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Introduction
Welcome to our October 2025 Regulatory Digest. As the year draws to a close, regulators across key African economies are intensifying their efforts to reshape the financial and digital landscapes. This month was marked by several high-impact developments.
In Nigeria, two events stand out: the nation's significant and welcome removal from the FATF grey list, and a long-awaited overhaul of agency banking rules by the Central Bank. This new guideline, the first major update in nearly a decade, introduces stringent new controls, including mandatory geo-tagging for all PoS terminals and daily limits on non-merchant transactions.
This push for tighter control is mirrored elsewhere. In Ghana, the cybersecurity regulator is seeking amendments to the 2020 Cybersecurity Act to expand its authority significantly, including powers to search, seize, and arrest in cybercrime investigations. Concurrently, Kenya has decisively moved to regulate its digital asset market by passing the Virtual Asset Service Providers Bill, officially designating the Central Bank of Kenya as the primary regulator for cryptocurrencies.
From financial crime monitoring to fintech and digital assets, this month's updates signal a clear, region-wide trend toward greater oversight and enforcement. In this digest, we analyse these key developments and their implications.
A quick summary...
CBN Issues Guidelines for the Operations of Agent Banking in Nigeria
The Central Bank of Nigeria (CBN), on October 6, 2025 issued the Guidelines for the Operations of Agent Banking in Nigeria (the "Guidelines") which supersede all previous guidelines on agent banking.
The Guidelines recognise the critical role of agent banking in expanding access to financial services and aim to strengthen the regulatory framework governing its operations. The Guidelines consolidate all existing policies relating to agent banking and agent relationships into a single, comprehensive document while addressing emerging issues within the ecosystem.
The Guidelines seek to enhance service delivery through agent banking channels, promote financial inclusion, and encourage responsible market conduct. They set out the roles and responsibilities of stakeholders, permissible and non-permissible activities, agent qualifications, due diligence requirements, and governance obligations.
Importantly, the Guidelines stipulate that an agent may belong exclusively to only one principal and may operate under the network of only one super-agent at a time. They also require a formal agreement between each agent and principal, incorporating the mandatory clauses outlined in the Guidelines. The Guidelines also set a daily cumulative cash-out limit of ₦1,200,000 per agent.
While the Guidelines take immediate effect, the provisions relating to agent location and agent exclusivity will become effective from April 1, 2026.
CBN Issues Draft Guidelines on the Operations of Automated Teller Machines in Nigeria
On October 9, 2025, the CBN published the Draft Guidelines on the Operations of Automated Teller Machines in Nigeria (the “Draft Guidelines”). The Draft Guidelines supersede the requirements on ATM operations contained in the Guidelines for the Operations of Electronic Payment Channels in Nigeria (2020) and all previous regulations relating to ATMs.
The Draft Guidelines which apply to all deposit money banks, other financial institutions, independent ATM deployers and any card-issuing institutions in Nigeria aim to establish minimum standards for the deployment, operation, and maintenance of ATMs across Nigeria. They seek to improve access to ATM services in both rural and urban areas, enhance consumer protection and align Nigeria’s ATM operations with global standards. They also provide additional guidance on ATM deployment density, operational and security requirements, and overall compliance monitoring.
The Draft Guidelines mandates all ATM deployers and acquirers to comply with the Payment Card Industry Data Security Standards (PCI DSS) and any Independent ATM Deployer (IAD) must obtain prior written approval from the CBN before commencing deployment activities. Additionally, to promote accessibility and inclusivity, two percent of ATMs deployed by each acquirer must feature tactile graphic symbols for the use of visually impaired customers, and the locations of such ATMs must be clearly publicised on the deployer’s corporate website. In addition, all card issuers are required to deploy at least one ATM for every 5,000 payment cards issued, to be achieved within three years - 30% by 2026, 60% by 2027, and 100% by 2028.
The Draft Guidelines also mandate instant reversal for failed on-us ATM transactions. Where instant reversal fails due to technical issues or other system glitches, manual reversals must be completed within 24 hours, while refunds for failed not-on-us transactions must be completed within 48 hours.
CBN Welcomes Nigeria’s Removal from FATF Grey List
CBN has announced Nigeria’s removal from the Financial Action Task Force’s (FATF) “grey list,” marking a significant step forward in the country’s anti-money laundering and counter-terrorism financing framework. The decision, which follows an on-site FATF assessment, confirms that Nigeria has addressed strategic deficiencies identified in previous evaluations.
The delisting is the culmination of a two-year national reform effort led by the Federal Government, with the CBN,Nigerian Financial Intelligence Unit (NFIU), the Economic and Financial Crimes Commission (EFCC), and Ministry of Justice playing key roles. The CBN’s contributions focused on improving supervision of financial institutions, enforcing risk-based compliance standards, strengthening information sharing among regulators, and enhancing transparency in foreign exchange operations.
Nigeria’s exit from the grey list is expected to boost investor confidence, lower cross-border compliance costs, and ease access to international financial channels. It also signals renewed global confidence in Nigeria’s financial governance and reform trajectory, reinforcing the country’s position as a credible player within the international financial system.
SEC Issues Public Warnings Against Unregistered Cryptocurrency Investment Platform
The Securities and Exchange Commission (SEC) issued public disclaimers warning investors against engaging with unregistered cryptocurrency trading and investment platforms. These notices, published through the SEC’s official website and social media channels, aim to protect the investing public from fraudulent or unregulated activities. This forms part of the SEC’s broader mandate to regulate and maintain transparency within Nigeria’s cryptocurrency trading and investment ecosystem.
SEC Reports over $50 Billion in Cryptocurrency Transactions in One Year
SEC reported that Nigeria’s cryptocurrency market recorded over $50 billion in transactions between July 2023 and June 2024, showing a growing trend of investors preference for digital assets compared to the low participation in the traditional capital market.
SEC Reports Low Capital Market Participation Among Nigerians
SEC reported that fewer than 4% of Nigeria’s adult population actively participates in the capital market, highlighting a significant gap in financial inclusion despite a strong appetite for risk among citizens. According to the Commission, this low participation contrasts sharply with the over 60 million Nigerians who engage in daily gambling activities averaging $5.5 billion daily. The Commission reflects on the need to rebuild investor confidence, expand financial access, and strengthen the capital market’s role in supporting Nigeria’s economic growth.
SEC Signs MOU with SMEDAN to Increase SMEs' Access to Capital Market Financing
SEC and the Small and Medium Enterprises Development Agency of Nigeria (SMEDAN) have signed a Memorandum of Understanding to improve access to long-term financing for small and medium enterprises (SMEs) through the Nigerian capital market. The partnership aims to create alternative funding sources for over 40 million registered SMEs, integrate them into the formal financial system, and support their access to equity and debt financing. It also provides for capacity-building, financial literacy programmes, and joint initiatives to encourage SME listings on recognised exchanges, aligning with national goals of economic growth, job creation, and financial inclusion.
FMCIDE and Denmark Formalise Digital Cooperation to Strengthen Innovation and Connectivity
The Federal Ministry of Communications, Innovation and Digital Economy (FMCIDE) and the Government of Denmark have formalised a new phase of digital cooperation through a Memorandum of Understanding (MoU). The partnership aims to advance collaboration in digital infrastructure, Artificial Intelligence (AI), connectivity, and innovation, fostering mutual growth and knowledge exchange between both nations. Under the agreement, initiatives will focus on expanding broadband access, developing smart governance solutions, and creating opportunities for Nigerian tech talent to engage with Danish companies. Denmark has also committed €12 million through the European Union to support Nigeria’s 3 Million Technical Talent (3MTT) programme, reinforcing its investment in Nigeria’s digital economy.
FMCIDE and Google Partner to Train Nigerian Public Servants in Artificial Intelligence
The FMCIDE and Google have launched a partnership to train Nigerian public servants in Artificial Intelligence (AI) applications as part of a global initiative to equip one million government workers. The programme will be delivered through the Apolitical Government AI Campus, a global platform for AI capacity building in governance supported by Google. It will include expert-led sessions, frameworks, and peer learning opportunities designed to help public sector leaders and practitioners apply AI tools to improve productivity and service delivery. The initiative reflects a shared commitment to advancing AI adoption, strengthening governance efficiency, and accelerating Nigeria’s digital transformation.
NITDA Launches National Digital Trustmark to Strengthen Online Security
On October 21, 2025, the National Information Technology Development Agency (NITDA), in collaboration with the Nigerian Association of Chambers of Commerce, Industry, Mines and Agriculture (NACCIMA) and supported by GIZ, launched the National Digital Trustmark. The initiative aims to enhance trust and security across Nigeria’s digital economy by certifying credible online businesses. It is designed to promote transparency, protect consumers, and drive inclusive growth within Nigeria’s expanding digital marketplace.
NITDA Receives Global Recognition for Advancing Open Digital Governance
Nigeria has achieved a significant milestone on the global stage as the NITDA received two international awards at the 2025 Open Government Partnership (OGP) Summit in Spain. In collaboration with civil society organisation Dataphyte, Nigeria secured the Regional Award for Africa and the Middle East for advancing open digital governance, and the Thematic Award as the global winner in the Digital Governance Category. Out of 160 commitments from 42 countries, NITDA’s leadership in promoting transparent, accountable, and citizen-focused digital governance positioned Nigeria as a model for innovation and trust-driven reform.
NITDA and UNITAR Strengthen Partnership to Advance Digital Capacity in Nigeria
NITDA and the United Nations Institute for Training and Research (UNITAR) are deepening their partnership to enhance digital skills and capacity development across Nigeria. The collaboration will focus on key areas including digital education, Artificial Intelligence (AI), cybersecurity, and governance, supporting efforts to build a digitally empowered and globally competitive workforce.
NITDA Commissions 10 Digital Economy Centres to Drive Inclusive Growth
NITDA, in collaboration with the Renewed Hope Initiative, has commissioned 10 Digital Economy Centres across Nigeria to bridge the digital divide and promote inclusive digital growth. The facilities, located in states including Abia, Delta, Edo, Kano, Lagos, and Ondo, are equipped with modern technology, learning tools, and internet connectivity to support digital education and innovation. Each centre will serve as a hub for students, entrepreneurs, and citizens to acquire digital skills, explore emerging technologies, and unlock new opportunities in the digital economy. The initiative reinforces NITDA’s mission to foster nationwide inclusion and advance the vision of a digitally empowered Nigeria.
NITDA Strengthens Collaboration with Finnish Experts to Enhance Cybersecurity Frameworks
NITDA is deepening collaboration with Finnish cybersecurity experts to strengthen Nigeria’s cybersecurity frameworks and promote sustainable digital resilience. The partnership, formalised during a visit by a Finnish delegation to NITDA’s headquarters in Abuja, focuses on advancing regular cybersecurity compliance checks for data centres and government institutions. It also seeks to embed periodic maturity assessments and sustainability frameworks to ensure adherence to global best practices. Both parties reaffirmed their commitment to fostering capacity building and promoting a culture of proactive cybersecurity management across Nigeria’s digital ecosystem.
NCC Opens Public Consultation on Draft Internet, Licensing, and Enforcement Regulations
The Nigerian Communications Commission (NCC) announced the commencement of public consultations on three key draft subsidiary legislations: the Internet Code of Practice (as amended), the Regulations on Licensing (as amended), and the Enforcement Process Regulations (as amended). The NCC invited stakeholders and the public to review and submit written comments ahead of the scheduled virtual public inquiry sessions set for November 11 and 12, 2025. The deadline for written submissions to be sent to the Commission was October 31, 2025.
Senate Confirms New NCC Chairman and Restores Full Board Leadership
The Nigerian Senate has confirmed Mr Idris Olorunnimbe as the new Chairman of the NCC, along with eight other board members, restoring full leadership to the commission after more than a year without a complete board. The confirmation, also reconstitutes the Universal Service Provision Fund (USPF) board. The new board, which includes experts from technology, law, and public policy, is expected to strengthen policy direction, improve broadband expansion, support 5G rollout, and enhance transparency in Nigeria’s $75 billion telecommunication sector.
NCC Collaborates with CBN on a Framework to Resolve Failed Electronic Transactions
The NCC, in collaboration with the CBN, has developed a joint framework to address failed airtime recharge and data subscription transactions on electronic platforms such as banking apps and USSD. The initiative aims to enhance consumer protection, ensure timely refunds for failed transactions, and strengthen trust in digital financial and telecom services.
NCC to Sign MOU with NFVCB to Address Digital Piracy and Protect Creative Industry
The NCC has announced plans to formalise its partnership with the National Film and Video Censors Board (NFVCB) through a Memorandum of Understanding (MoU) aimed at protecting Nigeria’s creative industry and curbing digital piracy. The partnership will strengthen efforts against unlicensed streaming and piracy on digital platforms while supporting child online protection initiatives and promoting a safer digital ecosystem for creative professionals.
NCC Launches Quarterly Network Performance Reports Initiative
The NCC has launched its quarterly Public Network Performance Reports initiative to enhance transparency, accountability, and consumer experience in the telecommunication sector. The reports will provide data-driven insights on network quality, 5G rollout, device adoption, and service performance, allowing consumers to compare operators and encouraging healthy competition. The initiative which is supported by the FCCPC and NITDA, aims to strengthen trust, promote informed investment, and guide network expansion through evidence-based regulation. The reports will be updated quarterly and made publicly available on the NCC’s website.
NCC Publishes Research Report on Telecom Service Quality in Major Cities
The NCC has published a research report on the quality of telecom services in Nigeria’s major cities, revealing that poor service experiences in areas such as Lagos and Abuja are largely due to limited network capacity and high data usage.The report highlights that congestion in densely populated urban zones has led to dropped calls, slow downloads, and poor streaming quality. The NCC recommended increased infrastructure investments, including accelerated 5G rollout and optimisation of existing 4G networks, to enhance service quality and improve user experience nationwide.
NCC Launches Crowdsourcing Report and National Coverage Maps
The NCC, in partnership with Ookla, has launched its crowdsourcing report and National Coverage Maps to promote data-driven regulation and improve consumer experience in the telecommunication sector. The initiative aims to enhance transparency, service quality, and accountability by allowing consumers to compare network performance and enabling operators and policymakers to make informed decisions. According to the NCC, the platform will help address network strain in major urban areas, guide 5G deployment, and expand coverage to underserved regions, supporting Nigeria’s goal of reliable and inclusive connectivity.
FMITI Teams with UNIDO to Launch Industrialisation Initiative (PCP 2024–2028)
The Federal Ministry of Industry, Trade & Investment (FMITI) partnered with UNIDO to inaugurate the Programme for Country Partnership (PCP 2024–2028), targeting inclusive industrial development and boosting export competitiveness. The move aligns donor support with national goals for industrial transformation. The key question: can this initiative strike the balance between high-level plans and ground-level impact?
FMITI Revives Nigeria International Trade Fair for Late 2025
The FMITI is spearheading the return of the Nigeria International Trade Fair (NITF 2025), scheduled for November 21 to 30 at the Lagos International Trade Fair Complex. This revival signals FMITI’s intent to leverage traditional trade platforms as catalysts for digital and export transformation. After years of pause, reviving this platform could reinvigorate national trade and investment visibility, but execution will matter more than memory.
Reps Urge FMITI to Inject ₦350m into 2026 Budget to Revive Ailing Industries
The House of Representatives has called on the FMITI to allocate ₦350 million in the 2026 budget for the revival of non-operational industries across Nigeria. The move is aimed at stimulating local production, safeguarding jobs, and enhancing Nigeria’s industrial resilience. While the sum may seem modest, it signals renewed legislative interest in industrial recovery and could serve as a test case for how effectively FMITI can link fiscal planning with real sector revival.
Kenya Enacts the Virtual Asset Service Providers Act, 2025
Kenya is set to formalise its digital asset market with the new Virtual Asset Service Providers (VASP) Act, commencing on November 4, 2025. This Act establishes a comprehensive regulatory and licensing framework to be jointly administered by the Central Bank of Kenya (CBK) and the Capital Markets Authority (CMA), a dual-regulator approach that replaces the previously proposed single authority. While the Treasury and regulators will develop the specific market-entry rules, the licensing regime is expected to cover a wide array of activities, from exchanges and wallet providers to stablecoin issuance and asset tokenisation. The Act mandates strong AML/CFT compliance, requiring all VASPs to implement digital KYC and transaction monitoring. This move aligns Kenya with global standards like the EU's MiCA, positioning it as a key, regulated hub for virtual assets in East Africa.
Ghana Seeks to Amend its Cybersecurity Law
In a move to strengthen its fight against cybercrimes, Ghana is seeking to amend its Cybersecurity Act of 2020. A review of the bill identified that the Cyber Security Authority, which is the regulator, will see its power expanded to include arrest, search, and seizure to prosecute cybercrimes under the Attorney General's authority, including the ability to recover criminal proceeds. A new Joint Cybersecurity Committee, uniting key state institutions, will coordinate national cybersecurity implementation. To ensure financial sustainability, the CSA is allocated substantial, diversified funding streams, including a 50% share of all fines levied under the Act and portions of specific taxes and levies. The regulatory scope extends to individuals, mandating that all cybersecurity professionals obtain CSA accreditation to practice, with fee-based services requiring a full license. Furthermore, the Authority will establish a mandatory national certification framework for practitioners and service providers, creating localised alternatives to international standards like ISO 27001, with the CSA also setting fee limits for these certifications.
The third quarter of 2025 has underscored a period of significant regulatory maturation and strategic realignment across Nigeria and the broader West African region. The collective activity from Nigerian authorities, ranging from new CBN directives in finance and the SEC's proactive partnerships in the capital and crypto markets, to strategic updates from NITDA, the NCC, and the FMITI, demonstrates a concerted shift from a reactive to a proactive, digital-first regulatory stance. This domestic momentum is reflected in regional counterparts, as seen in Ghana's contentious but significant proposed amendments to its cybersecurity law.
For businesses and investors, this evolving landscape presents both opportunity and obligation. The cascade of new rules demands heightened agility and robust compliance frameworks. The capstone to these domestic efforts is Nigeria's hard-won removal from the Financial Action Task Force (FATF) grey list, an achievement shared with Burkina Faso, Mozambique, and South Africa. This serves as a powerful international validation of the country's enhanced Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) regimes, signalling a more secure and credible investment environment.
Looking ahead, key developments will define the success of this regulatory push:
The common thread is a definitive move towards more sophisticated and structured regulatory environments. The ultimate challenge for regulators will be to maintain this momentum, ensuring that new frameworks achieve their core objectives of market safety and financial inclusion without inadvertently stifling innovation or compromising fundamental rights. The guardrails for a more robust and integrated economy are being firmly established, raising the stakes for compliance while clearing a more confident path for sustained growth.
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