TMT 2025

NIGERIA Law and Practice Contributed by: Tiwalola Osazuwa, Peretimi Akinmodun, Lazarus Uwa Kalu and Mubaraq Popoola, ǼLEX

ties, including fintech companies, that wish to offer the following services: (a) automated teller machine operations; (b) point of sale (POS) card acceptance; (c) mobile POS acceptance; and (d) web acceptance services. Compliance with these guidelines is mandatory to ensure the secure and efficient provision of electronic payment services in Nige - ria. Other regulations issued by the CBN include: (i) the CBN Risk-Based Cybersecu - rity Framework and Guidelines for Deposit Money Banks and Payment Service Banks 2024; (ii) the CBN Regulation on Electronic Payments and Collections for Public and Private Sectors in Nigeria 2019; (iii) the CBN Guidelines on International Money Transfer Services 2024; (iv) the CBN Operational Guidelines for Open Banking in Nigeria 2023; (v) the CBN Guidelines on Contactless Payments in Nigeria 2023; and (vi) the CBN Regulatory Framework for Mobile Money Services in Nigeria 2021. • The Investment and Securities Act (the “ISA”). The ISA established the Securities and Exchange Commission (the “SEC”) and it regulates: (a) investment and securities business in Nigeria; (b) securities exchange; (c) capital trade points; (d) futures, options and derivatives exchang - es; (e) commodity exchanges and any other recognised investment exchange; (f) offers of securities by public companies and entities and operators in the capital market; and

(g) capital market operators. The SEC issued the Rules on Issuance, Offering Platforms and Custody of Digital Assets 2022 (the “Digital Assets Rules”) which regulate entities offering cryptocurrencies and other virtual and digital assets in Nigeria. The Digital Assets Rules require all virtual assets service providers (VASPs) and is - suers of digital assets to register with the SEC prior to providing their services in the country. The SEC also issued the Acceler - ated Regulatory Incubation Programme Framework for the Onboarding of VASPs (the “ARIP Framework”) which provides an incubation programme for VASPs seeking to register with the SEC. The SEC has published amendments to the Digital Assets Rules through the Exposure of Amendments to the Digital Assets Rules (the “New Rules”) which will come into effect on 30 June 2025. • The Federal Competition and Consumer Protection Act (the “FCCPA”). The FCCPA prohibits anti-competitive practices in the Nigerian economy and also seeks to pro - tect and promote consumers’ interests. The FCCPA establishes the Federal Competi - tion and Consumer Protection Commission (the “FCCPC”), which is responsible for the enforcement of the FCCPA. To curb preda - tory lending practices in the digital space, the FCCPC issued the Limited Interim Regulatory Framework and Guidelines for Digital Lending 2022 which requires digital lending platforms in Nigeria to register with the FCCPC. • The Nigeria Startup Act 2022 (the “NSA”). The NSA regulates the Nigerian tech-enabled start-up ecosystem, which is a leading con - tributor to the Nigerian digital economy. The NSA was enacted to promote the develop - ment of Nigeria’s digital economy by provid - ing a legal and institutional framework that

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