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SERAP Rejects Banks’ Request for Social Media Handles for KYC

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CBN Ways and Means

By Adedapo Adesanya

The Socio-Economic Rights and Accountability Project (SERAP) has urged Mr Folashodun Shonubi, the acting Governor of the Central Bank of Nigeria (CBN), to remove the request for customers’ social media handles for know your customer (KYC) by banks.

SERAP also urged him to “withdraw the Circular number FPR/DIR/PUB/CIR/007/076 of 20 June 2023 mandating banks and other financial institutions to implement and comply with the mandatory unlawful provisions on customers’ social media handles in the CBN Regulations.”

According to Section 6(a)(iv) of the CBN Regulations, banks and other financial institutions “shall identify their customer and obtain information on the social media handle of the customer.” Section 6(b)(iii) contains a similar provision.

In the letter dated June 24, 2023, and signed by SERAP deputy director, Mr Kolawole Oluwadare, the organisation said: “The CBN Regulations and directive to banks to obtain details of customers’ social media address violate Nigerians’ rights to freedom of expression and privacy. It is inconsistent and incompatible with the rule of law.”

SERAP said, “The CBN ought to contribute to the advancement of respect for the rule of law and human rights in the discharge of its statutory functions and not undermine or violate these fundamental legal requirements and standards.”

According to SERAP, “The purported mandatory requirement would inhibit Nigerians from freely exercising their human rights online. If obtained, such information may also be misused for political and other unlawful purposes.”

The letter read in part: “We would be grateful if the recommended measures are taken within 3 days of the receipt and/or publication of this letter. If we have not heard from you by then, SERAP shall take all appropriate legal actions to compel you and the CBN to comply with our request in the public interest.

“The mandatory requirement of social media handles or addresses of customers does not serve any legitimate aim. Such information may be used to unjustifiably or arbitrarily to restrict the rights to freedom of expression and privacy.

“SERAP is gravely concerned that the CBN Regulations and directive to banks and other financial institutions would impermissibly restrict the constitutional and international rights to freedom of expression, privacy and victims’ right to justice and effective remedies.

“Requiring social media handles or addresses of customers as a means of identification would have a disproportionate chilling effect on the effective enjoyment by Nigerians of their rights to freedom of expression and privacy online.

“The CBN bears the burden of justifying any restriction on people’s freedom of expression and privacy. Under the Nigerian Constitution 1999 [as amended] and human rights treaties to which the country is a state party, any restrictions on these rights must be applied strictly so that the rights are not put in jeopardy.

“There are other means of identification such as passport, driver’s licence, Bank Verification Number (BVN), and Tax Identification Number (TIN), which banks and other financial institutions already require their customers to provide.

“The additional requirement of obtaining details of a customer’s social media handle or address fails to meet the requirements of legality, necessity, and proportionality.

“The requirement of necessity implies an assessment of the proportionality of the grounds, with the aim of ensuring that the excuse of ‘regulations on customer due diligence’ is not used as a pretext to unduly intrude upon the rights to freedom of expression and privacy.

“The CBN Regulation does not demonstrate how the use of social media handle or address as a means of identification would serve to improve banks and other financial institutions’ ability to implement and comply with the laws and regulations relating to customer due diligence.

“The Directive by the CBN, which does not in any event carry the force of law, also fails to provide any explanation as to how social media handles or addresses can facilitate compliance with regulations relating to customer due diligence.

“Obtaining the details of customers’ social media handles or addresses would unduly interfere with the rights to freedom of expression and privacy. It would also be disproportionate to any purported legitimate aim that the CBN seeks to achieve.

“The facts that there are sufficient means of identification for CBN, banks and other financial institutions to rely on to meet the requirement of Know Your Customer also heighten concerns of overreach, and confer far-reaching discretion on banks and financial institutions.

“Obtaining information on customers’ social media handles or addresses as means of identification is therefore more intrusive than necessary.

“The cumulative effect of any attempt to access details of customers’ social media handles or addresses would be to undermine the letter, substance and spirit of the rights to freedom of expression and privacy of Nigerians.

“The effective enjoyment of these fundamental rights constitutes a fundamental pillar for building a democratic society and strengthening democracy.

“The CBN fails to show how details of customers’ social media handles or addresses would assist banks and other financial institutions to effectively implement and comply with the laws and regulations relating to customer due diligence.

“Human rights, the rule of law and democracy are interlinked and mutually reinforcing and central to the universal and indivisible core values and principles of the United Nations, the African Union and the Economic Community of West African States to which Nigeria belongs.

“The CBN is bound to respect the constitutional and international human rights of Nigerians including the rights to freedom of expression and privacy.

“Under the principle of pacta sunt servanda and general principles governing the law of treaties, the CBN is also bound to uphold and apply in the discharge of its statutory functions the human rights treaties to which Nigeria is a state party.

“Indeed, under international human rights law, all public or governmental institutions including the CBN are in a position to engage the responsibility of the state.

“The positive obligations on Nigeria to ensure the rights to freedom of expression and privacy will only be fully discharged if individuals are protected against violations by institutions like the CBN.

“The Nigerian Constitution guarantees in Section 39 the right to freedom of expression and in Section 37, the right to privacy.

“Article 19 of the International Covenant on Civil and Political Rights and Article 9 of the African Charter on Human and Peoples’ Rights also guarantee the right to freedom of expression. Article 17 of the Covenant also guarantees the right to privacy.

“Freedom of expression and opinion are indispensable conditions for the advancement of any person or society, as the free exercise of the right facilitates the evolution and exchange of opinions, in turn enabling principles of transparency and accountability crucial for the promotion and protection of human rights.

“While under certain narrow circumstances, a State may restrict the right to freedom of expression, any such restrictions must be strictly limited and meet the conditions of legality (i.e. be “provided by law”), legitimate purpose, necessity, and proportionality. The CBN Regulations mandating social media handle or address as a form of identification for customers fail to meet these legal requirements.

“In particular, Article 19(1) of the Covenant establishes the right to freedom of opinion without interference. Article 19(2) establishes Nigeria’s obligations to respect and ensure ‘the right to freedom of expression,’ which includes the freedom to seek, receive and impart information and ideas of all kinds, regardless of frontiers.

“Under article 19(3), restrictions on the right to freedom of expression must be ‘provided by law’, and necessary ‘for respect of the rights or reputations of others’ or ‘for the protection of national security or of public order (ordre public), or of public health and morals.

“The principles of legality, necessity, and proportionality, apply to the right to privacy in the same manner as they do to freedom of expression and other fundamental freedoms.

“Restrictions to the rights to freedom of expression and privacy that do not comply with the elements of legality, legitimate purpose, and necessity and proportionality shall be deemed unlawful.”

Adedapo Adesanya is a journalist, polymath, and connoisseur of everything art. When he is not writing, he has his nose buried in one of the many books or articles he has bookmarked or simply listening to good music with a bottle of beer or wine. He supports the greatest club in the world, Manchester United F.C.

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Banks to Flag Suspicious BVNs Under New CBN Directive from May 1

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BVN microfinance banks

By Adedapo Adesanya

The Central Bank of Nigeria (CBN) has directed Nigerian banks to flag suspected fraud  Bank Verification Numbers (BVNs) after a 24-hour watchlist from May 1.

According to a circular signed by Mr Musa Jimoh, the Director of the Payment Systems Policy Department, the apex bank introduced this new policy in an amended version of the 2021 Revised Regulatory Framework for BVN and Watch-List for the Nigerian Banking Industry.

The circular titled, Addendum to the Revised Regulatory Framework for Bank Verification Number Operations and Watch-List for the Nigerian Banking Industry, disclosed that the new framework introduces four new policies which mandate Financial Institutions to establish and maintain a temporary watchlist for BVNs implicated in suspected fraudulent transactions reported by a financial institution.

The statement reads, “A BVN may remain on this temporary Watchlist for a maximum period of twenty-four (24) hours; during this period, the BVN owner shall be contacted to provide clarification regarding the identified transaction(s).”

For the BVN enrolment age requirement, the circular reads, “Enrolment for BVN is restricted to individuals who have attained the age of eighteen (18) years and above.”

For the restrictions on phone number amendments, the circular explained that updates on phone numbers linked to a BVN shall be allowed only once.

For Access to BVN data, the statement reads, “Access to the BVN databases shall be exclusively granted to Central Bank of Nigeria (CBN) licensed financial institutions. Notwithstanding this provision, the Central Bank of Nigeria (the Bank) reserves the right to approve access to the BVN databases in extenuating circumstances and in accordance with the provisions of extant laws.”

The apex bank urges financial institutions to act accordingly as implementation of the new provisions shall take effect from May 1, 2026.

Launched in February 2014 by the CBN in collaboration with the Nigeria Inter-Bank Settlement System (NIBSS), BVN was part of efforts to strengthen the security and integrity of Nigeria’s banking system amid broader banking reforms. It was introduced primarily to reduce banking fraud and identity theft, which had become widespread due to individuals opening multiple accounts under different identities across banks. By assigning each customer a unique biometric-based identification number linked to fingerprints and facial data, BVN ensures that all accounts belonging to a person across Nigerian banks can be verified and traced.

The system also improves the effectiveness of banks’ Know Your Customer (KYC) procedures, enhances transparency in financial transactions, and supports regulatory oversight within the financial sector.

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Banking

How Access Bank is Linking Africa’s Landlocked Markets

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Link Africa’s Landlocked Markets

At the Africa Trade Conference (ATC) 2026 held in Cape Town, South Africa, policymakers, financiers, and global business leaders gathered to confront one of Africa’s most persistent economic constraints: the continent’s vast trade financing gap.

Hosted by Access Bank Plc, the conference brought together stakeholders from governments, development finance institutions and the private sector to explore how Africa can transform its fragmented trade ecosystem and unlock the promise of the African Continental Free Trade Area.

The central message emerging from the discussions was clear: Africa must move from being a continent of landlocked markets to a network of land-linked economies, connected through finance, infrastructure and digital trade systems.

Turning Vision into Velocity

The conference, themed “Turning Vision into Velocity: Building Africa’s Trade Ecosystem for Real-World Impact,” focused on translating policy ambition into practical solutions for businesses across the continent.

Delivering the welcome address, Roosevelt Ogbonna, Managing Director and Chief Executive Officer of Access Bank Plc, emphasised that Africa must confront the structural barriers that continue to limit intra-continental commerce.

“The reality is that Africa still controls a small share of global trade,” Ogbonna said. “The corridors are still fragmented and more aspirational than functional, and too many small businesses that aspire to trade across Africa remain constrained.”

According to him, the conference was convened to continue the conversation begun at its inaugural edition in 2025, focusing on how Africa can expand trade within the continent while strengthening its participation in global markets.

“This conference must not end as another talking shop,” he said. “It must become the birthplace of a movement that contributes to transforming intra-African trade.”

For Access Bank Plc, the role of financial institutions in that transformation is evolving.

“At Access Bank, we see ourselves as financiers and connectors of markets, ideas and opportunities,” Ogbonna noted. “Our role is to help African businesses move from ambition to impact, from local relevance to global competitiveness.”

Bridging Africa’s Trade Finance Gap

Despite its abundant natural resources and population of more than 1.3 billion people, Africa remains underrepresented in global trade flows.

One of the biggest barriers is the lack of accessible financing for exporters, manufacturers and small businesses seeking to expand across borders. The trade finance gap continues to constrain intra-African commerce, which remains significantly below levels recorded in other regional trading blocs.

To address this, Ogbonna highlighted three strategic priorities that emerged from the previous edition of the conference: breaking down silos between policymakers, financial institutions and businesses; building a trade ecosystem powered by reliable data and analytics, and developing systems that support both large corporations and smaller businesses expanding across borders

Encouragingly, he noted that progress is already emerging across several sectors.

“We have seen value chains emerging across agriculture, manufacturing and services, and we are seeing African brands crossing borders and building a global presence,” he said.

Nevertheless, the gains remain uneven across the continent, with progress concentrated in a few markets and trade corridors.

Financing the Future of African Trade

Beyond the structural challenges of trade finance and infrastructure, the conference also explored the evolving financial architecture required to unlock Africa’s full trade potential.

Keynote addresses were delivered by Kennedy Mbekeani, Director General for the Southern Africa Region at the African Development Bank, and Kwabena Ayirebi, Managing Director of Banking Operations at the African Export-Import Bank.

Both speakers emphasised the need for stronger collaboration among development finance institutions, commercial banks and governments to mobilise the capital required to drive infrastructure development and support trade across the continent.

Mbekeani stressed that private capital would be crucial in bridging Africa’s infrastructure financing gap.

“The mobilisation of private capital remains crucial as many African governments are constrained by limited fiscal space and overstretched balance sheets,” he said.

“The mobilisation of capital, particularly private capital, is something that we need to work on.”

The conversation was further enriched by insights from Tolu Oyekan, Managing Director and Partner at Boston Consulting Group, who presented the Africa Trade Outlook 2026.

His presentation highlighted the macroeconomic forces shaping the future of African trade, including shifting global supply chains, the growing importance of regional value chains and emerging opportunities for African industries to capture greater value in global markets.

Digital infrastructure and payments were also central to the conversation.

Mike Ogbalu, Chief Executive Officer of the Pan-African Payment and Settlement System, underscored the importance of payment interoperability in enabling seamless cross-border transactions across the continent.

Efficient payment systems, he noted, are essential to reducing the cost and complexity of trading across African borders, particularly for small and medium-sized enterprises.

Policy, Finance and Partnerships

The conference also convened a high-level ministerial panel that brought together policymakers and financial sector leaders to examine the policy environment required to accelerate Africa’s economic integration.

Participants included Elizabeth Ofosu Adjare, Ghana’s Minister for Trade, Agribusiness and Industry, and Tiroeaone Ntsima, Botswana’s Minister of Trade and Entrepreneurship, alongside senior executives from international financial institutions.

Together, they explored how regulatory alignment, infrastructure development and innovative financing structures can accelerate the implementation of the African Continental Free Trade Area and unlock intra-African trade.

The objective, participants agreed, was not merely dialogue but partnership, bringing together the policymakers, financiers and businesses capable of translating Africa’s trade ambitions into tangible outcomes.

Reimagining Africa’s Economic Geography

Beyond policy discussions and financing strategies, the conference reflected a deeper shift in how Africa views its economic geography.

For decades, the continent’s development challenges have often been framed in terms of physical constraints: landlocked economies, fragmented markets and weak infrastructure.

But the emerging vision presented in Cape Town suggests a different future,  one where integrated banking networks, digital payment systems and trade finance platforms transform isolated markets into connected trade corridors.

For Access Bank Plc, that transformation is already underway.

With operations spanning 25 countries globally, including 16 across Africa, the bank is building financial corridors that link African businesses to each other and to global markets.

From Potential to Participation

The conversations at the Africa Trade Conference reinforced a growing consensus across the continent: Africa’s economic transformation will depend on policy reforms and institutions capable of financing and facilitating trade.

Banks, development finance institutions and payment platforms are increasingly becoming the connective tissue linking African markets.

For Access Bank, the ambition is clear,  helping reshape the narrative of African trade.

From isolated markets to integrated corridors. From landlocked constraints to land-linked opportunity. And from economic potential to meaningful participation in the global trading system.

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Banking

CBN Orders Banks, OFIs to Deploy AI Tech to Flag Illicit Money Flows

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Illicit Money Flows

By Adedapo Adesanya

The Central Bank of Nigeria (CBN) has rolled out fresh technology-driven rules compelling banks and other financial institutions to deploy automated anti-money laundering systems capable of detecting suspicious transactions in real time.

The directive, contained in a circular issued on March 10, 2026, applies to deposit money banks, mobile money operators, international money transfer operators, payment service providers, and other institutions under the apex bank’s supervision.

According to the regulator, the new framework sets minimum standards for automated anti-money laundering solutions designed to strengthen the detection and reporting of financial crimes within Nigeria’s rapidly digitising financial ecosystem.

In the circular, the CBN explained that the guidelines establish a baseline structure for financial institutions to deploy advanced monitoring tools capable of flagging suspicious financial activities instantly.

“The baseline standards provide a framework for implementing automated solutions that strengthen the detection and reporting of suspicious transactions in real time and enhance compliance with applicable AML/CFT/CPF laws and regulations, while also supporting the use of emerging technologies to improve overall financial crime risk management,” it stated.

The circular was jointly signed by the Director of Banking Supervision, Mrs Akinwunmi A. Olubukola, and Mrs Olubunmi Ayodele-Oni, acting for the Director of the Compliance Department.

Under the new policy, financial institutions must deploy automated anti-money laundering platforms that combine customer identification systems, transaction monitoring, sanctions screening, and risk assessment tools into a single integrated framework.

The CBN said the guidelines apply to all institutions operating within the financial system under its regulatory authority, including banks, payment companies, and other licensed financial service providers.

While the new rules take effect immediately, institutions have been given specific timelines to fully implement the required technology infrastructure.

Deposit money banks are expected to achieve full compliance within 18 months, while other financial institutions have 24 months to meet the regulatory requirements.

In addition, all institutions are required to submit detailed implementation roadmaps within three months of the issuance of the circular.

“The implementation of these guidelines shall start from the date of issuance, while full compliance shall be 18 months (for Deposit Money Banks) and 24-months (for Other Financial Institutions) from the date of issuance,” the apex bank added.

A major highlight of the framework is the emphasis on advanced technology tools such as artificial intelligence, machine learning, predictive analytics, and behavioural monitoring to identify unusual financial patterns that may indicate criminal activity.

Under the guidelines, institutions must deploy systems capable of conducting risk-based customer due diligence, monitoring transactions across multiple financial channels, and screening customers against sanctions databases and lists of politically exposed persons.

The CBN also directed that these automated systems must integrate seamlessly with core banking infrastructure and customer identity databases, enabling continuous real-time analysis of transaction flows and behavioural patterns.

According to the apex bank, traditional manual monitoring processes are increasingly inadequate in a financial environment that is becoming more complex and heavily driven by digital payments, fintech platforms, and mobile banking.

The regulator said automated surveillance systems would enable institutions to identify potential financial crimes earlier and report suspicious transactions promptly to authorities such as the CBN and the Nigerian Financial Intelligence Unit (NFIU).

The guidelines further require financial institutions to establish governance structures to oversee the performance of automated systems, validate artificial intelligence models, and ensure that data protection safeguards comply with Nigeria’s privacy regulations.

Beyond technology deployment, institutions must maintain detailed audit trails and case management systems that document investigations into suspicious financial activity and track regulatory reporting obligations.

The central bank warned that institutions that fail to comply with the new standards or operate ineffective anti-money laundering frameworks could face regulatory penalties.

Compliance will be monitored through a combination of off-site regulatory surveillance, on-site examinations, and targeted thematic reviews conducted by the banking regulator.

The CBN emphasised that the newly issued standards represent only the minimum compliance benchmark, adding that institutions may be required to implement stronger controls depending on their operational scale, transaction volumes, and risk exposure.

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