Nigeria implemented the crypto travel rule through Regulation 15 of the Securities and Exchange Commission (Capital Market Operators Anti-Money Laundering, Combating Terrorism Financing and Proliferation Financing) Regulations, 2022 (SEC AML/CFT/CPF Regulations), issued on May 12, 2022, one day after the SEC issued its New Rules on Issuance, Offering Platforms and Custody of Digital Assets (Digital Assets Rules, May 11, 2022), whose Part D sets registration requirements for virtual asset service providers. Regulation 15 requires all virtual asset transfers to be treated as cross-border transfers, with full originator and beneficiary information above USD 1,000 and a reduced data set below that threshold. The Money Laundering (Prevention and Prohibition) Act, 2022 (MLPPA) brings VASPs within the definition of financial institutions for AML purposes, and the Investments and Securities Act, 2025 (ISA 2025), signed into law on March 29, 2025, expressly includes virtual and digital assets in the definition of securities under the SEC's oversight.

Timeline: Implementation of the Crypto Travel Rule in Nigeria

• May 11, 2022: SEC issues the New Rules on Issuance, Offering Platforms and Custody of Digital Assets, including Part D on VASP registration.
• May 12, 2022: SEC issues the AML/CFT/CPF Regulations, 2022; Regulation 15 sets out the Travel Rule requirements for VASPs.
• May 2022: The Money Laundering (Prevention and Prohibition) Act, 2022 is enacted, bringing VASPs within Nigeria's AML regime.
• December 22, 2023: CBN issues the Guidelines on Operations of Bank Accounts for Virtual Assets Service Providers, permitting banks to provide accounts to SEC-licensed VASPs.
• March 29, 2025: The Investments and Securities Act, 2025 is signed into law, classifying virtual and digital assets as securities.

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Context

1. Is cryptocurrency legal in Nigeria?

Yes. Virtual and digital assets are expressly recognized as securities under the Investments and Securities Act, 2025, and dealing in digital assets is lawful subject to the SEC's Digital Assets Rules and registration requirements. Banks and other financial institutions may open designated accounts for SEC-licensed VASPs under the CBN Guidelines of December 22, 2023, which replaced the CBN's earlier restriction on banks servicing crypto businesses.

2. Are there any AML crypto regulations in Nigeria?

Yes. The MLPPA 2022 includes virtual asset service providers in its definition of financial institutions, subjecting them to Nigeria's AML obligations. For the capital market, the SEC AML/CFT/CPF Regulations, 2022 impose customer due diligence, record-keeping, suspicious transaction reporting and Travel Rule obligations on capital market operators (CMOs), including VASPs (Regulations 9, 15 and 21).

3. Is the Crypto Travel Rule mandated in Nigeria?

Yes. Regulation 15 of the SEC AML/CFT/CPF Regulations, 2022, titled "Travel Rule Requirements", requires VASPs to comply with the requirements applicable to all CMOs under the MLPPA and the Regulations, and subjects all virtual asset transfers to the information requirements for cross-border wire transfers (Regulation 15(1) and (3)).

4. Who regulates cryptocurrency in Nigeria?

The Securities and Exchange Commission (SEC) regulates virtual and digital assets as securities under the ISA 2025 and registers and supervises VASPs, digital asset exchanges, custodians and offering platforms under the Digital Assets Rules. The Central Bank of Nigeria (CBN) regulates how banks and other financial institutions provide accounts and settlement services to VASPs under its December 2023 Guidelines. The Nigerian Financial Intelligence Unit (NFIU) receives suspicious transaction reports.

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FATF Travel Rule requirements in Nigeria

1. Are there licensing or registration requirements for VASPs in Nigeria?

Yes. Part D of the Digital Assets Rules (Rules on Virtual Assets Service Providers) applies to all platforms that facilitate trading, exchange and transfer of virtual assets, to any person whose activities involve DLT-related and virtual digital asset services, to issuers and sponsors of virtual or digital assets, and to foreign operators that actively target Nigerian investors (Part D, Rule 1.1). A VASP must be structured as a body corporate (Part D, Rule 1.2) and register with the SEC, and the Rules set separate registration requirements for digital asset exchanges, custodians and offering platforms (Part D, General Requirements). In addition, under the CBN Guidelines, only entities licensed by the SEC may be provided designated bank accounts by Nigerian financial institutions.

2. When does the Crypto Travel Rule go into effect in Nigeria?

The Travel Rule requirements have applied since May 12, 2022, the date of the SEC AML/CFT/CPF Regulations, 2022, which contain the Travel Rule in Regulation 15.

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Complying with the FATF Crypto Travel Rule in Nigeria

1. What is the minimum threshold for the Crypto Travel Rule in Nigeria?

All virtual asset transfers must be treated as cross-border transfers and carry originator and beneficiary information regardless of amount (Regulation 15(3) and 15(6)). A wider scope of information is required at and above USD 1,000: cross-border transfers below USD 1,000 are exempt from the full information requirements and need only include the names and wallet addresses of the originator and beneficiary (Regulation 15(6)). For VASPs, an occasional transaction for customer due diligence purposes is one or more transactions exceeding the equivalent of USD 1,000 (Regulation 15(2)).

2. What personally identifiable information is required to be shared for the Crypto Travel Rule in Nigeria?

Originating VASPs must obtain, hold, verify and submit full originator and beneficiary information to the beneficiary VASP or financial institution immediately and securely, and beneficiary VASPs must obtain and hold the same information and verify the beneficiary information (Regulation 15(3)(a) and (b)). The required data varies with the transfer amount:

Source: SEC AML/CFT/CPF Regulations, 2022, Regulation 15(4) (full originator information), 15(5) (full beneficiary information) and 15(6) (transfers below USD 1,000). Regulation 15(5)(b) refers to "the originator's wallet address" as an element of full beneficiary information; in our interpretation this is intended to capture the wallet address associated with the beneficiary.

The same obligations apply to non-VASP capital market operators when sending or receiving virtual asset transfers on behalf of a customer (Regulation 15(3)(c)), and all originator and beneficiary information collected must be maintained in accordance with the record-keeping requirements of Regulation 21 (Regulation 15(7)).

3. Are there differences in customer PII requirements for cross-border transfers versus transfers within Nigeria?

No. All virtual asset transfers must be treated as cross-border transfers and are subject to the requirements for cross-border wire transfers (Regulation 15(3)). There is therefore no separate domestic regime for virtual asset transfers.

4. What are the non-custodial or self-hosted wallet requirements in Nigeria?

To our knowledge, Nigeria has not yet specified the requirements for transactions involving non-custodial or self-hosted wallets.

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Why choose Notabene for Crypto Travel Rule Compliance in Nigeria

Nigeria's Travel Rule is already in force: Regulation 15 requires every virtual asset transfer to carry originator and beneficiary information, with full data above USD 1,000, immediate and secure transmission, and verification duties on both sides of the transfer. Notabene's SafeTransact platform automates exactly this workflow for Nigerian VASPs and capital market operators, identifying counterparty VASPs, exchanging encrypted PII securely, applying the USD 1,000 threshold logic, and documenting compliance for the SEC.