Entries by Pavestones Legal

CBN CASH POOLING REFORM: IMPACT ON FOREIGN INVESTMENT AND THE OIL AND GAS SECTOR IN NIGERIA

BY ADERONKE ALEX-ADEDIPE & PROMISE ITAH Introduction On 25 March 2026, the Central Bank of Nigeria (CBN) issued a circular on Removal of Cash Pooling Requirements for International Oil Companies (the “Circular”) removing the restrictions previously imposed on the repatriation of export proceeds by International Oil Companies (IOCs). Under the new framework, IOCs may now […]

DECODING THE NCC’S DRAFT BUSINESS RULES FOR MOBILE VIRTUAL NETWORK OPERATORS IN NIGERIA

BY SEUN TIMI-KOLEOLU AND HILLARY OKOROTIE Introduction The Nigerian Communications Commission (“NCC”) recently published the Draft Business Rules for Mobile Virtual Network Operators in Nigeria (the “Draft Rules”), aimed at establishing a comprehensive regulatory framework for the operation of Mobile Virtual Network Operators (“MVNOs”) in Nigeria. The Draft Rules aim to promote transparency in the […]

NIGERIA CAPITAL MARKET REGULATORY UPDATE: SEC MANDATES REGISTRATION OF COLLATERAL MANAGEMENT COMPANIES, WAREHOUSE OPERATORS AND WAREHOUSES

BY ADERONKE ALEX-ADEDIPE & OMODELE FATODU On 11 May 2026, the Securities and Exchange Commission (the “Commission”) issued a circular clarifying the registration requirements applicable to certain capital market operators. The Circular applies to entities involved in the storage, management and facilitation of commodities used in structured trade financing or warehouse receipt arrangements. In particular: […]

KEY REGULATORY UPDATE IN THE POWER SECTOR: NERC MINI-GRID REGULATIONS 2026

BY SEUN TIMI-KOLEOLU AND MARK IMONITIE Introduction On 10 April 2026, the Nigerian Electricity Regulatory Commission (NERC) published updated Mini-Grid Regulations to accelerate electricity access for communities that are unserved or underserved by the national grid. The Mini‑Grid Regulations 2026 (“New Regulations”) replaces the Mini-Grid Regulations 2023 (“Previous Regulations”) and align with recent power-sector reforms. […]

PROTECTING INNOVATION IN NIGERIAN TECH CONTRACTS: COMMON PITFALLS AND SOLUTIONS

BY ADERONKE ALEX-ADEDIPE AND ENIOLA SOGBESAN Introduction In the current global digital economy, businesses enjoy significant competitive advantage from intangible assets such as intellectual property, confidential data and proprietary processes. In Nigeria, given that many businesses rely heavily on innovation and technology services, effective intellectual property is critical to long-term enterprise value and commercial sustainability. […]

BANKING AND FINANCE REGULATION IN NIGERIA – INTEREST RATE DETERMINATION, NOFR BENCHMARK

BY SEUN TIMI-KOLEOLU AND PROMISE ITAH Introduction On April 17, 2026, the Central Bank of Nigeria (CBN) announced the introduction of the Nigerian Overnight Financing Rate (NOFR) in collaboration with the Financial Markets Dealers Association (FMDA). The NOFR is a daily benchmark designed to reflect the actual cost of short-term borrowing between banks, based on real […]

REDEFINING AML COMPLIANCE: UNDERSTANDING CBN’S BASELINE STANDARDS FOR AUTOMATED AML SOLUTIONS FOR FINANCIAL INSTITUTIONS

BY ADERONKE ALEX-ADEDIPE AND HILLARY OKOROTIE Introduction With the increasing need to ensure financial security in today’s rapidly digitizing landscape and evolving compliance demands, the Central Bank of Nigeria (CBN) issued its Baseline Standards for Automated Anti-Money Laundering (AML) Solutions for Financial Institutions (“AML Solutions”) on March 10, 2026. This was followed by a Guidance […]

VIRTUAL ASSET SERVICE PROVIDER (VASP) LICENCES IN KENYA & NIGERIA – WHAT YOU NEED TO KNOW

By Seun Timi-Koleolu, Ombo Malumbe,  Eniola Sogbesan and Faith Ngarama    Introduction The future of Africa’s digital asset market is no longer speculative. It is real, growing, and increasingly regulated. For founders, Fintechs, and even traditional financial institutions looking to operate in the digital currency space, obtaining a Virtual Asset Service Provider (VASP) license is […]

KEY REGULATORY UPDATE: CBN GUIDELINES ON INSTANT PAYMENT FUNCTIONALITIES AND MOBILE BANKING SECURITY

By: Aderonke Alex-Adedipe and Mark Imonitie Introduction On 12 March 2026, the Central Bank of Nigeria (CBN) issued a circular (the “Circular”) to all financial institutions (FIs) offering Instant Payment (IP) services in Nigeria. The Circular provides the CBN’s Guidelines on instant payments and introduces sweeping measures to strengthen IP operations, enhance security protocols, improve […]

REGULATORY UPDATE: NDPC EXTENDS DATA AUDIT FILING DEADLINE

By Seun Timi-Koleolu and Omodele Fatodu The Nigeria Data Protection Commission (“NDPC”) has announced an extension of the deadline for the filing of the 2025 Data Protection Compliance Audit Returns (“CAR”) from March 31 to May 30, 2026. Data Processors and Controllers of Major Importance (“DPCMIs”) are therefore encouraged to utilise this period to ensure […]