Balogun Harold - Leading Commercial &amp; Corporate Law Firm

Minimum KYC Requirements for Opening Bank Accounts for Nigerian Entities Offshore

Notwithstanding the removal of Nigeria from the FATF Grey List, foreign banks are still required to conduct full KYC and AML/CFT checks for Nigerian clients, as these obligations remain mandatory under global banking regulations. This article provides some local intel for foreign banks on the minimum requirements for safely and efficiently onboarding Nigerian clients while maintaining compliance with international AML/CFT standards.

October 30, 2025

Defence & Security Financing in Nigeria: Recent Developments

The establishment of the Defence and Security Infrastructure Fund represents a significant step towards strengthening Nigeria’s security architecture

October 29, 2025

New Capital Gains Tax Rules for Nigerian M&A Transactions

While gains on the disposal of shares in Nigerian companies are generally chargeable, the Nigeria Tax Act introduces important exemptions designed to encourage investment and capital market activity.

October 29, 2025

When Should Liability Caps Be Applied – Before or after Set-Off ?

Technology contracts frequently include liability caps. For example, a technology vendor might agree that “no more than 12 months’ fees” can be claimed. But complications often arise when both parties have contractual claims against each other. Should the parties set off their claims first and then apply the liability cap to the net amount? Or should the cap bite on each party’s liability separately, with set-off only after the cap has reduced one side’s claim?

September 30, 2025

LASPA: Parking Regulations in Lagos State

Parking in Lagos is no longer an unregulated free-for-all. Since the enactment of the Lagos State Parking Authority Law, 2018 and the operational rollout of the Lagos State Parking Authority, the State has moved to bring both public and private parking under a unified regulatory framework.

September 16, 2025

Cross-Border Data Transfers in Nigeria – U.S. SaaS Companies

For DPOs and privacy counsel of U.S. SaaS companies and Nigerian customers, one big challenge is ensuring lawful cross-border data transfers. This article explains the rules and what NDPA compliance for U.S. SaaS companies requires in practice.

September 14, 2025

Legal Update

Nigeria Issues 2024 Online Trust and Safety Compliance Report

The National Information Technology Development Agency (NITDA) has released the 2024 Compliance Report on the Code of Practice for Interactive Computer Service Platforms/Internet Intermediaries (CoP for ICSPs/IIs).

August 22, 2025

Explainer

Technical and Organizational Measures- A Primer

Technical measures are the technological controls used to protect personal data. On the other hand, organizational measures are the internal policies, governance frameworks, and cultural practices that ensure personal data is processed responsibly

August 20, 2025

Artificial Intelligence in Nigeria: Key Regulatory Considerations

A recent report by Google titled "Our Life With AI: From Innovation to Application" suggests that generative AI adoption in emerging markets is significantly higher than global averages. Within that context, we examine some regulatory touch points within the emerging legal framework for artificial intelligence services in Nigeria.

August 17, 2025

Are U.S. Foreign SaaS Corporations Regulated by Nigeria?

We think that the African SaaS market is already significantly larger than commonly cited figures suggest. While some sources estimate it at around $3.5 billion in 2023, we believe this substantially understates actual consumption.

August 16, 2025

Online Safety Act: Age Verification and Data Reuse

The risk of reuse of age verification data is conceivable

August 13, 2025

Online Trust & Safety in Nigeria: An Overview

In Nigeria, the regulatory landscape surrounding online trust and safety is anchored primarily in the Code of Practice for Interactive Computer Service Platforms & Internet Intermediaries (the “Code”). This framework defines the rules that digital platforms must follow, with specific obligations

August 5, 2025

Bank Corporate Client Acquisitions: Employment Law Considerations

If women were selected, incentivized, or subtly pressured to use charm or appearance to attract business, this may constitute constructive dismissal, if such women feel compelled to resign.

August 5, 2025

Explainer

Nigeria Data Privacy Law 2025: NDPA & GAID Guide

In March 2025, NDPC issued the General Application and Implementation Directive (GAID) 2025, an operational rulebook that consolidates how the Act applies in practice and introduces detailed rules

August 5, 2025

Lagos State Publishes List of Over 170 Illegal Estates

The Lagos State Ministry of Physical Planning and Urban Development has issued a formal public notice identifying more than 170 real estate developments in Ibeju-Lekki, Epe, Eti-Osa, and other areas as non-compliant estates ( the "Illegal Estates Notice")

August 4, 2025

New Online Lending Regulations in Nigeria by FCCPC

The FCCPC is saying, if you are a digital lender and your business or partnerships do not meet certain minimum standards, we would not let you start the business or enter/continue that partnership agreement. If you have already commenced business, we would stop you from continuing to do business, until you meet our standards. This is a very high bar and commendable.

August 4, 2025

Legal Update

Nigeria's Open Banking: Data Access Considerations

As Nigeria transitions to an Open Banking regime, we anticipate a wave of fintech innovation driven by secure and regulated access to customer data. While this access presents significant opportunities for product development, it is governed by strict regulatory safeguards. In this update, we outline key considerations for Fintechs seeking to responsibly and lawfully leverage open banking APIs to access customer data.

July 29, 2025

CBN's Open Banking Guidelines: Implications for Non-Bank Entities

It is often assumed that the CBN's Open Banking Guidelines are relevant only to banks and licensed fintech companies. However, a closer reading of the Open Banking Guidelines suggests that its application is significantly broader, extending to any company that shares or consumes financial data through APIs, regardless of sector.

July 27, 2025

CBN Audits: Key Considerations for Fintechs & Microfinance Banks

A CBN audit is an on-site or off-site examination conducted by the Central Bank of Nigeria to assess a regulated financial institution’s compliance with applicable laws, regulations, guidelines, and prudential requirements

July 22, 2025

LASBCA “Request-for-Documents” Letters: Key Considerations

The Lagos State Building Control Agency (LASBCA) has begun mass-issuing “Request for Documents” notices to property owners in Lagos State.

July 17, 2025