access Bank (uk 2008); Mainstream Bank (Republic of Ireland 1988); fcmb (uk 2009); First Bank of Nigeria (uk 2002); Guaranty Trust Bank (uk 2007); uba (uk 2008); Union Bank (uk 2004); and Zenith Bank (uk 2007). Given that London is a major global financial centre, it is not surprising that one of the main banking business focuses of these uk subsidiaries of Nigerian banks is “to source international capital into Nigerian projects and businesses” (Cf. fcmb Annual Report 2009: 15). ⁶

The fact that the size of Nigerian banks is immaterial in the context of the uk banking system, coupled with the fact that they are now fully regulated by uk authorities clearly reduces the potential risks that Nigerian banks could pose to the uk economy. The same cannot be said of the subsidiary of Nigerian banks that have proliferated in smaller African countries and in some cases are prominent in the provision of banking services in such countries.

As already mentioned, most of the subsidiaries of Nigerian banks are located in Africa. By far the most popular countries for Nigerian banks looking to set up subsidiaries abroad have been the West African countries of Sierra Leone, Liberia, Ghana, and the Gambia. All the above countries are members of the West African Monetary Zone. With the exception of Liberia, all the above countries are also former British colonies. Currently, five Nigerian banks have subsidiaries in Sierra Leone and Ghana respectively while four Nigerian banks have subsidiaries in the Gambia. Also, three Nigerian banks have subsidiaries in Liberia.

It is as a consequence of the above strategy that Nigerian multinational banks in these countries compete with local banks for the patronage of local businesses and residents. The result is that most of the subsidiaries of the Nigerian multinational banks in West Africa have established several branches in their host countries. In 2012, for instance, Guaranty Trust Bank (Ghana) Limited established 6 new branches bringing its total branch network in the country to 22. “This is consistent with the growth trend experienced by other subsidiaries such as Guaranty Trust Bank (Sierra Leone) which expanded its network to 11 branches while Guaranty Trust Bank (Gambia) Limited increased its business outlets to 16” (2012 Annual Report: 35). Similarly, uba Ghana has 25 branches across Ghana. Nigerian banks have indeed become major players in the provision of financial services to their host businesses and citizens in West Africa. Recently, for instance, the Ghanaian High Commissioner to Nigeria, Vincent Azumah publicly acknowledged the importance of the services Nigerian banks provide to the Ghanaian economy (Leadership Newspaper, 9 March 2015).

The prominent position occupied by Nigerian multinational banks in the provision of banking services in Gambia, Sierra Leone, and Liberia is similar to that in Ghana. Beyond West Africa, Nigerian banks have also adopted similar strategies. When uba established a subsidiary in Zambia in 2010, for instance, the bank made it explicit that it was in the country “as a vehicle to ensure that Africans have their own bank that can assist in empowering indigenous Africans in growing intra-African trade and trade between Africa and the rest of the world” ( Lusaka Times, 4 March 2010).

The emergence of offshore subsidiaries of Nigerian banks however raises serious regulatory issues for the home and host countries of such multinational banks (Cf. Aliber 1975). Given the size and importance of Nigerian financial institutions in these jurisdictions, banking crises in Nigeria could easily be exported to host country jurisdictions. While this has not yet happened, bank failures in Nigeria have impacted the operations of its foreign subsidiaries. In 2009, for instance, the revocation of the licenses of some Nigerian multinational banks also led to the closure of some of their foreign subsidiaries. After losing its licence in Nigeria in 2009, for instance, Oceanic bank closed its subsidiaries in Cameroun and the Gambia. It also divested from its São Tomé and Principe operations.

Nigeria has since recognised these risks and the cbn has now signed bilateral Memoranda of Understanding (MoU) with: the Bank of Ghana; Commission Bancaire de l’Afrique Centrale (cobac); China Banking and Regulatory Commission; Bank of Uganda; Financial Services Authority (fsa); South Africa Reserve Bank; National Bank of Rwanda; Bank of Zambia; Central Bank of Kenya; Banque Centrale des Etals de l’Afrique (bceao); Central Bank of the Gambia; Bank of Sierra Leone; West African Monetary Zone (Gambia, Ghana, Guinea & Sierra Leone); Bank Negara Malaysia; Central Bank of Liberia; and Central Bank of Guinea. These MoUs, however, do not cover specific aspects of crisis management and resolution ( imf 2013).

Most of the above agreements have since been operationalised (Cf. cbn Annual Report 2011). In 2013, for instance, 15 joint examinations were conducted on off-shore subsidiaries of Nigerian banks with host supervisors in The Gambia, Ghana, Guinea, Liberia, and Sierra Leone under the Harmonised Supervisory Programme in the West African Monetary Zone (wamz). Also, eight cross-border on-site inspections of Nigerian banks were carried out in foreign jurisdictions outside the wamz (cbn Draft Annual Economic Report 2013). Despite such cooperation arrangements, problems remain (Cf. imf 2010). Subsidiaries of Nigerian banks in Africa and beyond have been known to breach host country regulations especially with respect to money laundering. On 30 April 2008, for instance, The Financial Crimes Enforcement Network (FinCEN) and the Office of the Comptroller of the Currency (occ) fined the New York branch of uba $us 15 million for violations of the Bank Secrecy Act (bsa). It was specifically determined that the branch failed to implement an adequate anti-money laundering programme that was designed to “identify and report transactions that exhibited indicia of money laundering or other suspicious activity involving approximately $197 million in suspicious transactions.” The occ then concluded that a “financial institution that recklessly disregards its obligations under the Bank Secrecy Act and continues to operate without an effective anti-money laundering program, despite repeated warnings and a business focus on areas of recognized high risk, should expect to be penalized” (Financial Crimes Enforcement Network 2008).

In the United Kingdom, the Financial Conduct Authority (fca) in 2013 fined Guaranty Trust Bank (uk) Ltd £525,000 “for failings in its anti-money laundering (aml) controls for high risk customers between May 2008 and June 2010” (Financial Conduct Authority, 2013). Also, on 23 July 2012, Bank of Ghana suspended Access Bank (Ghana) from the Foreign Exchange Market for six months. This was because the bank engaged in the “externalization of various sums in favour of a company which had no account relationship with the bank and, in another instance, in favour of a company without any documentation. The transfers were made without the documentation required by the Foreign Exchange Act and Guidelines” ( Ghana Business News, 23 July 2012).

Nigerian multinational banks have also had to contend with the increased share capital requirement in various host countries especially in Africa. Since the beginning of the current decade, several African countries, including Sierra Leone, Uganda, Kenya, Tanzania, Ghana, and Zambia have raised the minimum share capital requirement for banks operating in their jurisdictions. Initially, Nigerian banks were able to raise money at home to meet these capital requirements. In 2012, however, cbn expressed concern that given the lull in capital markets globally, including Nigeria, “these increased capital requirements have exerted pressure on the capital bases of local banks, ultimately weighing on their profitability and competitiveness” (Euromoney 2012). The cbn therefore gave “the banks three options: (1) raise fresh capital from the offshore capital markets via private placements or public offerings; (2) pursue a merger or acquisition; or (3) if external capital raisings fail, submit a strategy for exiting the relevant foreign jurisdictions not later than 30 June 2012” (Ibid.). ⁷ This policy has at least in part been responsible for the withdrawal of some Nigerian multinational banks from some of their subsidiaries abroad. In March 2014, for instance, Access Bank closed its subsidiary in Burundi while Keystone Bank sold its interest in its Ugandan subsidiary in February 2015.

Keystone Bank’s subsidiary in the Gambia has also been under administration since May 2014. At the time, the Central Bank of The Gambia (cbg) also took over the subsidiary of Access Bank in the country. According to the cbg, “the move is meant to stabilize and bring sanity to The Gambia’s Nigerian dominated banking industry” ( Star Africa, 6 May 2014). One week later, the takeover of Access Bank was rescinded. This was because investors in Access Bank’s Gambian unit promptly “injected over $15 million to recapitalize and take back control of the bank after it was briefly nationalized” ( Reuters, 13 May 2014).

Aside from the above regulatory issues, Nigeria’s reputation as a bastion for fraud and corruption sometimes hinders the ability of its multinational banks to provide financial services abroad. ⁸ Aside from the fact that such negative reputation normally make potential customers wary, some Nigerian civil society groups have also used this as a basis for actively campaigning against the operations of some of these Nigerian multinational banks abroad. In 2008, for instance, some members of the SaveNigeria Group, demonstrated at the London subsidiaries of gtb and Zenith. They stayed in front of the bank to hand “out flyers warning customers and the public against the risk of entrusting their money to money laundering operations called Nigerian banks” (Change Nigeria 2008).

Despite these difficulties, the services provided by Nigerian multinational banks have continued to contribute positively to the economic development of their host economies especially in Africa. Although regulation was the single most important causative factor in the emergence of Nigerian international banks, many of these banks, especially those operating in Africa, have been exploiting the business and economic opportunities in their host economies. The consequence of increased competitive pressures from Nigerian banks is the emergence of more efficient local banks. In the case of Ghana, for instance, it has been explained that many of the traditional local banks “responded to the innovative products and competition brought by the foreign banks by adopting a strategic rethink, and reshaped their focus and direction in order to be attractive to customers” ( Modern Ghana, 19 June 2008). For the cross-border activities of Nigerian multinational banks to be sustainable and mutually beneficial to their home and host countries in the long run, the home and host country regulators of such banks must continue to cooperate so as to ensure that unhealthy and unethical banking practices are punished and discouraged (Alade 2014).

Conclusion

This chapter has argued that the single most important factor that explains the emergence of Nigerian multinational banks over time has been home country regulation. It is this that facilitated the quest by Nigerian banks to expand their services to other jurisdictions. Specifically, it was the 2004 decision by the cbn to increase the minimum paid up capital requirement for Nigerian banks from N2 billion to N25 billion that necessitated the aggressive expansion of the services of compliant Nigerian banks abroad. The findings in this chapter therefore show that the conventional hypothesis which suggests that multinational banks normally follow their customer abroad is not the main reason for the emergence of Nigerian multinational banks.

Based on the above, it is not surprising that in several African countries, subsidiaries of Nigerian banks compete with host country banks for the provision of financial services to local businesses. Although the advent of these multinational banks have raised regulatory concerns in the banking arena of home and host countries, these have been mitigated by the increased cross-border regulatory cooperation by regulators in the home and host countries of such multinational banks. Continued vigilance and cooperation by the regulatory authorities in both jurisdictions is therefore a necessary condition for the continued and sustainable provision of cross border banking services by Nigerian multinational banks.