The CBN Guidelines on Operations of Bank Accounts for Virtual Assets Service Providers are Nigeria’s 2023 central-bank guidance for the banking relationship between CBN-regulated financial institutions and SEC-licensed virtual asset service providers. The Central Bank of Nigeria says it issued the guidelines on December 22, 2023, as part of a regulatory response to virtual assets, monetary stability, and financial-sector risk.
The guidelines are legally significant because they supersede the CBN’s earlier 2017 and 2021 virtual-currency banking circulars on the same subject, while preserving an important boundary: banks and other financial institutions remain prohibited from holding, trading, or transacting in virtual currencies on their own account. The circular required banks and other financial institutions to comply immediately.
Scope of the CBN VASP bank account guidelines
The instrument applies to banks and other financial institutions under the CBN’s regulatory purview. Its stated purpose is not to license VASPs directly, but to govern how regulated financial institutions may open and operate accounts for licensed VASPs and digital asset entities in Nigeria. The text frames the regime as complementary to AML/CFT/CPF laws and customer due diligence rules.
The CBN links the guidelines to Nigeria’s broader digital-asset framework, including the Securities and Exchange Commission’s 2022 rules on issuance, offering platforms, custody, VASPs, and digital asset exchanges. The SEC’s own rules page describes those 2022 rules as covering digital asset issuance, DAOPs, custodians, VASPs, and DAXs.
Key provisions for banks, VASPs, and digital asset entities
The guidelines permit financial institutions to open designated accounts, provide designated settlement accounts and settlement services, act as channels for certain FX flows and trade, and undertake any other activity the CBN may permit. Eligible stakeholders include commercial and merchant banks, certain payment service providers, SEC-registered VASPs, digital asset custodians, digital asset offering platforms, digital asset exchanges, DAX operators, and other entities the CBN may categorize.
- Designated account rule: accounts used for virtual or digital asset business must be designated for that purpose and opened in line with the guidelines.
- Approval and documentation: designated accounts require senior management approval and specified documentation, including evidence of a valid SEC licence, corporate filings, identity information, BVNs, beneficial-owner information, and AML/CFT/CPF policies.
- Account restrictions: designated accounts are limited to virtual or digital asset transactions; cash withdrawals and third-party cheques are not allowed.
- Monthly reporting: financial institutions must submit returns to the CBN covering designated account activity, transaction value and volume, counterparties, fraud or theft incidents, complaints, and remedial measures.
Settlement, AML/CFT, and consumer protection controls
For designated settlement accounts, financial institutions must obtain CBN authorization. The settlement account is intended to warehouse Naira positions, is not interest-bearing, and must not facilitate FX positions on the VASP or digital asset platform. The guidelines also refer to collateral, T+3 settlement, KYC-linked funding and receipts, and a rule that platform transactions are only in Naira.
The risk-management provisions require customer due diligence and enhanced due diligence on a risk basis, beneficial-ownership checks, source-of-funds and source-of-wealth measures, documentation validation, recordkeeping for at least five years, monitoring of unusual transactions, and suspicious transaction reporting to the Nigerian Financial Intelligence Unit. Consumer-protection measures include fraud controls, complaint channels, and complaints-redress mechanisms.
Status and legal effect
As of July 27, 2026, no CBN repeal or replacement was identified in the sources reviewed. The profile therefore treats the guidelines as in force for CBN-regulated financial institutions. The instrument remains best understood as agency guidance with operative supervisory effect for banks and other financial institutions, rather than a comprehensive licensing law for all digital asset activity in Nigeria.
