On December 22, 2023, the Central Bank of Nigeria (CBN)issued a directive to all banks and financial institutions(“Financial Institutions”, “FIs”) on their relationship with Virtual Asset Service Providers (VASPs). Accompanying this directive was the Guidelines on the Operations of Bank Accounts for Virtual Assets Service Providers (VASPs)(the “Guidelines”) to regulate the operations of VASPs due to the notable increase in peer-to-peer (P2P) exchanges within Nigeria, identified as a method to circumvent the previous prohibition on banks facilitating accounts for cryptocurrency transactions.

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