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Nigeria has taken another significant step towards bringing virtual assets, cryptocurrency businesses and blockchain-enabled financial services within a more coordinated regulatory framework.
President Bola Ahmed Tinubu's Presidential Executive Order on Virtual Assets Coordination, 2026 should not be viewed as another attempt to prohibit digital assets. Nor does it replace the existing powers of the Central Bank of Nigeria, the Securities and Exchange Commission (SEC), the Nigeria Revenue Service or other relevant agencies.
Principal objective is coordination.
The Executive Order seeks to reduce regulatory fragmentation by creating a framework through which the relevant authorities can share information, clarify responsibilities and supervise virtual-asset activities more consistently.
This development builds on the Investments and Securities Act 2025 (ISA), which already empowers the SEC to regulate virtual and digital assets, virtual-asset service providers, digital-asset exchanges, custodians and other operators within the investment and securities market.
For Nigerian fintechs, exchanges, custodians, token issuers, payment businesses and Web3 ventures, the message is clear: regulatory compliance can no longer be treated as an exercise to be undertaken after product launch. It must become part of product design, governance, banking, fundraising and market-entry strategy.
Here are seven steps operators should take now.
1. Determine your regulatory status
Not every digital-asset business will require the same license or approval. The appropriate regulatory pathway will depend on the nature of the asset; the service being provided and the risks created by the business model.
An operator must determine whether it is providing:
- an exchange or trading platform;
- custody or wallet services;
- payment or settlement services;
- brokerage or investment services;
- token issuance;
- staking, lending or yield products;
- peer-to-peer services; or
- a hybrid product falling within the jurisdiction of more than one regulator.
A company describing itself as "only a technology platform" will not necessarily escape financial-services regulation where its activities involve investment products, customer funds, payments or the custody and transfer of assets.
Immediate priority: conduct a regulatory-perimeter assessment and prepare a clear licensing and engagement roadmap.
2. Treat AML compliance as critical infrastructure
The involvement of the Nigerian Financial Intelligence Unit and national-security authorities demonstrates that anti-money laundering, terrorism financing, fraud, cybercrime and illicit cross-border transactions will remain central regulatory concerns.
A credible virtual-asset operator requires more than a generic compliance policy. Its systems should be capable of supporting:
- risk-based customer onboarding;
- reliable identity verification;
- beneficial-ownership checks;
- sanctions and politically exposed persons screening;
- transaction monitoring;
- wallet-risk assessment;
- suspicious-transaction escalation;
- ongoing customer due diligence; and
- proper recordkeeping.
Particular attention should be paid to high-risk jurisdictions, rapid movement of funds, unusual peer-to-peer transactions, mixers, privacy-enhancing tools and transactions with no apparent economic purpose.
Immediate priority: undertake an independent AML, counter-terrorism financing and sanctions-compliance review.
3. Prepare for greater tax transparency
The Nigeria Revenue Service is expected to play a major role in clarifying the application of existing tax laws to virtual-asset activities. Operators should not wait for an audit or information request before understanding how their businesses generate and record income.
Operators should begin reviewing:
- trading and platform fees;
- brokerage and custody income;
- gains and losses on digital assets;
- VAT treatment of services;
- token-issuance proceeds;
- staking and reward income;
- treasury holdings;
- cross-border transactions; and
- related-party arrangements.
Fintech platforms must also ensure that their systems can reconstruct transactions and produce reliable records where reporting obligations arise.
Immediate priority: align legal, finance, product and technology systems so that transactions can be properly identified, classified and reported.
4. Build a bankable business
Although the regulatory environment is becoming more structured, banks will still conduct extensive due diligence before providing accounts, payment channels or settlement services to virtual-asset businesses.
Operators seeking sustainable banking relationships should be ready to provide:
- evidence of their regulatory status;
- details of pending applications;
- beneficial-ownership information;
- governance structures;
- compliance policies;
- customer-flow diagrams;
- cybersecurity controls;
- transaction-monitoring arrangements; and
- clear explanations of how money enters and leaves the platform.
Businesses operating through personal accounts, undisclosed intermediaries or informal payment channels will face increasing regulatory and commercial risk.
Immediate priority: prepare a comprehensive banking and regulatory due-diligence pack.
5. Protect customer assets
The safeguarding of customer funds and digital assets will remain a major supervisory concern. Operators receiving money or holding assets on behalf of customers should be able to demonstrate how those assets are:
- identified;
- segregated;
- safeguarded;
- reconciled;
- accessed;
- transferred; and
- protected against loss or misuse.
Depending on the applicable rules and business model, this may require segregated accounts or wallets, independent custody arrangements, dual-access controls, private-key governance, reconciliations, insurance assessments and independent assurance.
Boards must recognise that virtual-asset custody is not merely an information-technology issue. It raises questions of fiduciary responsibility, consumer protection, operational resilience, fraud prevention and corporate governance.
Immediate priority: review customer-asset, treasury, custody, reconciliation and access-control arrangements.
6. Build compliance into product development
The principle of responsible innovation means that legal and regulatory analysis should begin before a product is released, not after regulators raise concerns.
Before launching a token, stablecoin, staking product, custody solution, investment scheme or peer-to-peer feature, an operator should assess:
- the legal classification of the product;
- whether regulatory approval is required;
- who may use the product;
- how it may be marketed;
- custody and redemption arrangements;
- fraud and market-manipulation risks;
- consumer disclosures;
- data-protection requirements;
- cross-border restrictions; and
- whether sandbox or regulatory-incubation participation is appropriate.
The "launch first and regularise later" approach is becoming increasingly dangerous, particularly were products may be characterised as unlawful investment schemes.
Immediate priority: establish a formal legal and compliance approval process for new products and material product changes.
7. Engage the policy process
Nigeria's virtual-assets framework will continue to develop through implementation guidelines, tax policies, supervisory standards and consultations. Responsible operators should not remain passive while rules affecting their businesses are being developed.
They should participate through recognised industry associations, consultation processes and properly structured engagement with the relevant authorities. Meaningful engagement should be evidence-based — operators should be able to explain how proposed rules will affect innovation, investment, consumer protection, financial inclusion, cybersecurity and market integrity.
Immediate priority: identify the policy issues that materially affect your business and prepare informed representations.
Compliance is now a competitive advantage
Nigeria is moving from regulatory fragmentation towards coordinated supervision. That transition will create additional obligations, but it should also provide greater certainty for serious operators, banks and investors.
The businesses most likely to succeed will be those that are:
- Properly classified — because they understand the approvals applicable to their
- Well governed— because they can safeguard customer assets and withstand regulatory
- Financial-crime resilient — because their systems can identify, investigate and escalate suspicious activity.
- Tax ready— because their transactions and revenue streams are transparent and
- Regulatorily engaged— because they treat government agencies as important stakeholders rather than obstacles.
The central question is no longer whether virtual assets will be regulated in Nigeria. It is whether each operator is building a business capable of attracting investment, maintaining institutional relationships and operating sustainably within the emerging framework.
The Road Ahead
Nigeria's digital assets regime is entering a new phase. The ISA 2025 and the SEC Rules provide a clearer legal foundation than previously existed, but they also signal greater regulatory expectations for businesses operating in the sector.
For market participants, the focus should extend beyond obtaining the necessary licences. Businesses should be reviewing their governance structures, compliance frameworks, customer onboarding processes, risk management systems and operational arrangements to ensure they are capable of meeting ongoing regulatory obligations as the market continues to mature.
Early engagement with the evolving framework is likely to place businesses in a stronger position to attract investment, build institutional partnerships and respond to future regulatory developments with confidence.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
