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An Overview of Legal Requirements For a Bank’s Website

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By Gbolahan Oluyemi

Websites create an online presence for businesses and serve as a valuable tool to enhance e-commerce, customer engagement, branding, marketing, and lead generation. A website provides the bank customers with information on branch location, the composition of the bank’s management team, product features, forms, and terms and conditions of service.

Aside from the branding and customer information, banks are legally required to publish certain information on their website. This article considers some of the information banks are mandated by law to publish on their respective websites. Additionally, banks may explore fractional general counsel services to navigate the intricate legal landscape efficiently, ensuring compliance and robust risk management.

  1. A bank is required to publish its foreign exchange, lending, and deposit rates on its website. This is because section 22 (1) of the Banking and Other Financial Institutions Act (BOFIA) directs all banks (except non-interest banks) to publish information on foreign exchange rates, lending and deposit rates on their respective websites, failing which such Bank will be liable to a penalty of not less than N5,000,000 and an additional N100,000 for every day during which the contravention continues.
  1. BOFIA require banks to disclose their obligations to report suspicious transactions on their respective websites, failing which the bank will be liable to a penalty of not less than N5,000,000 and an additional N100,000 for every day during which the contravention continues.
  1. A bank is required to publish its certificate of occupancy on its website. The bank is also required to publish its approved audited accounts and financial statements. Section 22 (1e) of BOFIA mandates these obligations and imposes a penalty of not less than N5,000,000 and an additional N100,000 for every day during which the contravention continues.
  1. The Nigerian Data Protection Regulation 2019 impose a duty on banks to publish a privacy policy on all data-collecting platforms (which may include a website). The privacy policy should address at minimum the items listed in Article 2.5 of the Nigerian Data Protection Regulation 2019 which include:
  • what constitutes the Data Subject’s consent;
  • description of collectable personal information;
  • purpose of collection of Personal Data;
  • technical methods used to collect and store personal information, cookies, JWT, web tokens etc;
  • access (if any) of third parties to Personal Data and purpose of access;
  • available remedies in the event of violation of the privacy policy;
  • the time frame for remedy.
  1. Another piece of information required on a bank’s website is the details and location of Automated Teller Machines (ATM) for persons with visual impairment. Article 1.1.1 (G) of the Central Bank of Nigeria (CBN) guidelines on operations of electronic payment channels in Nigeria requires that 2% of ATMs deployed should have tactile graphic symbols for the use of visually impaired customers. The location of the specialised ATMs should be published on the bank’s website.
  1. Banks deploying agent banking by providing services to customers through a third party (agent) are required by Article 9 of the CBN Guidelines for the regulation of Agent Banking and Agent Banking relationships in Nigeria to publish an updated list of all their agents on their websites.
  1. The CBN Corporate Governance Guidelines for Commercial, Merchant, Non-interest and Payment Service Banks in Nigeria 2023 require publicly quoted banks to publish a summary of their risk management policies. Further, all Banks are mandated by the guideline to publish a summary of the Bank’s insider trading and related party transaction policy on their website.

In view of the above, the content of a bank’s website is not solely a technology or branding affair.  There are legal issues to be considered in populating content for a bank’s website. In all, banks are mandated by the CBN Guidelines on Disclosure and Transparency to ensure that their websites and other information dissemination channels are functional and regularly updated with the current product features and service offerings.

Banks are encouraged by CBN guidelines to communicate with stakeholders via their website and also host a stakeholder communication policy on their website.

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Banking

CBN Delists Non-Compliant Bureaux De Change Operators

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By Adedapo Adesanya

The operating licences of all legacy Bureau De Change (BDC) operators who failed to meet the new licensing requirements have been revoked by the Central Bank of Nigeria (CBN).

This happened after the central bank streamlined the BDCs to 82 in order to sanitise the foreign exchange (FX) market in the country.

The latest development was revealed by the apex bank in its Frequently Asked Questions document on the current reform of the bureau de change, published on its website on Tuesday.

According to the document, the CBN has now enforced the final cutoff, declaring that any BDC that did not meet the requirements by the end of November is no longer recognised.

“The guidelines provided a transition timeline of six months from the effective date, 3 June 2024, with a deadline of 3 December 2024, for all existing BDCs to meet the requirement of the new Guidelines or lose their licence(s). However, the management of the CBN graciously extended this deadline by another six months, which ended 3 June 2025, to give ample time for as many legacy BDCs desirous of meeting the new requirements to do so.

“Consequently, any legacy BDC that failed to meet the requirements of the new Guidelines as of 30 November 2025 has ceased to be a BDC, as its licence no longer exists. Please visit the CBN website for the updated list of existing BDCs in Nigeria,” the apex bank said.

According to the CBN, before its latest decision, an extended compliance window was granted under the revised BDC Guidelines. Existing operators were initially given six months, June 3 to December 3, 2024, to satisfy the new regulatory conditions.

The CBN later granted an additional six-month extension, which elapsed on June 3, 2025, to allow more operators to align with the updated standards.

The new measures form part of broader efforts by the CBN to strengthen transparency, compliance, and stability within Nigeria’s foreign exchange market.

The new CBN regulatory framework for BDCs, introduced in February 2024, mandated BDC operators to meet higher capital requirements. Tier-1 operators are required to meet a minimum capital requirement of N2bn, while Tier-2 operators must meet N500m as MCR.

The bank added that it would continue to receive applications on its Licensing, Approval and Requests Portal from prospective promoters, and those that meet the criteria will be considered for a license.

However, the CBN said it reserves the right to discontinue the licensing of BDCs at any time.

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Banking

O3 Capital to Unlock N95bn Festive Spending Boom With Blink Card

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03 Capital Blink Card

By Modupe Gbadeyanka

A non-bank credit card issuer, 03 Capital, has introduced a travel card designed to unlock the N95 billion festive spending boom in Nigeria.

The new initiative, known as the 03 Capital Blink Travel Card, promotes economic participation among returning Nigerians, expatriates, and tourists.

A statement from the financial technology (fintech) firm is available instantly to use at over 40 million merchants and ATMs nationwide.

The Blink Card, to be issued in both digital and physical form, is loaded with currency from any foreign bank card, converted to Naira, enabling transactions to be completed in the local currency.

The card offers tap-to-pay and cash withdrawals at over 40 million merchants and ATMs nationwide, making it the ideal solution for visitors to Nigeria.

It also avails Nigerians in the Diaspora to spend like locals when they return to their country of origin.

Payments for goods and services can be completed via the virtual Blink Card, linked to the O3Cards app. Funds can also be transferred instantly to all local banks and other financial institutions.

According to the World Bank, remittance inflows account for approximately 5.6 per cent of Nigeria’s gross domestic product (GDP), and the resultant spending power is unlocked when the Diaspora returns home for the festive period.

In December 2024, about N95 billion was injected into the Nigerian economy by inbound passengers – 90 per cent being diasporic Nigerians – spending on short-let accommodation and hotels, events and hospitality, nightlife and dining, and vehicle rentals.  The launch of the Blink Card promises to spur this spending further, providing a significant boost to local businesses.

Blink Cards are available for collection at all Nigerian international airports, offering an immediate and hassle-free route to financial empowerment for people arriving in the country.

Blink Card carriers benefit from increased convenience, flexibility, and safety by not needing to carry large amounts of physical cash, while the ability to pre-load cards promotes smarter budgeting practices.

“We are excited to launch the Blink Card to promote greater economic participation among visitors to Nigeria.

“The card removes the needless friction and costs involved in legacy foreign exchange and cash payment processes, offering a quicker and more transparent option for spending in the country.

“As Nigerians begin travelling home for Christmas – combined with the regular traffic of arriving tourists, expatriates, and businesspeople – this is the perfect time to launch a solution catering to the financial needs of visitors, tapping into the seasonal spending boom which provides an annual lifeline for local economies and SMEs,” the chief executive of 03 Capital, Abimbola Pinheiro, stated.

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Banking

Interswitch Champions Dialogue on Alternative Credit Scoring for Underserved

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Alternative Credit Scoring for Underserved

By Modupe Gbadeyanka

Technology leaders from across Nigeria’s digital finance ecosystem recently converged on Eko Convention Centre in Lagos to explore pathways for expanding credit access to underserved communities.

It platform for this was the 2025 Committee of e-Business Industry Heads (CeBIH) Annual Conference themed Reimagining Financial Inclusion through Cultural Shifts in Consumer Credit. Interswitch was a returning gold sponsor.

At a high-impact panel session titled Alternative Credit Scoring for the Underserved, moderated by Wunmi Ogunbiyi of the CeBIH Advisory Council, the Divisional Head of Product Management and Solution Delivery at Verve International, a subsidiary of Interswitch Group, Mr Ademola Adeniran, examined how alternative data and digital intelligence can unlock credit for millions excluded by conventional financial models.

“For us, this conversation goes beyond technology. It is about designing credit systems that truly reflect African realities.

“Millions transact daily outside traditional banking frameworks, and alternative credit scoring enables us to recognise that economic activity and responsibly convert it into access to finance.

“At Verve and Interswitch, we are committed to building the digital infrastructure that makes this inclusion scalable and sustainable,” Mr Adeniran stated.

Also, the Vice President for Sales and Account Management, Digital Infrastructure and Managed Services at Interswitch Systegra, Ms Robinta Aluyi, stressed the importance of African-led solutions in addressing the continent’s financial challenges, noting that sustainable progress must be rooted in local realities.

Interswitch’s strength, she said, lies in the fact that it was built on the continent, for the continent, with solutions designed to serve individuals, small businesses, enterprises, and government institutions across every layer of the payment value chain.

She also emphasized the company’s purpose-driven approach to building the infrastructure that powers Africa’s digital economy and enabling secure money movement on a scale.

“Interswitch helps people navigate their daily lives with greater ease. We make transactions flow safely and reliably. We do this by connecting banks, supporting secure and reliable payments, and strengthening the entire value chain of digital finance.

“Today, we hold a significant portion of the market, and that achievement reflects the deep trust our banking and fintech partners place in our platforms. We continue to deliver because the ecosystem has worked with us every step of the way,” Ms Aliyu said.

There were also contributions from Munachimso Duru, Head, Products, Partnership and Innovation, Afrigopay Financial Services Limited; Damola Giwa, Country Manager, Visa West Africa; Nike Kolawole, representing Aisha Abdullahi, Executive Director, Credit and Portfolio Management, CREDICORP; and Ifeanyi Chukuwekem, Head, Corporate Strategy Department, eTranzact, offering a broad industry perspective on the future of responsible credit delivery.

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