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title: "Nigeria Crypto Regulation Monitor | cryptoassets.gi"
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description: "Nigeria crypto asset regulation: 8 categories, 91 sourced findings, updated 2026-11-04. Licensing, token classification, stablecoins, tax treatment."
generated_at: 2026-11-07T14:19:44Z
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# Nigeria Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed in transition overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/nigeria/), [World Payments](https://payments.gi/jurisdictions/nigeria/)

Last updated 2026-11-04 · 8 categories · 91 sourced
findings · 69 sources in the cumulative register

Download report (PDF) Expand all

Evidence re-verified: 2026-11-04 · Position last changed: 2026-11-04 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

[Open in Co-Pilot ↗](/reports/?type=copilot&j=NIGERIA)[Build Report](/reports/?j=NIGERIA)[Compare](/compare/?j=NIGERIA)

Framework posture In transition 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority SEC Nigeria Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) 2026-Q4 SEC Proposed Digital Asset Rules - final status expected

Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed

8 Categories

0 Moved this cycle 0 Key judgments 2 Open gaps 91 Findings

24 Tier-1 sources

Confidence mix 8 unpopulated
(sums to 8 rendered categories; click to filter)

No categories moved this cycle.

## Jurisdiction lead brief

###### Latest update · 4 November 2026

#### Lead Signal

Nigeria's digital asset perimeter continues to crystallise around the Investments and Securities Act 2025, which both gives the Securities and Exchange Commission statutory authority over virtual and digital asset exchanges, custodians and operators and classifies digital assets as securities. The practical edge of that framework this period is a capital-adequacy timeline: a January 2026 Commission circular sets category-specific capital thresholds for virtual asset service providers, ranging from 300 million to 2 billion naira, with compliance due by 30 June 2027. That date gives every licensed or aspiring virtual asset service provider in Nigeria a fixed point to plan around, whether that means raising capital, consolidating with a better-capitalised partner, or exiting the regulated perimeter altogether. A further Commission proposal would layer in still more granular tiers — 2 billion naira for exchanges and custodians, 500 million for offering platforms, 200 million for providers generally — though that proposal has not been adopted and should be read as a strong signal of direction rather than settled law.

#### Other Developments

On the stablecoin and payments side, a Virtual Assets Coordination Executive Order reported from around mid-2026 allocates payment, settlement and custody services involving non-security virtual assets to the Central Bank of Nigeria, coordinating with the Commission through a new Virtual Asset Council. This effectively splits Nigeria's digital asset perimeter along a security/non-security line, with the Commission governing the security side and the Central Bank taking the payment and settlement side — though no dedicated stablecoin issuance or reserve rulebook has yet surfaced from either regulator. On the commercial side, two developments stand out: Yellow Card, a pan-African stablecoin remittance operator with a Nigerian footprint, closed a 40 million US dollar funding round reported in October 2026, and Flutterwave secured a national microfinance banking licence through its acquisition of open-banking startup Mono, reported on 28 October 2026. Both point to continuing investor and operator confidence in Nigeria-linked payment infrastructure even as the formal rulebook is still being written.

#### Cross-Monitor Connections

The Commission's securities classification of digital assets and the Central Bank's emerging role over non-security virtual assets create a split regulatory perimeter that payment businesses operating in Nigeria need to navigate carefully, since the same underlying token can fall under different oversight depending on how it is structured and used. This split has a direct bearing on how global payment and remittance businesses plan their Nigerian stablecoin rails, and on how banking-licensed entities like Flutterwave position acquisitions such as Mono relative to both the securities and payments regulatory tracks. Investors backing stablecoin-rail businesses such as Yellow Card are, in effect, underwriting continued regulatory bifurcation risk between the two regulators until a unified rulebook, if one comes, resolves it.

#### Outlook

The clearest near-term marker to watch is the 30 June 2027 capital-compliance deadline: how virtual asset service providers respond to it — through capital raises, consolidation, or market exit — will be the first real test of how seriously Nigeria's new capital thresholds bite. Equally watch for whether the Commission's proposed further capital tiers are adopted, and whether the Central Bank follows its coordination order with an actual stablecoin issuance and reserve rulebook; until it does, the payments side of Nigeria's digital asset regime remains structurally under-specified even as its institutional allocation is now settled.

4 earlier updates not shown here.

###### Standing brief · as of 2 September 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

In July 2026, Nigeria's presidency signed an Executive Order establishing a Virtual Asset Council chaired by the Central Bank of Nigeria, with the Securities and Exchange Commission and the newly renamed Nigeria Revenue Service sitting as vice-chairs and the Nigerian Financial Intelligence Unit and the Office of the National Security Adviser as members (CLM-NG-d84f1c6a). The Council's stated purpose is to harmonise oversight of Nigeria's virtual-assets ecosystem, an ecosystem that has, since 2022, operated under a dual-track structure in which SEC Nigeria licenses digital-asset issuers, offering platforms, custodians, exchanges and other virtual-asset service providers under its Rules on Issuance, Offering and Custody of Digital Assets (CLM-NG-001), while the Central Bank separately governs the banking-sector interface through its December 2023 Guidelines permitting regulated banks to open designated accounts and provide settlement services for VASPs (CLM-NG-004). The Executive Order does not repeal either instrument; it layers a coordinating body over both tracks. This is a Probable-confidence, fold-inserted finding corroborated by a Tier-1 State House source, and it materially updates a licensing narrative that, until this cycle, described SEC and CBN oversight as running on parallel but uncoordinated rails. The Council's mandate, procedures and relationship to existing SEC registration and CBN banking-access processes remain to be defined in secondary rulemaking, but its creation signals that Abuja now treats the fragmentation between securities regulation and banking-sector access as a governance problem worth a presidential-level fix.

#### Other Developments

Beneath the headline coordination move, Nigeria's underlying licensing and classification architecture remains largely as previously mapped. SEC Nigeria continues to operate its Accelerated Regulatory Incubation Program, under which VASPs may obtain an Approval-in-Principle for limited operation ahead of full rule commencement (CLM-NG-002); as of August 2024, Busha and Quidax were the first exchanges to receive licences under this track, though neither held full registration and both remained subject to close scrutiny (CLM-NG-003). SEC's default classification posture -- that virtual crypto assets are presumed to be securities unless the issuer proves otherwise (CLM-NG-007) -- remains operative, now sitting alongside the Investments and Securities Act, 2025, which re-establishes SEC's statutory basis to regulate securities business including digital-asset activities characterised as securities (CLM-NG-006), though the Act's commencement date is not yet confirmed from a primary source. SEC's still-exposure-draft Rules on Digital and Virtual Assets Operations, Custody and Markets continues to signal direction of travel -- introducing a 'Recognised Foreign-issued Stablecoin' concept assessed against issuer status, reserves, redemption and custody arrangements (CLM-NG-009, CLM-NG-015, CLM-NG-016), extending coverage to tokenisation and hybrid arrangements (CLM-NG-011), and reserving Commission power over AMM and liquidity-pool settlement models (CLM-NG-012) -- but none of this has been confirmed as commenced. Nigeria's on-chain activity perimeter remains largely unaddressed: no primary source was located covering staking (CLM-NG-013), mining, node operation or validator activity (CLM-NG-014) in any dedicated way. On tax, the Nigeria Revenue Service has formally succeeded the Federal Inland Revenue Service as tax authority of record, effective 1 January 2026 under the Nigeria Tax Administration Act 2025 (CLM-NG-b7e2a9f4), while whether a finalised, crypto-specific tax regime now exists remains open -- the only primary-source finding located is a 2024 statement of legislative intent from the former FIRS (CLM-NG-022), against third-party estimates that taxable crypto activity in Nigeria approached $4.4 billion in 2025 (CLM-NG-023). On consumer protection, SEC's 2022-era minimum-capital and fidelity-bond requirements for registered exchanges remain the claim of record (CLM-NG-019), alongside CBN's Post-No-Debit/Suspicious Transaction Report protocol for VASP accounts with defective due-diligence records (CLM-NG-018) and SEC's standing advisory urging investors to verify promoters' regulatory status (CLM-NG-021).

#### Cross-Monitor Connections

Two threads intersect with sibling monitors this cycle. First, CBN's restriction confining VASP-linked designated bank-account transactions to Naira, and its bar on VASPs obtaining NUBAN accounts (CLM-NG-024), sits alongside a confirmed absence of any crypto-specific travel-rule or cross-border reporting-threshold instrument distinct from Nigeria's general Money Laundering (Prevention and Prohibition) Act, 2022 framework (CLM-NG-025) -- both flagged for cross-checking against Financial Integrity Monitor's subscribed AML/CTF module, which owns the substantive travel-rule and reporting-threshold surface for Nigerian VASPs. Nothing here should be read as a crypto-scope regulatory gap; it is confirmation that crypto-specific instruments have not displaced the general AML/CTF regime, which is tracked elsewhere. Second, the reported 2025/2026 tax overhaul and the CBN Naira-only settlement restriction are payments- and tax-adjacent developments flagged for World Payments Monitor's tracking of Nigerian tax treatment and payments-corridor coverage (CLM-NG-022, CLM-NG-023, CLM-NG-b7e2a9f4, CLM-NG-024).

#### Outlook

Several open questions will determine whether Nigeria's regime resolves toward consolidation or continues to fragment. The Virtual Asset Council's operating procedures and its relationship to existing SEC and CBN processes are unconfirmed and merit direct monitoring. Secondary reporting -- not yet corroborated by any Tier-1 to Tier-3 primary source -- suggests a January 2026 SEC circular may have raised minimum capital thresholds for exchanges and custodians, and that a broader 2025/2026 tax overhaul including new NRS guidance on virtual-asset taxation may already supersede the 'no finalised crypto tax law' framing carried this cycle; both have been held pending regulator or primary-source confirmation rather than folded into the baseline. The commencement date of the Investments and Securities Act, 2025 and the finalisation status of SEC's exposure-draft Rules on Digital and Virtual Assets Operations, Custody and Markets remain similarly unresolved. Until these are confirmed, Nigeria's regime is best read as in transition: a securities-first classification default and a banking-access channel are both in force, but the institutional architecture coordinating them, the capital thresholds governing them, and the tax regime taxing them are all mid-revision.

Read full brief · 1478 words

Key regulatory facts for Nigeria Regulatory Dimension Nigeria Standing Position

Jurisdiction Nigeria (NG)

Regulatory Scope Crypto & Digital Asset Regulation (8 modules, 91 sourced findings)

Crypto Licensing Nigeria licenses digital-asset issuance, offering platforms, custody, VASPs and exchanges under SEC's May 2022 Rules (CLM-NG-001), with an incubation track (ARIP) permitting limited operation via...

Token Classification SEC Nigeria presumes virtual crypto assets are securities unless the issuer proves otherwise (CLM-NG-007); CBN separately defines a narrower 'Digital Asset' (debt/equity claim) distinct from the broader 'Virtual...

On-Chain Activity Regime No dedicated in-force rule addresses staking (CLM-NG-013), mining, node operation or validator activity (CLM-NG-014).

Stablecoin Regime No in-force domestic stablecoin issuance/reserve/redemption regime exists in Nigeria.

Primary Instruments Cited SEC Nigeria, Accelerated Regulatory Incubation Program (ARIP), Busha and Quidax, Central Bank of Nigeria (CBN), SEC Nigeria

Last Confirmed / Updated 2026-11-04 (69 sources in cumulative register)

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### Nigeria: C1 Crypto LicensingAmberEnacted in forceModule confidence: Probable▾

Nigeria licenses digital-asset issuance, offering platforms, custody, VASPs and exchanges under SEC's May 2022 Rules (CLM-NG-001), with an incubation track (ARIP) permitting limited operation via Approval-in-Principle pending full commencement (CLM-NG-002); Busha and Quidax became the first ARIP-licensed exchanges as of August 2024, holding provisional rather than full registration (CLM-NG-003). CBN's December 2023 Guidelines separately reopened banking access for VASPs (CLM-NG-004). The Investments and Securities Act, 2025 refreshed SEC's statutory basis (CLM-NG-006), and SEC has circulated a still-unconfirmed exposure draft amending the 2022 Rules (CLM-NG-005). A July 2026 Executive Order established a CBN-chaired Virtual Asset Council to coordinate the previously fragmented SEC/CBN dual-track regime (CLM-NG-d84f1c6a).

Open gap — crypto-int-2 No T1 regulator-hosted primary text (sec.gov.ng, cbn.gov.ng) was directly retrieved this cycle; all claims rest on secondary legal/commercial commentary. no under-indexing note recorded

Horizon · 2027-06-30 (± a quarter) SEC VASP minimum-capital compliance deadline Adopted · Tier 3 source

Horizon · 2027-Q1 (± six months) SEC Proposed Rules on Digital and Virtual Asset Operations finalisation Consultation · Tier 3 source

Horizon · 2027-06-30 (± a quarter) Existing digital-asset entities must meet raised capital floors Adopted, not yet in force · Tier 3 source

Horizon · 2027-Q1 (± six months) SEC proposed digital-asset rules expected adoption Consultation · Tier 1 source

Horizon · 2026-Q4 (± six months) SEC Proposed Digital Asset Rules - final status expected Consultation · Tier 3 source

Horizon · 2027-06-30 (± a quarter) SEC capital-compliance deadline for DAX/DAC (N2bn floor) In force · Tier 3 source

Horizon · date not yet available ( not yet assessed )

Horizon · 2027-06-30 (± a quarter) SEC VASP capital/recapitalisation deadline In force · Tier 3 source

#### Crypto Licensing

Nigeria's licensing perimeter has, since May 2022, rested on SEC Nigeria's five-part Rules on Issuance, Offering and Custody of Digital Assets, which cover digital-asset issuance, Digital Asset Offering Platforms, Digital Asset Custodians, Virtual Asset Service Providers and Digital Asset Exchanges (CLM-NG-001). Because full registration under that framework has proven slow, SEC created the Accelerated Regulatory Incubation Program, under which a VASP or Digital Investment Service Provider -- local or foreign, so long as it serves Nigerian users -- may obtain an Approval-in-Principle permitting limited operation while full commencement of the rules is pending (CLM-NG-002). Busha and Quidax became, as of August 2024, the first firms to receive official SEC licences under this incubation track; notably, neither held full registration, and reporting at the time characterised both as remaining subject to close ongoing scrutiny, with the possibility of shut-down should conditions not be met (CLM-NG-003). Running in parallel to SEC's securities-law track, the Central Bank of Nigeria issued Guidelines in December 2023 permitting banks and other CBN-regulated financial institutions to open designated accounts and provide settlement services for VASPs, reversing an earlier posture of restriction on banking access for crypto firms (CLM-NG-004). The statutory foundation beneath SEC's authority was itself refreshed in 2025: the Investments and Securities Act, 2025 repeals and replaces the 2007 Act, re-establishing SEC's basis to regulate investments and securities business, including digital-asset activity characterised as securities business, though the new Act's commencement date has not yet been confirmed from a primary source (CLM-NG-006). SEC has also signalled that the 2022 Rules are themselves under revision: an exposure-draft 'Rules on Digital and Virtual Assets Operations, Custody and Markets' has been circulated, but its status as a still-unconfirmed, not-yet-commenced draft means it cannot yet be treated as displacing the 2022 rulebook (CLM-NG-005).

The most consequential development for this module is institutional rather than substantive: a July 2026 Presidential Executive Order established a CBN-chaired Virtual Asset Council, with SEC Nigeria and the Nigeria Revenue Service as vice-chairs and the Nigerian Financial Intelligence Unit and the Office of the National Security Adviser as members, tasked with harmonising regulation of Nigeria's virtual-assets ecosystem (CLM-NG-d84f1c6a). This is the first primary-source signal that Abuja intends to coordinate, rather than merely tolerate, the coexistence of SEC's securities-law licensing track and CBN's banking-access track. The Council's creation does not itself alter either underlying instrument, and its operating procedures, decision rights, and interaction with existing SEC registration and CBN account-designation processes are not yet defined in any primary source reviewed this cycle.

#### Outlook

The module's traffic-light status remains amber: core registration obligations are in force and enforced through the ARIP incubation mechanism, but the governing rulebook is mid-amendment, the great majority of licensed entities hold only provisional status, and the new coordination council has not yet been operationalised in public rulemaking. Three confirmations would materially change this picture: whether the Investments and Securities Act, 2025 has commenced and on what date; whether SEC's exposure-draft Rules have been finalised, and if so whether they supersede or supplement the 2022 Rules; and how the Virtual Asset Council's mandate interacts with SEC's and CBN's existing statutory powers. Until these are resolved, market participants face a licensing environment where the applicable rulebook, its date of full effect, and its coordinating institutional structure are all simultaneously in motion.

Read full sub-brief · 548 words Periodic update · new data 2026-10-25

#### Crypto Licensing

Nigeria's virtual-asset licensing regime is administered by the Securities and Exchange Commission (SEC Nigeria) under the Investments and Securities Act (ISA) 2025, the SEC Rules on Digital Assets (2022), and, as of the lead development, SEC Circular No. 26-1 of 2026. The circular raised the minimum paid-up capital requirement for VASP registration and for fintech operators within SEC's remit to NGN500,000,000. Firms that had been operating under the Accelerated Regulatory Incubation Program (ARIP) or under older provisional licences issued before the revised capital rule took effect are required to submit a board-approved capitalisation plan, with a first progress report due 30 April 2026, and to achieve full compliance with the revised capital threshold by a hard-stop deadline of 30 June 2027. This structure gives affected firms a defined multi-stage compliance runway rather than an immediate step-change, but the direction of travel is unambiguous: Nigeria's VASP licensing regime is tightening its capital-adequacy bar considerably relative to the earlier ARIP-era provisional-licensing environment.

Separately, the Central Bank of Nigeria's December 2023 guidelines, which reversed Nigeria's 2021 ban on banks servicing crypto-asset businesses, continue to permit banks to provide accounts to licensed VASPs, while prohibiting banks from holding, trading or transacting in crypto-assets for their own account. This banking-access reversal remains unchanged and continues to function as the operational bridge that allows licensed VASPs to maintain banking relationships in Nigeria, a precondition for practical compliance with the raised capital-adequacy requirements under SEC Circular No. 26-1, since a VASP without banking access would struggle to demonstrate and maintain the required capital base in practice.

The primary instrument behind the raised capital requirement, SEC Circular No. 26-1, was not independently retrieved from the regulator's own site; the capital figures and deadline dates rest on a legal-practice-guide secondary source. This is a gap worth noting for firms relying on this brief for compliance planning: direct verification of the circular's exact text, including any grace-period or phased-compliance provisions not captured in secondary commentary, remains outstanding.

#### Outlook

The 30 June 2027 hard-stop deadline for full capital compliance is the primary marker for this module going forward. Firms currently operating under ARIP or provisional licences face the most immediate planning pressure, having already passed or being close to the 30 April 2026 progress-report milestone. Whether SEC extends, clarifies, or enforces against non-compliant firms as the 2027 deadline approaches will be the next material development to track.

3 earlier distinct update(s) Periodic update · new data 2026-10-18

#### Crypto Licensing

Nigeria's crypto licensing regime rests on the Investments and Securities Act 2025, which since 25 March 2025 has given the Securities and Exchange Commission exclusive statutory authority under section 3(3)(b)-(i) to register and regulate virtual and digital asset exchanges, virtual asset service providers, custodians and digital-asset operators as capital-market activity. That statutory authority is currently administered through SEC's 2022 Digital Asset Rules and a January 2026 capital circular, but both are mid-revision: on 20 August 2026 SEC published Proposed Rules on Digital and Virtual Asset Operations, Custody and Markets for public comment, intended to replace the 2022 Rules outright. The draft rules would quadruple existing capital floors, introducing a tiered structure of N500 million for DAPO and RATOP categories and N200 million for other digital-asset providers, layered on top of the N2 billion minimum capital requirement the January 2026 circular already imposes on Digital Asset Exchanges and Custodians, with full compliance against that N2 billion floor due by 30 June 2027. The reported comment period on the August 2026 draft closed within roughly two weeks of exposure, around 3 September 2026, and the rules' finalised status has not been confirmed this cycle. For an operator assessing Nigeria, the licensing picture is therefore best read as a statutory foundation that is settled and in force, sitting beneath an operational rulebook that is actively tightening and whose final shape remains open.

#### Outlook

The SEC Proposed Rules are expected to reach some form of final status around the fourth quarter of 2026, and that finalisation is the single clearest near-term event that would change the entry calculus for a prospective Nigerian digital-asset licensee, particularly given the reported move toward Nigerian incorporation and resident-CEO requirements. Independent of that process, the 30 June 2027 deadline for Digital Asset Exchanges and Custodians to meet the N2 billion capital floor is already running and unaffected by the draft rules' outcome.

Periodic update · new data 2026-10-11

#### Crypto Licensing

Nigeria's crypto licensing regime rests on a layered set of instruments that are still being reconciled into a single coherent framework. The foundational instrument is the Investments and Securities Act 2025, assented to by President Bola Tinubu on 25 March 2025, which under section 357 classifies virtual and digital assets, including cryptocurrencies and tokenised investment contracts, within the statutory definition of securities. This classification brings virtual asset service providers, digital asset exchanges and digital asset offering platforms within the Securities and Exchange Commission's registration and regulatory purview, and represents the single most consequential structural fact in Nigeria's crypto-licensing architecture: it resolved, at the level of statute, a question that had previously been addressed only through SEC rulemaking of uncertain statutory footing.

Building on that statutory base, the SEC's Amended Digital Assets Rules, which became effective 30 June 2025, introduced several important changes to the regulation of digital assets in Nigeria, addressing what their own framing describes as inadequacies in the prior regulatory approach. These rules represent the operative licensing framework under which Nigeria's digital asset exchanges and custodians currently function, pending the outcome of the next layer of rulemaking.

That next layer arrived on 20 August 2026, when the SEC published proposed Rules on Digital and Virtual Asset Operations, Custody and Markets for public comment. As drafted, these would raise the minimum capital for digital asset exchanges and custodians to NGN2 billion, for platform operators to NGN500 million, introduce a NGN30 million registration fee, and require Nigerian incorporation together with a Nigeria-resident chief executive or managing director. If adopted, these thresholds would represent a material tightening relative to the 2025 Amended Rules, materially raising the bar to market entry and potentially consolidating activity among better-capitalised incumbents. No public-comment closing date or adoption timeline was located in material reviewed this cycle, so the proposed rules should be treated as a draft rather than a binding requirement at this stage.

Overlaying both the statutory classification and the SEC rulemaking track is the Presidential Executive Order on Virtual Assets Coordination, which established a Virtual Asset Council chaired by the Central Bank of Nigeria, with the SEC and the Nigeria Revenue Service as vice-chairs. The Order is framed as responding to a regulatory environment that had become fragmented as virtual assets increasingly blurred the traditional boundaries between CBN's monetary and payments mandate and the SEC's securities mandate. The Council's practical function, as of this cycle, is coordination rather than displacement of either regulator's existing authority, and its effect on the pace or outcome of the SEC's August 2026 proposed rules has not yet been demonstrated in available material. Separately, the SEC's Agent Registration and Investor Protection programme had admitted a cumulative total of at least 27 operating cryptocurrency companies and startups in Nigeria as of 2025, by one secondary estimate, indicating a licensing track that is already populated and active even as the rules governing it continue to evolve.

#### Outlook

The principal open question for this module is the fate of the SEC's August 2026 proposed rules: whether they are adopted as drafted, materially softened following consultation, or allowed to lapse pending further Virtual Asset Council coordination. Until a public-comment closing date is confirmed, the NGN2 billion and NGN500 million capital thresholds should be treated as proposed rather than binding. The practical operation of the Virtual Asset Council, and whether it in fact expedites or further complicates the relationship between SEC licensing authority and CBN payments oversight, is the second open item carrying forward into the next cycle.

Periodic update · new data 2026-09-28

#### Crypto Licensing

Nigeria's crypto licensing framework rests on the Securities and Exchange Commission's 2022 Rules on Issuance, Offering Platforms and Custody of Digital Assets, which require digital asset offering platforms, digital asset exchanges, digital asset custodians and virtual asset service providers to register with and obtain SEC licensing. This foundational instrument was reinforced by the Investments and Securities Act 2025, effective 25 March 2025, which expressly extended the SEC's statutory investments-and-securities-business perimeter to cover digital and virtual asset issuance, offering, tokenisation, lifecycle management and hybrid digital-asset arrangements, giving the licensing regime a firmer statutory foundation than the 2022 Rules alone provided.

A further significant structural fact underpinning market access is the Central Bank of Nigeria's December 2023 Guidelines on Operations of Bank Accounts for Virtual Assets Service Providers, which reversed the CBN's 2021 ban and now permits banks to open and operate accounts for licensed VASPs. This reversal removed a major practical barrier that had previously constrained licensed crypto businesses' ability to access core banking services.

The licensing regime tightened materially in 2026 on two fronts. First, the SEC's revised minimum-capital guidelines, dated 16 January 2026, raise capital floors to approximately ₦1 billion for digital asset offering platforms and ₦2 billion for digital asset exchanges and digital asset custodians, with a compliance deadline of 30 June 2027, a substantial increase from prior thresholds that will particularly affect smaller VASPs. Second, the Presidential Executive Order on Virtual Assets Coordination, signed 17 July 2026, establishes a Virtual Asset Council to coordinate the SEC's, the CBN's and other authorities' overlapping virtual-asset mandates, while explicitly preserving each authority's existing statutory powers rather than consolidating them into a single regulator.

Taken together, an operative and actively-enforced licensing regime exists, but it remains mid-transition: overlapping SEC/CBN/Executive-Order coordination has not yet fully settled, and the revised capital floors are not yet due for compliance.

#### Outlook

The 30 June 2027 compliance deadline for the revised minimum-capital guidelines is the clearest near-term date to track, as is whether the Virtual Asset Council produces concrete coordination outcomes or remains a preservation-of-existing-powers arrangement. The SEC's broader August 2026 proposed rules, which would extend the classification and licensing perimeter to a consolidated framework covering foreign persons serving Nigerian residents, are expected to reach a decision point around the first quarter of 2027 and would represent a further material expansion of the licensing perimeter if adopted.

Sources and findings (11)
- T1[SEC Nigeria](https://home.sec.gov.ng/our-mandate/regulation/rules-and-regulations/) — A five-part registration framework (Rules on Issuance, Offering and Custody of Digital Assets, 11 May 2022) covering digital-asset issuance, Digital Asset Offering Platforms (DAOPs), Digital Asset Custodians (DACs), Virtual Asset Service Providers (VASPs) and Digital Asset Exchanges (DAX).
- T1[Accelerated Regulatory Incubation Program (ARIP)](https://sec.gov.ng/about/resources/checklists/accelerated-regulatory-incubation-program-arip-checklist-for-vasp-onboarding/) — A VASP or Digital Investment Service Provider to obtain an Approval-in-Principle (AIP) for limited operation pending full rule commencement, applicable to local or foreign providers serving Nigeria.
- T4[Busha and Quidax](https://www.coindesk.com/opinion/2024/09/04/nigerias-crypto-thaw-not-what-it-seems) — First official SEC licences under ARIP as of August 2024; neither firm held full registration and both remained subject to close scrutiny with possibility of shut-down.
- T1[Central Bank of Nigeria (CBN)](https://www.cbn.gov.ng/out/2024/fprd/guidelines%20on%20operations%20of%20bank%20accounts%20for%20virtual%20asset%20providers.pdf) — Banks and CBN-regulated financial institutions to open designated accounts and provide settlement services for VASPs (Dec 2023 Guidelines), reversing prior restrictions.
- T1[SEC Nigeria](https://sec.gov.ng/category/circular/) — Existing Rules on Digital Assets Issuance, Offering Platforms, Exchange and Custody via a still exposure-draft 'Rules on Digital and Virtual Assets Operations, Custody and Markets', not confirmed as commenced.
- T1 · Chambers Practice Guides[Investments and Securities Act, 2025](https://sec.gov.ng/documents/1326/INVESTMENT-AND-SECURITIES-ACT-NIGERIA-2025_1.pdf) — Investments and Securities Act No. 29 of 2007, re-establishing SEC Nigeria's statutory basis to regulate investments and securities business including digital-asset activities characterised as securities.
- T1[Presidential Executive Order on Virtual Assets Coordination, 2026](https://statehouse.gov.ng/president-tinubu-signs-executive-order-on-virtual-assets-establishes-council-to-harmonise-regulation-of-digital-economy/) — A CBN-chaired Virtual Asset Council, with the Nigeria Revenue Service (NRS) and SEC Nigeria as vice-chairs and the NFIU and ONSA as members, to harmonise regulation of Nigeria's virtual-assets ecosystem, effective immediately from 17 July 2026.
- T3[Securities and Exchange Commission (SEC Nigeria)](https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/nigeria/trends-and-developments) — 2025-03-25
- T3[Yellow Card](https://theconversation.com/nigerias-new-digital-economy-rules-leave-gaps-in-crypto-regulation-financial-law-expert-explains-288413) — Yellow Card — 40000000
- T3[SEC Nigeria capital circular (January 2026)](https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/nigeria/trends-and-developments) — 2027-06-30
- T3[Flutterwave / Mono](https://www.themeridian50.com/2026/09/27/sec-proposed-rules-digital-virtual-asset-operations/) — Flutterwave / Mono — Flutterwave secured a national microfinance banking licence through its acquisition of open-banking startup Mono: true

### Nigeria: C2 Token ClassificationAmberEnacted in forceModule confidence: Probable▾

SEC Nigeria presumes virtual crypto assets are securities unless the issuer proves otherwise (CLM-NG-007); CBN separately defines a narrower 'Digital Asset' (debt/equity claim) distinct from the broader 'Virtual Asset' category (CLM-NG-008). Utility tokens and NFTs lack a settled classification distinct from the general presumption (CLM-NG-010), and a draft foreign-issued-stablecoin classification concept remains unconfirmed as commenced (CLM-NG-009).

Horizon · 2027-Q1 (± six months) SEC proposed rules on digital/virtual asset operations, custody and markets Consultation · Tier 1 source

Periodic update · new data 2026-10-18

#### Token Classification

Since 25 March 2025, section 357 of the Investments and Securities Act 2025 has brought virtual and digital assets within the statutory definition of securities, establishing a default securities classification for digital assets in Nigeria rather than a bespoke or sui generis token taxonomy. This default classification is a standing statutory fact and has not changed this cycle, but the practical architecture built on top of it is shifting: SEC's August 2026 draft rules introduce functional categories, Digital Asset Exchange and Custodian, DAPO and RATOP, that begin to differentiate treatment within the broader securities frame rather than displacing it. At the same time, the June 2026 Executive Order on Virtual Assets Coordination has created an institutional split between SEC's securities-like perimeter and a newly CBN-domiciled Virtual Asset Office responsible for payment, settlement and custody aspects of stablecoins, meaning that token classification in Nigeria increasingly turns on which functional category a digital asset or activity falls into, not solely on whether it meets the general securities definition under section 357.

#### Outlook

The DAPO and RATOP functional categories proposed in the August 2026 draft rules remain unconfirmed in final form, and the full delineation between SEC's securities-based classification and the Virtual Asset Council's coordination role over stablecoin-adjacent assets is still being worked out between the two bodies, pending finalisation of both the draft rules and clearer guidance from the Virtual Asset Office.

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 17 traced claims · Re-verified 2026-11-04

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### Nigeria: C3 On-Chain Activity RegimeRedEnacted in forceModule confidence: Probable▾

No dedicated in-force rule addresses staking (CLM-NG-013), mining, node operation or validator activity (CLM-NG-014). SEC's exposure-draft Rules extend prospective coverage to tokenisation and hybrid arrangements (CLM-NG-011) and would empower the Commission over AMM/liquidity-pool settlement models (CLM-NG-012), but neither is confirmed as commenced.

C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 12 traced claims · Re-verified 2026-11-04

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### Nigeria: C4 Stablecoin RegimeRedEnacted in forceModule confidence: Probable▾

No in-force domestic stablecoin issuance/reserve/redemption regime exists in Nigeria. SEC's exposure draft introduces a 'Recognised Foreign-issued Stablecoin' concept (CLM-NG-015) including an anticipated redemption-framework element (CLM-NG-016), and CBN's regulatory attention has focused on VASP banking access rather than reserve-backed Naira stablecoin issuance (CLM-NG-017).

Periodic update · new data 2026-10-18

#### Stablecoin Regime

Nigeria's stablecoin oversight architecture changed materially this cycle with the Executive Order on Virtual Assets Coordination 2026, which created a Central Bank of Nigeria-chaired Virtual Asset Council, with SEC and the Nigeria Revenue Service sitting as vice-chairs, together with a CBN-domiciled Virtual Asset Office. This structure splits oversight of payment, settlement and custody aspects of stablecoins toward the central bank, while leaving securities-like digital-asset activity within SEC's existing capital-markets remit. The Order is reported to have taken immediate effect following a Presidency announcement, though its exact gazette date has not been independently confirmed this cycle. Layered on top of this coordination structure, SEC's August 2026 draft rules propose substantive reserve requirements for stablecoins themselves: a minimum 120 percent liquid-reserve requirement for foreign-currency-backed stablecoins, and 150 percent for crypto-backed tokens, figures that, if finalised, would place Nigeria's reserve-backing standard well above the simple one-to-one benchmark common in other regimes. Both the institutional split and the reserve-ratio proposal remain in a transitional state: the coordination body is reportedly operating, but the substantive prudential rules that would give its mandate teeth are still in draft.

#### Outlook

The principal uncertainty is whether the proposed 120 percent and 150 percent reserve ratios survive finalisation of the SEC rules, and whether the Virtual Asset Office issues its own implementing guidance to operationalise the Executive Order's institutional split. Confirmation of the Order's precise gazette date would also clarify exactly when the Council's authority became legally effective.

Periodic update · new data 2026-09-28

#### Stablecoin Regime

Nigeria's stablecoin-specific regulatory framework is actively being built but has not yet been finalised. The Securities and Exchange Commission published a draft framework on 20 August 2026 that would bar stablecoins pegged to foreign currencies from being listed on exchanges or held by consumers without SEC approval of that specific stablecoin. This draft rule, if adopted, would establish a case-by-case approval gate for foreign-currency-pegged stablecoins rather than either a blanket permission or a blanket prohibition, and it remains at the draft stage with its finalisation timeline unconfirmed.

Alongside the draft restrictive framework, the Central Bank of Nigeria opened Cohort 2 of its Regulatory Sandbox Programme in 2026, providing a dedicated live-testing route for fiat-backed stablecoin payments, issuance models, wallets, custody, on-ramps, off-ramps and payment-token exchanges. Participation in this sandbox does not confer permanent operating authority; it is an interim, supervised pathway allowing the CBN to observe stablecoin-payment models in a controlled environment before any permanent licensing framework is settled.

Read together, the SEC's draft restrictive approach to foreign-currency-pegged stablecoins and the CBN's supervised sandbox route for fiat-backed stablecoin models suggest a regulatory posture that is cautious toward stablecoins denominated in or referencing foreign currency, while remaining open to controlled experimentation with domestically-oriented, fiat-backed stablecoin payment models. This is consistent with the broader crypto-regime pattern in Nigeria this cycle: active tightening and consolidation rather than either liberalisation or prohibition.

#### Outlook

Whether the SEC's 20 August 2026 draft stablecoin framework is finalised, and in what form, is the central open question for this module. The progress and eventual graduates of the CBN's Sandbox Cohort 2 stablecoin-payments track will be a useful practical indicator of how Nigeria's regulators intend to treat fiat-backed stablecoin models once the sandbox period concludes.

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 15 traced claims · Re-verified 2026-11-04

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### Nigeria: C5 Consumer ProtectionAmberEnacted in forceModule confidence: Probable▾

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).

#### Consumer Protection

Nigeria's consumer-protection measures for crypto users are distributed across SEC and CBN instruments rather than consolidated in a single rulebook. On the banking side, CBN's December 2023 Guidelines require that where a designated VASP account holder's due-diligence information is found to be incorrect or invalid, the account must be placed on Post-No-Debit status, the customer asked to update records, and a corresponding Suspicious Transaction Report rendered (CLM-NG-018). On the securities side, SEC requires 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 charge fees that are fair, reasonable and transparent (CLM-NG-019); this claim, sourced to 2022-era reporting, has been flagged by Challenger review as potentially superseded by a reported January 2026 SEC capital circular, but that reported update rests only on Tier-4 secondary sourcing and has not been confirmed against SEC's own primary circular text, so the 2022-era figures remain the claim of record pending confirmation. SEC also maintains 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 -- an undated, evergreen advisory rather than a dated rule (CLM-NG-021). Separately, SEC's exposure-draft Rules would require 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 (CLM-NG-020); this disclosure obligation remains draft and non-normative pending the Rules' finalisation.

#### 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.

Read full sub-brief · 357 words Periodic update · new data 2026-10-18

#### 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 (14)
- T1[Central Bank of Nigeria (CBN)](https://www.cbn.gov.ng/out/2024/fprd/guidelines%20on%20operations%20of%20bank%20accounts%20for%20virtual%20asset%20providers.pdf) — 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.
- T4[SEC Nigeria](https://www.coindesk.com/policy/2022/05/16/nigerias-sec-affirms-all-digital-assets-are-securities-in-new-rulebook) — 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.
- T1 · Ogunyemi Solicitors[SEC Nigeria (draft Rules)](https://sec.gov.ng/documents/1503/Proposed_Rules_on_Digital_and_Virtual_Asset_Operations_Custody_and_Markets.pdf) — 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.
- T1[SEC Nigeria](https://sec.gov.ng/for-investors/keep-track-of-circulars/sec-clears-further-2-additional-vasps-for-admission-into-the-accelerated-regulatory-incubation-programme-arip/) — 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.
- T1[Securities and Exchange Commission, Nigeria](https://sec.gov.ng/documents/8/Rules-on-Issuance-Offering-and-Custody-of-Digital-Assets.pdf) — 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.
- T1[Securities and Exchange Commission, Nigeria](https://sec.gov.ng/documents/8/Rules-on-Issuance-Offering-and-Custody-of-Digital-Assets.pdf) — 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.
- T1[Securities and Exchange Commission, Nigeria](https://sec.gov.ng/documents/8/Rules-on-Issuance-Offering-and-Custody-of-Digital-Assets.pdf) — 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.
- T1[Federal Republic of Nigeria / Securities and Exchange Commission, Nigeria](https://sec.gov.ng/documents/1319/Investments_and_Securities_Act_2025_x9rSXtI.pdf) — 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.
- T1[Securities and Exchange Commission, Nigeria](https://sec.gov.ng/enforcements/keep-track-of-enforcement-updates/cbexcrypto-bridge-exchange-super-technology-st-technologies-international-ltd/) — 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.
- T1[Securities and Exchange Commission, Nigeria](https://sec.gov.ng/for-investors/keep-track-of-circulars/circular-on-the-activities-of-binance-nigeria-limited/) — 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.
- T1[Securities and Exchange Commission, Nigeria](https://sec.gov.ng/for-investors/keep-track-of-circulars/public-notice-unregistered-online-investment-schemes/) — 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.
- T1[Federal Republic of Nigeria / Securities and Exchange Commission, Nigeria](https://sec.gov.ng/documents/1319/Investments_and_Securities_Act_2025_x9rSXtI.pdf) — 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.
- T1[Securities and Exchange Commission, Nigeria](https://sec.gov.ng/documents/1503/Proposed_Rules_on_Digital_and_Virtual_Asset_Operations_Custody_and_Markets.pdf) — 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.
- T3[SEC Nigeria finfluencer promotion rule](https://www.legit.ng/business-economy/technology/1726800-sec-proposes-n30m-crypto-registration-fee-n2bn-capital-requirement-exchanges/) — SEC Nigeria finfluencer promotion rule — promoters including finfluencers must verify VASP and product SEC licensing before promotion: true

### Nigeria: C6 Tax TreatmentRedEnacted in forceModule confidence: Probable▾

The Nigeria Revenue Service formally succeeded FIRS as tax authority effective 1 January 2026 (CLM-NG-b7e2a9f4). No primary source confirms a finalised crypto-specific capital-gains, income, VAT or withholding regime (CLM-NG-023); the sole primary-source signal remains a 2024 statement of legislative intent by the former FIRS (CLM-NG-022). Challenger-cited T4 reporting of a broader 2025/2026 tax overhaul is held pending primary-source confirmation.

Periodic update · new data 2026-10-11

#### Tax Treatment

Nigeria's tax treatment of virtual assets acquired a dedicated instrument this cycle with the Nigeria Revenue Service's publication of Information Circular 2026/21, Guidelines on the Taxation of Virtual Assets, on 31 July 2026. This circular is now the operative guidance governing how virtual-asset transactions are to be treated for tax purposes in Nigeria, and its publication represents a material step beyond reliance on general tax principles applied by analogy to crypto transactions, which had previously been the closest available guidance.

The specific substantive content of the circular — in particular the applicable capital-gains and value-added-tax rates, the thresholds at which reporting or payment obligations are triggered, and any exemptions for de minimis transactions — was not independently retrieved in material available this cycle. This is recorded as an open gap rather than inferred: the existence and title of the circular is well evidenced, but its pinpoint tax-rate provisions are not yet confirmed to primary-source level. Readers should treat the circular as the now-operative framework while awaiting confirmation of its specific rate and threshold provisions.

The timing of the circular's publication, 31 July 2026, places it shortly after the Presidential Executive Order on Virtual Assets Coordination of 17 July 2026, which directed work toward a virtual-asset tax policy as one of its stated objectives, with the Nigeria Revenue Service sitting as a vice-chair of the resulting coordination council. This sequencing is consistent with, though not independently confirmed to be, a direct output of the Order's coordination mandate; the circular may equally represent tax-authority work already in train prior to the Order. Both readings are consistent with the broader picture of a Nigerian digital-asset tax and regulatory framework that is actively being built out across multiple instruments and institutions concurrently, rather than through a single comprehensive enactment.

#### Outlook

The principal outstanding item for this module is confirmation of Information Circular 2026/21's specific rate and threshold provisions, which were not located in material reviewed this cycle. Until those are confirmed, market participants and advisers operating in Nigeria's virtual-asset sector should treat the circular's existence and its applicability as confirmed, but its precise computational mechanics as unconfirmed pending further primary-source retrieval in a future cycle.

Periodic update · new data 2026-09-28

#### Tax Treatment

Nigeria's crypto tax treatment gained a dedicated administrative framework this cycle. Guidelines on the Taxation of Virtual Assets, reported in August 2026, establish provisions covering taxpayers, virtual asset service providers and peer-to-peer operators, addressing registration, reporting, record-keeping and valuation. This represents a materially different posture from a purely general-provisions approach: rather than relying solely on existing capital-gains rules applied by analogy to crypto transactions, Nigeria now has guidelines specifically addressing how virtual-asset market participants, including intermediary VASPs and peer-to-peer operators, are expected to register and report for tax purposes.

The precise scope, thresholds and rates within these guidelines were not independently verified against primary Nigeria Revenue Service text this cycle, and this gap should be treated as a genuine limitation on confidence rather than resolved by inference. What can be said with reasonable confidence is that the guidelines mark an administrative-framework emergence: a dedicated instrument now exists, covering multiple categories of market participant, where previously general tax provisions applied without crypto-specific guidance.

#### Outlook

Independent verification of the Guidelines on the Taxation of Virtual Assets against primary Nigeria Revenue Service text remains the priority gap to close in a future cycle, particularly regarding the specific thresholds and valuation methodology applied to virtual-asset transactions. How actively the NRS enforces the new registration and reporting requirements among VASPs and peer-to-peer operators will be a useful indicator of the framework's practical bite.

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 13 traced claims · Re-verified 2026-11-04

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### Nigeria: C7 Cross-Border TransferAmberEnacted in forceModule confidence: Probable▾

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).

Periodic update · new data 2026-10-25

#### Cross-Border Transfer

Nigeria's regulatory treatment of cross-border virtual-asset activity has tightened around a sovereignty-oriented perimeter requirement. According to secondary commentary, an offshore virtual-asset service provider seeking to serve Nigerian users must now either establish a fully capitalised local subsidiary in Nigeria or enter into a White Label agreement with a local exchange that is itself capitalised at NGN2,000,000,000. Critically, no licence-sharing or umbrella arrangement spanning multiple jurisdictions is recognised under this framework: an offshore platform cannot rely on a licence held in another jurisdiction, nor on an informal partnership structure, to serve Nigerian users compliantly. Commentary describes this shift as ending the era of borderless crypto-trading access to the Nigerian market, reflecting a broader move by Nigerian authorities toward requiring a capitalised, accountable domestic presence, whether direct or via formal White Label partnership, as the price of market access.

This cross-border requirement should be read alongside the capital-adequacy tightening under SEC Circular No. 26-1 covered under the licensing module: both developments push in the same direction, raising the bar for any entity, domestic or foreign, seeking to serve the Nigerian virtual-asset market, and both originate from the same underlying SEC policy direction toward a more capitalised, locally accountable digital-asset sector. The specific SEC rule or circular establishing the local-establishment and White Label route has not been independently located on the regulator's own site; the finding rests on a legal-practice-guide secondary source, and the precise regulatory instrument, its date, and its exact text remain to be confirmed against a primary SEC publication.

#### Outlook

The principal open question is whether SEC publishes its own primary text establishing the local-subsidiary/White Label requirement, which would allow independent confirmation of the NGN2,000,000,000 local-exchange capitalisation figure and the scope of the no-licence-sharing rule. Offshore platforms currently serving Nigerian users without a local subsidiary or White Label partner face the most immediate exposure under this tightening perimeter.

Periodic update · new data 2026-10-18

#### 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.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 9 traced claims · Re-verified 2026-11-04

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### Nigeria: C8 AML/CFT RegimeGreenEnacted in forceModule confidence: Probable▾

This module is intentionally out-of-scope for the crypto baseline this cycle; substantive AML/CFT and travel-rule claims for Nigerian VASPs are consolidated into Financial Integrity Monitor's subscribed aml_ctf module per the fleet subscription model, and no claims are carried in the crypto register for this module.

C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-04

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