How is your legal team navigating Nigeria’s evolving regulatory compliance requirements, particularly under CAMA 2020, ISA 2025, and Central Bank directives?

The team remains up to date with, and actively monitors, proposed changes in laws and regulations through the websites and portals of legislators and regulators, including the National Assembly, the Central Bank of Nigeria (CBN) and the Nigeria Data Protection Commission, as well as through publications issued by leading law firms and key industry stakeholders. We continuously map new governance and reporting requirements into our internal policies and control frameworks, ensuring that corporate governance practices are implemented effectively and in line with regulatory expectations.

Over the past year, the regulatory landscape shaped by CBN directives has evolved significantly. Recent developments include the CBN’s mandate requiring all licensed payment service operators to complete migration to the ISO 20022 payment messaging standard and to geo-tag all payment terminals within specified deadlines. This has necessitated formal project plans, system upgrades and enhanced operational reporting to ensure compliance across our payment platforms. These directives have been incorporated into our compliance roadmap, with close collaboration between the compliance, technology and operations teams to implement the required changes, conduct testing and demonstrate readiness for regulatory examinations.

In addition, the CBN has strengthened transaction routing requirements through licensed Payment Terminal Service Aggregators (PTSAs), expanded sanctions screening obligations to include real-time customer and transaction monitoring under AML/CFT regulations, and clarified reporting requirements to agencies such as the Nigerian Financial Intelligence Unit (NFIU). The compliance team continues to oversee the implementation and operationalisation of these requirements across the organisation.

How is your legal department leveraging technology to improve compliance monitoring, contract management, or governance reporting?

For compliance monitoring, we leverage digital compliance and verification platforms such as Smile ID, MetaMap and Blusalt for customer due diligence at onboarding and identity verification, as well as Probe Compliance and Pastel for transaction monitoring and enhanced due diligence. By integrating the company’s mobile application and platform with these third-party software solutions, we ensure that regulatory requirements are embedded directly into our operational processes.

Internally, compliance obligations are tracked through centralised registers and shared dashboards, enabling timely reviews, prompt escalation of issues and audit readiness.

The legal department transitioned to a fully remote working arrangement in June 2025 and has continued to manage its internal functions through the effective use of technology, including Microsoft Office Suite tools such as Outlook, Teams, SharePoint, OneDrive and DocuSign. Contracts are managed through secure digital repositories with version control and structured approval workflows, reducing manual handling and enhancing visibility across the Group.

For governance reporting, we utilise standardised regulatory reporting templates prescribed by regulators and embed them into our internal processes. Required returns are submitted electronically through the relevant regulatory portals, including platforms such as the NFIU goAML portal for the submission of weekly AML/PEP reports, ensuring accuracy, consistency and timely regulatory engagement.