What The Virtual Assets Coordination Order Means For Digital Assets Operators

Banking and Finance Law, Business Advisory, Business, Entrepreneurs, Business, Small Business, Capital Markets, Corporate & Commercial, Financial Services, Financial Technology (FinTech), Investment LawBy Shola Adekunle August 24, 2026

The coming into force of the Investments and Securities Act 2025, which repealed the Investments and Securities Act 2007, marked significant changes to the regulatory framework applicable to virtual and digital assets in Nigeria. Virtual and digital assets are now recognized as securities, and the businesses involved in activities relating to such assets falls within the regulatory purview of the Securities and Exchange Commission (SEC). The implications of this reclassification for issuers, exchanges and the wider public have been discussed in previous articles. It has, however, become clear that this is only one aspect of the evolving regulatory framework applicable to digital-asset businesses in Nigeria. Three separate regulatory tracks, an executive coordination order, an increase in the capital requirements prescribed by the SEC, and a bill currently before the Senate have, over the past eighteen months, further shaped the regulatory framework applicable to digital asset businesses in Nigeria.

After The Extension: A Data Protection Playbook For Banks & Fintechs

Banking and Finance Law, Business Advisory, Business, Entrepreneurs, Business, Small Business, Corporate & Commercial, Financial Services, Financial Technology (FinTech)By Shola Adekunle August 17, 2026

The extended deadline for the 2025 Compliance Audit Return has passed. For banks and FinTechs, the question is no longer simply whether a return was filed, but whether the data protection programme behind that filing can withstand regulatory scrutiny. Data protection compliance in Nigeria has moved beyond simply having a privacy policy or obtaining consent from customers. The Nigeria Data Protection Act 2023 (NDPA) established the Nigeria Data Protection Commission (NDPC) and created a comprehensive statutory framework for the protection of personal data. The General Application and Implementation Directive 2025 (“GAID” or “Directive”), which took effect on 19 September 2025, turned this Act into the documented, auditable programme that now governs every Data Controller and Processor of Major Importance in the country. For banks and FinTechs, data protection compliance is therefore not simply another legal or IT issue. It is a governance, operational and reputational issue that should be receiving attention across all leadership cadres.

Tinubu Signs Executive Order Coordinating Nigeria’s Virtual Asset Regulation

UpdatesBy Goldsmiths Solicitors July 22, 2026

President Bola Tinubu has signed the Presidential Executive Order on Virtual Assets Coordination, 2026, to establish a coordinated oversight framework for Nigeria’s virtual assets industry. The Order which was made pursuant to section 5 of the Nigerian Constitution, 1999 (as amended) and which takes effect immediately, is a response to a regulatory landscape that had become fragmented across multiple agencies with overlaps and enforcement gaps that exposed Nigerians to fraud, money laundering and unchecked losses from unregulated operators.

Data Localisation: What the New Payments Circular Means for Banks & Fintechs

Business Advisory, Business, Entrepreneurs, Corporate & Commercial, Financial Services, Financial Technology (FinTech), Innovation and Technology, Startups and MSME LawBy Colin Egemonye July 20, 2026

Nigeria’s digital payments sector grew faster than the regulatory architecture that has been built around it. Electronic transaction volumes have increased, mobile money adoption has grown and a few switching, processing and payment solutions providers are at the center of how money moves around the country. The Central Bank of Nigeria concluded that this growth created risks that its rules were not designed to deal with and in June 2026, issued a new circular focusing on data localisation, market concentration & ownership transparency in the payments sector titled “Introduction of Market Structure Requirements, Data Localisation, Ultimate Beneficial Ownership Disclosure, and Systemic Oversight Measures in the Nigeria Payments System” (the “Circular”).

What the Investment & Securities Act 2025 Will Mean for Your Business

Banking and Finance Law, Business Advisory, Business, Entrepreneurs, Capital Markets, Corporate & Commercial, Investment LawBy Colin Egemonye July 15, 2026

The Investment and Securities Act 2025 (ISA 2025), signed into law by President Bola Ahmed Tinubu in March 2025 is the most comprehensive reform of Nigeria’s capital market legislation in nearly two decades. It repealed the Investment and Securities Act 2007 and provides for a new restructured framework to accommodate new asset classes and to significantly expand the enforcement powers of the Securities and Exchange Commission (SEC) so as to align Nigeria’s capital markets with world standards. This article highlights six changes that are important to public companies, issuers, capital market operators including virtual/digital assets businesses in Nigeria.

What the CBN’s Financial Holding Company Rules Mean for Banking Groups Banking and Finance Practice

Banking and Finance Law, Business Advisory, Capital Markets, Corporate & Commercial, Corporate Restructuring and Insolvency, Financial Technology (FinTech)By Colin Egemonye July 6, 2026

On 10 June 2026, the CBN published an Exposure Draft of Revised Guidelines for the Licensing and Regulation of Financial Holding Companies in Nigeria. The Exposure Draft’s public consultation window ends on 9 July 2026. Among the most significant changes to the holding company framework in the draft is the move from three-pillar structures to four-pillar structures. If approved, the proposed framework would be the most significant revamp of the holding company framework since the guidelines were issued for Nigerian banking groups during restructuring away from universal banking into holding companies structures in 2014.

How to Commercialise Your Intellectual Property While Maintaining Control

UpdatesBy Colin Egemonye June 24, 2026

IP licensing is the grant of a right to use the intellectual property, usually for a fee, royalty or other consideration. It is one of the most commercially underutilised tools available to Nigerian businesses. A trademark, established through years of investment, can generate a continuous stream of licensing revenues from franchisees, distributors or commercial partners. Software developed for internal use can be licensed to third parties in related markets. A unique proprietary method or approach distinguishing a professional services firm can be packaged and licensed into other geographies.

The NITDA Digital Economy Policy Review 2026: What Every Nigerian Technology Business Should Know

UpdatesBy Colin Egemonye June 16, 2026

The regulatory environment for Nigeria’s digital economy is on the cusp of its most significant shift in more than ten years. This article outlines the implications of the National Information Technology Development Agency (NITDA) 2026 policy review on businesses and the immediate steps required to achieve compliance. It is updated to incorporate recent legal and regulatory developments as of May 2026. In this article, we have discussed s the five (5) top priority areas within the NITDA 2026 policy review and how organisations should proceed immediately.

Nigerian Open Banking: The Legal Framework All Banks and FinTechs Need to Know

Banking and Finance Law, Business Advisory, Corporate & Commercial, Financial Technology (FinTech), Innovation and Technology, Startups and MSME LawBy Colin Egemonye June 10, 2026

The Central Bank of Nigeria (CBN) framework on open banking has now transitioned from a policy document to a phased implementation. Nigeria has a comprehensive history of open banking; with the Central Bank issuing Africa’s first Open Banking Regulatory framework in February 2021, followed by the Operational Guidelines in March 2023. In April 2025, the CBN provided August 2025 as the launch date for an operation that would have seen Nigeria emerge as the first African country to launch national open banking. However, the initial launch date was deferred as the CBN stressed that a wholly automated system that offers robust data protection and stringent consumer protection mechanisms should first be in place.

Corporate Restructuring in Nigeria: When to Do It, Why It Matters, and How to Do It Right

Business Advisory, Business, Entrepreneurs, Business, Small Business, Corporate & Commercial, Corporate Restructuring and Insolvency, Public-Private Partnerships (PPP), Startups and MSME LawBy Colin Egemonye June 3, 2026

The legal process for restructuring is the most significant for a Nigerian company, and arguably, one that is the most often initiated incorrectly. Those who get restructuring right treat it as a thoughtful, planned process – one with clear commercial objectives and the benefit of legal advice that understands both the relevant legal and regulatory framework, and the desired business outcome. Those who get it wrong approach restructuring reactively: when time-critical, after a term sheet is signed or in the midst of a shareholder dispute that is already causing damage to the relationships the restructuring is intended to resolve. Below are the five typical triggers that can give rise to a restructuring in Nigeria: what options are available and what mistakes are the costliest when dealing with them. Please note that all references to stamp duties and other related fiscal levies apply in accordance with the Nigeria Tax Act (NTA) 2025, effective January 1, 2026.