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An Overview of Legal Requirements For a Bank’s Website

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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.

  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

How FairMoney Is Powering Financial Inclusion for Nigerian Hustlers

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Financial Inclusion for Nigerian Hustlers

By Margaret Banasko

Urbanization is reshaping Nigeria’s economic landscape, creating new possibilities for millions of young people who relocate each year in search of opportunity. Cities like Lagos, Kano, and Abuja continue to expand as ambitious Nigerians leave their hometowns with the hope of building stable, sustainable livelihoods.

Recent figures highlight the pace of this shift. As of 2024, more than half of Nigeria’s population – around 128 million people – live in urban areas. Many of these individuals are young entrepreneurs and self-employed workers determined to turn their skills, ideas, and hustle into meaningful income. However, navigating the financial requirements needed to sustain and grow a small business is often challenging for those operating in informal or early-stage sectors.

This is where digital financial platforms have become transformational. With only a mobile phone, an internet connection, and a Bank Verification Number (BVN), Nigerians are increasingly able to access a wider range of financial tools designed to support their daily needs and long-term goals. FairMoney is among the institutions driving this progress by offering services that meet people where they are and support their ambition to grow.

Aigbe Osasere’s experience reflects this evolution. He moved from Benin City to Lagos with the goal of establishing a fish farming business in Ijegun, Alimosho. His vision was clear: create a small, efficient operation that could supply fresh fish to local buyers. Like many small business owners, he needed reliable access to funds to purchase fingerlings, buy feed, replace equipment, and maintain steady production. Managing these cycles required financial tools that matched the fast pace of his operations.

Through the FairMoney app, Aigbe gained access to digital banking services immediately after completing BVN verification. The availability of instant loans provided the flexibility he needed to restock quickly and maintain continuous production. For a business model where timing is central to profitability, this support allowed him to keep his operations consistent and responsive to customer demand.

Opening a FairMoney bank account and receiving a physical debit card further strengthened his business structure. Bulk buyers began paying him directly into his account, giving him clearer financial records and better visibility into his daily revenue. With his debit card, he could purchase supplies, withdraw cash conveniently, and manage his finances in a more organized way.

Aigbe also adopted FairMoney’s savings features to help him preserve and grow his earnings. By setting aside a portion of his daily sales, he is gradually building the capital needed to increase his fish tanks, expand his capacity, and move toward a more scalable operation.

Beyond supporting his business, FairMoney has become part of his everyday life. From the app, he sends money to family members, pays bills, buys airtime and data, and settles electricity tokens quickly and efficiently. This convenience allows him to focus more fully on running and growing his business.

Aigbe’s story is one example of how digital banking is broadening access to financial services across Nigeria. Entrepreneurs, freelancers, traders, and young workers are increasingly leveraging digital platforms to manage money, plan for growth, and participate more actively in the financial system.

As more Nigerians pursue self-employment and urban entrepreneurship, tools that offer accessibility, speed, and flexibility are playing an important role in supporting their progress. With FairMoney, many are finding a dependable partner that aligns with their goals, their pace, and their vision for the future.

Margaret Banasko is the Head of Marketing at FairMoney MFB

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Banking

CBN Revokes Operating Licences of Aso Savings, Union Homes

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By Adedapo Adesanya

The operating licences of Aso Savings and Loans Plc and Union Homes Savings and Loans Plc have been revoked by the Central Bank of Nigeria (CBN) as part of efforts to strengthen the mortgage sub-sector and enforce compliance with banking regulations.

Mortgage banks are financial institutions that provide home loans and other housing finance products, and so, they are strictly regulated by the CBN to protect customers and ensure the stability of Nigeria’s financial system.

According to a post by the Acting Director of Corporate Communications of CBN, Mrs Hakama Ali, on the apex bank’s X handle on Tuesday, the affected institutions were accused of violating several provisions of the Banks and Other Financial Institutions Act (BOFIA) 2020 and the Revised Guidelines for Mortgage Banks in Nigeria.

The revocation is part of the central bank’s ongoing efforts to maintain a safe and reliable banking sector, protect customers’ deposits, and ensure that only financially sound institutions operate in the mortgage market.

“The breaches included failure to meet the minimum paid-up share capital requirement, insufficient assets to meet liabilities, being critically undercapitalised with a capital adequacy ratio below the prudential minimum, and non-compliance with directives issued by the CBN,” the post noted.

The CBN emphasised that the revocation aligns with its mandate to ensure financial system stability and maintain public confidence in the banking sector, assuring it is committed to promoting a sound and resilient financial system in Nigeria.

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Banking

Sagecom N225bn Case: Apex Court Cuts Fidelity Bank Judgment Debt to N30bn

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Nneka Onyeali-Ikpe Fidelity Bank

By Adedapo Adesanya

A five-member panel of the Supreme Court, led by Justice Lawal Garba, last Friday ruled in favour of Fidelity Bank in its appeal against Sagecom Concepts Limited.

The judgment brings definitive closure to a legacy case that has attracted attention across the financial sector for more than two decades. It also marks a significant victory for Fidelity Bank in a long-running legal dispute.

In a motion dated October 8, 2025, Fidelity Bank sought clarification from the Supreme Court, requesting a consequential order that the judgment debt be paid in Naira. The bank also asked that the interest rate be set at 19.5 per cent per annum rather than 19.5 per cent compounded daily.

It also requested the exchange rate used for conversion be the rate applicable as of the date of the High Court judgment, in line with the Supreme Court’s decision in Anibaba v. Dana Airlines.

Fidelity Bank further requested the judgment debt be fixed at N30,197,286,603.13 and that interest on this amount be payable at 19.5 per cent per annum until full settlement.

In the judgment delivered by Justice Adamu Jauro, the apex court granted the bank’s first three prayers but declined the fourth and fifth. As a result, the judgment sum will be paid in Naira at an annual interest rate of 19.5 per cent, rather than the daily compounded rate previously awarded by the High Court.

The Supreme Court equally affirmed that the applicable exchange rate should be the rate as of the date of the High Court judgment, consistent with its earlier decision in Anibaba v. Dana Airlines.

The dispute originated from a legacy transaction involving the former FSB International Bank, which merged with Fidelity Bank in 2005. It stemmed from a 2002 credit facility extended to G. Cappa Plc and subsequent legal proceedings tied to the collateral.

This ruling provides finality for years of litigation and confirms a significantly lower liability than the N225 billion previously speculated in the review of decisions leading up to the decision.

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