On-shore VASP in Nigeria

SEC Nigeria — VASP licensing, digital asset exchange regulation

CBN — Banking restrictions (banned bank servicing Feb 2021, partially reversed Dec 2023), eNaira CBDC

NFIU/SCUML — Financial intelligence, AML compliance

SEC Nigeria Rules on Virtual Assets (2024) — VASP licensing — exchange, offering platform, custody, broker-dealer categories

VASP: VASP License from SEC Nigeria. Exchange: NGN 500M (~$320K USD). Offering Platform: NGN 100M. Custody: NGN 2B. Broker-Dealer: NGN 100M. 3-6 months. Highest crypto adoption in Africa. Framework is new — enforcement capacity limited.

CUSTODY: Digital Asset Custody license — NGN 2B minimum capital

EXCHANGE: Digital Asset Exchange license — NGN 500M minimum capital. Naira volatility and FX controls drive massive P2P trading. CBN launched eNaira partly as alternative to crypto.

Digital Assets Exchanges (DAX): Full license for trading platforms.

Digital Assets Custody (DAC): For custody providers holding virtual assets.

Incorporate with CAC as VASP.

Apply to SEC under ARIP: Pay application fee ₦100,000 (~$240), processing fee ₦300,000 (~$722).

Receive Approval in Principle; meet conditions (capital, bond, KYC policies, officers).

Pay registration fee ₦30 million (~$72,000); obtain full license and "No Objection" letter before operations.

Obtain CBN clearance for banking services if needed.

Investments and Securities Act 2025

SEC Rules on Issuance, Offering Platforms and Custody of Digital Assets 2022: https://sec.gov.ng/documents/8/Rules-on-Issuance-Offering-and-Custody-of-Digital-Assets.pdf

ARIP Framework (June 2024)

CBN VASP Guidelines (Dec 2023)

Securities and Exchange Commission (SEC): Oversees crypto exchanges, Virtual Asset Service Providers (VASPs), and digital asset platforms as securities; enforces capital markets regulations and licensing.

NFIU's Mandate: NFIU receives mandatory reports (e.g., Suspicious Transaction Reports within 24 hours) from Financial Institutions (FIs), Other Financial Institutions (OFIs), and DNFBPs. Businesses must register as reporting entities on the NFIU's goAML portal, submitting documents like CAC registration, industry regulator licenses (e.g., CBN, SEC), and compliance officer details.

SCUML's Mandate: SCUML enforces AML/CFT rules for DNFBPs (e.g., lawyers, accountants, real estate agents), including registration (with certificate issuance), risk-based customer due diligence (CDD), internal compliance programs, record-keeping, staff training, and reporting suspicious activities to NFIU. From January 1, 2026, all DNFBP reports must use the SCUML portal exclusively.

Shared Framework: Both operate under laws like the Money Laundering (Prohibition and Prevention) Act (MLPPA). DNFBPs report to NFIU but are supervised by SCUML, while FIs report directly to NFIU via regulators like CBN or SEC. All entities must conduct KYC/CDD, risk assessments, and file timely reports to align with FATF/GIABA standards.

Nigeria is actively taking strides toward Travel Rule implementation but has not yet enacted legislation or made it operational, per 2026 global status reports.

No effective date has been established or scheduled for Nigeria, unlike jurisdictions such as Australia (31 July 2026) or Brazil (2 February 2027).

No Nigeria-specific threshold is defined, as implementation is pending. FATF recommends a global de minimis of $1,000/€1,000, but jurisdictions set their own (or none), with varying rules above/below it.

Rate: Flat 10% on gains (sales proceeds minus allowable disposal expenses).

Entities must compute, pay, and file self-assessment returns twice yearly (by June 30 and December 31).

Overseen by Federal Inland Revenue Service (FIRS) as primary tax authority (no direct FIRS crypto page in results; general guidance via Finance Acts).

Finance Act 2023: First explicit inclusion of digital assets in CGT Act; effective May 1, 2023.

Investments and Securities Act (ISA) 2025: Classifies digital assets as securities, reinforcing taxability.

Entity Targeted: Over 1,100 (specifically 1,146) bank accounts of crypto traders and peer-to-peer merchants. Violation Type: Foreign-exchange racketeering, currency (naira) manipulation, money laundering, terrorism financing. Penalty Amount: Not specified (accounts frozen, no fines detailed).

Date: Accounts frozen as part of an ongoing investigation starting early 2024; court order obtained by April 2024 (90-day investigation period noted)

Outcome: Accounts frozen pending investigation completion; EFCC part of interagency task force probing naira manipulation linked to platforms like Binance. Investigation ongoing with potential blocks on fund retrieval even if court-ordered

New frameworks mandate national ID linkage for transactions and naira delisting from P2P exchanges (2024-2026), with penalties like license loss for unreported transactions.