Feature/OPED
The NSE, Oscar Onyema Foundation and Corporate Governance
By Olufemi Awoyemi
“Ethics is knowing the difference between what you have a right to do and what is right to do.” – Potter Stewart.
The mandate given to the newly constituted executive management of the NSE post-Ndi Okereke-Onyuike was to develop, grow and implement an exchange driven by, and able to hold itself to the best possible standards of governance and to exercise extreme caution where any appearance of or circumstance may present itself.
The exchange has been executing this mandate without incident till Friday, August 17, 2018 when it supervised the launch of a private foundation of the CEO at its office, including organizing a bell ringing session; an activity hitherto reserved for departing CEOs.
This is an isolated case but one that indicates acquiescence, if not support from the NSE Council – the mandate keepers. Mr Oscar Onyema is thoughtful, professional and a gentleman who has every right to pursue socially uplifting causes. It is a good thing to do but not sufficient to meet the highest standards of corporate governance; in so far as he holds the position of the CEO of the exchange.
I believe that this was an honest mistake devoid of ulterior motives yet has however thrown up obvious conflicts arising from the use of the exchange in the launch and promotion of the foundation. The related issues, impact and implications arising therefrom and related to now forms the subject of this memo to the market.
That said, when it comes to how and what Oscar Onyema, the NSE Council and indeed the foundation should decide next on this matter, sovereignty over decision-making does not rest with commentators and independent analysts like me; they rarely do. It will be one in which the parties will have to make in the best interest of the market – as they wish to be remembered.
It is my expectation that pedigree, intent and value orientation(s) will kick in and corrective action will be taken to make this a non-issue.
Context Matters
Market operators know the story of Ndi Okereke-Onyiuke’s 2008 outing under the aegis of “Africans for Obama Campaign”, the fund-raising that followed, and the ensuing governance issues raised concerning the director-general’s role and that of the Nigerian Stock Exchange (NSE) as an institution.
Students of Nigerian corporate governance history will equally recall that Ndi’s mistake here was to repeat the May 2005 act by then President Obasanjo to invite and receive donations into the Olusegun Obasanjo Presidential Library (OOPL) project which was launched in Abeokuta with the goal of raising N7 billion for the project, while he was still in office.
It would appear that the Nigerian Stock Exchange hasn’t grasped that history lesson fully. Instead, the exchange seems to be acting out the same script, the consequence of which would indicate sadly that there is no institutional memory or sustained desire to elevate the governance environment in our markets beyond where it bottomed out.
To “mobilise and sensitise Africans about the Obama policies and message”, Ndi Okereke-Onyuike, OON, then Director-General/CEO of the Nigeria Stock Exchange in 2008 organized and caused to be held an August 11, 2008 glamorous fundraiser where business leaders and high-society elites paid up for tables. This generated a whole lot of heat and enquiry for which she was cleared of any wrongdoing because no Nigerian laws were broken. That said, the fact that US laws prohibited overseas donations ab-initio made the purpose, positioning and promotion of the fundraiser and the associated role of the exchange a continuing corporate governance concern, especially on matters bothering on conflict of interest and of roles.
To demonstrate and deepen democracy in Nigeria, then President Obasanjo initiated and caused to be incorporated on November 12, 2002 the Olusegun Obasanjo Presidential Library Foundation and subsequently held a fundraiser on Saturday, May 14, 2005 for the said presidential library. Donors to this project included oil companies, financial institutions, business leaders and high-society elite.
Good Intentions Actualized Should Matter & Be Encouraged In Our Society
The referenced saga above exemplifies Oscar’s predicament with the launch on Friday, August 17, 2018 at the Exchange, of the ONO Foundation, which for all intents and purpose speaks to our common humanity and response to the plea for private sector leaders to play a structured role in helping to build a better society.
Babatunde Folawiyo, a well-regarded business leader and chairman, board of trustees, ONO Foundation, echoed the message from Oscar Onyema when he said “the foundation is borne out of an understanding that the society of our dreams cannot materialize if its future (the children and the youth) are not properly trained, inspired and equipped to be the catalyst and springboard of change and growth”.
Good Intentions, Bad Optics For Governance
The reasoning for the foundation is not a problem and should not be a subject of a debate. The issue however is with the launch signaling, timing, linkage to the exchange and role of the principal progenitor in current status. It is all about corporate governance which according to Advocate Johan Myburgh “is not a matter of right or wrong; it is more nuanced than that.” The nuance is exemplified in the optics.
This was an Oscar Onyema who was the CEO of the NSE but decided to seat for the exams of the Chartered Institute of Stockbrokers (CIS), passed and thus conferred esteem upon the practice members. He is, and has always been committed to market best practice and this is the threshold with which the current optics is being viewed.
The deployment of socially uplifting projects in pursuit of the common good seldom succeed when deployed under a cloud of ethical and governance challenges. Instead of saluting Oscar however for the launch as he did it, we may unfortunately end up seeing him as a conspicuous victim here of his own good track record to date on the subject of best practice and higher standards corporate governance.
There must be a more cogent explanation for the role of the exchange beyond rules, conventions and privileges given what we know of the man and his service pedigree. I am not aware of any known case of any wrongdoing against the CEO but believe that the elimination of ‘incestuous relationships’ is critical to the functioning of the exchange CEO in the discharge of the CEO’s responsibilities.
Oscar N. Onyema OON is the CEO of the Nigerian Stock Exchange (NSE), a position he was employed to on 4 April 2011; and for which he is currently serving a second five-year term. He has over twenty years working experience in the United States of America‘s financial markets and the Nigerian information technology sector. Onyema is also the Chairman of the Central Securities Clearing System (CSCS) Plc, a fellow and member of the Governing Council of the Chartered Institute of Stockbrokers of Nigeria (CIS), the President of the African Securities Exchanges Association (ASEA), a Global Agenda Council member of the World Economic Forum (WEF), member of the Board of Trustees of the Investors’ Protection Fund (IPF), and he serves on the boards of all subsidiaries of The Exchange, National Pension Commission of Nigeria, FMDQ OTC PLC.
In his work coverage, he had served as the senior vice president and chief administrative officer at American Stock Exchange (Amex), which he joined in 2001 and has the unique distinction of being the first person of colour to hold that position, and was instrumental in integrating the Amex equity business into the New York Stock Exchange (NYSE) Euronext equity business after the latter’s acquisition of Amex in 2008. He then managed the NYSE Amex equity trading business, which he helped position as a premier market for small and mid-cap securities.
Oscar, an alumnus of Harvard Business School where he completed the Advanced Management Program, is no slouch and he knows his onions.
It is this level of responsibility, engagement and exposure that defines minimum expectations and professional conduct which makes it all the more baffling why he would allow his name to be associated with, or involved in the implied, if not apparent conflict of role situation, the launch of the Oscar N. Onyema Foundation (ONO) at the premises of the exchange presents.
The Nigerian Stock Exchange (as a self-regulatory organization), has done a lot of work in the areas of corporate governance and has adopted best practices as a key element in achieving its vision and mission. This is well articulated and demonstrated by its governing board – the National Council of the Exchange – who regards corporate governance as fundamentally important to the discharge of its responsibilities and its conduct in all its dealings with its stakeholders.
It would thus stand to reason therefore that any appearance of conflict will be an issue to be addressed under risks associated with the executive committee’s mandate.
Identifying Risks And Concerns
This Friday escapade and the questions it threw up, ought to have been an issue which the governing council ought to have addressed its minds to prior to the event; and immediately afterwards vis-à-vis the obvious corporate governance implications arising therefrom, in a clime like ours and at a time like this; especially when juxtaposed against our recent history of an incestuous relationship-biased regulatory environment, and the steps needed to restore confidence in the financial market system, nay the capital market.
The fact that, three or more years after, the board of the Securities & Exchange Commission (SEC) of Nigeria has not been officially constituted illuminates actions taken by a SRO operating in a governance challenged environment more clearly.
Taking together, a common view of the ONO foundation profile the existence or implied infusion of a real or perceived conflict of interest or/and role situation on face value; at the minimum.
An attempt to articulate and decouple the two roles the CEO of the exchange seeks to play here is both a matter of precedence and corporate governance ethos at the exchange.
The primary concerns relate to the determination of the following:
As an employee of the exchange, was there a need for, and was a request made, and an approval granted by the Council of the Exchange.
Was there an approval for the CEO to serve as a trustee and board member of a privately funded foundation named after him?
Would having a foundation bearing his name and having some aspects of its objects similar to undertaking by the exchange’s CSR plan have led to a consequential review of best efforts (including for example the mentoring program)?
Would conducting such a launch in the exchange and deploying its resources in the public engagements require an approval? and
Did the council consider it fit and proper to approve the hosting of a bell ringing session for the CEO, an otherwise revered activity reserved as a sending-off gesture by the exchange for deserving executives; especially when such administrative approvals were vested in the CEO (the beneficiary in this case)?
Is it an allowable practice for a serving CEO to hold a board/trustee position in a private entity (including an NGO with related parties on board) while in office?
Are there provisions for handling co-board positions with directly related party(ies) of a listed entity in the code and are there waivers for this?
Are there disclosures of a conflict of interest or role requirements for:
The exchange’s CEO where such a proposition presents itself?
Any member with direct or indirect dealings with the exchange?
The elimination of safeguards or wall between the exchange and the foundation?
What advisory will the NSE provide to firms who approach it seeking guidance in deciding which social cause (CSR) is priority to the exchange between NSE’s CSR activities (corporate cancer funding, schools program etc) and the ONO foundation’s programs?
Would the duplicitous representation not serve to convey and deliver an “unintended consequence” on stakeholders involved with the exchange, who would feel the pressure and compulsion to “support” the CEO’s foundation as part of ‘good relationship management?
Would such support contributions not qualify as in-kind benefits or/and possibly a vehicle for the inducement of a principal officer of the exchange?
Under what circumstance is such a practice allowable for other executive committee members who may also be so motivated to pursue such socially beneficial cause(s)?
A review of these possible scenarios and best practice cases guided us to reaching a position, if not a conclusion – that this was a bad precedence and one that the market and principals need to work together on by elevating thought to resolve along the lines of institution building.
Legality And Capital Market Governance
As a collective, we seem to have come a long way from the 2008 discourse level which by 2014 had produced an NSE well aware of the need for a higher standard of corporate governance as Oscar Onyema himself brilliantly espoused in Corporate Governance: Ideas & Changes in the Nigerian Capital Market
Nigerians have since risen up and humiliated their political class over its handling of financial conduct, and particularly of the level of impairment evident in the regulators ability to rise above the numerous incestuous relationships they are often cluttered with.
Indeed and sadly, the generality of the public have come to accept and see nothing terribly unusual about their sense of powerlessness and alienation from the responsibility imperative of regulators, which it has been proven collectively, brought us to the state where we felt a wholesome change was need in our markets in 2010.
If we cannot change behaviour at the level of the sovereign, we can at least do this effectively at the level of industry and thus help provide teachable lessons for the development of the culture required to raise governance standards in the country and create a veritable example for listed entities.
This is one of such unique opportunities.
Moving on from here would require more than compliance with existing rules, conventions, laws and statutes – it requires setting new standards beyond rules to help us untangle roles and relationships.
Conflict of Interest – Overcoming Potential Impediments
Conflict of interest is difficult to define, yet it often appears obvious to many people who think they know it when they see it. If ever there was an issue that captures this sentiment, this foundation launch offers us an opportunity to discuss the grey areas inherent in our codes and how we should walk through them.
The legal definition of conflict of interest, usually set out in conventions, rules and laws governing non-profit entities and indeed SRO’s, is very specific and covers relatively few situations. Most conflicts fall into the ‘grey area’ where ethics and public perception are more relevant than statutes or precedents.
For this purpose, conflict of interest is therefore placed in the background to raise the much informed argument about the ‘conflict of roles’ which arises whenever the personal or professional responsibilities of a market-based entity and board member appear to be potentially at odds with the best interests and objectives of the market as a fair and level playing space.
Such possible areas of conflict (in roles/interest) can be narrowed down to the following ‘cultural’ issues, viz:
Conflict by association – linkage of the exchange to the foundation;
Conflict arising from relationship with board members;
Conflict arising from professional responsibility;
Conflict arising from precedence; and
Conflict arising from related parties and entanglement.
It is obvious that there is so much to unpack here. I must however crave the markets indulgence to draw a close on this memo on the premise established – i.e. that the appearance of a conflict of interest is a minimum criteria for council oversight in the affairs of the NSE.
While it is my hope and expectation that responsible parties singled out here will respond and take appropriate actions; it comforts me to leave you with the words of Bishop Desmond Tutu, from whom we may draw the inspiration needed to act in the circumstance, viz:
“We must not allow ourselves to become like the system we oppose. We cannot afford to use methods of which we will be ashamed when we look back, when we say, ‘…we shouldn’t have done that.’ We must remember, my friends, that we have been given a wonderful cause. The cause of freedom! And you and I must be those who will walk with heads held high. We will say, ‘We used methods that can stand the harsh scrutiny of history.’”
Olufemi Awoyemi is the Founder and Chief Executive Officer of Proshare Nigeria Limited.
Feature/OPED
From Convenience to Culture: How Streaming Will Shape Entertainment in Nigeria in 2026
Not too long ago, streaming in Nigeria was seen as a convenience, an alternative to traditional television, used mostly to catch up on missed shows or explore international content. Today, it has evolved into something far more ingrained. Streaming is now a culture: a daily habit that shapes conversations, influences pop culture, drives fandoms and even dictates how stories are told.
From late-night binge sessions and group watch parties to live-tweeting reality shows and football matches, streaming has become woven into how Nigerians experience entertainment. As mobile devices, smart TVs and affordable data options continue to expand access, the platform has moved from the fringes to the centre of everyday life. In 2026, this cultural shift will become even more pronounced.
Here’s what to expect as streaming continues to evolve in Nigeria and across Africa.
Value Will Define Loyalty in an Overcrowded Streaming Market: As streaming becomes mainstream, Nigerian audiences are becoming more discerning. Subscription fatigue is real, and users are no longer impressed by platforms with limited libraries or infrequent updates.
In 2026, loyalty will belong to platforms that offer sustained value, not just headline titles. This means:
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Deep content libraries that go beyond a handful of popular shows
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A healthy mix of live TV, sports and on-demand entertainment
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Regular content refreshes that keep audiences engaged month after month
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Viewers now understand value, and they will gravitate towards platforms that consistently deliver variety and relevance.
Local Stories Will Drive Cultural Relevance: Streaming has amplified the power of Nigerian storytelling, giving local productions the scale and visibility once reserved for traditional TV. Viewers are showing a clear preference for stories that feel familiar, authentic and culturally grounded.
In Nigeria, titles like Omera, Glass House, Italo, The Real Housewives of Lagos, Nigerian Idol and Big Brother Naija have become shared cultural moments, driving online conversations and real-world buzz. These shows are not just being watched; they are being experienced.
Across the continent, similar patterns are emerging, reinforcing the role of hyperlocal content in building loyalty and identity. In 2026, investment in African creators will remain central to streaming growth.
Streaming Becomes Personal and Predictive: As streaming matures, platforms will increasingly rely on AI to understand viewers on a deeper level. In 2026, Nigerian users can expect:
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More intuitive recommendations tailored to individual tastes
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Smarter content discovery that reduces the time spent searching
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Interactive experiences that respond to viewer behaviour
Beyond content, AI will also enhance advertising relevance and customer support, creating a smoother, more personalised user journey.
Live Sports Will Continue to Anchor Streaming Culture: While binge-worthy series drive daily engagement, live sports remain one of streaming’s biggest cultural anchors. Football, in particular, continues to command passionate followership in Nigeria.
With the 2026 FIFA World Cup scheduled for June–July, live streaming will dominate viewing behaviour once domestic leagues conclude. Nigerian football fans demand quality, reliability and immediacy, making official platforms with full broadcast rights, such as SuperSport, essential destinations during major tournaments.
In 2026, sports will further reinforce the value of legitimate, high-quality streaming experiences.
Security Becomes Non-Negotiable: As streaming cements its cultural relevance, content protection will take on greater importance. Premium sports and entertainment remain prime targets for piracy, but the response is becoming more sophisticated.
Technologies from cybersecurity firms like Irdeto now enable real-time monitoring, rapid takedowns and legal action against illicit streaming networks. These measures protect not just platforms, but creators and the broader creative ecosystem, a critical consideration as local production continues to grow.
Innovation Makes Streaming More Inclusive: One of the most significant shifts in Nigeria’s streaming landscape is how inclusive it has become. Platforms are innovating around:
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Flexible pricing
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Bundled services that combine TV and streaming
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Multi-device access, including mobile-first options
Whether premium or entry-level, users can now find options that suit their lifestyle and budget, reinforcing streaming’s position as an everyday entertainment staple.
A More Conscious Streaming Audience Emerges: As streaming culture matures, so does audience awareness. Nigerian viewers are increasingly able to identify illegal streaming platforms and understand the long-term damage piracy causes to the industry.
In 2026, conscious viewing will continue to gain ground, with users learning to avoid red flags such as “free” premium streams, unofficial apps, VPN-only access and excessive pop-up advertising.
Streaming is no longer simply about watching content, it is about belonging to moments, communities and conversations. In Nigeria, it has evolved into a cultural force that shapes how stories are told, shared and celebrated.
As 2026 unfolds, streaming will continue to thrive at the intersection of technology, culture and creativity, offering entertainment that is accessible, relevant and deeply local.
Feature/OPED
How Compliance through Technology among Banks can Promote Intra-Africa Trade
By Anne Mureithi
Provision of banking services in Africa continues to undergo profound digital transformation where most transactions are conducted virtually via digital devices and cash moved electronically. Mobile banking, fintech innovation, and cross-border digital payments have reshaped how individuals and businesses consume financial services.
In Nigeria and across the continent face, banks face sharp scrutiny from expanding regulatory landscape, including Anti-Money Laundering (AML), combating the financing of terrorism (CFT) and combating the financing of proliferation (CPF) that involves disrupting funds for weapons of mass destruction (WMD) through targeted financial sanctions.
With increased cross border trade, everyone including governments look upon banks to provide Know Your Customer (KYC) services, fraud risk management, and increasingly adhere to stringent data protection and privacy regulations as well as Environmental, Social, and Governance (ESG) reporting standards.
Compliance is no longer a back-office obligation, and this calls for increased investments in technology, particularly Artificial Intelligence (AI) and Machine Learning (ML) to enable banks to meet compliance requirements.
This is important as local traders want a banking partner who offers one-stop shop services on compliance matters. For banks, this is a competitive advantage, a core capability, and a source of differentiation. By embedding compliance into product and process design, banks can meet regulatory obligations efficiently while fostering innovation through a compliance-by-design approach.
In March 2025, the Central Bank of Kenya published the results of a survey on AI adoption in the banking sector, revealing moderate uptake, with 50% of respondents indicating some level of implementation. The survey found that among institutions that had adopted AI and machine learning, the leading applications were credit risk assessment (65%), cybersecurity (54%) and customer service (43%), followed by e-KYC (41%) and fraud risk management (40%).
These findings underscore significant untapped potential for AI to transform customer experience and strengthen risk management, particularly in AML and compliance monitoring. As intra-Africa trade continues to increase, compliance teams within banks must play a leading role in establishing strong governance, ensuring transparency, and preparing institutions for emerging regulatory expectations.
The Central Bank of Kenya has confirmed that it is in the final stages of developing a Guidance Note on Artificial Intelligence, with 95% of surveyed institutions having requested formal regulatory direction. The anticipated principles-based framework will focus on governance, risk management, transparency, and the ethical use of AI, laying the foundation for responsible innovation in the financial sector.
AI and ML models offer practical solutions to compliance challenges by learning and tracking typical behavioural patterns by customer, product, and corridor, flagging anomalies such as unusual counterparties, transaction values, or routing patterns in cross-border flows. These tools can also generate more accurate and complete assessments of ongoing customer due diligence and customer risk, which can be updated to account for new and emerging threats in real time.
By detecting potential violations of normal customer profiles in data or groups of customers with higher-risk characteristics, AI has streamlined priorities towards high-risk cases and reduced the time spent on false positives. This capability is increasingly critical as transaction volumes and complexity grow. Such technological advances transform compliance from a costly obligation into a strategic advantage.
Customers do not need to know one another to execute a transaction since AI-powered identity authenticates customer identity through document scanning, biometric verification and mobile-based identity solutions. These solutions have also enabled banks to onboard new customers remotely without the need to visit a physical bank to fill in registration details.
Accounts are fully secure and only users who pass the mobile-based identity verification are allowed access thereby preventing fraud. This also supports financial inclusion by enabling access to financial services for individuals who struggle to provide adequate identification documents for opening bank accounts.
In addition, Regulatory Technology (RegTech) solutions enable financial institutions to monitor regulatory developments, map obligations across their operations, conduct initial gap assessments, ensure that policies and procedures are always up to date and streamline regulatory reporting.
This capability is particularly valuable for pan-African institutions in ensuring agility while responding to regulatory changes across multiple jurisdictions. With its presence in 34 African countries, Ecobank advocates for harmonised payment systems and regulatory frameworks as a catalyst for accelerating intra-African trade.
Regional regulatory alignment further amplifies these gains. As African regulators work towards greater harmonisation of standards, banks with pan-African footprints are uniquely positioned to bridge local realities with global expectations, enabling smoother cross-border transactions and reducing friction for businesses operating across multiple markets.
The convergence of digital innovation and regulation presents an opportunity to support regional integration and strengthen public confidence. Banks that integrate compliance into their digital strategies, invest in ethical AI, enforce strong governance, and actively engage regulators will be best positioned to compete, facilitate trade, and protect financial integrity.
On an Africa-wide platform, traders from Nigeria want a synchronised platform that provides them with end-to-end solutions. Say Ecobank Group’s AML monitoring and sanctions screening capabilities within its SWIFT payment infrastructure ensure that all cross-border payment messages undergo real-time compliance checks prior to fund settlement.
With increased intra-Africa trade that rides on online platforms, accelerated digitalisation of cross-border transactions, timely, efficient, and secure payment processing is paramount. Real-time compliance monitoring is a non-negotiable cornerstone of safeguarding the integrity of international payment flows.
Ultimately, the future of banking in Africa will be defined by how institutions harness technology to meet regulatory obligations, deter financial crime, and foster trust among businesses, consumers, and public institutions alike. Compliance is no longer a constraint on growth; it is a foundation for sustainable innovation, regional integration, and long-term confidence in Africa’s financial system.
Ms Mureithi is a director in charge of compliance at Ecobank, Central, Eastern and Southern Africa (CESA)
Feature/OPED
The Missing Pieces in Nigeria’s Banking Recapitalisation
By Blaise Udunze
Nigeria’s economy will be experiencing yet another round of reform; after the new tax implementation, the banking sector recapitalisation exercise will begin within less than three months until the March 31, 2026, deadline. The Central Bank of Nigeria (CBN) Governor, Olayemi Cardoso, disclosed that 27 banks have tapped the capital market via public offers and rights issues.
The figures show that of 21 the 37 commercial, merchant, and non-interest banks in the country have met or exceeded the revised minimum capital thresholds of N500 billion for internationally authorised banks, N200 billion for national banks, N50 billion for regional banks, and N10-20 billion for non-interest banks. With the developments above, policymakers are betting that stronger balance sheets will help banks withstand macroeconomic shocks, finance growth, and restore confidence in the financial system. On the surface, the logic is sound, capital matters. But history warns us that capital alone is not a cure-all.
Nigeria has been here before, going by the 2004-2005 era of the then-governor of CBN, Charles Soludo, whose banking consolidation dramatically reduced the number of banks from 89 to 25 and created national champions. Yet barely five years later, the system was back in crisis, requiring regulatory intervention, bailouts, and the creation of the Asset Management Corporation of Nigeria (AMCON) to absorb toxic assets. The lesson here is clear, which revealed that recapitalisation that ignores structural weaknesses merely postpones failure.
If the current exercise is to succeed, the CBN must use it not only to raise capital but to repair the deeper fault lines that have long undermined the stability, credibility, and effectiveness of Nigeria’s banking sector.
More Capital isn’t Always Better Capital
The first and most critical issue is the quality of capital being raised. Disclosures made by the banks have shown that the combined capital base of about N5.142 trillion is already locked in by lenders across the different licence categories. Bigger numbers on paper mean little if the capital is not genuinely loss-absorbing. In past recapitalisation cycles, concerns emerged about funds being raised through related parties, short-term borrowings disguised as equity, or complex arrangements that ultimately recycled the same risks back into the system.
This time, the CBN must insist on transparent, verifiable sources of capital. Every naira raised should be traceable, free from conflicts of interest, and capable of absorbing real losses in a downturn. Otherwise, recapitalisation becomes an accounting exercise rather than a resilience-building one.
Why Corporate Governance Remains the Achilles’ Heel
Perhaps the most persistent weakness in Nigeria’s banking sector is corporate governance failure. Many bank crises have not been caused by macroeconomic shocks alone, but by poor board oversight, insider abuse, weak risk culture, and excessive executive power.
Recapitalisation provides a rare regulatory leverage point. The CBN should use it to reset governance standards, not just capital thresholds. Boards must be independent in substance, not just in form. Being one of the critical aspects of the banking challenge, insider lending rules should be enforced without exception. Risk committees in every financial institution must be empowered, not sidelined by dominant executives.
Without the apex bank fixing governance, new capital risks become fresh fuel for old excesses.
The Unresolved Burden of Non-Performing Loans (NPLs)
Data from the CBN’s latest macroeconomic outlook showed that the banking industry’s Non-Performing Loans ratio climbed to an estimated 7 percent, pushing the sector above the prudential ceiling of 5 percent. Nigeria’s banking sector continues to be drowned with high volumes and recurring non-performing loans (NPLs), and this is often concentrated in sectors such as oil and gas, power, and government-linked projects. Though with the trend of events, one may say that regulatory forbearance has helped maintain surface stability in the sector, no doubt it has also masked underlying vulnerabilities.
The truth is that a credible recapitalisation exercise must confront this reality head-on. Loan classification and provisioning standards should reflect economic truth, not regulatory convenience. Banks should not be allowed to carry impaired assets indefinitely while presenting healthy balance sheets to investors and the public.
Transparency around asset quality is not a threat to stability; it is a foundation for it.
How Foreign Exchange Risk Quietly Amplifies Financial Shocks
Few risks have damaged bank balance sheets in recent years as severely as foreign exchange volatility. Many banks continue to carry significant FX mismatches, borrowing short-term in foreign currency while lending long-term to clients with naira revenues.
During periods of FX adjustment, these mismatches can rapidly erode capital, no matter how well-capitalised a bank appears on paper. Recapitalisation must therefore be accompanied by tighter supervision of FX exposure, stronger disclosure requirements, and realistic stress testing that assumes adverse currency scenarios, not best-case outcomes.
Ignoring FX risk is no longer an option in a structurally import-dependent economy.
Concentration Risk and the Narrow Credit Base
Another long-standing weakness is excessive concentration risk. A disproportionate share of bank lending is often tied to a small number of large corporates or government-related exposures. While this may appear safe in the short term, it creates systemic vulnerability when those sectors face stress.
At the same time, the real economy, particularly SMEs and productive sectors, remains underfinanced because, over the years, Nigeria’s banks faced significant concentration risk, particularly in the oil and gas sector and in foreign currency exposure, while grappling with a narrow credit base characterised by limited lending to the private sector. This is due to high credit risk and tight monetary policy. Owing to this trend, recapitalisation should therefore be in alignment with policies that encourage credit diversification, improved credit underwriting, and smarter risk-sharing mechanisms, and not the other way round.
Therefore, it will be right to say that banks that grow larger but remain narrowly exposed do not strengthen the economy; they amplify its fragilities.
Risk Management in a Volatile Economy
The recurring inflation shocks, interest-rate swings, fiscal pressures, and external shocks are frequent features, not rare events, which show that Nigeria is not a low-volatility environment.
Currently, the Nigerian banking sector’s financial performance and investment returns are equally affected by various risks, including credit, liquidity, market, and operational risks.
Today, many banks still operate risk models that assume stability rather than disruption. Time has proven that risk management is essential for mitigating these risks and ensuring stability and profitability.
The apex bank must ensure that the recapitalisation process mandates robust, Nigeria-specific stress testing, and banks must demonstrate resilience under severe but plausible scenarios. This includes sharp currency depreciation, interest-rate spikes and sovereign stress. It must evolve from a compliance function to a strategic discipline.
Transparency and Financial Reporting
Investors, depositors, and analysts must be able to understand banks’ true financial positions without navigating a lack of transparent disclosures or creative accounting. Hence, public trust in the banking sector depends heavily on credible financial reporting.
The CBN should use recapitalisation to strengthen the International Financial Reporting Standard enforcement, disclosure standards, and audit quality. In championing this course, banks’ financial statements should clearly reflect capital adequacy, asset quality, related-party transactions, and off-balance-sheet exposures. Transparency is to enable confidence, not about exposing weakness.
Regulatory Consistency and Credibility
Policy credibility has been one of the greatest challenges for Nigeria’s financial regulators.
Abrupt changes, unclear timelines, and inconsistent enforcement undermine investor confidence and weaken reform outcomes.
Recapitalisation must be governed by clear rules, predictable timelines, and consistent enforcement. Both domestic and foreign investors need assurance that the rules of the game will not change midstream. Regulatory credibility is itself a form of capital.
Consumer Protection and Banking Ethics
While recapitalisation focuses on banks’ balance sheets, the public experiences banking through fees, service quality, dispute resolution, and ethical conduct. Persistent complaints about hidden charges and poor customer treatment erode trust in the system and a stronger banking sector must also be a fairer and more accountable one. It must be noted that strengthening consumer protection frameworks alongside recapitalisation will help rebuild public confidence and reinforce financial inclusion goals.
Too Big to Fail and How to Resolve Failure
Looking at what is obtainable in the system, larger, better-capitalised banks can also become systemically dangerous if failure resolution frameworks are weak. This requires that recapitalisation should therefore be accompanied by credible plans for resolving distressed banks without destabilising the entire system or resorting to taxpayer-funded bailouts, which has been the norm in the Nigerian banking sector today. The cynic might say that recapitalisation simply made big banks bigger and empowered dominant shareholders. However, a more prospective approach invites all stakeholders, including regulators, customers, civil society and bankers themselves, to co-design the next chapter of Nigerian banking; one that balances scale with inclusion, profitability with impact, and stability with innovation.
Clear resolution mechanisms reduce moral hazard and reinforce market discipline.
A Moment That Must Not Be Wasted
Recapitalisation is not merely a financial exercise; it is a governance and trust reset opportunity. If the CBN focuses solely on capital numbers, Nigeria risks repeating a familiar cycle of apparent stability followed by crisis.
The banking sector can lay a solid foundation that truly supports economic transformation if recapitalization is used to address governance failures, asset quality, FX risk, transparency, and regulatory credibility.
Nigeria does not just need bigger banks. It needs better banks, institutions that are resilient, transparent, well-governed, and trusted by the public they serve. Hence, it must be a system that creates a more robust buffer against shocks and positions Nigerian banking as a global competitor capable of funding a $1 trillion economy, as the case may be.
This recapitalisation moment must be about building durability, not just size. The cost of missing that opportunity would be far greater than the cost of getting it right.
Blaise, a journalist and PR professional, writes from Lagos and can be reached via: [email protected]
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