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UNDERSTANDING NIGERIA’S APPROPRIATION BILL 2025

The 2025 Budget, titled “The Restoration Budget: Securing Peace, Rebuilding Prosperity,” was presented by President Bola Ahmed Tinubu during a Joint Session of the National Assembly on Wednesday, December 18, 2024. To date, the budget is yet to receive legislative approval from the National Assembly, marking the latest start to the yearly legislative process for financial appropriation in 25 years. The Chairman of the Senate Committee on Appropriation, Senator Solomon Adeola, attributed the delay to the introduction of the Tax Reform Bill which is required to be passed concurrently with the Appropriation Bill 2025 and without which the underpinning revenue assumption will be doubtful. He further noted that the National Assembly is working diligently to pass the Appropriation Bill by January 31, 2025. In the interim, the National Assembly has approved an extension to the term of the 2024 Appropriation Act from December 31st 2024 to June 2025.

The 2025 Budget represents a significant step toward improving the overall health of the Nation’s economy, restoring macroeconomic stability, and building on the progress recorded by the current administration in the last nineteen months to give the Nigerian economy the much needed uplift.

In his Budget Proposal presentation,  President Bola Tinubu outlined the Federal Government’s key priority areas for the 2025 fiscal year, to include restructuring the economy, boosting human capital development, increasing trade and investment volumes, bolstering oil and gas production, and revitalizing the manufacturing sector to enhance Nigeria’s economic competitiveness. He emphasized that defense and internal security, infrastructure development, healthcare, education, human capital development, and agriculture remain at the core of his administration’s fiscal objectives.

The budget proposal is guided by the assumptions set out in the multi-year Medium Term Expenditure Framework (MTEF) 2025–2027 and the Fiscal Strategy Paper (FSP) which serve as a vital tool for prudent fiscal management and resource allocation. The MTEF incorporates factors such as inflation, interest rate, currency exchange rates, foreign exchange reserves, capital import flows, and the performance of the preceding year’s budget to establish the foundational assumptions influencing the fiscal plan for 2025.

Comparative Analysis of Key Budget Assumptions

  2025 2024 2023
Crude Oil Price (Per Barrel) $75 $77.96 $75
Crude Oil Production (MBPD) 2.06 1.78 1.69
GDP Growth Rate 4.6% 3.88% 3.75%
Inflation Rate 15% 21.4% 17.16%
Exchange Rate (USD 1) NGN 1500 NGN 800 NGN 435.57
 Table 1: Comparison of key assumptions underlying Nigerian budgets from 2023 to 2025

 

Fig 1: Key Assumptions in the 2025 budget

 

Key Elements of the Budget – Revenue summary

The 2025 Appropriation Bill projects a total revenue of NGN 36.35 Trillion, a 40.51% increase from the total aggregate revenue for 2024.

The total aggregate revenue of NGN36,352,202,174,299 for 2025 is therefore broken down as follows:

  1. FGN Share of Net Federation revenue is projected to be NGN 27.49 Trillion – (75.56% of the total aggregate expenditure).
  2. Independent Revenue is projected to be 3.47 Trillion representing – (9.51% of the total aggregate expenditure).
  3. Other Dividends (less NLNG Dividend) are projected to be NGN 7.52Billion – (0.02% of the total aggregate expenditure).
  4. Aids and Grants are projected to be NGN 761.9 Billion – (2.09% of the total aggregate expenditure).
  5. Special Funds/Account Receipts are projected to be NGN 300 Billion – (0.83% of the total aggregate expenditure).
  6. Revenue from Government-Owned Enterprises are projected to be NGN 2.87 Trillion – (7.89% of the total aggregate expenditure).
  7. Other Revenue Sources are projected to be NGN 1.46 Trillion – (4.02% of the total aggregate expenditure).

The Medium-Term Expenditure Framework (MTEF) 2025–2027 and Fiscal Strategy Paper (FSP) assumes a total revenue of NGN 34.82 Trillion for 2025:

  1. Oil-related sources: NGN 19.6 Trillion, representing 56.32% of the total projected revenue.
  2. Non-Oil-related sources: NGN 15.22 Trillion, representing 43.68% of the total projected revenue, which includes non-oil taxes, mining revenue, GOE revenue, aids, grants, and social fund receipts.

Whilst there exists a marginal discrepancy between the projected revenue in the 2025 Appropriation Bill (NGN 36.35 Trillion) and the MTEF/FSP assumption (NGN 34.82 Trillion), the negligible margin of difference suggests alignment in the fiscal posture of the Federal Government. The almost equal ratio of oil related revenue and non-oil related emphasizes the drive to achieve a more diversified revenue pool, particularly from taxes, government-owned enterprises, and social funds, reinforcing the government’s commitment to a sustainable fiscal mix.

Figure 2: percentage-based representation of revenue projection under the 2025 budget

Key Elements of the Budget – Expenditure Summary

The Appropriation Bill 2025 projects a total aggregate expenditure of NGN49.74 Trillion, reflecting a 41.91% increase in comparison 2024, including the approved supplementary budgets.

The projected expenditure for 2025, amounting to NGN49,740,165,355,396, is allocated as follows:

  1. Aggregate Capital Expenditure is estimated at NGN14.85 Trillion representing 29.85% of the total aggregate expenditure, and a 7.84% increase from the 2024 budget including the approved supplementary budgets.
  2. Recurrent (non-debt) expenditure is estimated at NGN14.12Trillion representing 28.39% of the total aggregate expenditure, and a 25.40% increase from the 2024 budget including the approved supplementary budgets.
  3. Total Debt service is estimated at NGN16.33Trillion, representing 32.83% of the total aggregate expenditure, and a 97.81% increase from the 2024 budget including the approved supplementary budgets.
  4. Statutory transfers are estimated at NGN4.44 Trillion, representing 8.93% of the total aggregate expenditure, and a 154.60% increase from the 2024 budget including the approved supplementary budgets.

Of the total aggregate expenditure approved for the 2025 financial year, a total of NGN8.2 trillion is appropriated for the service of domestic debts and NGN7.6 trillion for the service of foreign debts, while NGN 430.268 billion is to be held in a Sinking Fund Account for the retirement of maturing promissory notes.

 

 

Fig. 3: percentage based representation of revenue allocation under the 2025 budget

 

  2025 2024 2023
Aggregate Expenditure NGN49.74tn NGN28.7tn NGN21.83tn
Statutory transfers NGN4.44tn NGN1.743tn NGN967.49bn
Recurrent (non-debt) expenditure NGN14.12tn NGN8.769tn NGN8.33tn
Capital expenditure NGN14.85tn NGN9.995tn NGN6.46tn
Debt service NGN15.89tn NGN8.271tn NGN6.31tn
Sinking Fund NGN430.2bn NGN223.662bn NGN247.7bn
Table 2:  YOY Comparison of expenditure allocation in the budgets from 2023 – 2025

Key Elements of the Budget – Budget Deficit and Deficit Financing

The Budget deficit for the 2025 fiscal year stands at NGN13.39 trillion, representing 3.9% of our National GDP and a 45.36% increment from the NGN 9.18 trillion budget deficit for 2024. This sharp increase highlights the Federal Government’s strategic decision to expand fiscal spending in response to pressing national priorities. Although this exceeds the threshold set by the Fiscal Responsibility Act, the Federal Government has represented that the need to address critical security and economic challenges validates this increased expenditure. The Budget deficit is expected to be financed primarily from the proceeds of strategic asset sales/privatization which Federal Government estimates will return circa NGN312,332,810,711 (2% of total deficit); multilateral/bilateral project-tied loans disbursements estimated at NGN3,799,281,435,450 (28% of total deficit) and other debt financing sources estimated at NGN9,276,348,934,936 (69% of total deficit).

The Federal Government’s approach to deficit financing reflects an unprecedented strategy, relying on a domestic and external borrowing threshold. Whilst this strategy will likely facilitate economic growth and development across various sectors, it leaves in its trail growing concerns about rising National debt,  layered with rising cost of debt service which could further flay inflationary pressure.

Fig 4: percentage-based representation of the allocation of the budget deficit financing under the 2025 budget

Analysis of the 2025 Budget – Key highlights

  1. Macroeconomic assumptions

As with previous budgets, questions have been raised around the viability of the macroeconomic assumptions underpinning the 2025 Appropriation Bill. The USD exchange rate benchmark is set at NGN1,500/USD, whereas current market rate hovers around NGN1,535/USD. The gap between the projected and actual exchange rates signals a significant risk, especially if FX availability declines or the FX market conditions worsen. We note however that the Central Bank of Nigeria’s (CBN) Electronic Foreign Exchange Matching System (EFEMS), may likely improve transparency and efficiency in the FX market.

Furthermore, a review of the performance of the 2024 budget reveals discrepancies in inflation assumptions which was projected at 21% for 2024 and which later settled at 34.6%; oil production was pegged at 1.78mbpd, yet actual production averaged 1.4mbpd. These variances have raised significant concerns about the credibility of the 2025 assumptions, especially given persisting challenges such as oil theft, fluctuating global crude prices, and foreign exchange volatility. Critics argue that these overly optimistic assumptions could lead to higher deficits and greater borrowing to cover revenue shortfalls.

  1. Ambitious Revenue Assumptions

The revenue projections for 2025 have drawn significant scrutiny from experts, with the Federal Government projecting a total revenue of NGN36.35 trillion, representing a 40.51% increase from the 2024 budget revenue projection. This includes projected oil revenue of NGN19.6 trillion, a target that many consider overly optimistic, given Nigeria’s declining oil production volumes of circa 1.6mbpd over the past two years and the persistent challenges of pipeline vandalism, oil theft, and fluctuating crude prices. However, the recent approval of major oil and gas acquisitions, such as the Seplat-Mobil Petroleum Nigeria Unincorporated (MPNU), Oando-Eni, Chappal-Equinor, and Shell-Renaissance deals are expected to increase oil and gas production capacity. These deals, which bring in critical investments for the development of new oil fields and the revitalization of existing ones, are anticipated to help Nigeria achieve higher output levels, and possibly validate the production assumptions.

In the light of the record decline in consumer spending and the growing economic hardship, many stakeholders have also adjudged the Non-oil revenue projections as ambitious. The Federal Government expects NGN15.22 trillion from non-oil sources, including VAT and Corporate taxes. It is however worthy of note that the Federal Inland Revenue Service (FIRS) exceeded its 2024 revenue collection target, realizing NGN21.6 trillion over and above the NGN19.4 trillion target, including significant gains in Company Income Tax and Education Tax.

It is our considered opinion that achieving the 2025 revenue projections hinged primarily on increased oil and gas production, Stabilization of global oil prices and production costs fluctuations in oil prices could directly impact the revenue from this sector and Significantly improve the non-oil revenue stream.

  1. Debt Financing and Rising Debt Servicing Cost

Under the 2025 Budget, debt service is estimated at NGN16.33 trillion, accounting for 32.83% of total expenditure, significantly higher than the NGN8.49 trillion allocated in 2024. This increase reflects both the rising debt stock and the impact of global interest rate hikes on external borrowings. The fluctuating exchange rate, instability of the Nigerian Naira, and the rise in domestic lending rates further exacerbate the debt servicing burden, as more local currency may be required to meet both foreign and domestic debt obligations.

Nigeria’s growing debt burden continues to be of great concern to stakeholders. The 2025 Budget deficit of NGN13.39 trillion will be financed through a mix of borrowing, multilateral loans, and asset sales/privatization proceeds, further increasing the country’s debt stock. Debt-to-GDP ratio, which stood at 50.7% in 2024 is however projected to decrease marginally to 49% in 2025, highlighting concerns about long-term fiscal sustainability. The high debt-servicing costs will crowd out spending in vital sectors such as healthcare, education, and infrastructure, hindering efforts to achieve inclusive economic growth, thereby calling for an efficient long-term debt management strategy and enhanced fiscal discipline.

  1. The 2025 Tax Reform Bill

The proposed 2025 Tax Reform Bill, currently undergoing the legislative approval process, is what underpins key revenue assumptions under the 2025 Budget and the Federal Government’s strategy to increase revenue generation and improve fiscal sustainability. This Bill which has been applauded by many stakeholders, shows a much longer term approach to tax reforms in contrast to the previous Buhari administration, which passed a Finance Bill alongside its Appropriation Laws to deliver strategic reforms and stimulate economic activity in priority sectors in each Fiscal Year. The Tax Reform Bill when passed, is expected to enhance tax compliance, streamline fiscal policies, expand the national tax base, and consolidate existing tax laws, whilst delivering long-term fiscal health, and addressing systemic inefficiencies in tax administration and aligning tax policies to the broader fiscal objectives of the Federal Government.

Conclusion

The 2025 Appropriation Bill is an ambitious fiscal proposal designed to restructure critical sectors of Nigeria’s economy, drive revenue growth, and tackle pressing national challenges. Its key objectives include reducing dependence on petroleum imports, promoting the export of finished petroleum products, boosting agricultural production through improved security, and increasing foreign exchange inflows through foreign investments. Further, the budget targets a significant increase in crude oil output and exports while aiming to lower upstream oil and gas production costs. However, the ongoing delay in the budget’s approval by the National Assembly poses the risk of potentially stalling progress on these vital initiatives and delaying the execution of key projects.

Achieving the objectives of the 2025 budget will require a comprehensive and strategic approach by the Federal Government. This includes the rigorous implementation of tax reforms, diversification of the economy to reduce oil dependency, substantial investment in critical infrastructure, and the strengthening of governance frameworks to enhance transparency and accountability. These measures are essential for improving fiscal discipline, attracting investments, and building a resilient economic foundation.

For businesses, subject to its timely passage, we already see key economic benefits that are likely to positively impact the business landscape in Nigeria. The significant increase in capital expenditure is expected to translate to increased infrastructure development; it is also expected that the Country will enjoy a much more stable and predictable fiscal and monetary policy direction which will restore investor confidence and promote economic growth.

The Budget also records significant allocation of revenue to education:- supporting teacher training, supporting initiatives such as the Universal Basic Education, Vocational Training Initiative, the expansion of the National Open University of Nigeria, and the promotion of equal opportunity to education through  scholarships and grants to students from disadvantaged backgrounds. This will in the long run improve the size and depth of the Nation’s skilled workforce pool which has suffered significantly on account of increased workforce migration.

In summary, the 2025 budget presents promising opportunities for sectors such as manufacturing, agriculture, education and infrastructure with the increased capital flow to be recorded in the current fiscal year and the overall impact this will have on the overall economy. Nonetheless, businesses must remain proactive and adaptable, keeping a close watch on evolving fiscal policies, potential tax reforms, and macroeconomic indices that may impact their operations. Ultimately, the budget’s success will depend on timely legislative approval, efficient policy execution, and prudent fiscal management. These factors will determine the extent to which the 2025 budget influences Nigeria’s economic trajectory and the broader business landscape.

 

About DealHQ

We are a Pan-African transactional advisory firm dedicated to enabling businesses operate efficiently within Africa’s dynamic market. We provide stellar business solutions which help businesses navigate the unique challenges and opportunities in the African business landscape whilst enabling them to operate efficiently within their market sphere.

Our service offering includes: corporate commercial, real estate & construction, finance, capital markets & derivatives, mergers and acquisitions, private equity, infrastructure, technovation and data privacy, agriculture & commodities, business formations & start up support amongst others.

The content of this Article is not intended to replace professional legal advice. It merely provides general information to the public on the subject matter. Should you wish to seek specialist legal advice on this or any other related subject, you may contact us.

info@dealhqpartners.com

www.dealhqpartners.com

+234 (0) 201 4536427 , +234 (0) 809 093 8104

 

Click here to access the pdf file  DEALHQ – UNDERSTANDING NIGERIA’S APPROPRIATION BILL 2025

WHAT YOU NEED TO KNOW ABOUT THE APPROPRIATION ACT 2024

The 2024 Budget which has been tagged the “Budget of Renewed Hope” was signed into law on the 1st of January 2024 by the President of the Federal Republic of Nigeria; President Bola Ahmed Tinubu. The Budget represents a major milestone towards improving the overall health of the Nigerian economy and restoring macro-economic stability. In tandem with the last administration’s effort to keep to a consistent budget cycle, it was a relief to see the trend continue with the current administration.

The President in his speech at the Joint Session of the National Assembly on Wednesday, November 29, 2023, highlighted the priority areas for the Federal Government in the 2024 Appropriation Act. Primarily, the Budget is focused on setting the tone for achieving: job-rich economic growth, macro-economic stability, improved investment environment, enhanced human capital development, poverty reduction, and greater access to social security. The President further noted that defense and internal security, human capital development, investment in education, and a greener and sustainable economy remain the core elements of his administration’s budget objectives.

The budget proposal is underpinned by the assumptions outlined in the multi-year Medium Term Expenditure Framework (MTEF) 2024 -2026 and Fiscal Strategy Paper (FSP) which serve as a vital tool for prudent fiscal management and resource allocation. The Medium-term Expenditure Framework takes into account factors such as inflation, lending rate, currency exchange rate, foreign exchange reserve size, capital import flows and preceding year budget performance, to determine the key assumptions underpinning the fiscal plan for the 2024 financial year.

Comparative Analysis of Key Budget  Assumptions

  2024 2023 2022
Crude Oil Price (Per Barrel) USD77.96 USD75 USD62
Crude Oil Production (MBPD) 1.78 1.69 1.86
GDP Growth Rate 3.88% 3.75% 4.2%
Inflation Rate 21.40% 17.16% 13%
Exchange Rate (USD 1) NGN 800 NGN 435.57 NGN 410.15
Table 1: Comparison of key assumptions underlying Nigerian budgets from 2022 to 2024
                                                            Fig 1: Key assumptions in the 2024 budget

 

Key Elements of the Budget – Revenue summary

Of the total NGN28.78 Trillion required to fund this year’s budget; the Federal Government’s assumption on Total Revenue available to fund the Budget is estimated at NGN19.60 Trillion, with NGN9.21 Trillion projected to come from oil-related sources, NGN3.52 Trillion from non-oil sources, and NGN6.87 Trillion from other Independent sources, including revenue of GOEs (Government Owned Enterprises), aids, grants and social funds/Accounts receipts. Whilst many believe that the Federal Government’s 2024 Revenue assumptions are quite ambitious; the revenue assumptions underpinning the 2023 Appropriation Act returned quite close to call at the end of the financial year flaring the Government’s optimism for its forecasted income.

 

                                                                   Fig 2: Summary of the revenue allocation in the 2024 budget

 

Key Elements of the Budget – Expenditure Summary

The Appropriation Act 2024 projects a total aggregate expenditure of NGN 28.78 Trillion, which is 10.9% higher than the total aggregate expenditure for 2023 including approved supplementary budgets.

The total aggregate expenditure for 2024 is projected to be NGN28,777,404,073,861, broken down as follows:

    1. Aggregate Capital expenditure is estimated at NGN9.99 Trillion (35% of the total aggregate expenditure)
    2. Recurrent (non-debt) expenditure is estimated at NGN8.7Trillion (30% of the total aggregate expenditure)
    3. Total Debt service is estimated at NGN8.27Trillion, representing 29% of the total aggregate expenditure
    4. Statutory transfers are estimated at NGN1.74 Trillion, representing 6% of the total aggregate expenditure

Of the total aggregate expenditure approved for the 2024 financial year, a total of NGN5.3 trillion is appropriated for the service of domestic debts, NGN2.748 trillion is appropriated for the service of foreign debts, while N223.662 billion is to be held in a Sinking Fund Account for the retirement of maturing promissory notes.

Fig 3: Percentage based representation of revenue allocation under the 2024 budget

 

  2024 2023 2022
Aggregate Expenditure NGN28.7tn NGN21.83tn NGN17.13tn
Statutory transfers NGN1.743tn NGN967.49bn NGN869.67bn
Recurrent (non-debt) expenditure NGN8.769tn NGN8.33tn NGN6.91tn
Capital expenditure NGN9.995tn NGN6.46tn NGN5.47tn
Debt service NGN8.271tn NGN6.31tn NGN3.61tn
Sinking Fund NGN223.662bn NGN247.7bn NGN270.7bn
Table 2:  YOY Comparison of expenditure allocation in the budgets from 2022 – 2024

Key Elements of the Budget – Budget Deficit and Deficit Financing

The Budget deficit for the 2024 fiscal year stands at NGN9.179 trillion, representing 3.88% of our National GDP and representing a massive 33.38% reduction from the 2023 budget deficit. This downward trend evidences a demonstration of significant expenditure discipline. The NGN9.179Trillion Budget deficit is projected to be financed through asset sales/privatization which Federal Government estimates will return circa NGN298,486,421,740; multilateral/bilateral project-tied loans disbursements estimated at NGN1,051,914,486,314 and other debt financing sources estimated at NGN7,828,529,477,860.

The National Assembly has approved the Federal Government’s request to borrow USD7.8billion and EUR100 million as part of its 2022 – 2024 borrowing plan. The Loan Facilities which were initially approved on May 15, 2023 by the Federal Executive Council (FEC) under former President Muhammadu Buhari will be utilized in key priority sectors such as finance infrastructure, healthcare, education, agriculture and security amongst others.

 

Securitization of Ways and Means Advances from the CBN

The National Assembly on the 30th of December 2023 approved the securitization of the outstanding debit balance of NGN7.3 trillion Ways and Means Advance from the Federal Government.

Ways and Means is a loan facility through which the CBN finances the government’s budget shortfalls, made pursuant to section 38 of the CBN Act 2007, which stipulates that the apex bank may grant temporary advances to the federal government in respect of temporary deficiency of budget revenue provided such overdraft do not surpass five per cent of the government revenue from the previous year.

 

Analysis of the 2024 Budget – Key highlights  

  1. Macroeconomic assumptions

Many schools of thought following the passage of the 2024 Appropriation Act have questioned the underlying assumptions in the budget given current macroeconomic realities and historic performance. For instance, the USD benchmark for the Budget is pegged at NGN800/1USD whereas as at the time of this publication the official exchange rate as published by the Central Bank is averaging NGN1400/USD. An overview of the Budget performance for 2023 also shows significant variation between the underlying macro-economic assumptions and the actual position; specifically in relation to inflation rate, foreign exchange rate and oil production levels giving a strong basis for the perceived pessimism. Benchmark inflation rate for 2023 was 17.6% relative to an actual inflation rate of 28.20% as of December 2023; Benchmark USD exchange rate was NGN437.57/USD1, whilst actual exchange rate was NGN853/USD1 as at December 2023. Similarly, oil production levels of 1.49mbpd was below the 2023 Budgetary assumption pegged at 1.69mbpd.

If the 2023 budget performance is anything to go by, it is safe to say that the 2024 Budget assumptions do not accurately reflect current macroeconomic trends raising concerns about increased deficit and the consequent borrowing to meet expenditure shortfalls.

  1. Ambitious Revenue Assumptions

Many have described the revenue assumptions underpinning the 2024 Budget as overly ambitious and doubtful; projecting a total NGN19.60 trillion revenue being a 54% increase relative to the 2023 revenue forecast. The assumptions around the benchmark price of crude oil and the projected daily oil production target of 1.78mbpd seems to be in complete dissonance with historical performance (Nigeria recorded an average production rate of 1.2mbpd over the last 2 years) and current market realities including decline in oil production, unabated oil theft and committed future production tied to swaps and forward contracts. Additionally, the increase in non-oil revenue assumptions from NGN2.43 Trillion in 2023 to NGN3.52 Trillion in 2024 seems not to have taken cognizance of shrinking economic activities, and lower consumption of VAT related goods due to ongoing economic hardship.

  1. Ways and Means Advances

The securitization of the due and outstanding NGN7.3 Trillion Ways and Means advance has remained one of the most debated elements of the 2024 fiscal plan; The continued reliance by the Federal Government on Ways and Means advances to fund budget deficits and subsequently requesting its securitization rather than repayment raises significant concern about budget discipline and Nigeria’s growing debt profile. Ways and Means Advances are primarily short-term, or emergency funding disbursed by the Central Bank of Nigeria to the Federal Government to fund delayed government cash receipts.

Whilst Section 38 of the CBN Act authorizes the Ways and Means Advances by the Central Bank; it limits the total available to draw amount to 5% of the actual revenue of the Federal Government for the preceding year, whilst also mandating that repayment be done within the same calendar year in which it is disbursed. Over the last 8 years Federal Government has continued to accrue ways and means liabilities without any reasonable repayment structure hence the pressure to restructure them into securitized loan notes. Recall that the National Assembly in 2023, similarly approved the President Buhari led Administration’s request to securitize about NGN22.7Trillion of ways and means obligations accrued during his 8 year tenure.

Following the National Assembly’s approval of the proposed Securitization, the Federal Government would issue debt notes to the Central Bank for a tenure of 40 years at an annual interest rate of 9% Per Annum (significantly less that the cost of carry of the CBN Ways and means Advance which was MPR+3%). Further, the loan will be included in the National Debt Profile for transparency.

It is important to note that the Ways and Means advances finds judicial backing in the provisions of Section 38 of the CBN Act. It is however also important to add that while Section 38 of the CBN Act empowers the CBN to advance this facility, the Act provides that the amount of such advances outstanding shall not at any time exceed 5% of the previous year’s actual revenue of the Federal Government and that all such advances when disbursed shall be repaid within the same Financial Year in which it is granted.

  1. The Emergency Economic Intervention Bill

Even though the President, in his speech, confirmed that current tax and fiscal laws are being reviewed to increase the ratio of revenue to GDP to 18 percent, the current administration unlike its predecessor has not passed a finance bill alongside its Appropriation Act. It is important to note however that the Presidential Fiscal Policy and Tax Reforms Committee Emergency has proposed an Economic Intervention Bill which appears to propose changes to certain tax and fiscal laws. It our considered opinion however, that when passed, the Emergency Economic Intervention Bill may support the implementation of the 2024 Budget and enhance the prompt realization of Federal Government’s revenue assumptions and government’s revenue generation plans.

Conclusion

With impressive continuity, the Bola Ahmed Tinubu led administration has kept to the culture of prompt passage of the Budget. Generally, the budget is quite ambitious as it generally takes a posture of increasing government spending to support real economic growth. Whilst the Government’s assumptions on revenue seem overly optimistic, there is a marked reduction in budget deficit and increased capital expenditure relative to recurrent expenditure. Despite concerns about some mismatch in the assumptions underpinning the Budget; key stakeholders generally remain optimistic about the potential of Nigeria’s biggest budget yet to deliver on the Federal Government’s mantra of “Renewed Hope”.

 

About DealHQ

We are an Africa Focused deal advisory/boutique commercial law firm focused on supporting businesses and positioning them to operate efficiently within their market sphere. We are known for our quality service delivery which is focused on attention to detail, creativity, timely execution and client satisfaction.

Our service offering includes: corporate commercial, real estate & construction, finance, capital markets & derivatives, mergers and acquisitions, private equity, infrastructure, technovation and data privacy, agriculture & commodities, business formations & start up support amongst others.

The content of this Article is not intended to replace professional legal advice. It merely provides general information to the public on the subject matter. Should you wish to seek specialist legal advice on this or any other related subject, you may contact us.

HOW TO GET STARTED

Do you need to know more about the Appropriation Act? Our Finance team is available to support you.

You may contact our team on: Email: info@dealhqpartners.com Telephone: +234 1 4536427 or +234 9087107575

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CBN LIFTS RESTRICTION ON THE OPERATION OF BANK ACCOUNTS BY VIRTUAL ASSETS SERVICE OPERATORS (VASPs) IN NIGERIA.

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On Friday 22nd December 2023, the Central Bank of Nigeria (“CBN”) lifted its hitherto ban restricting banks and financial institutions from dealing in or facilitating cryptocurrency related transactions through its recently published “Guideline on Operations of Bank Accounts for Virtual Assets Service Providers (VASPs)” which now authorizes Banks and other Financial Institutions to provide  banking services to virtual asset service providers (VASPs) in compliance with relevant anti-money laundering laws issued by competent authorities. VASPs, Digital Assets Custodians, Digital Assets Offering Platforms, Digital Asset Exchanges, Digital Asset Exchange Operators, and any other entity that may be categorized by the CBN who are licensed by the Securities and Exchange Commission, can now legally operate a designated account with banks and financial institutions subject to the conditions stipulated in the Guideline.

The CBN’s earlier directive of February 5th, 2021, had excluded cryptocurrency transactions from the scope of transactions permitted to be facilitated or processed by financial institutions operating within Nigeria’s mainstream banking system. The 2-year ban which was the Apex Bank’s response to global concerns around money laundering and terrorism finance risks underlying the very opaque and unregulated cryptocurrency market has set the country back significantly from harnessing the benefits of the early adoption of digital currencies as a viable financial asset class.

The Guideline signals a positive change for Nigeria’s hitherto comatose digital assets ecosystem as financial institutions can now outside of their primary activity; facilitate the opening and operation of accounts for VASPs whilst being mandated to establish adequate risk management systems for combating money laundering, financing of terrorism and countering proliferation financing and to ensure adequate activity monitoring/tracking and customer protection. It is worthy of note that this guideline still prohibits banks and other financial institutions from holding, trading and/or transacting in virtual currencies on their own account.

The Guideline prescribes strict requirements for the onboarding of VASPs and operation of bank accounts by VASP account holders – including protocols for customer onboarding/due diligence in a bid to entrench transparency and effective reporting.  Also, it sets operational and transactional limit for all VASP accounts whilst… Click here to download article

 

About DealHQ

We are an Africa Focused deal advisory/boutique commercial law firm focused on supporting businesses and positioning them to operate efficiently within their market sphere. We are known for our quality service delivery which is focused on attention to detail, creativity, timely execution and client satisfaction.

Our service offering includes: corporate commercial, real estate & construction, finance, capital markets & derivatives, mergers and acquisitions, private equity, infrastructure, technovation and data privacy, agriculture & commodities, business formations & start up support amongst others.

The content of this Article is not intended to replace professional legal advice. It merely provides general information to the public on the subject matter.

Email: info@dealhqpartners.com; clientservices@dealhqpartners.com

Telephone: +234 1 4536427 or +234 9087107575

 

NIGERIA: UNDERSTANDING THE REGULATORY FRAMEWORK FOR OPEN BANKING

The open banking ecosystem in Africa has certainly taken flight, with countries such as South Africa, Kenya, Nigeria and Ghana recording unprecedented rate of product development, innovation and adoption across the regions digital financial services market. That said, strengthening financial systems regulation, risk management and financial data governance remain critical to achieving continuous and sustainable growth in the sector. The introduction of Nigeria’s open banking regulations is bold, audacious and enviable. It is expected that its implementation will be strategic and impactful.

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WHAT YOU SHOULD KNOW ABOUT THE APPROPRIATION ACT, 2023

PARAMETERS AND KEY ASSUMPTIONS

The 2023 “Budget of Fiscal Consolidation and Transition’’ was signed into law on the 3rd of January 2023; at its core, it focuses on maintaining fiscal viability and ensuring a smooth transition for the incoming administration, come May 29, 2023.

President Muhammadu Buhari in his speech at the joint session of the National Assembly on the 7th of October 2022, noted that beyond ensuring fiscal sustainability, his administration will in the new year focus on improving the country’s business enabling environment, accelerate revenue-based fiscal consolidation efforts and strengthen expenditure and debt management.

The 2023 budget proposal was primarily influenced by the Federal Government’s medium-term fiscal outlook which takes into cognizance current fiscal and economic realities such as the continuing global and domestic challenges sparked by recurring COVID-19 spikes, climate change and the impact of Russia-Ukraine War on global economies.  It is therefore anticipated that Nigerian State will grapple the headwinds of low revenue, high inflation, exchange rate depreciation and insecurity.

Key Elements of The Budget: Expenditure Summary

The expenditure policy of the Federal Government for 2023 is designed to achieve the strategic objectives of the National Development Plan (2021 – 2025), which include macroeconomic stability; human development; food security; improved business environment; energy sufficiency; improving transport infrastructure; and promoting industrialization through Small and Medium Scale Enterprises.

The aggregate expenditure (inclusive of GOEs and project-tied Loans) is projected to be NGN 21.83trillion – which is 20% higher than the total expenditure for 2022 (including supplemental appropriations).

  1. Recurrent (non-debt) spending is estimated at NGN8.33trillion, (including NGN200 Billion to fund the Federal Governments social investment programme). Total Recurrent (non-debt) spending therefore amounts to 38.2 % of total expenditure;
  2. Aggregate Capital Expenditure stands at NGN6.46trillion amounting to 30% of total expenditure which is 10% higher than the total Capital Expenditure spend for 2022;
  3. Total Debt Service spend stands at NGN6.31trillion amounting to 29% of total expenditure. This is 71. % higher than 2022 as it includes total interest payment of NGN1.2 trillion on Ways & Means Advances from the Central Bank.

Key Elements of The Budget: Revenue Summary

Total revenue available to fund the 2023 FGN Budget is estimated at NGN11.1 trillion. In aggregate, about 20% of projected revenue will come from oil-related sources, while circa 80% will come from non-oil sources primarily taxes and Government collections.  The Federal Government has therefore developed a robust strategy to enhance collections and widen the tax revenue pool. This includes:

  1. Improving non-oil revenue receipts, tax administration and sustain the effort to expand the non-oil revenue base;
  2. Strengthening tax systems by improving collection efficiency, enhancing compliance, and reorganizing the business practices of revenue agencies by deploying appropriate technology;
  3. Widening the tax net to include businesses in the informal sector;
  4. Introduction of frameworks for recovering duties, taxes and appropriate fees from custom related transactions conducted over electronic networks;
  5. Enhancing port efficiency, strengthen anti-smuggling measures, review of tariffs and waivers and issue of licenses for the development of modern terminals in existing ports, especially outside Lagos:
  6. Enforcing extant laws limiting cost-to-revenue ratio of GOEs to a maximum of 50 percent;
  7. Deploy Technology and ICT solutions needed to enhance revenue collections and compliance;
  8. Improve the performance of GOEs through the effective implementation of the approved Performance Management Framework.

Key Elements of The Budget: Deficit and Deficit Financing

Overall budget deficit stands at NGN10.78trillion (circa 4.78% of GDP) which is to be finance financed mainly through government borrowings from local and foreign sources including multilateral/bilateral loan draw downs and privatization proceeds. Once more this exceeds the threshold set by the Fiscal Responsibility Act however considering the existential security and economic challenges plaguing the Federal Government is compelled to increase its overall fiscal expenditure.

SUMMARY OF THE FINANCE BILL 2022

The Nigerian Finance Bill 2023 has been passed by both legislative houses but is yet to be assented to by the President. At the presentation of the budget by the Minister of Finance on 4th of January 2023, the Honourable Minister stated that the delay in the passage of the bill was as a result of the ongoing vetting and approval process from key stakeholders. it is anticipated that the bill which has now completed its legislative approval cycle will get executive assent any time now.

The Finance Bill amongst other things amends the: Capital Gains Tax Act (CGTA), Companies Income Tax Act (CITA), Customs, Excise Tariff, Etc. (Consolidation) Act, Personal Income Tax Act (PITA), Petroleum Profits Tax Act (PPTA), Stamp Duties Act (SDA), Value Added Tax Act (VATA), Corrupt Practices and Other Related Offences Act and Public Procurement Act.

The table below details the key changes in law effected via the Bill.

 

Conclusion

As is typical of this administration, the Federal Government kept to its commitment to pass and commence implementation of the Appropriation Act in a timely fashion even though the complementary Finance Bill suffered a delay snag. Generally due to the change of administration anticipated at around mid-year 2023, it is expected that supplementary appropriation laws will be passed to align the Appropriation Act with the Economic and Fiscal Policy of the incoming administration.  Furthermore, gleaning from the posture of the Federal Government and the spirit and letter of the budget it is expected (at least for the first half of the year) that:

  1. More incentives and tax holidays for players in the renewable energy sector will be implemented in line with the Federal Government’s intention to encourage domestic and industrial adoption of renewable energy alternatives.
  2. More repeals and cancellation of tax benefits and incentives;
  3. More effort to promote, incentivize and adopt technology and innovation;
  4. Fiscal instability, slow growth, food crisis, and high interest rates are likely to continue into 2023 as the underlying causes such as Russia-Ukraine war and the Covid-19 crises are yet to abate;
  5. Likely removal of fuel subsidy after the expiration of the extension will potentially increase the cost of living and doing business in Nigeria;
  6. Federal Government will drive revenue generation and tax collection aggressively;
  7. Increased government borrowing may provide short-term relief but lead to negative impacts such as higher interest rates, inflation, and shrinking disposable income in the long term;
  8. Federal Government will pass and effect the enforcement of the Finance Bill.

HOW TO GET STARTED

Do you need to know more about the Appropriation Act? Our Finance team is available to support you.

You may contact our team on: Email: info@dealhqpartners.com Telephone: +234 1 4536427 or +234 9087107575

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Season 2 Episode 1- The Appropriation Act 2023: Key Implication for Nigerian Businesses

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On the first episode of Season 2, Our Tosin Ajose leads Mr. Opeyemi Agbaje, the Founder and CEO of RTC Advisory Services Ltd – a leading strategy and business advisory firm, in a conversation on the recently enacted 2023 Appropriation Act. The conversation bothers on the key elements of the expenditure and revenue summary, Nigeria’s ballooning public debt profile, and the potential impact of the 2022 finance bill on Nigerian businesses.

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Season 1 Episode 11 – Financial Technology – Bridging Africa’s Financial Exclusion Gender Gap through Social Innovation

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On Episode 11, our final episode in Season 1, our Orinari Horsfall is joined by Solape Akinpelu, a Certified Financial Education Instructor and Co-founder of HerVest, Nigerian based fintech company pioneering inclusive finance for African women, in a conversation on gender based financial exclusion in Africa. Specifically, the conversation discusses the effect of highlights the impact of gender based exclusion on Africa’s development and economic prosperity and the role that HerVest and other social innovators in Africa are playing in tackling issues around access to finance for African Women.

 

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OVERVIEW OF THE EXPOSURE GUIDELINES FOR CONTACTLESS PAYMENT IN NIGERIA, 2022

The Covid-19 pandemic and the resultant lockdown triggered significant changes in the payment industry. Specifically, it amplified the need for contactless payment and ushered in a wave of unprecedented innovation and product development in the payment industry globally.Embark on a journey of precision timekeeping with our UK sale of hublot replica watches, equipped with the utmost accuracy from elite Swiss movements.Top Swiss Breitling fake Watches UK Online Store For Everyone:www.breitlingreplica.top

Given the record traction in the Nigerian payment market; the Central Bank of Nigeria (CBN), recognizing the need for a tailored regulatory framework to support the burgeoning sector growth, in January 2021, issued the Framework for Quick Response (QR) Code Payment; and more recently, in October 2022, released the Exposure Draft of the CBN Guidelines for Contactless Payment in Nigeria.

The Guideline defines contactless payment as: “the consummation of financial transaction without physical contact between payer and the acquiring device(s)”. This means that secure payments can be made with tags, debit/credit cards, smart cards, mobile and other devices that use Near-Field Communication (NFC), Radio Frequency or QR Codes.

In a bid to preserve the integrity, safety and stability of the Nigerian financial system and to facilitate the safe and secure use of Contactless payment, the Guideline amongst other things provides for:
i. the roles and responsibilities of various stakeholders within the contactless payment eco- system;
ii. the minimum standard/specification for all contactless payment terminals, applications, and processing systems;
iii. guidelines for the provision of Value-Added Services; and
iv. the power of the CBN to prescribe and enforce sanctions and penalties for breach of the Guideline.

KEY STAKEHOLDERS IN THE CONTACTLESS PAYMENT ECOSYSTEM

The Guideline clearly articulates the role and responsibilities of the various stakeholders in the contactless payment eco-system, prescribing standards and specification for all forms of market technology and systems whilst also prescribing processes and principles that will govern their relationship with each other.

A.  Acquirers
An Acquirer is a CBN-licensed institution that facilitates the acceptance of payments from customers to merchants through contactless payment devices such as Point of Sale Terminals (POS), Mobile Applications, and QR Codes amongst others. An Acquirer will typically be the account bank of a merchant who is utilizing the contactless payment system for fee collection from its customers.
The guideline requires all Acquirers to:
i. ensure that all deployed contactless payment devices deployed are certified by CBN and meet prescribed specifications/standards.
ii. operate an agnostic acceptance policy such that all cards, capable of contactless payment, issued in Nigeria shall be accepted irrespective of the issuer.
iii. conduct customer KYC (Know Your Customer) and train Customers compliance with applicable Regulations.
iv. take measures to prevent the use of their networks and devices in violation of Anti-Money Laundering Laws.
v. execute a Contactless Payment Agreement with all Customers prior to granting access to the Acquirer’s contactless payment platform.

In a bid to protect unwary or naive customers from the perpetuation of fraud, the guideline restricts Acquirers from admitting or profiling agent banking terminals operators to its Platform or facilitating contactless transactions on their behalf.

B. Issuers
Like the Acquirers, only CBN-licensed institutions are permitted to act as Issuers for contactless payments. An Issuer is responsible for issuing contactless payment enabled cards, tags, or mobile applications to consumers (consumers being people who procure cards, tags, tokens or contactless payment enabled mobile apps to facilitate payments to merchants or other service providers. Examples of CBN-licenced institutions in Nigeria that already issue contactless payment enabled cards and devices include the First Bank of Nigeria, United Bank for Africa, and Providus bank. These cards have embedded Radio Frequency Identification (RFID) technology which communicates with card readers to enable payment transfers. Issuers are required to ensure, that all tokens and devices issued by them for payment by Customers meet prescribed standards and specifications. Furthermore, Issuers are required to obtain and properly document Customer’s consent prior to enabling Customer’s device for contactless payment. Specifically, the guideline prohibits unsolicited activation of contactless payment service on any payment enabled device owned by any Customer. Relatedly, prior to activating contactless payment service for any Customer, an Issuer is required to verify and identify such Customers by his/her Bank Verification Number (BVN).

C. Payment System and Card System Administrators
Payment/Card System Administrators are operators of card and payment systems (such as Mastercard, Visa, Remita, and Flutterwave). Whilst Issuers are responsible for issuing cards and other enabled devices to Customers, the Payment/Card System Administrators oversees the administration and use of issued cards for payment. Payment System and Card System Administrators are required to comply with the Guideline generally and act in accordance with prescribed processing specifications whilst ensuring that their systems and schemes are interoperable.

D. Switching Companies
Switching Companies are CBN-licensed institutions that oversee the routing of transaction data, interbank payment clearing and settlement, payment authentication and authorisation and risk management. The Nigeria Interbank Settlement System (NIBSS) is the Central Switch for the Nigerian Financial Market. Other than the NIBSS; Interswitch, eTranzact, and Flutterwave are some of the other licensed Switching Companies. The Guideline mandates Switching Companies to ensure that contactless transactions via approved payment instruments issued in Nigeria are successfully switched and to undertake periodic risk assessment to mitigate against money laundering and financing terrorism within the system.

E. Payment Terminal Services Providers
Payment Terminal Service Providers are CBN-licenced institutions that deploy contactless payment enabled Payment Terminals (Point of Sale Terminals) for use within the financial ecosystem. Payment Terminal Services Providers are by the Guideline, required to assure the quality and functionality of all contactless payment enabled terminals issued by them through optimal maintenance, availability of a 24/7 support infrastructure. It is recommended that response time for repair or replacement should not exceed 48 hours from the time of escalation.

F. Payment Terminal Service Aggregator
A Payment Terminal Service Aggregator (“PTSA”) oversees the interconnectivity of all payment terminals deployed with the Nigerian Payment Ecosystem. The Nigeria Interbank Settlement Scheme is the sole PTSA in Nigeria. It ensures that all terminals used in the e-payment ecosystem and all devices deployed in Nigeria are brand-agnostic and would accept all cards issued by any bank or other licensed card schemes without discrimination. NIBSS ensures the standardization of technical and operational specifications of all devices deployed within the Nigerian financial system. The Guideline requires the PTSA to certify that all Point-of-Sale terminals used for contactless payment meet required standard for the payment industry. It is also required to implement a documented risk management process to identify threats before, during and after all payment transactions.

G. Merchants
These include businesses (large institutions or SMEs), that employ contactless payment devices as a means of receiving payment from customers. Merchants are by the Guideline, required to ensure that devices deployed for contactless payments are of the required specification, they are also required to exercise due diligence in effecting all payment transactions as they remain liable for any fraud resulting from negligence or connivance during a contactless payment transaction.

The Guideline further, requires all merchants who accept contactless payments to display the contactless payment symbol visibly in their location. They are also required to undertake second level authentication for transactions of a value which is higher than the stipulated limit per day via the customer’s Personal Identification Number (PIN) OR token code.

H. Customers
A customer is anyone making payment through a Contactless payment method. The Guideline requires Customers to exercise due diligence during contactless payment transactions whilst leaving them in full control to opt-in or out of any contactless payment service.

BENEFITS AND CHALLENGES
Prior to the release of the Draft Guideline, the only existing regulation in the contactless payment ecosystem was the Framework for Quick Response (QR) Code Payment in Nigeria, January 2021 (“Framework”). The Exposure Guideline is therefore a solid improvement on the hitherto QR Code Framework as it specifically sets out market requirements for the use and operation of all forms of contactless payment technology.

Apart from the wider scope of the Guideline, the general adoption of contactless payment will have an overall far-reaching effect on the economy as it will create a smarter, faster, more efficient and easy-to-use mode of payment which requires less manpower. It will also promote health and safety and reduce potential disease transmission at points of sale.

It is also necessary to mention that the posture of the Guideline is generally User-Centric, as the CBN mandates that use of contactless payment service must be elective whilst holding all participants within the value chain to regulatory service levels.

Without doubt, the benefit of the Guideline is enormous, yet a big impediment remains the introduction of transaction limit for contactless transactions, the Exposure Draft specifically provides for a NGN5000 (five thousand naira) transaction limit for a single transaction and a cumulative daily transaction limit of NGN30,000 (thirty thousand naira) per User. Transactions that fall outside this limit require an additional layer of authentication. Whilst the intention of the limit is noble and driven by the need to protect Users from significant impact should fraud, theft, impersonation, funds misappropriation occur; the threshold seems too low considering commercial realities in present day Nigeria. To guarantee that the contactless payment system remains a viable alternative for users therefore, it is imperative for the CBN to consider an upward review of the prescribed limit.

Finally, the Guideline envisages growth and innovation in the contactless payment ecosystem and therefore provides a protocol for innovative use cases. Where any stakeholder intends to offer novel or value-added service falling within the contactless payment niche, it is required to procure and obtain the prior approval of the CBN.

CONCLUSION

Contactless payment is fast becoming a preferred mode of payment across the Globe. UK Finance magazine reports that contactless payments accounted for over a quarter of all payment transactions in the United Kingdom in 2021. It is therefore expected that the introduction and implementation of the Guideline, shall in days to come foster public trust, deepen the contactless payment eco-system and consequently accelerate the speed of its adoption in Nigeria.

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Season 1 Episode 10 – Anniversary Special: DealHQ Partners 4 years of enabling Businesses in Africa

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On Episode 10, we are joined by our Lead Advisor and founding partner – Tosin Ajose who takes us on a journey down memory lane. She shares insights on the Firms values, foundational goals, the challenges of starting up and building a sustainable legal enterprise, and the Firm’s unique winning culture.

 

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Season 1 Episode 7 – A, B, C of Islamic Finance: Understanding the Islamic Financial Market

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On Episode 7, our Orinari Horsfall is joined by Dr. Basheer Oshodi, the CEO and co-founder of TrustBanc Arthur and a seasoned expert in ethical finance and non-interest banking, in a conversation on Islamic Finance- a constantly evolving global alternative to conventional finance. Specifically, the conversation assesses the trends, benefits and opportunities for Islamic Finance in the Nigerian financial marketplace. It also contemplates what actions can be taken to deepen the market.

 

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