The Central Bank of Nigeria (CBN) has introduced a stringent requirement for peer-to-peer (P2P) cryptocurrency transactions conducted on platforms, mandating that the naira account name and Bank Verification Number (BVN) must match the verified customer before any Regulated Token—including stablecoins—can be released or credited.
New Regulatory Framework and Licence Rules
Detailed in Section 10.3.3 of the CBN’s Regulations for the Operations of Non-Security Virtual Assets in Nigeria (November 2026), the new directive targets platform-facilitated P2P services, which include matching, order display, escrow, settlement assistance, and dispute resolution for Regulated Tokens traded against naira or other approved assets.
A key provision restricts platforms from releasing tokens until the naira payment account’s name and BVN align with the verified customer profile. This rule does not apply to direct two-party transfers without any platform involvement, as those transactions remain outside the CBN’s immediate oversight for P2P services.
The regulations specify that only entities with appropriate authorisation—such as the Other Services Licence, Other Services Authorisation, or approval to extend permitted activities—can facilitate P2P services. General approval for other virtual asset services is not sufficient; explicit permission that covers P2P activities must be granted by the bank.
Providers must enforce identity verification, conduct thorough due diligence, and maintain ongoing monitoring of customers before any trading occurs. They are required to collect sufficient information to accurately identify customers and counterparties, and to ensure every transaction can be traced to the correct accounts, wallets, and settlement systems.
Operational Protocols and Compliance Standards
Section 10.3.3 introduces a firm control: platforms are forbidden from releasing or crediting Regulated Tokens if the BVN and name on the naira account do not correspond to the verified customer details. The CBN reserves the right to impose additional controls on payment accounts, customer categories, and transaction limits in the future.
Section 10.3.4 outlaws the use of third-party, nominee, false, or otherwise misleading accounts to conceal the true ownership behind a transaction. Providers must apply enhanced scrutiny for high-volume or publicly advertised P2P sellers, who are to be treated as business users. This subjects them to stricter controls, board-level review, and mandatory reporting to the CBN. However, the business seller categorization does not equate to implicit regulatory approval for running P2P services without the required licence.
Stablecoins and Cross-Border Transactions
The BVN match rule has significant implications for stablecoin P2P trading. For instance, when a platform holds or releases a dollar- or naira-pegged token after a naira transfer, only the customer whose bank account’s name and BVN match the verified platform profile is eligible to receive the token. This provision is designed to close compliance gaps and prevent circumvention via misaligned payment and token ownership.
The same regulatory package has set a N15 billion capital requirement for issuers of Class 2 dollar stablecoins, underscoring the seriousness of Nigeria’s approach to virtual asset oversight.
Mini dictionary: Bank Verification Number (BVN) — An identity verification system used by Nigerian banks to uniquely identify and monitor account holders in order to reduce fraud and improve oversight across the financial sector.
Foreign currency-based P2P trades remain subject to additional restrictions. Section 10.6.2 prohibits such trades involving naira and Class 2 stablecoins unless specifically approved by the CBN, with the requirement for transactions to be routed through authorized dealers and subject to appropriate reporting and monitoring standards. Domestic P2P authorizations do not extend to cross-border activities.
| Transaction type | BVN match rule applies? | Requires CBN approval? |
|---|---|---|
| Platform-facilitated P2P (naira, Regulated Token) | Yes | Yes |
| Direct two-party transfer (no platform involved) | No | No |
| P2P involving foreign currency stablecoin | Yes | Yes (additional requirements) |
Transition Period and Implementation Timeline
The effective date for these requirements will be set by a formal CBN announcement under Section 56. Those currently operating affected services have 180 days from that notification to obtain proper authorisation, with interim restrictions in place. All existing providers must register within 30 days, while anti-money laundering obligations start immediately.
Until all licences and approvals are issued, the rule is clear: no platform-based P2P transaction can result in a Regulated Token being released unless the naira account details fully match the verified customer’s name and BVN.
Section 10.3.3 stipulates that release of stablecoins and other regulated tokens on a platform is contingent on the naira account holder’s name and BVN matching the platform’s verified customer, placing a strong compliance gate at the critical step of P2P token distribution.
CBN’s approach aims to ensure that only the rightful account holder may unlock tokens tied to naira payments, tightening controls over the rapidly growing P2P market in Nigeria’s crypto ecosystem.
