AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
The Charity Commission expects trustees to use the formal, regulated banking system wherever possible, to use only money service businesses registered with HMRC or authorised by the FCA, and to keep an audit trail for every transaction from the UK account to evidence of collection in Nigeria. Cash couriers are not banned but carry significant risks, and unregistered transfer agents are described as an unacceptable risk.
Diaspora charities raise money in pounds and spend it in naira: school fees and books, a borehole, medical outreach, widows' support. Getting the money there is where trustees take most risk, because the Charity Commission holds them responsible for its safe arrival and proper use. Its guidance, "Holding, moving and receiving funds safely in the UK and internationally" (chapter 4, updated 20 August 2026, applying to England and Wales), sets out what it expects.
Use regulated channels
The Commission says all charities need to have access to and use the formal, regulated banking system wherever possible. For transfers, that leaves three routes, in this order of preference:
- A bank transfer from the charity's UK account to a partner's account in Nigeria.
- A money service business (MSB) or payment firm. The guidance says MSBs must be registered with HMRC unless supervised by the FCA, and that using an unregistered MSB is an unacceptable risk for charities. Payment firms should be registered with the FCA. Trustees can check HMRC's register of supervised businesses before using one.
- Informal value transfer such as hawala, only where formal banking is unavailable and urgent needs must be met; the Commission calls these more inherently risky than formal banking.
On currency, the guidance asks trustees to try to get the best possible price for exchange and transfer services, and to record, authorise and review foreign exchange gains and losses. It also notes that exchange rates can change quickly. For how cost is built up on any route (transfer fee, exchange-rate margin against the mid-market rate, speed and payout method), compare the provider's own figures on the day you send.
Cash carried by hand
A trustee flying to Lagos with an envelope of donations is common and risky. The Commission's guidance says couriers are not prohibited but there are significant risks, advises trustees, staff and volunteers against carrying significant cash on their person or in luggage, and expects written agreements on amount, currency, arrival timing and payee before cash is handed over. Cash carried must be declared above the threshold: GOV.UK's cash page sets it at £10,000 or more when travelling between Great Britain and a country outside the UK (the Commission's older text quotes a euro figure). Undeclared cash can be seized.
The audit trail
The guidance says an audit trail must be kept for each transaction in the chain. In practice, for each transfer keep:
- The payment voucher or authorisation, signed in line with the charity's controls.
- The amount, date, payer, payee, fee and the intermediary's name and address.
- Evidence the funds left the UK bank account.
- Evidence of collection or receipt in Nigeria, such as a partner's receipt and bank statement.
- For cash: a breakdown prepared by someone independent of the courier, signed receipts and a self-declaration on return.
The guidance also warns that, under the Finance Act 2010, overseas spending not supported by evidence of reasonable steps to ensure charitable use may be treated as non-charitable expenditure, with tax consequences.
Partners and intermediaries in Nigeria
The Commission says trustees should only use intermediaries, including other charities and NGOs, after considering the risks with due diligence and safeguards in place. Using another charity merely as a conduit is unusual and must be shown to be in the charity's interests, backed by formal agreements. Where practical, wait for confirmation that one transfer arrived before sending the next. Checking a Nigerian partner's registration is covered in how to verify a Nigerian company.
When something goes wrong
A serious incident is, in the Commission's words, an adverse event, actual or alleged, which results in or risks significant loss, damage or harm. Suspected crimes should be reported to the police promptly and a crime reference obtained. Charities with income over £25,000 must declare in their annual return that no reportable serious incidents went unreported.
Worked example: a school-fees project
Example only. A charity sends £6,000 a term for 40 pupils' fees in Enugu. Trustees agree a written grant agreement with the partner school, send by bank transfer from the charity's account after two trustees approve, receive the school's receipt and list of pupils within two weeks, and only then release the next term's payment. The treasurer records the sterling sent, the naira received and the exchange gain or loss each term.
For setting up such a charity, see registering a UK charity for projects in Nigeria. This is information, not legal advice.
Where Pryme fits
A Pryme Business Account holds GBP and NGN with local details, so a charity can choose when to convert; Swap shows the rate first and the fee on its own line before trustees approve, and each step is recorded. Outside Nigeria, Pryme's activities are carried out through regulated partners. See /p/b-swap and /p/bulk-payouts.
Questions people ask
Can a UK charity send money to Nigeria?
Yes. The Charity Commission expects trustees to use regulated channels, carry out due diligence on partners and keep an audit trail through to evidence of receipt.
Can trustees carry donations to Nigeria in cash?
It is not prohibited, but the Commission advises against carrying significant cash. Cash of £10,000 or more must be declared when leaving Great Britain.
Can a charity use a money transfer app?
The guidance says MSBs must be registered with HMRC unless FCA-supervised, and payment firms registered with the FCA. Using an unregistered MSB is described as an unacceptable risk.
What records should we keep for overseas grants?
An audit trail for each transaction: authorisation, amount, date, payer, payee, fee, intermediary and evidence of receipt in Nigeria.
Sources
- Charity Commission: Chapter 4, holding, moving and receiving funds safely in the UK and internationally (updated 20 Aug 2026) · accessed Oct 2026
- GOV.UK: Take cash in and out of Great Britain · accessed Oct 2026
- GOV.UK: Check if a business is registered for money laundering supervision (updated 19 Oct 2026) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.