Nigeria – CM PB

2025, Cross-border, Update

Country Manual Private Banking

Nigeria

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Source of changesAnswers
Law / RegulationYes
New Position of the AuthoritiesNo
Evolution of Expert’s InterpretationNo

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

We have reviewed the documents following consultations with our local counsel. The Country Manual Private Banking Nigeria now includes references to new regulations, such as the CBN Guidelines on contactless payments. The Advertising Code was also revised in 2023 and now contains some slightly more specific rules regarding financial services. The most significant development is the introduction of the CBN Guidelines on Representative Offices. These do not introduce any major changes, but provide welcome clarification on permitted activities.

Non-material changes

Several paragraphs have been reworded, to provide more clarity and a more detailed explanation. In addition, the reception of orders (execution only) no longer includes the condition “on a one-to-one basis”, because the request necessarily comes from a single existing client.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “NIGERIA” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, May 13th, 2025