Entries by Pavestones Legal

WHEN THE REGULATOR TAKES THE BOARD: THE LEGAL LIMITS OF NERC’S INTERVENTION

BY ADERONKE ALEX-ADEDIPE & EFE OKPARAVERO Introduction On 10 August 2026, the Nigerian Electricity Regulatory Commission (“NERC”) issued Order No. NERC/2026/086 in respect of Kaduna Electricity Distribution Plc (“KAEDC”), dissolving its existing board and appointing an interim board of “Special Directors” to oversee the company. NERC has also appointed an Administrator and commenced a 12-month […]

TAXATION OF VIRTUAL ASSETS IN NIGERIA

SEUN TIMI-KOLEOLU & PROMISE ITAH Introduction On July 31, 2026, the Nigeria Revenue Service (NRS) issued the Guidelines on the Taxation of Virtual Assets (the “Guidelines”), providing the first comprehensive administrative framework for the taxation of virtual asset transactions in Nigeria. While the Guidelines do not introduce new taxes, they clarify how existing tax laws […]

NIGERIA’S FOREIGN EXCHANGE MARKET: RECENT REGULATORY REQUIREMENTS FOR BDC OPERATORS AND BANKS

BY ADERONKE ALEX-ADEDIPE & HILLARY OKOROTIE Introduction On February 10, 2026, the Central Bank of Nigeria (CBN) issued a circular on the Participation of Licensed Bureau De Change Operators in the Nigerian Foreign Exchange Market, permitting licensed Bureau De Change (BDC) operators to participate in the Nigerian Foreign Exchange Market (NFEM). Following the commencement of […]

NIGERIA’S FINANCIAL MARKETS REFORM – THE VIRTUAL ASSETS COORDINATION EXECUTIVE ORDER 2026 AND SEC’S PROPOSED CROSS-BORDER TRADING RULES

BY SEUN TIMI-KOLEOLU & ENIOLA SOGBESAN Introduction Nigeria continues to take significant steps towards modernizing its financial markets by creating a more transparent, innovative and globally competitive investment ecosystem. Two recent developments reflect this direction: the Presidential Executive Order on Virtual Assets Coordination 2026 (the “Executive Order”) and the Securities and Exchange Commission’s (SEC) Proposed […]

NAICOM’S GUIDELINES FOR FOREIGN HEALTH INSURANCE PROVIDERS: KEY COMPLIANCE CONSIDERATIONS FOR INSURERS AND POLICYHOLDERS IN NIGERIA

BY ADERONKE ALEX-ADEDIPE & OLUWAYEMI IBIRINDE Introduction On 31 March 2026, the National Insurance Commission (“NAICOM”) issued the Guidelines for the Operation of Foreign or International Health Insurance Providers (the “Guidelines”) pursuant to the Nigerian Insurance Industry Reform Act, 2025 (“NIIRA 2025”). The Guidelines establish, for the first time, a comprehensive regulatory framework governing foreign or […]

ONE AFRICA, ONE CLICK: WHAT THE AFCFTA DIGITAL TRADE PROTOCOL MEANS FOR AFRICA

BY SEUN TIMI-KOLEOLU & EFE OKPARAVERO Introduction Last week, Lagos hosted the AfCFTA Digital Trade Forum 2026, bringing together policymakers, regulators, financial institutions, technology companies, legal practitioners, and other stakeholders from across Africa and beyond under the theme, “Digital Trade for a Connected African Market.” The Forum underscored the growing momentum behind the AfCFTA Protocol on […]

CBN’S DATA LOCALISATION DIRECTIVE – COMPLIANCE CONSIDERATIONS FOR PAYMENT SYSTEM PARTICIPANTS

BY ADERONKE ALEX-ADEDIPE & PROMISE ITAH Introduction On June 15, 2026, the Central Bank of Nigeria (“CBN“) issued a Circular on Introduction of Market Structure Requirements, Data Localisation, Ultimate Beneficial Ownership Disclosure, and Systemic Oversight Measures in the Nigeria Payments System (the “Circular“). Among other regulatory reforms, the Circular introduces a significant data localisation requirement […]

AN OVERVIEW OF THE CBN DRAFT GUIDELINES ON RING FENCING OF THE OPERATIONS OF ENTITIES: COMPLIANCE OBLIGATIONS FOR FINANCIAL INSTITUTIONS

BY SEUN TIMI-KOLEOLU & HILLARY OKOROTIE Introduction The interconnectedness of financial institutions has created opportunities for operational efficiency. In many cases, financial institutions hold interests in one or more financial service providers. This structure, however, raises some regulatory concerns, including: commingling of consumer funds; and the risk that the financial failure of one entity may […]

BEYOND LICENSING – CBN’S DRAFT GUIDELINES FOR FINANCIAL HOLDING COMPANIES IN NIGERIA

BY ADERONKE ALEX-ADEDIPE AND ENIOLA SOGBESAN BEYOND LICENSING – CBN’S DRAFT GUIDELINES FOR FINANCIAL HOLDING COMPANIES IN NIGERIA. Introduction On 10 June 2026, the Central Bank of Nigeria (CBN) issued an Exposure Draft of the Revised Guidelines for Licensing and Regulating Financial Holding Companies (FHCs) in Nigeria (the “Draft Guidelines”). The Draft Guidelines is the […]

KEY REGULATORY UPDATE IN NIGERIA: THE CBN FOREIGN EXCHANGE MANUAL 2026

BY SEUN TIMI-KOLEOLU & OLUWAYEMI IBIRINDE Introduction On June 1, 2026, the Central Bank of Nigeria (CBN) implemented the Fourth Edition of the Foreign Exchange Manual (the “2026 Manual”), replacing the Foreign Exchange Manual 2018 (the “2018 Manual”). The 2026 Manual introduces significant changes to currency and trade rules and consolidates various foreign exchange policies […]