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Newsletter on the Nigeria Data Protection Act General Application and Implementation Directive (GAID) 2025

 Introduction The Nigeria Data Protection Commission (NDPC or the Commission) has issued the Nigeria Data Protection Act General Application and Implementation Directive (GAID or the Directive) 2025, pursuant to the Commission’s power under Sections 1(a), 6(c), 61 & 62 of the Nigeria Data Protection Act (NDPA or the Act) 2023, to provide clarity on compliance obligations under the Act. The Directive […]

CBN’s Cash-Out Limits for Agent Banking Transactions

Introduction On 17 December 2024, the Central Bank of Nigeria (CBN) issued a circular on cash-out limits for agent banking transactions to advance the cash-less economy while addressing challenges in the agency banking space (the Circular). This policy intervention introduces new limits and operational standards for agents, to reduce fraud, improve service delivery, and ensure […]

CBN’s Directive for Payment Service Providers on Connectivity to Payment Terminal Service Aggregators

Introduction  The Central Bank of Nigeria (CBN) on September 11, 2024, issued a Directive mandating all Payment Service Providers (PSPs) [1] to route Point of Sale (PoS) transactions through CBN licensed Payment Terminal Service Aggregators (PTSAs) – (the “Directive”). The Directive is aimed at decentralizing the routing of PoS transactions through multiple aggregators and improving the […]

FAQs on Data Protection Audit and Compliance

Background As a licensed Data Protection Compliance Organization (DPCO), we are fully equipped to monitor, audit, report, and offer comprehensive data protection compliance services to organizations across various industries.  We have prepared a set of FAQs to help you better understand our new role and how we can support your organization’s data protection needs and […]

Common Legal Issues Faced by Early-Stage Companies in Africa

Introduction The African startup ecosystem has evolved in the past few years. Many startups have emerged, some thriving while others have struggled or shut down completely. Regardless of the industry or the nature of the products or services being offered by a startup, there are some common success factors applicable to startups on the continent; […]

Interpretation of Single Shareholding under CAMA 2020

Introduction   On 30 July 2024, the Federal High Court delivered a judgment on the interpretation of Section 18(2) of the Companies and Allied Matters Act (CAMA) 2020 in the case of Primetech Design and Engineering Nigeria Limited & Julius Berger Nigeria Plc v. Corporate Affairs Commission in Suit no: FHC/ABJ/CS/665/2023, (the “Primetech case”) The central […]

Newsletter on The SEC Accelerated Regulatory Incubation Program

Background  On the 21st of June, 2024, the Securities Exchange Commission ( the SEC) issued a notice (the Notice) on the amendment of the Rules on Digital Assets Issuance, Offering Platforms, Exchange and Custody (the VASP Rule). Consequently, the SEC opened a regulatory incubation window known as the Accelerated Regulatory Incubation Program (ARIP) to accept […]

SEC Proposed Rules on the Issuance and Allotment of Private Companies Securities

Background   The Securities Exchange Commission in Nigeria (SEC or the Commission) recently published the proposed rules on the issuance and allotment of securities by private companies which govern the issuance of debt securities by private Companies in Nigeria (the Proposed Rules).   These rules have been proposed in furtherance of the recent amendment of Section 67(1) […]

Newsletter on CAC’s Directive on Registration of PoS Agents

Introduction On May 7, 2024, the Corporate Affairs Commission (CAC) issued a directive requiring Point of Sale (POS) agents to register as businesses with the CAC within a two-month deadline (July 7, 2024). The directive is an attempt to curb the increasing concern over fraudulent activities facilitated through POS transactions in Nigeria. This newsletter examines […]

Digital Assets Regulation in Nigeria: Recent Regulatory Developments

Introduction The digital assets regulatory landscape in Nigeria has been marked by significant shifts and developments over the past years. The Central Bank of Nigeria (CBN) imposed a ban on digital assets transactions in 2021[1] prohibiting financial institutions from providing services to digital assets exchanges or facilitating digital asset or cryptocurrency transactions. However, in December […]