Virtual Assets · Nigeria
The Virtual Asset Council Explained: What Tinubu's Executive Order Actually Changes for Crypto Businesses in Nigeria
By Tunde Kelani, Director, License Advisory Limited
On Friday, 17th July 2026, President Tinubu signed the Presidential Executive Order on Virtual Assets Coordination. It took effect immediately. Within hours, my phone was busy. Founders, investors, two exchange operators, one custody provider — all asking the same question in different words: "Tunde, what does this mean for me?"
I have spent over 11 years in the payment space, and the last several helping companies get licensed in this country. I have sat in the rooms. I have carried the files between agencies. So let me break this down the way I break it down for my clients — no legal jargon, no panic. Just what it says, what it changes, and what you should do.
First, the problem this order is trying to solve
If you have ever tried to run a virtual asset business in Nigeria, you know the problem was never that there were no rules. It was that there were too many doors.
Is your token a security? Go and see SEC. Touching naira? That's CBN territory. Moving money for customers? NFIU wants to know about your AML controls. Making revenue? The tax authority has questions nobody could answer clearly. Each agency had its own view, its own timeline, and its own opinion about whether your business should exist at all.
I call this death by a thousand doors. You spend 80% of your time on compliance and 20% actually building. I lived it as an operator before I started helping others through it. We bled. Then built.
Let me tell you about two clients — no names, but the stories are real.
The exchange that got a yes and a no in the same month. A digital asset exchange we worked with had done everything right on the SEC side — application in, positive signals. Then their banking partner received a query referencing the old CBN posture on crypto, and overnight their settlement accounts were under review. One arm of government was processing their approval while another was questioning their right to bank. We spent months building a compliance file thick enough to satisfy both — doing the coordination work the government itself had not done. They survived it. Many of their competitors simply moved.
The startup that wasn't sure who to ask. A custody-and-wallet startup came to us with a simple question: "Who is our regulator?" Their product touched stored value (CBN), digital assets (SEC), and cross-border flows (NFIU). Three honest lawyers gave them three different answers. We designed their licensing pathway around the SEC's framework while building CBN-grade controls in parallel — belt and braces — because the safest assumption was that both would eventually come asking. It worked, but it cost time and money no startup in a coordinated market would ever spend.
That is the world this Executive Order was written for.
What the President is actually saying — step by step
Strip away the government language and the order does five things:
Step 1: It creates one table.
The order establishes a Virtual Asset Council — a standing committee where every regulator that touches your business must now sit together. The Central Bank of Nigeria (CBN) chairs it. The Securities and Exchange Commission (SEC) and the Nigeria Revenue Service (NRS) are vice-chairs. The Nigerian Financial Intelligence Unit (NFIU) and the Office of the National Security Adviser (ONSA) are members. The silos are now legally required to coordinate.
Step 2: It does NOT create a new regulator or a new license.
This is the part most headlines got wrong. The order coordinates supervision without introducing new layers of regulation or displacing existing agency mandates. SEC is still SEC. CBN is still CBN. If you are in the SEC's Accelerated Regulatory Incubation Programme (ARIP), that pathway still stands. Nobody is starting over.
Step 3: A supervised sandbox is coming.
The CBN will announce a sandbox — a controlled environment where approved operators can test virtual asset products under the eyes of all the participating agencies before going to the wider market. For serious builders, this is an opportunity: you innovate with the regulators watching, instead of innovating quietly and praying.
Step 4: A tax policy is coming.
The NRS will release a tax policy for the virtual assets sector. For years, operators asked "how exactly do I pay tax on this?" and received shrugs. Clear tax rules mean you can finally plan, price, and report with certainty — and the sector gets treated as a legitimate part of the economy, not a grey zone.
Step 5: Enforcement against the unregistered will get sharper.
The order's stated purpose includes protecting Nigerians from fraudulent operators who exploited the gaps between agencies. When regulators share intelligence at one table, the operators hiding in the cracks lose their hiding place.
SEC and CBN: the new relationship, in plain language
For years, the SEC–CBN relationship on crypto was, politely, complicated. In 2021, CBN told banks to stay away from crypto businesses entirely. SEC, meanwhile, was building a framework to license those same businesses. Founders were caught in the middle — licensed by one arm of government, unbanked by another. My exchange client lived that contradiction personally.
Here is how I read the new arrangement:
SEC remains your primary licensing regulator for virtual asset services — exchanges, custody, token offerings. That mandate is untouched. ARIP continues.
CBN takes the coordination chair, which reflects reality: virtual assets ultimately touch the banking system, the naira, and financial stability. The banking side and the securities side of your business are finally supervised by people in the same room.
The practical win: the days of a green light from SEC and a red light from your bank should be numbered.
The practical caution: coordination means shared visibility. What SEC knows, CBN will know. What NFIU flags, everyone sees. Your compliance posture must now be consistent across every agency, because they are comparing notes.
So what should you do? My honest advice
- If you are licensed or in ARIP: stay the course, but audit your compliance file as if all five Council agencies will read it together — because now they might.
- If you are operating unregistered: regularise now, on your own terms, before enforcement finds you on its terms.
- If you are building something new: watch for the CBN sandbox announcement and position early. Sandbox cohorts are small, and early entrants shape the rules everyone else follows.
- If you are a foreign VASP eyeing Nigeria: this order is your signal. Coordinated regulation is exactly what institutional players wait for before entering a market.
- Everyone: get tax-ready. When the NRS policy lands, businesses with clean books will comply in weeks. The ones without will spend a year reconstructing records.
Nigeria has moved from prohibition (2021), to cautious licensing (2024–2025), to coordination (2026). That is the direction of a country deciding to lead this industry rather than fight it. The doors are still there — but for the first time, they are opening in the same direction.
The Council also sits inside a bigger enforcement shift I have tracked across sectors — from CBN's data localisation mandate to NUPRC's drill-or-drop warning upstream and NIMASA's zero-tolerance vessel campaign on the water. Virtual assets are simply the newest surface.
If you want to talk through what this means for your business, my team at License Advisory has walked this road with operators on both the SEC and CBN sides. We survived the system. We can help you build through it.
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License Advisory Limited helps businesses obtain licenses and regulatory approvals from CBN, SEC, PENCOM, NDPC, NUPRC, and NIMASA. One conversation can save you a year.