This report is developed for the purpose of providing the true representation of events tothe narrative as expressed by the Independent Corrupt Practices Commission (ICPC) ina tweet late on Tuesday, February 7, 2023.

Background

1.   A regulatory monitoring team visited our Abuja Central Business District (CBD)Complex on February 3, 2023.

2.  The monitoring team, in the company of the branch service manager and otherstaff, inspected and observed the following꞉

a. The branch’s ATMs were dispensing all denominations of the newly designed notes.

b. The branch was in full compliance with the regulator’s recommendations onOver ‑ The‑Counter (OTC) disbursements.

During the inspection, the monitoring team made inquiries about the details of thecash observed in the vaults. To which the team responded with details of the branch’sATM and OTC cash disbursement processes.

To our knowledge, all responses provided were satisfactory as no further queries were raised.

The monitoring team promptly left the premises upon concluding the inspection.

3.   Approximately  one  hour  later,  officials  of  the  Independent  Corrupt  Practices Commission (ICPC), accompanied by the monitoring team, returned tothe branch and removed two of the branch’s staff for further questioning at theICPC headquarters in Abuja.

4.   The Sterling staff were held at the  ICPC office and were later released withoutany charges levied against them by the close of the business day on February 3, 2023.

About the visit to Sterling Bank, CBD, Abuja

1.   The Sterling branch at the Central Business District, Abuja, is a regional headquarters and serves as a hub for 5 Sterling branches and 15 ATM terminals within the region.

2.   During the visit, members of the monitoring team inspected the vault of the branch and observed the sum of N258,000,000 in N1000, N500 and N200 denominations.

3.  The distribution records from the CBD branch to other locations served within the region were presented for the evaluation of the monitoring team.

4.  The  monitoring team  proceeded to visit two  branches  in  Utako and Wuye as  both locations receive their cash disbursements from the regional headquarters of Sterling in CBD.

5.   Upon their visits to the Utako and Wuye branches, the monitoring team reviewed the records submitted for the movement of cash from the CBD branch to other branches served within the region.  It is important to state that cash was being paid over the counter at  both  branches,  and  the  ATM  terminals  were  dispensing  the  newly  designed denominations during the monitoring exercise.

Matters Arising

Sterling deems it necessary to point out the following꞉

1.   Members of the regulatory monitoring team were informed of the sums contained inthe branch’s vault prior to the inspection. These sums were confirmed with areview of the records as presented by representatives of the Bank.

The assertion of a “discovery”, as presented in the narrative, is inaccurate andgrossly misleading.

2.  All cash observed in the vault of the CBD branch was earmarked for distribution toother branches in the region for disbursement to customers of the bank and the public.

3.  The sum of N5,000,000 each as contained in the monitoring team’s report,represents the cash moved to augment the vault balances of the Utako, Wuye,Seda Close and Kotangora branches (in line with the bank’s daily routine of cash management) and also for disbursement to the public via their ATM terminals.

4.  All balances in our vaults are reported daily to the Central Bank of Nigeria and form the basis for the allocation of new notes in an efficient manner; it is therefore,untrue that such monies are ‘stashed’ or ‘hoarded.’

Sterling’s Distribution of New Notes

From the commencement of the distribution of the re‑designed denominations, the CBD branch has received the total sum of N1,543,000,000 from the apex bankand paid to customers as summarized below꞉

1.   The  sum  of  N892,700,000  paid  out  in  about  104,821 transactions  across  15ATM terminals between January 6 to February 6, 2023.

2.  The sum of N78,600,000 paid out in approximately 3,892 over‑the‑counter transactions across all 6 branches in the Abuja region between February 2, 2023 to February 6, 2023.

This was commenced upon receipt of the directive from the regulator to disburse the new notes over the counter ‑ subject to a limit of N20,000 per transaction.

3.  The sum of N1,000,000,000 in a combination of old and new notes, was disbursed to customers over the counter in about 2,124 transactions between December 15, 2022 and January 5, 2023.

The current balances across the 6 branches in Abuja as at the close of business onFebruary 7, 2023 stood at N178,670,000.

The average vault balances currently held in the six locations is N30m per branch; well below our historical vault balances.

Conclusions

1. The  representatives of the  bank duly  informed the  regulatory  monitoring team and officials  of  the  ICPC  of  the  sums  in  the vault,  stating  the  purpose  as  intended  for distribution to other branches.

2. It must be noted that no cash was “stashed” in the vault of the regional office.

For emphasis, we wish to state that Sterling Bank has complied with all the guidelines on the distribution of redesigned notes from inception to date.