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In Nigeria’s virtual asset market, anti-money laundering compliance is no longer an administrative formality. It is the gateway to market access, determining whether a virtual asset service provider can be licensed, banked, funded, and scaled.

The Investments and Securities Act 2025 recognises virtual assets as securities. Nigeria’s exit from the Financial Action Task Force grey list has raised supervisory expectations, and the Money Laundering (Prevention and Prohibition) Act 2022 places virtual asset service providers squarely within the definition of financial institutions. Enforcement trends confirm how quickly a compliance gap becomes an operational and investor risk.

In this publication, TEMPLARS Partner, Emmanuel Gbahabo and Associates, Onyinye Omenugha and Obinna Onyishi set out the obligations that now govern market participation, the pitfalls that most often expose operators, and the practical steps that keep a business compliant, investible, and competitive.

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