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CBN restricts VASP-linked designated bank-account transactions to Naira and bars VASPs from NUBAN accounts (CLM-NG-024). No dedicated crypto-specific cross-border reporting-threshold or travel-rule instrument distinct from the general AML/CFT framework was identified; such obligations sit under the Money Laundering (Prevention and Prohibition) Act, 2022 and are owned by Financial Integrity Monitor's subscribed module (CLM-NG-025).
Outlook
The module's amber rating reflects a genuinely binding, in-force settlement-currency restriction on the regulated banking channel, set against the absence of any crypto-specific cross-border reporting or travel-rule instrument outside the general AML/CFT regime. The principal item to track is whether SEC's or CBN's evolving rulemaking -- including the exposure-draft Rules and the newly established Virtual Asset Council -- introduces any crypto-specific cross-border reporting threshold distinct from the existing Naira-only banking-channel restriction and the general AML/CFT framework owned by Financial Integrity Monitor's subscribed module.
Cross-Border Transfer
SEC's August 2026 draft rules assert that no person may carry on digital-asset business in Nigeria, or targeted at persons resident in Nigeria, without SEC registration, an extraterritorial reach that extends the registration requirement to offshore platforms serving Nigerian residents regardless of where the platform is incorporated or operated. This reach is reportedly reinforced through DNS-filtering of non-compliant offshore virtual-asset service provider websites by the Nigerian Communications Commission, giving the extraterritorial registration requirement a practical enforcement mechanism at the network-access level rather than relying solely on formal cross-border enforcement cooperation. No dedicated cross-border capital-control rule specific to crypto transfers, separate from this registration-and-access-control approach, has been located this cycle.
Outlook
The durability of the DNS-filtering enforcement mechanism, and whether it is formalised as a standing NCC practice tied to SEC's registration regime once the draft rules are finalised, is the key development to watch for offshore platforms serving the Nigerian market.
Sources and findings (8)
- T1Central Bank of Nigeria (CBN) — Transactions on a VASP or Digital Asset platform conducted through a designated bank account shall only be in Naira, and financial institutions/NIBSS shall not allow the usage or creation of NUBAN accounts by VASPs.retrieved M4bindingin forcenew
- T1Nigeria (SEC/CBN primary sources) — No dedicated cross-border reporting-threshold or crypto-specific travel-rule instrument distinct from Nigeria's general AML/CFT framework was identified; such obligations sit under the Money Laundering (Prevention and Prohibition) Act, 2022 and are produced by the subscribed FIM aml_ctf module.retrieved M2non-bindingnew
- T1 · Securities and Exchange Commission, NigeriaSecurities and Exchange Commission, Nigeria — Regulation 15 of the SEC's AML/CFT/CPF Regulations 2022 imposes the FATF travel rule on Nigerian VASPs by deeming all virtual-asset transfers to be cross-border transfers requiring full originator and beneficiary information to be obtained, verified and transmitted to the beneficiary institution.retrieved M4bindingin force
- T1 · Securities and Exchange Commission, NigeriaSecurities and Exchange Commission, Nigeria — The SEC travel-rule threshold for VASPs is the equivalent of USD 1,000: below it only originator name, beneficiary name and wallet addresses must accompany the transfer; full originator information includes name, wallet address and physical address or national identity number.retrieved M3bindingin force
- T1 · Nigeria Revenue ServiceNigeria Revenue Service — The Nigeria Revenue Service's Information Circular No. 2026/21 provides that converting Naira into virtual assets for cross-border settlement is not a taxable disposal, while requiring a Nigerian intermediary in a cross-border business-to-business payment to withhold tax in token units before onward transmission.retrieved M3bindingin force
- T1 · National Assembly of the Federal Republic of NigeriaNational Assembly of the Federal Republic of Nigeria — Section 46 of the Nigeria Tax Act 2025 gives Nigeria taxing situs over digital assets held offshore by deeming incorporeal property including digital assets to be situated in Nigeria where the beneficial owner is resident in Nigeria.retrieved M4bindingin force
- T3 · Policy and Legal Advocacy Centre — Laws of Nigeria databasePolicy and Legal Advocacy Centre — Laws of Nigeria database — Foreign-exchange transactions in Nigeria must be conducted in the official market through Authorised Dealers or Authorised Buyers appointed by the Central Bank under the Foreign Exchange (Monitoring and Miscellaneous Provisions) Act, which is the general capital-control framework crypto-linked FX flows sit beneath.retrieved M3bindingin force
- T1 · Securities and Exchange Commission, NigeriaSecurities and Exchange Commission, Nigeria — The SEC's exposure-draft Rules on Digital and Virtual Asset Operations, Custody and Markets (published 20 August 2026) would require regulated entities to segregate and tag domestic versus cross-border flows so that inflows and outflows to and from Nigeria are traceable and attributable to identifiable users; this is not yet in force.retrieved M4non-bindingproposed