NIGERIA Law and Practice Contributed by: Omoruyi Edoigiawerie, Adebomi Adekeye and Habeeb Eyinade, EandC Legal
• prohibited schemes – Section 196 specifically out- laws ponzi and pyramid structures, common in the digital asset space; and • statutory enforcement – the Investments and Secu- rities Tribunal (IST) holds exclusive jurisdiction over these infractions, ensuring specialised adjudication outside the general court system. Traditional Securities Versus Digital Assets While the prohibitions are aligned, the surveillance and enforcement mechanisms differ significantly to account for the pseudonymity of blockchain. • The concept of inside information – for traditional securities, inside information is tied to corporate filings. For digital assets, the ISA 2025 expands this to include technical asymmetries, such as knowledge of upcoming protocol forks, exchange listings, or major token burns by founders. • Enhanced digital surveillance – the SEC now has express powers to obtain subscriber and commu- nication data from internet and telecoms providers to trace the origin of market-moving rumours or co-ordinated manipulation. • National Confiscation Wallet – a unique 2026 inno- vation is the SEC’s National Confiscation Wallet. Unlike traditional assets, which are frozen in bank accounts, the SEC can now administratively seize and move forfeited digital assets into a govern- ment-controlled multi-party signature wallet. A major factor in Nigeria’s market abuse regime is the shift towards data-driven enforcement. The SEC is no longer reliant on manual reporting; it is actively integrating blockchain forensics to map transaction patterns. 2.6 Non-Compliance Notable Enforcement Actions and Jurisdictional Rigour Nigeria’s enforcement landscape in 2026 is charac- terised by high-impact intervention. Regulators have shifted from broad warnings to targeted, high-stakes litigation and administrative sanctions. The most significant benchmark remains the State’s multi-billion dollar enforcement action against glob- al exchanges (notably Binance) for tax evasion and
unauthorised FX intermediation. As of early 2026, these cases have transitioned into structured out-of- court settlements, mandating local incorporation, full tax transparency, and the integration of Nigerian regu- latory monitoring nodes into exchange infrastructure. Nigeria’s successful exit from the FATF Grey List on 24 October 2025 was underpinned by aggressive AML/CFT enforcement. This included the EFCC’s 2025 “Operation Serengeti”, which successfully froze hundreds of accounts linked to unlicensed shadow exchanges, signalling a zero-tolerance approach to unhosted and unregulated fiat-to-crypto gateways. The SEC has intensified its Illegal Operator alerts, resulting in the immediate cancellation of registrations for firms and the blacklisting of offshore platforms tar- geting Nigerian residents without local licensing. Cross-Border Breach Management Regulators have moved beyond territorial boundaries by asserting extraterritorial jurisdiction through digital and diplomatic channels. The Nigerian Communications Commission, acting on SEC directives, utilises sophisticated DNS-filtering to block access to the web interfaces of unlicensed off- shore VASPs. The SEC’s 2025 Regulatory Hub now facilitates real- time data sharing with international bodies such as IOSCO. This allows Nigerian regulators to initiate co- operative enforcement, where foreign regulators are requested to freeze assets or serve notices on enti- ties operating from their jurisdictions but targeting the Nigerian market. To operate legally, cross-border firms must now main- tain a local physical presence and a Nigerian-resident Compliance Officer who is personally liable for report- ing failures under the Money Laundering Act 2022. Regulatory Trajectory: The Next 12 Months The consensus is a shift from active enforcement to systemic supervision. With the NTAA 2025 coming into full effect in 2026, the next 12 months will see a wave of enforcement
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