OPERATING IN A FREE TRADE ZONE IN NIGERIA

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By Seun Timi-Koleolu and Sharon Okpo

 

INTRODUCTION

Dangote recently inaugurated its refinery in Lagos, and following this, the attention of many Nigerians was drawn to the operation of the Free Trade Zones in Nigeria. The Dangote Refinery is situate in a free zone, owned and managed by the Dangote Industries Free Zone Development Company. More than ever before, businesses, both local and foreign, have shown interest in understanding the Nigerian free trade zone, its benefits, and how to set up a business within a free zone.

This publication provides more information on the free trade zones, the licensing requirements, and the benefits of investing in a free trade zone in Nigeria.

1. WHAT IS A FREE TRADE ZONE?
A free trade zone (“Zone”) is a geographical location or area within a country where business (including manufacturing, storage, importation, and exportation of goods) may be conducted under less stringent regulations than that which is applicable to the rest of the country. The World Bank has defined it as “small, fenced-in, duty-free areas offering warehousing, storage, and distribution facilities for trade, transshipment, and re-export operations”.

The primary legislation regarding free trade zones in Nigeria is the Nigeria Export Processing Zones Act LFN 2004 (the “Act”). The Act establishes the Nigeria Export Processing Zones Authority (NEPZA), as the principal authority and regulator of the Zones within Nigeria. Although the Act makes no provisions on the definition of a free trade zone, the NEPZA Regulations (the “Regulations”) made pursuant to the Act provides that free zones mean “export processing zones, border free zones, free trade zones, export processing factories and export processing farms established pursuant to the Nigeria Export Processing Zones Act No. 63 of 1992”.

According to the Act, a Zone may be operated and managed by a public, private, or a combination of public and private entity under the supervision of and with the approval of NEPZA. There are currently 19 operational Zones in Nigeria which include the Lagos Free Trade Zone, Snake Island Integrated Free Zone, Lekki Free Trade Zone, Calabar Free Trade Zone, Nigerian International Commerce City (Eko Atlantic), Dangote Industries Free Zone Development Company, etc.

2. WHY SET UP AN ENTITY WITHIN THE ZONE?
The Act provides various incentives for entities investing and setting up their business within the Zone, and they include:

  1. Zero tax- entities within the Zone are excluded from paying Federal, state and government taxes, levies and rates which are ordinarily applicable to companies operating within Nigeria.
  2. full repatriation of foreign capital investments, profits and dividends earned by foreign investors in the Zones;
  3. right to import capital goods, consumer goods, raw materials, and other components used in connection with an approved activity into the Zones free of customs duty;
  4. entities are not required to pay rent for any lease during its construction stage;
  5. 100% foreign ownership of business;
  6. ease of doing business, as NEPZA provides a one-stop approval for permits and operating licence. For instance, an entity seeking to employ a foreigner is only required to apply directly to NEPZA on behalf of such foreigner for all requisite immigration and employment permits, rather than dealing with the immigration authority. Also, where the entity has not already been registered as a company with the Corporate Affairs Commission, an operating licence issued by NEPZA satisfies this requirement of registration;
  7. holders of a free zone developers licence also have the opportunity to obtain a large expanse of land at a highly subsidized price, which can in turn, be leased to entities that set up operations within their Zone.

3. WHAT ARE THE VARIOUS LICENSES REQUIRED TO OPERATE WITHIN A FREE TRADE ZONE?
Further to the provisions of the Act, any entity that intends to undertake any of the approved activities within the Zone shall apply to NEPZA requesting permission to do so. Upon such application, NEPZA may, subject to the fulfillment of any terms and conditions as it may direct from time to time grant such entity approval to conduct the approved activity and issue a licence to such entity.
Paragraph 2 Part 4 of the Regulations provide for 3 (three) different licenses-

  1. Free Zone Developers Licence– this licence is issued solely by NEPZA to either a public, private or a combination of the two for the establishment and management of a free zone in Nigeria. The Zone, when established, shall be under the direct supervision of NEPZA. The licensee shall have supervisory and managerial control over the activities within the Zone and is empowered to grant licences to other entities to operate within the Zone. In the exercise of its supervisory and managerial authority, the licensee may release regulations and circulars to direct the licensing and activities of enterprises within the Zone.
  2. Free Zone Enterprise Licence– this is a license granted to an enterprise to undertake an approved activity within a Zone. These activities may be manufacturing, trading, or service provision. This license may be granted by either NEPZA or the holder of a Developers’ licence (referred to as the “Zone Management”).
  3. Export Processing Factory/Export Processing Farm Licence– this licence is issued solely by NEPZA to export-oriented manufacturing farm enterprises (production of agricultural produce) located in Nigeria, that have the capacity to export over 75% of its production.

4. WHAT ARE THE ELIGIBILITY REQUIREMENTS FOR OBTAINING A LICENCE?
To be eligible for any of the licences listed above, NEPZA or the Zone Management (depending on the issuer) may consider the following:

  1. the activities the applicant proposes to carry on within the Zone;
  2. how much the proposed activity will add to and be consistent with the development programme of the Zone;
  3. compliance with the Act and applicable rules and regulations put in place by NEPZA or the Zone Management;
  4. technical, financial and managerial capabilities of the applicant;
  5. applicant’s experience and track record;
  6. level of foreign direct investment proposed by the applicant;
  7. payment of the prescribed licence fee; and
  8. in the case of applicants for the developers licence, evidence of title to a suitable land area free of any encumbrance. The applicant will also be required to provide the following details-
    • the name and profile of the chief executive officer of the entity;
    • major selling points of the Zone;
    • number of enterprises that may be able to operate within the Zone;
    • key partners;
    • sectors available for investment;
    • percentage of land for future development, etc.

The licence when granted cannot be assigned or transferred either in whole or in part to any other entity. The licence is valid from the time of issue until the end of the year of issue. It may be renewed upon expiration following the payment of a renewal fee, production of any required documents, returns or information, and payment of all outstanding amounts due to NEPZA or the Zone Management, if any.

It is important to note that this licence can only be used within the Zone for which it was issued and cannot be used anywhere else within Nigeria. Any licensee who wishes to carry out any business outside the Zone must comply with all applicable laws in force outside of the Zone.

5. CAN A FOREIGNER OR FOREIGN ENTITY SET UP OR OWN A ZONE?
Yes, foreigners and foreign entities are allowed to operate or establish a business within a Zone. This can be inferred from the provision of the Act which allows for 100% ownership of an entity within a Zone.

6. WHAT ARE THE APPROVED ACTIVITIES WITHIN A ZONE?
The following are some of the approved activities within a Zone:

  1. manufacturing of goods for export;
  2. handling of duty-free goods;
  3. banking, stock exchange and other financial services, insurance and reinsurance;
  4. import of goods for special services, exhibitions and publicity;
  5. international commercial arbitration services;

No entity is permitted to engage in any retail business within the Zone.
Some of the permissible industries include electrical and electronic products; textile products/garments; leather and petroleum products; cosmetics and other chemical products; medical kits, optical instruments, and appliances; pastries and food processing businesses; pharmaceutical products; shipbuilding & repairs, Oil and Gas logistics; etc.

CONCLUSION
There are numerous incentives made available by the Nigerian government to encourage entities to set up operations within a Zone. Businesses seeking to set up operations within the Zones should seek guidance from their legal counsel to obtain the necessary licences and permits.

REGULATORY UPDATE: NIGERIAN ELECTRICITY REGULATORY COMMISSION CUSTOMER PROTECTION REGULATIONS

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By Aderonke Alex-Adedipe and Nuratulahi Yishawu

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Introduction
Reliable access to electricity is vital for the development and progress of any nation. Nigeria has grappled with a persistent problem of irregular power supply and arbitrary disconnection of electricity services to consumers. This has not only posed hardship for consumers but has also hindered economic growth and stifled productivity for businesses. Recognizing the urgency and importance of this matter, the Nigerian Electricity Regulatory Commission (“NERC“) has taken a proactive step by formulating the Customer Protection Regulation, 2023 (the “Regulation”) to regulate the Nigerian Electricity Supply Industry (“NESI”). This Regulation, which was released on May 12, 2023 applies to and seeks to protect the interests of both electricity distribution companies (“DisCos“) and their customers.

In this newsletter, we examine the key provisions of the Regulation with respect to the connection and disconnection of electricity supply vis-a-vis consumer protection.

1. Repeal of prior regulatory instruments
The Regulation repealed the existing NERC regulations which dealt with the protection of customers [1] and is, therefore, the sole Regulation on all customer-related matters in the NESI.

2. Requirements for connecting to electricity supply
Customers who require electricity connection to their premises are expected to provide all the connection materials needed in accordance with the standard approved by the DisCo, while the DisCo shall, within 48hrs of the provision of the required materials, ensure that electricity is connected to the customer’s premises. Upon connection, the DisCo is required to provide the meter and meter accessories to ensure proper billing of the customer’s energy consumption.

In addition to other requirements, a customer is required to provide the DisCo with acceptable means of identification and the DisCo reserves the right to reject the customer’s request for a supply of electricity where the customer refuses to provide identification and/or refuses to pay the security deposit required by the DisCo.

It should be noted that the Regulation provides that DisCos shall not charge Maximum Demand Customers (i.e, customers who consume high voltages and whose premises are not exclusively residential) any fees for the inspection, survey, testing and commissioning of electricity supply to their premises.

3. When can a DisCo disconnect a customer’s electricity supply?
A DisCo reserves the right to disconnect the electricity supply to a customer where the customer fails to pay electricity bills on or before the payment date specified on the bill. The payment date must be at least 10 days from the date of delivery of the bill and the period between the payment date and the date of scheduled disconnection for non-payment should not be less than 2 working days. Therefore, a DisCo can disconnect a customer if he fails to pay the bill after 12 days of the delivery date of the bill. Where the DisCo fails to disconnect the customer after the date on which he should have been disconnected, the Regulation provides that such a customer must not be billed for that period.
However, it is important to note that the Regulation prevents discos from disconnecting electricity supply to a premise in which they are aware that a life support machine is in use. In such instances, the DisCo may recover existing debt by recourse to other legal means.

4. Is there any penalty or compensation for unjust disconnection of electricity supply?
Yes, there is. The Regulation provides that customers whose electricity supply have been disconnected in contravention of the Regulation shall be compensated with energy credits equivalent to their average daily consumption for every day the wrongful disconnection lasts.

5. What happens when a customer decides to move to another premises?
If a prepaid meter customer is moving out, a final meter reading must be requested from the DisCo to ensure there are no outstanding payments. If the customer’s negligence prevents the DisCo from accessing the meter, the DisCo will interrupt the electricity supply and issue the final bill. Customers are responsible for paying their debts and DisCos can collect debts from them. If a defaulting customer moves out, the debt must not be transferred to the new resident.

6. What is the procedure for handling a customer complaint?
All DisCos are expected to establish customer complaints units (“CCU”) which shall be primarily responsible for receiving and resolving customer complaints. The following are the procedures for handling customer complaints under the regulation:

i. All complaints by the customer must first be made to the CCU of the DisCo and the DisCo must ensure that it acknowledges the complaint in a way that is traceable.
ii. Customers may lodge complaints through phone calls, SMS, emails or any other method created by the DisCo for receiving customer complaints.
iii. All complaints must be resolved within 15 days. Where the complaint is in relation to meter accuracy and reconciliation of bills, it must be resolved within a billing cycle of one month.
iv. Where the customer complaint is not resolved within the specified period, the DisCo shall give reasons in writing and request an extension of not more than 15 additional days from the customer to resolve the complaint.
v. After the expiration of a maximum period of 30 days, a customer who is not satisfied with the way his complaint has been handled by the Disco or where the Disco and the Customer are unable to agree on a resolution, the complaint may be referred to the Forum Office of the NERC.

Conclusion
Given the current terrain and reports of indiscriminate charges as well as unlawful disconnection from power supply, the issuance of the Regulation is timely and commendable. It is, however, important that the DisCos as well as the consumers are sensitized and enlightened about their rights and obligations under the Regulations. It is also important that efficient systems be established to ensure that the Regulation is given effect as this will not only address the challenges faced by customers but also help create a sustainable and efficient electricity supply industry in Nigeria.

[1] -The Regulation repealed the following instruments: Nigerian Electricity Regulatory Commission Customer Complaints Handling Standards and Procedures, Nigerian Electricity Regulatory Commission Connection and Disconnection Procedures for Electricity Services, Nigerian Electricity Regulatory Commission Customer Service Standards of Performance for Distribution Companies, Nigerian Electricity Regulatory Commission Methodology for the Determination of Connection Charges for Electricity Supply Regulations, and Nigerian Electricity Regulatory Commission Meter Reading, Billing, Cash Collections and Credit Management for Electricity Supply Regulations.

NGX TECHNOLOGY BOARD: CONSIDERATIONS FOR LISTING YOUR TECHNOLOGY COMPANY ON THE NIGERIAN STOCK EXCHANGE

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By Seun Timi-Koleolu and Qasim Ogunjimi 

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Introduction

The Nigerian technology ecosystem has grown astronomically over years, with startups and technology companies springing up across the country. In recent times, however, factors such as the current economic downturn have made it difficult for these companies to raise funds through traditional channels such as angel investment and venture capital. In view of this, the introduction of the Technology Board (the “Tech Board”) by the Nigerian Exchange Limited (the “Exchange”) presents a unique opportunity for tech companies to access capital from the public.

In this newsletter, we will be discussing the factors technology companies should consider before listing on the Tech Board as well as the potential benefits and challenges of such listing.

1. LISTING ON THE TECHNOLOGY BOARD
The Tech Board is designed specifically to cater to the needs of technology companies, providing a platform for them to access capital and investors. One of the key benefits of the Tech Board is that it offers technology companies an alternative listing venue to the traditional boards (main, premium and growth board) of the Exchange. Unlike the traditional boards, which have stringent listing requirements that may be difficult for some technology companies to fulfill, the Tech Board has a more flexible listing process that takes into account the unique characteristics of tech companies.

2. FACTORS TECHNOLOGY COMPANIES SHOULD CONSIDER BEFORE LISTING ON THE TECH BOARD

i. Listing Eligibility Requirements: Technology companies seeking to raise capital through the Exchange may be listed on either the start-up tech or big tech segment of the Tech Board. The start-up tech segment requires a market capitalization of at least US$1 million and a maximum of US$100 million, while the big tech segment requires a market capitalization of over US$100 million to US$1 billion. Additionally, the company must be a public company limited by shares. Please see our previous newsletter, “Fundraising Opportunities by Listing on the Technology Board of NGX,” for more information on eligibility criteria and other necessary details for technology companies interested in listing on the Tech Board.

ii. Financial Readiness: The company should have a strong financial foundation with consistent revenue streams, profits, and positive cash flow.

iii. Market Conditions and Timing: The overall state of the market should be assessed to determine if it is favorable for a listing. The timing of a listing can affect the valuation of a company and its ability to attract investors, making it a critical factor for tech companies to consider.

iv. Valuation: A company’s valuation represents its worth in the eyes of investors and is a critical factor that determines the company’s ability to raise capital. Before listing, a company must conduct a thorough valuation of its assets, including intellectual property, brand value, and projected earnings, to determine its share price. A well-conducted valuation ensures that the company is not overvalued or undervalued.

v. Investor Demand: Investor demand is an important factor for tech companies to consider before listing on the exchange because it directly affects the success of the listing. The company needs to assess if there is enough demand from potential investors to support the listing. If investor demand is strong, the company may be able to achieve a higher valuation and raise more capital through the IPO. On the other hand, if investor demand is weak, the company may struggle to attract investors and may have to settle for a lower valuation and raise less capital.

vi. Corporate Governance: Corporate governance is a crucial factor for technology companies to consider before listing on the Tech Board. Strong corporate governance practices help to ensure transparency, accountability, and fairness in the management of a company. This includes having a clear organizational structure, an independent and diverse board of directors, and well-defined policies and procedures for decision-making, risk management, and ethical conduct. Good corporate governance practices can help to build investor confidence, increase access to capital, and reduce the risk of legal and reputational issues. Therefore, technology companies need to consider their corporate governance practices and ensure that they meet the standards required by the Exchange and regulatory bodies.

vii. Legal Considerations: The companies should ensure that they comply with all the relevant laws and regulations, as well as the listing requirements of the Exchange. This can include compliance with securities laws, intellectual property laws, data privacy regulations, and other relevant laws and regulations. Failure to comply with legal requirements can result in legal action, reputational damage, and financial penalties, which can be detrimental to the success of the company’s listing.

3. POTENTIAL BENEFITS OF LISTING ON THE TECH BOARD
Technology companies are often on the cutting edge of innovation, developing new products and services that have the potential to change the world. However, turning these innovative ideas into a successful business often requires significant amounts of capital, access to which can be challenging. Some of the potential benefits of listing on the Tech Board include:

i. Access to Capital: One of the primary benefits of listing on the stock exchange is access to capital. By listing on the Exchange, technology companies can raise funds to expand their operations and develop new products or services, by issuing new shares to investors.

ii. Increased Visibility and Credibility: Listing on the Exchange increases a technology company’s visibility and credibility in the eyes of potential customers, partners, and investors. A listed company is perceived as being more established, reputable, and reliable.

iii. Diversification of Investor Base: By listing on the stock exchange, technology companies can diversify their investor base and attract new investors interested in investing in publicly-traded companies. This will help to reduce the company’s reliance on a small group of investors. A diverse investor base can also provide the company with access to a wider range of expertise, contacts, and resources, which can help to support its growth and development.

iv. Improved Corporate Governance: Listing on the Exchange requires tech companies to comply with certain regulations and corporate governance standards. This can help to improve the company’s management practices and increase its transparency, which can lead to increased investor confidence.

4. POTENTIAL CHALLENGES TO CONSIDER
Listing on the Tech Board presents many benefits for technology companies, but it is not without its risks and challenges. There is the risk of market volatility and fluctuations, which can impact the company’s share price and investor sentiment. Another major risk is the potential for regulatory and compliance challenges, as the listing requirements are dynamic and may require ongoing maintenance. Additionally, listing on the Tech Board may subject the company to greater scrutiny and expectations from investors and the public, which can result in added pressure and scrutiny on the company’s operations and financial performance.

CONCLUSION
Technology companies should thoroughly evaluate the decision to get listed on the Tech Board, taking into account the distinct features and nuances of their business. Going public can be a major milestone, but it comes with its own set of challenges and risks. It is therefore crucial that Technology companies engage the services of professionals like financial advisors, legal experts, and capital market experts who can provide guidance and support throughout the listing process.

 

NIGERIA’S DIGITAL FUTURE: THE BLOCKCHAIN ADOPTION STRATEGY

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By Aderonke Alex-Adedipe and Sharon Okpo

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Introduction

Blockchain, which is mostly associated with cryptocurrencies and the like, had remained largely unregulated in Nigeria until September 2020, when the Securities and Exchange Commission (“SEC”) issued a statement on digital assets, to the effect that crypto-offerings and other forms of blockchain-based offers in Nigeria or targeted at Nigerian investors would be regulated by the SEC1. Following this statement, the Central Bank of Nigeria (“CBN”) in February 2021, issued a circular, prohibiting banks from dealing in cryptocurrencies or enabling payments for cryptocurrency exchanges. There is no denying the tension and the negative impact this development had in the innovation and technology space.

With the continuous increase in decentralized finance (“DeFi”) and the obvious importance and significance of blockchain in driving economic growth, the government of the Federal Republic of Nigeria (“FRN”), through the National Information Technology Development Agency (“NITDA”) acknowledged the need to develop the Draft National Blockchain Adoption Strategy (the “Strategy”) in 2020. The aim of the Strategy is to drive the adoption of blockchain technology in government in a way that supports efficiency, transparency, and productivity. Having recognized the potential of blockchain technology to create new transaction channels for the development of the digital economy, and the need for the government and regulators to embrace its disruptive nature and proactively participate in same, the FRN has now approved the Strategy on May 3, 2023.

This publication highlights some of the salient provisions of the Strategy.

A. WHAT IS BLOCKCHAIN?

According to the Strategy, blockchain technology is defined as a decentralized and distributed ledger that records and validates the authenticity of digital assets. Its technology allows individuals and organisations to record information which cannot be altered without the authorization of the persons or organisations who share the network. Any alterations done to any entry in any ledger without the prior approval will automatically corrupt the entire ledger. This dispenses with the need for the employment of any third party to supervise or validate transactions and address the issues of compromise and vulnerability of this third party.

Blockchain technology is often and most popularly known to be used in financial transactions and transactions involving the transfer of digital assets. This technology however is also used in various other sectors and for various purposes ranging from healthcare to voting, national identity management, internal revenue monitoring, and registries.  The Strategy also provides for additional use cases that can benefit from the deployment of blockchain technology in various sectors of the Nigerian economy, such as:

  1. Data management: this includes cloud storage; identity data management; contract management; Internet of Things (IoT) sensor data purchasing, etc.
  2. Data verification: this includes document notarization; identity verification;   product quality verification by the Standard Organisation of Nigeria (SON) and the Nigerian Agency for Food and Drug Administration (NAFDAC); proof of origin for products, etc.
  3. Financial sector: this includes currency exchange and remittance; crowdfunding;  peer-to-peer (P2P) transactions; insurance; and supply chain management in e-commerce.
  4. Other additional uses can be found in lottery systems; gaming; social rating creation and monitoring; outsourcing of computational power for scientific purposes; etc.

B. THE GOVERNMENT’S STRATEGY FOR BLOCKCHAIN ADOPTION

Through the Strategy, the government has formulated three main pillars upon which the strategy for blockchain adoption is built. They are initiatives; strategic objectives; and consideration for existing government policies, frameworks, and strategies. The goal is to increase the contribution of information and communications technology (ICT) to the country’s gross domestic product (GDP).

  1. Initiatives: there are six (6) key initiatives upon which the adoption of blockchain would be built. They include:
  • Establishment of Nigerian Blockchain Consortium- the primary objective of the consortium will be to drive the initiatives. It will be designated with the responsibility of formulating plans to effectively implement the use of blockchain technology in providing products and services in the public sector. Some of its activities will include the support of blockchain research, development, and education; promotion of legal certainty for blockchain applications; facilitation of collaboration with private sector and citizens; and assistance in the creation of a flexible regulatory environment that allows for experimentation.
  • Regulation and Legal Framework- a regulatory environment conducive to innovation and growth will be created, which will address issues such as cybersecurity, privacy, legal, ethical and regulatory issues, incentives system, data storage and immutability, and interoperability. The outcome of this regulatory regime will be modeled after the Oxford Blockchain Regulation Framework which seeks to focus on outcomes, protect all stakeholders, foster trust, balance competition and promote innovation.
  • National Digital Identity Framework- the blockchain technology upon adoption is expected to support in harmonization of biometrics and identification (ID) such as National Identity Number (NIN), Bank Verification Number (BVN), voter IDs and sim-card registration details.
  • Blockchain Business Incentives- this will ensure the prioritization of digital entrepreneurship and innovation. By this initiative, preference will be given to digitally skilled Nigerians for government-funded projects.
  • Blockchain Digital Literacy and Awareness- this initiative proposes the inclusion of blockchain learning and awareness in school curricula.
  • National Blockchain Sandbox- this initiative will ensure that developers and non-developers alike are given a platform to innovate and test-run their ideas without fear of sanction or breach. This will be championed by key regulators of the technology and financial technology sectors.

ii.   Strategic Objectives: there are five (5) strategic objectives for the adoption of blockchain technology. They are to:

  • Provide regulatory oversight- in the adoption of blockchain technology, the government intends to achieve a balance between the need to promote and properly use new technology and enhance innovation, on the one hand, and the need to avoid money laundering and safeguard the rights of consumers on the other hand.
  • Stimulate innovation and entrepreneurship- the aim is to increase opportunities for innovation and entrepreneurship, by introducing new models of businesses using blockchain technology. This will involve the integration of blockchain proficiency skills in school curricula, and a mandate on government institutions to acquire blockchain solutions to address their needs.
  • Ensure the security, trust, and transparency of digital assets and value chain.
  • Increase investment opportunities and create jobs.
  • Increase efficiency in governance.

iii.     Consideration of Existing Government Policies and Regulatory Frameworks: existing frameworks such as the National Digital Economy Policy and Strategy 2020-2023, the E-Govt. Master Plan, Nigeria Data Protection Regulation 2019, Nigeria Cloud Policy 2019, National ICT Policy, 2012, National Broadband Plan 2020-2025, etc. will need to be put into consideration in the implementation of the initiatives under the Strategy.

C.  WHO ARE THE STAKEHOLDERS FOR IMPLEMENTATION?

Some of the government institutions with key roles to play in the implementation of the Strategy include SEC, CBN, the Fintech Association of Nigeria, the Corporate Affairs Commission (CAC), NITDA, Federal Ministry of Communication and Digital Economy, Nigerian Bar Association (NBA), Stakeholders in Blockchain Technology Association of Nigeria (SIBAN), Nigerian Bureau of Statistics (NBS), etc.

CONCLUSION

While the government remains somewhat skeptical about the adoption of blockchain, there is no denying that the government recognizes the inevitable role it must play in the global economy.

It is important to note also that the approval of the Strategy has in no way changed any of the existing regulations or directives earlier issued by SEC and the CBN in relation to crypto transactions and crypto offerings. The status quo remains the same until officially recalled by the regulators.

We anticipate, however, that the implementation of the Strategy and the consequent issuance (and amendment where necessary) of regulations and policies will herald a positive shift in the Nigerian technology and financial technology sectors.