Banking
An Overview of Legal Requirements For a Bank’s Website
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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
Banking
Public Offer: Sterling Holdco Allots 13.812 billion Shares to 18,276 Shareholders
By Aduragbemi Omiyale
Sterling Financial Holdings Company Plc has allotted shares from its public offer of 2025 to investors with valid applications.
The allotment follows the earlier receipt of final approval from the Central Bank of Nigeria (CBN) and the recent clearance by the Securities and Exchange Commission (SEC).
In September 2025, the financial institution offered for sale about 12,581,000,000 ordinary shares of 50 kobo each at N7.00 per share in public offer.
However, the exercise received wide participation from the investing public, with the company getting 18,280 applications for 16,839,524,401 ordinary shares valued at approximately N117.88 billion.
Following a thorough verification process, valid applications were received from 18,276 shareholders for a total of 13,812,239,000 ordinary shares, representing a subscription level of 109.79 per cent and reflecting sustained confidence in Sterling Holdco’s strategic direction, governance, and long-term growth prospects.
The firm approached the capital market for additional funds for the recapitalisation of its two flagship subsidiaries, Sterling Bank and The Alternative Bank.
The capital injection will support the commencement of full operations and contribute to the group’s revenue diversification objectives.
In line with the guidelines set out in the offer prospectus, Sterling Holdco confirmed that all valid applications will be allotted in full. Every investor who complied with the terms of the offer will receive all the shares for which they applied.
A very small number of applications were not processed or were partially rejected due to non-compliance with the offer terms, including duplicate payments and failure to meet the minimum subscription requirement of 1,000 units or its multiples, as stipulated in the offer documents.
The group ensures a seamless post-offer process, with refunds for excess or rejected applications, along with applicable interest, to be remitted via Real Time Gross Settlement or NIBSS Electronic Funds Transfer directly to the bank accounts detailed in the application forms.
Simultaneously, the electronic allotment of shares has be credited to successful shareholders’ accounts with the Central Securities Clearing System (CSCS) on February 17, and for applicants who do not currently have CSCS accounts, their allotted shares will be temporarily held in a registrar-managed pool account pending the submission of their completed account opening documentation to Pace Registrars Limited, after which the shares will be transferred to their personal CSCS accounts.
Banking
CBN Governor Seeks Coordinated Digital Payment Reforms
By Modupe Gbadeyanka
To drive inclusive growth, strengthen financial stability, and deepen global financial integration across developing economies, there must be coordinated reforms in digital cross-border payments.
This was the submission of the Governor of the Central Bank of Nigeria (CBN), Mr Olayemi Cardoso, at the G‑24 Technical Group Meetings in Abuja on Thursday, February 19, 2026.
According to him, high remittance costs, settlement delays, fragmented systems, and heavy compliance burdens still limit the participation of households and Micro, Small and Medium Enterprises (MSMEs) in global trade.
The central banker emphasised that efficient payment systems are essential for economic inclusion, highlighting that global remittance corridors still incur average costs above 6 per cent, with settlement delays of several days, excluding millions from modern economic activity.
Mr Cardoso cautioned that while digital payments present significant opportunities, they also carry risks such as currency substitution, weakened monetary transmission, increased FX volatility, capital-flow pressures, and regulatory fragmentation.
The G-24 TGM 2026, themed Mobilising finance for sustainable, inclusive, and job-rich transformation, convened global financial stakeholders to advance the modernisation of finance in support of emerging and developing economies.
The CBN chief reaffirmed Nigeria’s commitment to working with G-24 members, the IMF, the World Bank Group, and other partners to build a more inclusive, resilient, and development-oriented global financial architecture.
“We have strengthened our AML/CFT frameworks in line with FATF guidelines, requiring strict dual-screening of cross-border transactions to mitigate risks.
“To deepen regional integration, the CBN introduced simplified KYC/AML requirements for low-value cross-border transactions to encourage broader participation in PAPSS, easing processes for Nigerian SMEs and enabling faster intra-African trade payments.
“We have also embraced fintech innovation through our Regulatory Sandbox, allowing payment-focused fintechs to test secure, instant cross-border solutions under close CBN supervision,” he disclosed.

Banking
Unity Bank, Providus Bank Merger Awaits Final Court Approval
By Modupe Gbadeyanka
The merger and business combination between Unity Bank Plc and Providus Bank Limited remains firmly on course, a statement from one of the parties disclosed.
According to Unity Bank, there is no iota of truth in reports in certain sections of the media suggesting that the merger process had stalled, as the transaction remains firmly on track.
It was disclosed that the necessary regulatory steps have been completed, but only a few other steps to finalise the transaction, especially the final court sanction.
There had been speculations that both lenders may not meet the new minimum capital requirement of the Central Bank of Nigeria (CBN) before the March 31, 2026, deadline.
However, it was noted that the combined capital base of Unity Bank and Providus Bank exceeds N200 billion, which is the minimum requirement to retain a national banking licence under the CBN’s recapitalisation framework.
When completed, the Unity-Providus merger is expected to deliver a stronger, more competitive, and customer-centric financial institution — one with the scale, innovation, and reach to redefine the retail and SME banking landscape in Nigeria.
“The merger with Providus Bank significantly enhances our capital base, operational capacity, and strategic positioning.
“We are confident that the combined institution will be better equipped to support economic growth and deliver innovative financial solutions across Nigeria,” the chief executive of Unity Bank, Mr Ebenezer Kolawole, stated.
Recall that a few months ago, shareholders authorised the merger between the two entities at Court-Ordered Meetings. They also adopted the scheme of merger at their respective Extraordinary General Meetings (EGMs) in September 2025,
The central bank also backed the merger, with a pivotal financial accommodation to support the transaction. The merger also received a further boost with a “no objection” nod from the Securities and Exchange Commission (SEC).
The regulatory approvals form part of broader efforts to strengthen the resilience of Nigeria’s banking system, reinforce capital adequacy across the sector, and mitigate potential systemic risks.
The development positions the combined entity among the 21 banks that have satisfied the apex bank’s new capital threshold for national banking operations.
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