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When you buy cryptocurrencies such as Bitcoin or Ether on a local exchange, you are often trusting the platform with one simple task: to keep your funds safe.
But what happens if the exchange is hacked, freezes withdrawals or suddenly shuts down?
Nigeria’s Securities and Exchange Commission (SEC) wants cryptocurrency companies to have better answers.
Under proposed rules released on August 20, crypto exchanges and other digital asset firms would have to separate customer funds from their own, strengthen how they safeguard cryptocurrencies, and report major losses, cyber incidents, and other material operational failures to the regulator.
The framework, which is open for public comment, brings a rule already familiar in the traditional banking sector to the digital asset industry: when something goes wrong, the regulator expects to know about it quickly. Like banks, crypto firms would have to notify their regulator of certain incident reporting within 24 hours with further updates where necessary; the SEC’s proposal also requires digital asset firms to submit a detailed incident report within 48 hours.
The SEC is also proposing higher financial requirements for digital asset businesses. Digital Asset Exchanges and Digital Asset Custodians (DACs) would each need minimum paid-up capital of ₦2 billion ($1.5 million) while Digital Asset Platform Operators (DAPOs), Digital Asset Offering Platforms (DAOPs), and Real-World Asset Tokenisation Platforms (RATOPs) would require ₦500 million ($371,600). Virtual Asset Service Providers would require ₦200 million ($149,000).
The proposal also requires a current fidelity insurance bond covering at least 25% of the applicable minimum paid-up capital.
The rules are aimed at strengthening investor protection and reducing the risk that customers lose access to their assets when a digital asset company fails. The stakes are high in a market where the collapse or failure of a platform can leave customers unable to access their money, with little clarity on when—or whether—they will be repaid.
TechCabal Intelligence
Test your virtual asset business model against Nigeria SEC’s capital locks, supervisory levies, and stress traps.
1. Setup 2. Capital 3. Traps 4. Results Select Business Category This determines your legal capital baseline, licensing fees, and whether you are forced to lock assets in offline cold storage. Digital Asset Exchange (DAX) Digital Asset Custodian (DAC) Virtual Asset Service Provider (Brokerage) Digital Asset Offering Platform (DAOP) Real-World Asset Tokenisation (RATOP) SEC Authorisation Status ARIP is a transitional 2-year incubation phase. Full registration is permanent but carries higher ongoing turnover levies. ARIP Incubation Full Registration Next: Set Capital → Starting Paid-Up Capital (₦) The total equity capital injected into the company. Note: Exchanges (DAXs) and Custodians require a strict ₦2.00 billion minimum baseline. ₦1.50 billion Est. Monthly Transaction Turnover (₦) Your projected client trading or transaction volume. The SEC uses this figure to calculate your mandatory ongoing supervisory tax. ₦5.00 billion ← Back Next: Add Traps → Select Operational Stress Traps Simulate actual SEC regulatory rules and market shocks to see if your remaining operating cash can absorb the liquidity friction.
Multi-Model Expansion (Rule 15(10)(f)):
Offering P2P, OTC, or AMM alongside an order book requires an additional 50% minimum capital buffer.
30% Crypto Market Crash as a recommended stress test event recommended by the SEC (Schedule II):
Triggers mandatory collateral haircuts (BTC valued at 75%, ETH at 70%, Altcoins at 60%).
100% Escrow Refund Lock (Rule 9(6) & 13(2)):
100% of token raise funds locked in escrow during the 5-day cooling-off window. ← Back Run Simulation → 12-Month Solvency Score 0% Calculating… Minimum Capital Baseline ₦0 Multi-Model Buffer Increase (50%) ₦0 Locked Fidelity Bond (25%) ₦0 Licensing & Processing Fees ₦0 Annual SEC Turnover Levy ₦0 Cold Storage Vault Lock (80%) ₦0 Remaining Free Cash Buffer ₦0 Loading analysis… ↺ Start Over Data Source: SEC Nigeria Rules on Digital Assets (2024/2025) TechCabal Engineering &&
The proposal also gives retail investors a five-business-day cooling-off period for certain digital asset offerings. During that period, investors can withdraw their subscription and receive a full refund, subject to the conditions set out in the rules. The provision applies to subscriptions to digital asset offerings; it is not a blanket five-day withdrawal right for every cryptocurrency purchase on an exchange.
Nigerians have already seen what can happen when a crypto company fails to protect customer assets. Patricia, a Nigerian crypto startup, suffered a breach in January 2022 that was reported to have cost the company about $2 million. The company later froze withdrawals, leaving customers unable to access their assets for extended periods.
The SEC’s proposed fidelity insurance requirement is intended to provide another layer of protection against losses suffered by clients or investors as a result of operational failure, technology failure, cybersecurity breaches, custody failures, fraud, negligence, misconduct, misappropriation or unauthorised transactions.
The protection would not extend to losses caused by market movements, price volatility or poor investment performance.
Globally, crypto platforms can hold assets belonging to many customers in the same wallet or account, a structure commonly known as an omnibus account. But those assets are still legally and operationally distinct from the platform’s own property.
The 2022 wave of crypto failures in the United States showed the consequences when that separation breaks down. Firms including Celsius, Voyager, and FTX collapsed after taking on significant risks tied to lending, trading and related activities, leaving customers to navigate lengthy bankruptcy proceedings and uncertainty over the recovery of their assets.
In FTX’s case, the US regulators alleged that customer funds were diverted to Alameda Research, its trading affiliate, and used for expenses and debts. The collapse prompted renewed scrutiny of customer-asset segregation and custody arrangements.
In a post-FTX proposal, the Commodity Futures Trading Commission (CFTC) said customer and company funds should be kept separate, with daily reconciliations and records showing who owns the assets. In August 2026, the US SEC also proposed stronger custody requirements for investment advisers holding customer crypto assets.
Nigeria’s SEC is proposing similar safeguards. Virtual Asset Service Providers (VASPs) would have to keep client assets separate from their own, while Digital Asset Custodians would have to legally segregate client assets from proprietary assets and those of affiliated entities. Custodians would also have to maintain separate wallets for each client, or equivalent internal ledgering systems that accurately attribute assets to individual clients.
Custodians would also not be allowed to use client assets for proprietary trading, or lend, pledge, rehypothecate, or otherwise encumber them, unless the arrangement is disclosed, the client gives separate consent and the SEC permits it. They would also have to reconcile client assets, with discrepancies reported to the SEC within 24 hours.
VASPs must keep customer funds separate from their own when users deposit naira or withdraw money from a crypto platform. Digital asset exchanges (DAXs) cannot use customer fiat to fund their own trading, operating expenses, lending, investments, or other obligations.
“Client fiat funds received or held in connection with on-ramp or off-ramp services shall be segregated from the [virtual asset service provider] VASP’s proprietary funds and handled in accordance with the client funds, trust account, safeguarding, and settlement requirements prescribed by the Commission,” the regulator said in the draft.
Keeping client money and assets separate makes it easier to identify ownership and protect customers if a company becomes insolvent.
TechCabal Intelligence
Check your legal token fundraising limit, SEC whitepaper taxes, or retail investment caps under Nigeria’s digital asset offering rules.
1. User Role 2. Targets 3. Results Select Your Perspective Choose whether you are a startup founder planning a token sale, or an everyday retail investor buying digital tokens. The rules apply very differently to both sides. Token Issuer / Founder Retail Investor Company Shareholders’ Funds / Net Equity (₦) Your company’s net paid-up equity capital. The government legally caps your total token fundraising at 20 times this amount over any 12-month period to prevent shell companies from raising massive capital. ₦50.00 million Your Estimated Net Worth (₦) Your total personal net worth. The government mandates extra risk warnings and suitability checks if you invest more than 5% of your net worth in a single token offer to protect you from heavy losses. ₦10.00 million Next: Set Offer Amounts → Target Token Raise Amount (₦) The total capital you wish to raise from the public through your digital asset offering. The SEC applies a tiered tax on this amount. ₦500.00 million Soft Cap / Minimum Funding Threshold (%) The minimum percentage of your raise target required for the project to proceed. If you fail to reach this threshold, SEC rules force you to refund 100% of all investor money within 5 business days. 50% (₦250.00 million) Planned Investment in Current Token Offer (₦) How much you want to invest in this specific token project. The absolute legal limit for everyday retail investors is ₦1.00 million per project. ₦800,000 Total Invested in Other Token Sales This Year (₦) The total money you have already put into other digital asset offerings in the past 12 months. Everyday retail investors cannot legally exceed ₦10.00 million in aggregate per year across all platforms. ₦2.00 million ← Back Calculate Legal Limits → Primary Regulatory Metric ₦0 Checking Status… Loading regulatory analysis… ↺ Start Over Data Source: SEC Rules on Digital Assets (Rules 8, 9 & Schedule I) TechCabal Engineering &&
The regulator is also setting consumer-protection rules for the emerging crypto-backed lending sector. Custodians would generally be prohibited from lending, pledging, or rehypothecating client crypto assets, unless the arrangement is disclosed, the client explicitly consents, and the SEC permits it.
Digital Asset Exchanges (DAXs), meanwhile, would not be allowed to use client assets for their own benefit or for the benefit of affiliates or third parties. If an exchange wants to provide separate custody services, the proposed rules require the custody entity to be separately incorporated and registered or authorised as a Digital Asset Custodian.
Several Nigerian and Africa-serving crypto companies, including Busha, Bitmonie, and Blockchain.com, have entered the crypto-backed lending market. If the SEC’s proposal is adopted as drafted, exchanges that want to continue offering custody, lending, or related services may need to obtain the relevant registration or restructure those activities through a separately authorised entity.
A Nigerian virtual asset company operating across multiple categories could therefore face multiple registration requirements, fees, and minimum-capital thresholds, depending on the functions it performs.
Digital asset custodians would have to keep at least 80% of customer assets in cold storage, leaving only what is needed for withdrawals, settlements, and transactions in online wallets.
Cold storage systems are designed to keep crypto stored offline, reducing the risk of hackers accessing customer assets. Such examples include crypto hardware wallets which are a popular cold storage method; companies such as Trezor and Ledger manufacture physical wallets for storing crypto.
Several Nigerian cryptocurrency exchanges operate custodial wallets and storage systems, which allow them to store customer assets themselves, rather than non-custodial wallets, which users control. Requiring custodians—which can also include exchanges—to keep 80% of customer assets in cold storage could increase demand for hardware wallets and other offline storage systems from foreign manufacturers.
A man using a crypto app on their phone. Image Source: AdobeStock.
Yet, several hardware wallet companies do not heavily prioritise African markets, including Nigeria, due to customs duties and the loss of control over last-mile delivery.
In December 2025, Singapore-based hardware wallet manufacturer Cypherock told TechCabal that it had sold about 15,000 wallets globally, but only about 200 in Africa.
However, the proposed rules could change that. The SEC’s logic is to keep customer assets in offline locations to make them easier to retrieve when needed, such as when the regulator or other authorities need to freeze them during an investigation.
But hardware wallets have shown they are not hack-proof.
In June, hackers exploited a vulnerability in Coldcard, an offline hardware wallet built by Canadian company Coinkite, stealing about 1,779 Bitcoins worth over $113 million, according to US-based research firm Galaxy Research.
With possibly stronger demand for cold storage, however, hot storage wallet providers who primarily serve Nigerian cryptocurrency exchanges may be caught in this regulatory provision, limiting business and adoption. If custodians must keep 80% of customer assets offline, online wallet technology providers could see less demand for their services.
Technical service providers, including wallet infrastructure companies, would fall under the digital asset custody rules if they directly hold customers’ private keys. The regulator also wants multiple people or signatories involved in accessing customers’ assets, so no single person can control them, as well as records that can be audited at all times, whether they use custodial or non-custodial wallets.
Stablecoin issuers, foreign-based or local, would also have to keep enough assets in reserve to cover what they owe holders—retail users and businesses.
Naira-backed stablecoins would need reserves equal to 100% of their outstanding liabilities, in cash or cash equivalents. Foreign-currency stablecoins would need reserves worth at least 120% of what they owe, held in the same currency or equivalent cash instruments.
A USD-backed stablecoin serving the Nigerian market, such as USDT and USDC, can be held in USD instruments, but would require a higher redemption limit.
A trader using the Kraken crypto app on their phone. Image Source: Kraken.
The SEC also wants stablecoin reserves to be kept separate from customer funds. While foreign issuers would not need to hold those reserves in Nigeria, they must still hire a local representative, show proof that they’re regulated abroad, and regularly disclose their reserves.
Kenya took a different approach with its gazetted rules, requiring stablecoin issuers to keep 30% of their reserves with local banks and the rest in local instruments.
On August 25, Tether opened roles for expansion leads in Nigeria and Côte d’Ivoire, underscoring the El Salvador-based issuer’s immediate focus.
Commodity-backed stablecoins, such as gold-backed tokens like Tether’s XAUt, would need to hold 100% backing, while crypto-backed stablecoins would need to hold at least $150 worth of approved liquid crypto assets for every $100 of stablecoins issued, keeping that level of backing at all times.
The rule would also prevent connected companies from controlling different parts of the same stablecoin business in a way that creates conflicts of interest.
If Company A owns Company B and Company B issues a stablecoin, Company A cannot promote that stablecoin on its platform without meeting the SEC’s restrictions and safeguards.
TechCabal Intelligence
Compare the true capital cost of issuing Naira, Foreign, or Crypto-backed stablecoins under Nigeria’s new rules.
1. Base Asset 2. Financials 3. Results Select Stablecoin Backing Type Choose what backs your token. The government encourages local currency tokens but applies heavy financial penalties if you back your token with US dollars or volatile cryptocurrencies. Tier 1: Naira-Backed (100% Reserve) Tier 2: Foreign Currency-Backed / USD (120% Reserve) Tier 4: Crypto-Backed via BTC (150% Reserve + 25% Haircut) Tier 4: Crypto-Backed via ETH (150% Reserve + 30% Haircut) Next: Set Issuance Targets → Planned Stablecoin Issuance (₦ Equivalent) This is the total face value of digital tokens you want to create and put into the hands of everyday users across Nigeria. ₦1.00 billion Projected 30-Day Redemption Rate (%) How much of your token supply do you expect users to turn back into cash in a normal month? The government requires you to keep an extra 120% liquid cash buffer ready to honor these withdrawals instantly. 20% ← Back Calculate Capital Drag → Total Gross Assets Required ₦0 0% Capital Drag Value Issued to Users Locked Capital Drag Target Circulating Supply ₦0 Base SEC Reserve Ratio 100% Collateral Haircut Penalty 0% Trapped Capital / Excess Reserves ₦0 Mandatory 30-Day Liquid Cash Buffer (LCR) ₦0 Loading regulatory insight… ↺ Start Over Data Source: SEC Rules on Digital Assets (Schedule II) TechCabal Engineering
The regulator is also tightening who can issue and list digital assets in Nigeria. Like Kenya, Nigeria has also proposed that foreign-issued stablecoins, such as USDT or USDC, must be approved by the SEC before cryptocurrency exchanges can list them on their platforms.
“A foreign-issued stablecoin shall not be listed, admitted for trading, custodied, settled, promoted, or otherwise used by a DAX [digital asset exchange] or other regulated platform in Nigeria unless recognised or authorised by the Commission,” the regulator said.
If more African countries adopt this rule, foreign stablecoin issuers like Tether and Circle must soon set up local entities in different countries to comply with specific local rules, or otherwise be selective about the countries they prioritise, forcing them to price risk.
At scale, it could lead to a scenario where USDT and USDC, popular US dollar-backed stablecoins, would no longer be accessible in certain African markets, as regulators fight to uphold monetary sovereignty.
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