Digital assets are now firmly within Nigerian regulation. The Investments and Securities Act 2025 recognises virtual and digital assets as securities and brings digital asset businesses within the supervision of the Securities and Exchange Commission (SEC). The SEC has issued rules for digital asset offerings, platforms and custody, and runs an incubation programme through which digital asset service providers move towards full registration. The Central Bank of Nigeria (CBN) has also issued guidelines allowing banks to open and operate accounts for registered virtual asset service providers.
At the same time, digital asset businesses must comply with anti-money laundering rules, tax law, data protection and consumer protection. We help clients build compliant businesses and products, and act for them when things go wrong.
Who we act for
- crypto exchanges, brokers, custodians and wallet providers
- Web3, DeFi and blockchain infrastructure startups
- token issuers, including real estate and asset tokenisation projects
- fintechs and payment companies adding digital asset features
- banks and investors dealing with digital asset businesses
- individuals and companies who have lost funds in crypto fraud
SEC registration and regulatory compliance
- assessing whether a product or token is a security or digital asset within SEC regulation
- registration of digital asset exchanges, offering platforms, custodians and other service providers, including through the SEC's incubation programme; see SEC registration
- minimum capital, governance, custody and cybersecurity requirements
- consumer disclosures, risk warnings and marketing rules
- ongoing reporting and responses to SEC enquiries
Token offerings and tokenisation
We advise on structuring and launching token offerings, initial exchange offerings and the tokenisation of real-world assets such as real estate, commodities and receivables, including the documents, disclosures and approvals needed and how investors' rights are protected.
Banking, AML and tax
- opening and maintaining bank accounts under the CBN's guidelines for virtual asset service providers
- anti-money laundering and counter-terrorist financing compliance, including know-your-customer checks, transaction monitoring and suspicious transaction reporting; see AML compliance
- the travel rule and sanctions screening
- tax on digital asset transactions and gains following the 2025 tax reforms; see tax advisory
Structuring Web3 businesses
Many Web3 businesses operate across several countries. We advise on corporate structure, including offshore holding companies, foundations and DAOs, token allocations to founders and investors, and the contracts and terms of service that govern the platform. We also review smart contracts' legal terms and their enforceability under Nigerian law.
Disputes and crypto fraud recovery
Crypto fraud, hacks and failed platforms cause large losses. Where funds can be traced to an exchange or wallet, we act quickly to obtain freezing orders and disclosure from exchanges, work with law enforcement and pursue recovery. We also act in disputes between platforms and their customers, partners and investors.
Related services
Digital asset businesses often need other approvals too. See our fintech lawyers for payments and lending licences, and data protection compliance for customer data.
Our technology lawyers in Lagos and Abuja advise local and international blockchain businesses. To discuss your project, contact us.
