TMT 2025

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

Additionally, in December 2024, the Nigerian Financial Intelligence Unit (the “NFIU”) released the Guidelines for the Identification, Verifica - tion and Reporting of Suspicious Transactions, applicable to all financial institutions, to bolster the detection and reporting of suspicious trans - actions and ensure compliance with the provi - sions of the Money Laundering (Prevention and Prohibition) Act 2022 and the Terrorism (Preven - tion and Prohibition) Act 2022. This increase in compliance pressures across the board aligns with Nigeria’s push to get off the Financial Action Task Force (FATF) grey list, by reducing fraud and improving anti-money laundering practices. Beyond the improved monitoring and enforce - ment efforts by the regulator, fintech entities are also taking decisive steps to combat the menace of money laundering and fraud through investing in advanced technology, consumer awareness and education and collaboration among industry players. For example, in 2023, Nigerian fintech companies launched Project Radar to share data on individuals and groups that had attempted or made fraudulent transactions. These enhanced efforts by fintech entities, com - bined with stronger regulatory enforcement, are gradually fostering a safer environment thereby restoring trust and confidence in the industry positioning it for sustainable development and advancing the greater goal of financial inclusion. Digital Economy Regulation The proposed Digital Economy and E-Governance Bill The national Digital Economy and E-Governance Bill was introduced and passed its first reading in the National Assembly in July 2024. Among other things, the Bill is aimed at enhancing the use of digital technology to grow Nigeria’s econ - omy, creating an enabling environment for fair

competition to promote innovation, growth and competitiveness for the Nigerian digital econo - my and creating a framework for the enhance - ment of digital economy governance in minis - tries, departments and agencies. The Bill represents a significant step towards formalising and expanding the country’s digital economy. With the growing influence of digital technologies in sectors such as finance, edu - cation, healthcare and governance, it seeks to provide a comprehensive legal and institutional framework for fostering innovation, protecting users and encouraging investments in digital infrastructure. The Bill applies to all electronic transactions and communications within Nigeria and establishes the legal framework for the recognition, creation and use of electronic records, signatures and communications. The Bill also seeks to complement existing laws such as the Federal Competition and Consumer Protection Act 2018 (the “FCCPA”) and the Nige - rian Data Protection Act 2023 (the “NDPA”) by introducing measures that enhance consumer protection in digital transactions. However, there is a need to ensure complete alignment between the provisions of the Bill and these existing laws to avoid possible conflicts. Artificial Intelligence (AI) Increased adoption of AI and its regulatory impact As is the trend globally, AI is becoming a trans - formative force in Nigeria, with adoption growing exponentially and opportunities for economic growth, innovation and improved service deliv - ery presenting themselves. However, like several other jurisdictions, Nigeria lacks a robust and specific legal framework regulating AI, thereby

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