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CBN requires Post-No-Debit and STR treatment for VASP accounts with defective due diligence (CLM-NG-018). SEC requires minimum paid-up capital and a 25% fidelity bond for registered exchanges (CLM-NG-019) -- a claim Challenger flagged as potentially superseded by a Tier-4-only-sourced January 2026 capital circular, escalated to human/regulator review and left intact pending confirmation. SEC's exposure draft would require non-custodial wallet disclosures (CLM-NG-020), and SEC maintains a standing investor-verification advisory (CLM-NG-021).
Outlook
The module's amber rating reflects multiple partial, in-force consumer-protection measures spread across two regulators, without a single consolidated crypto consumer-protection rulebook tying them together. The most consequential open item is the reported January 2026 SEC capital circular, which -- if confirmed -- would raise minimum-capital requirements for exchanges, custodians and offering platforms; this has been held for regulator or primary-source confirmation this cycle rather than folded into the baseline, given its exclusively Tier-4 sourcing. A secondary item to track is whether SEC's exposure-draft non-custodial-wallet disclosure requirement is finalised and brought into force.
Consumer Protection
Investor-protection provisions for Nigerian digital-asset customers are currently proposal-stage only. SEC's August 2026 draft rules would require firms to segregate customer digital assets from firm assets, strengthen custody arrangements, and notify SEC of material incidents within 24 hours of discovery, with a detailed report due within 48 hours. No finalised custody, segregation or incident-notification rule specific to digital assets exists yet in Nigeria outside of this draft; the underlying statutory securities-law framework under the Investments and Securities Act 2025 applies generally, but the digital-asset-specific operational protections remain pending.
Outlook
Whether these segregation, custody and incident-reporting requirements are adopted as drafted, and on what timeline, depends on the finalisation of SEC's broader Proposed Rules on Digital and Virtual Asset Operations, Custody and Markets, expected to reach some resolution around the fourth quarter of 2026.
Sources and findings (13)
- T1Central Bank of Nigeria (CBN) — Where a designated VASP account holder's due-diligence information is found to be incorrect or invalid, the account shall be placed on Post-No-Debit and the customer asked to update records, with a corresponding Suspicious Transaction Report rendered.retrieved M3bindingin forcenew
- T4SEC Nigeria — Registered digital-asset exchanges to be capitalised with a minimum paid-up capital and to post a fidelity bond of at least 25% of that amount, and to operate with fees that are fair, reasonable and transparent.M4bindingin forcenew
- T1SEC Nigeria (draft Rules) — A VASP offering non-custodial wallet interface or access services to clearly disclose that it does not provide custody, that the client is responsible for safeguarding private keys and recovery materials, and the limits of any transaction-reversal or recovery mechanism.retrieved M3non-bindingnew
- T1SEC Nigeria — An ongoing public advisory urging investors to verify the regulatory status of any person promoting investment products or services through the Commission's official channels before engaging with them.retrieved M3bindingin forcenew
- T1 · Securities and Exchange Commission, NigeriaSecurities and Exchange Commission, Nigeria — The SEC's 2022 Digital Assets Rules require a digital-asset exchange and offering platform to display prominently all necessary risk-warning statements, access criteria, fees, complaints-handling and dispute-resolution procedures and cessation-of-business contingency arrangements.retrieved M4bindingin force
- T1 · Securities and Exchange Commission, NigeriaSecurities and Exchange Commission, Nigeria — Under the SEC's 2022 Digital Assets Rules an operator must obtain and retain self-declared risk acknowledgement forms from users before they participate, and must disclose in advance that losses from a digital-asset offering are not covered by any Investor Protection Fund.retrieved M4bindingin force
- T1 · Securities and Exchange Commission, NigeriaSecurities and Exchange Commission, Nigeria — The SEC's 2022 Digital Assets Rules require every whitepaper for an initial digital-asset offering pending assessment to carry a bold-letter statement that the Commission has not approved the tokens or determined whether they are securities, and that false or misleading representation is a criminal offence.retrieved M3bindingin force
- T1 · Federal Republic of Nigeria / Securities and Exchange Commission, NigeriaFederal Republic of Nigeria / Securities and Exchange Commission, Nigeria — Section 196(3) of the Investments and Securities Act 2025 makes promoters and operators of a prohibited scheme — expressly including Ponzi and pyramid schemes operated through the internet — liable to a fine of not less than N20,000,000 or ten years' imprisonment or both, and empowers the SEC to seal and freeze such schemes.retrieved M5bindingin force
- T1 · Securities and Exchange Commission, NigeriaSecurities and Exchange Commission, Nigeria — The SEC invoked section 196 of the Investments and Securities Act 2025 against CBEX (Crypto Bridge Exchange) and its affiliates in an April 2025 enforcement notice, confirming they were never registered as a Digital Assets Exchange and had failed to honour withdrawals.retrieved M4bindingin force
- T1 · Securities and Exchange Commission, NigeriaSecurities and Exchange Commission, Nigeria — In a June 2023 circular the SEC declared the operations of Binance Nigeria Limited illegal because it was neither registered nor regulated by the Commission, and warned that investing in crypto-assets through unregistered providers is extremely risky.retrieved M4bindingin force
- T1 · Securities and Exchange Commission, NigeriaSecurities and Exchange Commission, Nigeria — In a May 2026 public notice the SEC warned against unregistered online investment schemes promoted on WhatsApp, Instagram, Telegram, Facebook and TikTok, stating that under the Investments and Securities Act 2025 only entities it registers may promote investment services or solicit funds from the public.retrieved M3bindingin force
- T1 · Federal Republic of Nigeria / Securities and Exchange Commission, NigeriaFederal Republic of Nigeria / Securities and Exchange Commission, Nigeria — Section 95 of the Investments and Securities Act 2025 prohibits invitations to the public to acquire securities unless the issuer is registered with the SEC, with a penalty of at least 10% of the gross value of securities or deposits received for a body corporate and N2,000,000 for an individual, plus investor rescission rights.retrieved M4bindingin force
- T1 · Securities and Exchange Commission, NigeriaSecurities and Exchange Commission, Nigeria — The SEC's exposure-draft Rules would require a VASP providing a non-custodial wallet interface to disclose that it does not provide custody and that the client bears responsibility for private keys, and would require disclosed settlement finality, reversal procedures and complaint channels; proposed only.retrieved M3non-bindingproposed