The Central Bank of Nigeria (CBN) has introduced a stringent requirement for peer-to-peer (P2P) cryptocurrency transactions on platform-based services. According to Section 10.3.3 of its Nove
The Central Bank of Nigeria (CBN) has introduced a stringent requirement for peer-to-peer (P2P) cryptocurrency transactions on platform-based services. According to Section 10.3.3 of its November 2026 Regulations for the Operations of Non-Security Virtual Assets in Nigeria, platforms must ensure that the naira account name and Bank Verification Number (BVN) exactly match the verified customer before releasing or crediting regulated tokens, including stablecoins.
The regulation focuses on services facilitated by platforms, covering activities like matching buyers and sellers, order display, escrow, payment assistance, settlement, checks, and dispute resolution. The rules apply to regulated tokens in exchange for naira or other permitted values. Transactions carried out between two individuals without platform assistance are not subject to this section.
The document classifies Regulated Tokens as Class 1 and Class 2 stablecoins, Deposit Money Tokens, and Other Designated Tokens. For anyone wishing to operate a P2P service, CBN states that a standalone P2P license will not be issued. Only entities with an Other Services Licence, Other Services Authorisation, or specific approval to expand permitted activities can offer such services. Any P2P facilitation also requires explicit approval from the bank—it is not enough to receive general virtual asset service permission.
Customer verification measures are rigorously enforced at the token release stage. Before trading, platforms must conduct comprehensive identity checks, due diligence, and ongoing customer monitoring. Information on both parties in a transaction must be sufficient to verify their identities and connect each deal precisely to corresponding accounts, wallets, or payment channels.
Section 10.3.3 requires that if the naira payment account’s name and BVN do not match the verified customer, the provider cannot release or credit regulated tokens. The CBN may add further account checks, customer categories, or restrictions at its discretion.
The regulations strictly prohibit using third-party, nominee, mule, or other false accounts or wallets to conceal ownership or identity. High-volume or advertised P2P sellers are classified as business users, subject to enhanced review, trade limits, and mandatory reporting to the central bank. However, such designation does not grant permission to conduct regulated activity without the required licensing and approval.
The rules address persistent questions about identity verification in P2P stablecoin trading. For each naira transfer on a platform, it is the verified customer controlling the naira account who must be matched before a regulated token is credited or released. This measure closes a loophole seen in some informal Nigerian P2P markets, where fiat payments could go to one party while tokens are released to a different individual.
For stablecoin issuers, the regulations accompany a minimum capital requirement of N15 billion for Class 2 dollar stablecoin projects. The BVN match applies specifically at the point of token release during P2P sales, focusing on the identity behind the naira leg of the transaction rather than simply the wallet address involved.
Mini dictionary: BVN (Bank Verification Number) is a unique identification number issued by Nigerian banks to every customer, used to tie all accounts and ensure accurate identity verification in financial transactions.
Cross-currency and cross-border swaps face additional restrictions. Section 10.6.2 forbids platform P2P exchanges between naira and Class 2 stablecoins or foreign currency unless CBN provides explicit approval. Such approvals must be routed through authorized dealers and subject to strict reporting and monitoring requirements. Domestic P2P approval does not cover international activity under Section 10.9.
Token Class P2P Approval Needed Minimum Capital BVN Match Required Class 1 Stablecoin Yes Not specified Yes Class 2 Stablecoin Yes N15 billion Yes Deposit Money Token Yes Not specified YesThe effective date of these requirements depends on the central bank’s issuing circular as described under Section 56. Existing P2P operators have 180 calendar days from this start date to seek proper authorization, with an initial 30-day deadline for registration. Anti-money laundering controls begin immediately during this transition phase.
Until the new licensing regime fully comes into effect, the central rule is already clear: Regulated tokens cannot be released in a platform-mediated P2P transaction unless the naira account name and BVN confirm the recipient is the verified customer of record.
While digital trades may look straightforward in user interfaces, Nigeria’s approach emphasizes that only the verified bank account holder can unlock token credits on regulated P2P platforms.
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