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The SEC, Crypto and the Law: What the Investments and Securities Act 2025 Means for the Future of Digital Finance in Nigeria

Date:

By: Omobolanle Alashe & Taiwo Kehinde Mosunmola

Introduction

The human economy has been characterised by the interplay of needs and the scarcity of resources required to satisfy those needs. This has formed the major driving force behind the creation and persistent evolution of the modern economy.

Before the nascence of legal tender, humans acquired what they needed through a bartering system, where goods were exchanged for goods. Eventually, coins replaced this system, with precious metals such as gold and silver forming the legal tender of different societies.[1]

As time and technology progressed, paper notes (fiat currency backed by the government) phased out metal currency.[2] As is the case with many other spheres of life, currency has evolved in the wake of the influence of technology. The modern introduction of cryptocurrency can be traced to 2009[3] with the launch of Bitcoin.[4]

The Nigerian digital finance landscape has experienced several regulatory changes over the past few years, with the Central Bank of Nigeria (CBN) initially placing a ban on crypto and digital currency in 2017. In 2020, the Securities and Exchange Commission (SEC) released a circular that set in motion the acceptance of digital assets as securities.[5] In 2022 and 2023, the SEC and the CBN released more circulars and regulations that set wheels in motion for the regulation of digital assets. In March 2025, President Bola Ahmed Tinubu signed into law the Investments and Securities Act 2025, which statutorily recognises digital/virtual assets as a form of securities.[6] This legislation, which repeals the previous ISA 2007, introduces comprehensive reforms aimed at strengthening the legal and regulatory framework for investments and capital market activities in the country, as well as boosting investor confidence, strengthening market operation, and structuring Nigeria’s capital market with global best practices.[7]

Why the ISA 2025 Matters

The 2025 Investments and Securities Act ushers in a new era of financial regulation of the investment industry in Nigeria. One of the Act’s most ground-breaking provisions is the formal recognition of virtual assets, including cryptocurrencies, as securities. This classification brings Virtual Asset Service Providers (VASPs), Digital Asset Operators (DAOPs), and Digital Asset Exchanges under the regulatory purview of the Securities and Exchange Commission. The ISA 2025 also introduces stricter measures to combat fraudulent investment schemes, such as Ponzi schemes, by prescribing stringent penalties for promoters of such programs. This move is expected to deter financial malpractices and protect investors from unscrupulous operators. Furthermore, the Act encourages the SEC’s enforcement powers and aligns its regulatory composition with standards of the International Organization of Securities Commissions (IOSCO). This composition not only invigorates Nigeria’s standing in the global financial system but also guarantees that the country’s capital market operates in line with international standards, positioning the country as a competitive target for both local and foreign investments in the field of digital finance.[8]

The SEC and Digital Assets

How the ISA 2025 Redefines Digital Assets

Before the ISA 2025 was signed into law, the SEC maintained that “virtual crypto assets are securities, unless proven otherwise.” As such, the issuer of the assets was burdened with the responsibility of proving that the crypto assets they sought to issue were in fact securities. By virtue of this, crypto assets were treated by the SEC and other stakeholders as commodities if they were traded on a recognised investment exchange and were made subject to the provisions of the SEC Rules and Regulations.[9]

Section 357 of the ISA 2025 nowdefines securities as debentures, stock, shares, bonds, notes issued by a government or a body corporate; any right in respect of such debentures, stocks, shares, bonds or notes; virtual assets; commodities futures, contracts, options and other derivatives.[10] This gives official statutory recognition of digital assets as a form of securities, placing it under the regulatory purview of the SEC.

Digital Assets (also known as Virtual Assets) are digital tokens that represent assets such as debts or equity claims on issuers.[11] The definition of digital assets also extends to digital representations of value that can be transferred, digitally traded and can be used for payment or investment purposes. This definition does not include digital representations of fiat currencies, securities and other financial assets.[12]

The SEC’s Role in Crypto Regulation

The SEC, in performing its functions, aims to ensure the protection of investors and the maintenance of fair and transparent markets through the prevention and punishment of fraudulent and unfair trade practices. The SEC also aims to ensure the development of the capital market and promotion of economic development.[13] The Commission registers, regulates and supervises investments and securities businesses in Nigeria, securities and securities exchanges, capital market operators, custodians of assets, securities and other intermediaries, and prevents the unauthorised dealing in securities, among other functions.[14]

The SEC performs the above functions and more in relation to cryptocurrency and other digital assets that are securities.

In a proactive move to circumvent fraudulent practices, the SEC has introduced rigorous measures targeting the promotion of digital assets. Effective June 30, 2025, the SEC mandates all crypto platforms and VASPs to obtain a license from the SEC before engaging in promotional activities across various media channels. In the same vein, social media influencers endorsing these platforms must conspicuously disclose any paid partnerships and other such affiliations. Non-compliance with these directives could result in fines up to ₦10 million and imprisonment for up to three years.[15] 

Key Provisions of the ISA 2025

This section of the paper reviews salient provisions of the ISA 2025 and the implications on the Nigerian investment industry.

Crypto as Securities: Legal Implications

Under the ISA 2025, digital assets as securities fall under the regulatory purview of the SEC. This means that all regulatory provisions imposed on other forms of securities (shares, stocks, bonds and investment contracts) are also imposed on digital assets. Some of these are discussed herein.

Registration

Under the ISA 2025, any issuer of a digital asset that qualifies as a security must register the offering with the SEC.[16] This registration includes filing the necessary documents as required for traditional securities. This is to facilitate transparency and protect investors by ensuring they have access to full and accurate information before making investment decisions. Registration also extends to entities such as Digital Asset Offering Platforms (DAOPs), Virtual Asset Service Providers (VASPs), and Digital Asset Custodians (DACs). These service providers must undergo licensing and adhere to regulatory obligations related to capital requirements, operational standards, and investor protection mechanisms. These include compliance requirements for anti-money laundering (AML) and know-your-customer (KYC) protocols. In addition to the above, the ISA mandates that an entity seeking to trade or offer for sale any securities must seek the prior approval of the SEC, failing which a fine of not less than 50% of the value of the securities shall be imposed on the offender.[17]

Initial assessment filing

Before a digital asset can be publicly offered, the issuer must make an Initial Assessment Filing with the SEC. This process allows the SEC to determine whether the asset qualifies as a security under the ISA and whether the proposed offering meets regulatory standards. This is necessary to reduce the risk of fraudulent or misleading schemes, many of which have previously exploited regulatory gaps in the digital finance space. The Initial Assessment Filing must contain a description of the digital asset, the nature of the interest it conveys, the terms of the offering and so on.

Legal Consequences of Non-Compliance

Issuers and operators who fail to register or comply with SEC guidelines are subject to sanctions, including monetary penalties[18], cease-and-desist orders, or even criminal prosecution in severe cases.[19] This elevates the legal risk for operators who may have previously functioned in regulatory grey zones, encouraging full transparency and adherence to best practices. In addition, entities operating in the crypto arena are mandated to attain SEC approval before engaging in promotional activities.

Investor Rights and Legal Remedies

As securities, digital assets now afford investors certain rights, including access to information and legal remedies through the SEC in case of fraud or unfair practices. By formalising these rights under the ISA, Nigeria is aligning itself with international practices that emphasise investor protection and market stability. The ISA specifically established the Investments and Securities Tribunal as the appropriate court before which disputes involving securities (digital or traditional) may be brought and resolved.[20]

Impact on Crypto Startups and Investors

This regulatory shift spells change for many actors in the investment scene, including startups and investors. This section highlights what the ISA 2025 means for these stakeholders.

Legitimisation of Virtual Assets

Startups can now raise capital with legal backing, pitch to institutional investors without the lurking shadows of disclaimers, and operate platforms with a stamp of regulatory approval. This alone transforms the perception of crypto enterprises from suspicious side-hustles to fully-fledged financial entities. Crypto Startups now operate in a defined legal space, which makes them more attractive to investors, both local and international.

Moreover, with formal recognition comes access to infrastructure: partnerships with banks and other commercial institutions and integration with national ID systems for KYC processes. With formal recognition, crypto businesses are more likely to regain access to commercial banking services previously denied due to regulatory uncertainty.

On the flip-side, they face the challenge of bearing the costs of legal registration, regulatory filings, and compliance with SEC rules. This may prove prohibitive for early-stage startups.

Likewise, stringent controls could stifle innovation, especially in areas like DeFi (decentralized finance) or NFT[21] markets where regulatory definitions remain fluid.

Enhanced Investor Confidence

For investors, regulation brings a comforting clarity. They have greater protection from scams and other fraudulent schemes. Likewise, the guarantee of legal recourse makes digital assets less of a gamble to investors. In addition, it places more confidence in trading platforms which, once registered, are more likely to adhere to transparency standards, making investment decisions more informed and secure. With these measures in place, potential investors may find the Nigerian market more appealing, leading to improved capital inflow and market engagement.[22]

Catalyst for Innovation

By furnishing a clear regulatory framework, the ISA 2025 paves way for innovation within the digital finance environment. Entrepreneurs and fintech companies can now develop new products and services, knowing there are established guidelines to ensure compliance and protect consumers. This environment fosters creativity and positions Nigeria as a hub for digital financial innovation.[23]

Challenges: Compliance Costs and Restrictions

While the Act seeks to legitimize and structure the rising cryptocurrency market, it also ushers notable compliance costs and operational restrictions that pose challenges for industry stakeholders. These challenges are highlighted and discussed below.

Escalated Financial Obligations

A significant challenge is the substantial increase in registration fees for digital asset platforms. The Securities and Exchange Commission (SEC) has proposed elevating the registration fee for crypto exchanges from ₦30 million to ₦150 million, amounting to a 400% hike. Similarly, application fees have tripled from ₦100,000 to ₦300,000, and processing fees have increased from ₦300,000 to ₦1 million.[24] These financial demands are further heightened by a proposed minimum paid-up capital requirement of ₦500 million. Such costly financial barriers may dissuade startups and smaller enterprises, potentially stifling innovation and limiting market diversity.

Operational Constraints and Localization Mandates

The SEC’s revised regulations mandate that Virtual Asset Service Providers (VASPs) must be incorporated within Nigeria and maintain a physical office presence. Moreover, key executives, such as Chief Executive Officers or Managing Directors, are required to reside in the country. While these measures aim to ensure closer regulatory oversight and accountability, they may pose logistical challenges for international firms and could discourage foreign investment in Nigeria’s crypto landscape.[25]

Stricter Oversight on Promotional Activities

In an effort to circumvent misleading promotions and protect investors, the SEC has introduced rigorous regulations targeting crypto influencers and promotional activities. VASPs intending to engage in promotional endeavours must ensure they obtain prior approval from the SEC. Influencers are obligated to disclose any paid promotions, with non-compliance attracting penalties of up to ₦10 million in fines and potential imprisonment of up to three years. While these regulations seek to sanitize the market, they also impose additional compliance burdens on both service providers and marketers.[26]

Balancing regulatory objectives with the need to improve innovation and inclusivity remains essential for the sustainable development of Nigeria’s digital asset ecosystem.

Nigeria vs Global Crypto Regulations

To appreciate the uniqueness of Nigeria’s approach, it is insightful to compare it with what exists in other jurisdictions, particularly the United States, the European Union, and the United Kingdom.

The U.S. Approach

The Securities and Exchange Commission of the United States, chaired by Gary Gensler treats most crypto assets as securities by default based on the Howey Test. Under the U.S. laws, a digital asset is deemed a security if the asset is an investment contract under the Howey Test. This test establishes an asset as a security when there is (a) an investment of money; (b) in a common enterprise; (c) with an expectation of profit; (d) relying on the efforts of others.[27] This tests determines whether assets are securities or not, and as such, whether they are subject to the regulation of the SEC and the Commodity Futures Trading Commission (CFTC).

The U.S. Congress, has made efforts to pass crypto-specific bills into law, like the FIT21 Act. Such efforts remain ongoing.

While both Nigeria and the U.S. treat most digital assets as securities, Nigeria’s ISA provides a statutory definition and procedural clarity for the registration, trading and custody of such assets. In contrast, the U.S. leans on litigation and regulatory interpretation. Specific federal agencies in the US determine the definition of cryptocurrency itself. The CFTC views crypto as commodities, the Internal Revenue Service (IRS) defines crypto as property, while the SEC establishes crypto as securities.[28]

As against Nigeria’s move toward rigorous regulation, the United States has recently shifted toward a more lenient posture on cryptocurrency enforcement. Under the Trump administration, the Department of Justice (DOJ) dispersed its National Cryptocurrency Enforcement Team, indicating a downtrend of regulatory pressure on the crypto industry. Deputy Attorney General Todd Blanche highlighted that future enforcement would concentrate on individuals and entities directly engaged in fraudulent activities, rather than on platforms like exchanges or wallet providers. This policy change conforms with President Trump’s broader pro-crypto agenda, seeking to position the U.S. as a global hub for digital assets.[29] While Nigeria seeks to fuse cryptocurrencies into its formal financial system through regulation, the U.S. appears to be adopting a more laissez-faire approach, potentially fostering innovation but also raising concerns about investor protection.

The U.K. Approach

The Financial Conduct Authority (FCA) of the United Kingdom takes a different approach to crypto regulation, which some have described as function-based. The FCA published the 2019 Guidance on Crypto-assets, which divides digital tokens into security tokens and e-money tokens. Only these tokens fall under financial regulations and confer rights and obligations. It also classifies tokens: exchange tokens, utility tokens, and security tokens, which are unregulated.[30] The UK has also implemented a registration regime for crypto firms, focusing on anti-money laundering (AML) compliance. Recent moves under the Financial Services and Markets Act 2023empower regulators to bring more crypto activities into formal oversight.

While the U.K. maintains a differential treatment of tokens based on function and classification, the Nigerian ISA 2025 opts for a broad classification of all digital assets as securities unless otherwise exempted. Once under this category, the asset is subject to the general rules and regulations imposed on all other forms of securities.

The EU Approach

The European Union has taken a rather cautious approach to cryptocurrency regulation. The European Securities and Markets Authority (ESMA) has issued warnings[31] about the potential financial stability risks posed by the developing cryptocurrency sector. Despite crypto-assets representing a small portion of the market, ESMA noted that disruptions in even minor markets could be a major threat to broader financial stability, especially given the heightened linkages between crypto and traditional financial systems.

This cautious approach emphasizes the EU’s aim to closely observe the crypto sector, guaranteeing that its integration into the broader financial system does not compromise stability. Nigeria’s ISA 2025 mirrors this prudence by implementing rigorous measures to oversee virtual assets, seeking to protect investors and maintain financial integrity. Nigeria’s enactment of the ISA 2025 represents a proactive effort to integrate virtual assets into its financial system through clear and comprehensive regulation. When compared to the divergent approaches of the governments of these jurisdictions, Nigeria’s strategy reflects a commitment to fostering innovation while ensuring financial stability and investor protection. As the global landscape of digital finance continues to evolve, Nigeria’s regulatory framework positions it as a potential leader in the African crypto market, navigating the complex interplay between innovation and regulation.

The Future of Digital Finance in Nigeria

As digital currencies and virtual assets gain traction in the investment scene, our regulatory frameworks must evolve in a way that does not stifle innovation. Despite the promising outlook, challenges persist. Rigorous regulations may impose compliance burdens on startups and smaller enterprises, potentially preventing innovation.

To achieve the balance between regulation and financial inclusion, it is important for the regulatory bodies such as the SEC and the Legislature to involve key stakeholders in the process of policy making. Comprehensive frameworks for cybersecurity and anti-money laundering are also important in mitigating legal and financial risks. In addition, investing in digital infrastructure, literacy programs and FinTech solutions will ensure that marginalised populations are not left behind.

Conclusion

By aligning with international standards, the ISA 2025 places Nigeria as a competitive destination for digital asset investments, potentially boosting economic growth. This will bring about the much-needed increase in national investments.On a final note, it is important to establish that, in spite of this regulatory change, digital assets remain very volatile and subject to the risks inherent in any form of security, as well as those unique to virtual securities. As such, the relevant regulatory bodies must adopt a flexible and forward-thinking approach that anticipates technological advancements and the attendant risks. The dynamic nature of digital finance requires incessant adaptation of regulatory frameworks to address emerging risks and market developments.[32]

Achieving this balance will ensure sustainable growth in the Nigerian digital finance space. As Emomotimi Agama, the Director-General of the SEC, put it, the ISA 2025 reflects the commitment to building a dynamic and resilient capital market. With the introduction of regulatory provisions that address regulatory gaps, the new Act empowers the SEC to establish a competitive yet safe space for innovation and investment.


[1] ‘The Definition and History of Legal Tender’, (Law For Everything, 17 June, 2024) https://lawforeverything.com/definition-and-history-of-legal-tender/ accessed 1 April, 2025

[2] The major limitation of metallic currency was the need for large amounts to be carried in order to carry out large payments. It was a currency of inconvenience.

[3] Kevin Voigt and ors, ‘What is Bitcoin? Definition, Basics & How to Use’, (Nerd Wallet, 4 February, 2025) https://www.nerdwallet.com/article/investing/what-is-bitcoin#:~:text=bitcoin is a form of digital currency that aims to,users on a decentralized network.com accessed 10 March, 2025

[4] A Decentralised digital currency that utilises blockchain technology to support transactions.

[5] The SEC stated that crypto and digital assets will be treated as securities unless proven otherwise.

[6] Investments and Securities Act 2025, Section 357

[7] ‘Tinubu Signs Investments and Securities Act 2025 into Law’, (Nairametrics.com, March 29, 2025) https://nairametrics.com/2025/03/29/tinubu-signs-investment-and-securities-act-2025-into-law/  accessed 5 April, 2025

[8] Iheanyi Nwachukwu, ‘Nigeria Recognises Cryptocurrencies as Securities in Landmark Legal Shift’, (Business Day, 1  April, 2025) https://businessday.ng/markets/article/nigeria-recognises-cryptocurrencies-as-securities-in-landmark-legal-shift/ accessed 5 April, 2025

[9] Nigerian Securities and Exchange Commission, Statement on Digital Assets and Their Classification and Treatment (11 September, 2020) https://sec.gov.ng/statement-on-digital-assets-and-their-classification-and-treatment/ accessed 10 April, 2025

[10] Investments and Securities Act 2025, Section 357

[11] Rules on Issuance, Offering and Custody of Digital Assets, Part A

[12] Exposure of Amendments to the Rules on Digital Assets Issuance, Offering Platform, Exchange and Custody

[13] Investments and Securities Act 2025, Section 3(2)

[14] Investments and Securities Act 2025, Section 3(3)

[15] Zelda Akindele, Victor Sameria and Joshua Chizoma, ‘SEC Further Tightens Rules on Digital Assets with New Amendments’ (Templars, 6 January, 2025) https://www.templars-law.com/app/uploads/2025/01/SEC-Further-Tightens-Rules-on-Digital-Assets-with-New-Amendments.pdf accessed 6 April, 2025

[16] Investments and Securities Act 2025, Section 86(1)

[17] Investments and Securities Act 2025, Section 86(6)

[18] Investments and Securities Act 2025, Section 86

[19] Investments and Securities Act 2025, Sections 343 and 344

[20] Investments and Securities Act 2025, Section 326

[21] Non-fungible Tokens

[22] Iheanyi Nwachukwu, ‘Nigeria Recognises Cryptocurrencies as Securities in Landmark Legal Shift’, (Business Day, April 1, 2025) https://businessday.ng/markets/article/nigeria-recognises-cryptocurrencies-as-securities-in-landmark-legal-shift/ accessed 5 April, 2025

[23] ‘An Overview of Nigeria’s Regulatory Landscape for Fintech in 2024 and Outlook for 2025’, (Udo Udoma & Belo-Osagie, 17 March, 2025) https://www.mondaq.com/nigeria/fin-tech/1598186/an-overview-of-nigerias-regulatory-landscape-for-fintech-in-2024-and-outlook-for-2025 accessed 9 April, 2025

[24] Michael Ndu-Okeke, ‘Nigerian SEC Raises Crypto Exchange Registration Fee from N30 Million to N150 Million’ (Naira Metrics, March 2025) https://nairametrics.com/2024/03/16/nigerian-sec-raises-crypto-exchange-registration-fee-from-n30-million-to-n150million/#:~:text=Nigerian%20SEC%20Raises%20Crypto%20Exchange%20Registration%20Fee%20from%20N30%20million%20to%20N150million,-by%20Michael%20Ndu&text=Nigeria’s%20Securities%20and%20Exchange%20Commission,150%20million%20naira%20(%2493%2C000).  Accessed 10 April, 2025

[25] Osamu Ekhator, ‘SEC Mandates Nigerian Offices for Virtual Asset Companies Under New Regulation’, (Techpoint Africa) https://techpoint.africa/news/sec-nigerian-offices-virtual-asset-companies/ accessed 9 April, 2025

[26]  ‘Nigeria SEC to Unveil New Laws to Regulate Crypto Influencers’, (Coin Market Cap, January, 2025) https://coinmarketcap.com/academy/article/679736b3-b38c-4003-aa8a-607d8a6ae819#:~:text=As%20part%20of%20the%20requirements,effect%20on%20June%2030%2C%202025. Accessed 10 April, 2025

[27] Howey Test was established by the U.S. Supreme Court in SEC v W.J. Howey Co. (1946)

[28] Allie Grace-Garnett, ‘Cryptocurrency Regulation: Rules are in Development’, (Encyclopedia Britannica, 16 April, 2025) https://www.britannica.com/money/cryptocurrency-regulation accessed 22 April, 2025

[29] ‘Under Trump, US Justice Department Ends Cryptocurrency Investigations’, (Al Jazeera, 8 April, 2025) https://www.aljazeera.com/news/2025/4/8/under-trump-us-justice-department-ends-cryptocurrency-investigations accessed 9 April, 2025

[30] Adam Goldberg, Richard P. Donoghue, David Oliwenstein, ‘How are Digital Assets Regulated in the United States and Elsewhere?’ (Pillsbury Law, 17 January, 2023) https://www.pillsburylaw.com/en/news-and-insights/digital-assets-regulated-us-elsewhere.html accessed 10 April, 2025

[31] Warning on Crypto Assets (2025), European Securities and Market Authorities

[32] Kenneth Chukwujekwu Nwafor, Emmanuel Ayodeji-Ayodele, ‘Regulatory Challenges aka Innovations in Financial Technology: Safeguarding Against Fraud While Maximizing ROI’ (2024) Volume 5 Issue 10 International Journal of Research Publication and Reviews pp 4983-4994 https://doi.org/10.55248/gengpi.5.1024.3125 accessed 11 April, 2025


References

  1. ‘An Overview of Nigeria’s Regulatory Landscape for Fintech in 2024 and Outlook for 2025’, (Udo Udoma & Belo-Osagie, 17 March, 2025) https://www.mondaq.com/nigeria/fin-tech/1598186/an-overview-of-nigerias-regulatory-landscape-for-fintech-in-2024-and-outlook-for-2025
  2. ‘Nigeria SEC to Unveil New Laws to Regulate Crypto Influencers’, (Coin Market Cap, January, 2025) https://coinmarketcap.com/academy/article/679736b3-b38c-4003-aa8a-607d8a6ae819#:~:text=As%20part%20of%20the%20requirements,effect%20on%20June%2030%2C%202025.
  3. ‘The Definition and History of Legal Tender’, (Law for Everything, 17 June, 2024) https://lawforeverything.com/definition-and-history-of-legal-tender/
  4. ‘Tituba Signs Investments and Securities Act 2025 into Law’, (Nairametrics.com, March 29, 2025) https://nairametrics.com/2025/03/29/tinubu-signs-investment-and-securities-act-2025-into-law/
  5. ‘Under Trump, US Justice Department Ends Cryptocurrency Investigations’, (Al Jazeera, 8 April, 2025) https://www.aljazeera.com/news/2025/4/8/under-trump-us-justice-department-ends-cryptocurrency-investigations
  6. Akindele, Z., Sameria, V. and Chizoma, J., ‘SEC Further Tightens Rules on Digital Assets with New Amendments’ (Templars, 6 January, 2025) https://www.templars-law.com/app/uploads/2025/01/SEC-Further-Tightens-Rules-on-Digital-Assets-with-New-Amendments.pdf
  7. Ekhator, O., ‘SEC Mandates Nigerian Offices for Virtual Asset Companies Under New Regulation’, (Techpoint Africa) https://techpoint.africa/news/sec-nigerian-offices-virtual-asset-companies/
  8. European Securities and Market Authorities Warning on Crypto Assets 2025
  9. Exposure of Amendments to the Rules on Digital Assets Issuance, Offering Platform, Exchange and Custody (revised September 2024)
  10. Goldberg, A., Donoghue R., Oliwenstein D., ‘How are Digital Assets Regulated in the United States and Elsewhere?’ (Pillsbury Law, 17 January, 2023) https://www.pillsburylaw.com/en/news-and-insights/digital-assets-regulated-us-elsewhere.html
  11. Grace-Garnett, A., ‘Cryptocurrency Regulation: Rules are in Development’, (Encyclopedia Britannica, 16 April, 2025) https://www.britannica.com/money/cryptocurrency-regulation
  12. Iheanyi Nwachukwu, ‘Nigeria Recognises Cryptocurrencies as Securities in Landmark Legal Shift’, (Business Day, 1 April, 2025) https://businessday.ng/markets/article/nigeria-recognises-cryptocurrencies-as-securities-in-landmark-legal-shift/
  13. Investments and Securities Act 2025
  14.  Michael, Ndu-Okeke, ‘Nigerian SEC Raises Crypto Exchange Registration Fee from N30 Million to N150 Million’ (Naira Metrics, March 2025) https://nairametrics.com/2024/03/16/nigerian-sec-raises-crypto-exchange-registration-fee-from-n30-million-to-n150million/#:~:text=Nigerian%20SEC%20Raises%20Crypto%20Exchange%20Registration%20Fee%20from%20N30%20million%20to%20N150million,-by%20Michael%20Ndu&text=Nigeria’s%20Securities%20and%20Exchange%20Commission,150%20million%20naira%20(%2493%2C000).
  15. Nigerian Securities and Exchange Commission, Statement on Digital Assets and Their Classification and Treatment (11 September, 2020) https://sec.gov.ng/statement-on-digital-assets-and-their-classification-and-treatment/
  16. Nwafor, K., Ayodeji-Ayodele, E., ‘Regulatory Challenges aka Innovations in Financial Technology: Safeguarding Against Fraud While Maximizing ROI’ (2024) Volume 5 Issue 10 International Journal of Research Publication and Reviews pp 4983-4994 https://doi.org/10.55248/gengpi.5.1024.3125
  17. Rules on Issuance, Offering and Custody of Digital Assets 2022
  18. SEC v W.J. Howey Co. 328 U.S. 239 (1946)
  19.  Voigt, K. and ors, ‘What is Bitcoin? Definition, Basics & How to Use’, (Nerd Wallet, 4 February, 2025) https://www.nerdwallet.com/article/investing/what-is-bitcoin#:~:text=bitcoin is a form of digital currency that aims to,users on a decentralized network.com
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