Finance Law and Banking Law

Effective investment management requires more than sound decision-making—it demands a robust institutional framework to protect investors' money and assets. At the heart of this framework lies a critical relationship between two distinct participants: the fund manager who directs investment strategy, and the custodian who safeguards and administers those assets. This deliberate separation of functions serves as a fundamental investor-protection mechanism that underpins the integrity of modern investme

Private equity, venture capital, and private credit markets in Nigeria are evolving rapidly, with disclosed deal values surging 84% to US$810.7 million in 2025. While venture capital dominates transaction volume and value, private debt is expanding its role in working capital, acquisition finance, and infrastructure. The critical question is not whether capital can enter Nigeria at scale, but whether it can stay, perform through cycles, and ultimately return to investors as distributions.

Nigeria's Securities and Exchange Commission has introduced new capital adequacy rules for fund managers and private capital participants, establishing tiered minimum capital requirements based on assets under management. The guidelines clarify what constitutes qualifying capital, outline compliance pathways including cash injection and securities transfer, and set a June 2027 deadline for full implementation.

Project finance transactions are, by their nature, capital-intensive and typically funded through a combination of debt instruments drawn from multiple sources: senior lenders, mezzanine financiers, subordinated creditors, and increasingly, development finance institutions.

Nigeria's Nollywood has emerged as the world's second-largest film industry by volume, yet financing remains a critical bottleneck for filmmakers who rely primarily on personal savings and informal investors.

The Central Bank of Nigeria has issued new guidance clarifying that suspensions of payment obligations and termination rights under financial contracts involving Nigerian banks will not exceed two business days. This interpretative circular addresses a critical gap in the Banks and Other Financial Institutions Act, 2020, providing certainty for counterparties trading derivatives, repos, and other financial instruments with CBN-regulated institutions.

Nigeria's capital market has transitioned to a T+1 settlement cycle, reducing the time between trade execution and settlement to one business day. This reform addresses counterparty risk, liquidity constraints and operational inefficiencies that persisted under the previous T+3 and T+2 frameworks, fundamentally reshaping expectations for brokers, custodians and institutional investors.

The Securities and Exchange Commission has issued new guidance requiring collateral management companies, warehouse operators, and commodity exchange-linked warehouses to formally register within 90 days. Entities operating under informal arrangements must now meet specific capital requirements ranging from ₦200 million to ₦500 million and submit comprehensive documentation demonstrating operational capacity, governance structures, and financial standing.

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 Nigerian Federal Competition and Consumer Protection Commission has conditionally approved MTN Group Limited's acquisition of IHS Holding Limited, requiring MTN to divest 30 percent of IHS's Nigerian business to local investors. This decision addresses vertical competition concerns arising from MTN's transition from minority shareholder and customer to controlling owner of a telecommunications infrastructure provider that serves multiple mobile network operators.

Nigeria's Securities and Exchange Commission has proposed comprehensive rules for online Forex trading and Contracts for Difference (CFDs), establishing a regulatory framework that extends beyond brokers to encompass technology and platform providers. The proposed regulations introduce stringent capital requirements, operational standards, and compliance obligations for businesses providing trading infrastructure, raising critical questions about registration, data localization

The Cabotage Vessel Financing Fund (CVFF) was launched in January 2026 to address financing gaps for indigenous Nigerian shipowners. Six months later, despite receiving 92 applications, no disbursements have been made due to bureaucratic bottlenecks, extensive risk assessments by primary lending institutions, and complex documentation requirements across multiple regulatory agencies.