Thinking
Essays, Notes, Frameworks and some of my random thoughts on government affairs, public policy, technology policy, financial crime, compliance management, and the plumbing of financial services in Africa.
The +234 VARA Conundrum
An examination of Nigeria's virtual asset regulatory attempts and the recurring patterns that have defined the country's approach to crypto regulation. We have been here before.
Originally published on Medium
Read essay →The Case for Local Attribution: Why Blockchain Analytics Needs African Context
If you work in or use crypto on compliant centralised exchanges, you have likely encountered the limitations of global analytics tools in African markets. A case for localised attribution models.
Originally published on Medium
Read essay →Notes on Social Media and Customer Due Diligence
How much information do you need to know a person? How does social media alter the dynamics of financial crime investigations and customer due diligence?
Originally published on Medium
Government Response to COVID-19 and Civil Liberties in Africa
A critical look at how African governments leveraged pandemic response measures to expand state power, and the lasting impact on civil liberties across the continent.
Originally published on Medium
Banking without Banks: A Dive into the Draft Guidelines for Bank Neutral Cash Hubs
The CBN has released guidelines for Bank Neutral Cash Hubs to ease cash management and deepen financial inclusion. This article examines the compliance touchpoints, the tension with the cashless policy, and the key differences between BNCHs and Agent Banking.
Originally published as a Regcompass Newsletter
Tightening the Lid on Customer Biometric Data: A Review of the CBN's Revised BVN Regulatory Framework
The CBN's Revised BVN Framework introduces tiered access, wider sanctions, new reporting obligations, and API implementation guidance. This article examines the key innovations and their impact on the financial ecosystem.
Originally published as a Regcompass Newsletter
CBN's August Circular to Microfinance Banks: A Potential Fall of the Hammer?
The CBN issued a stern warning to MfB licence holders to refrain from non-permissible activities. This article examines the implications for digital banks operating under MfB licences and the potential clash with financial inclusion goals.
Originally published as a Regcompass Newsletter
Unpacking CBN's New E-invoicing Directive
In its latest attempt to plug forex leaks, cost duplication, and pervasive trading practices, the CBN issued a guideline on the introduction of electronic evaluation and invoicing. This article unpacks the compliance touchpoints and potential conflict areas.
Originally published as a Regcompass Newsletter
All There Is to Know About the eNaira
A comprehensive examination of Nigeria's Central Bank Digital Currency, covering its design, motivations, the ecosystem of participants, perceivable advantages, and the potential teething problems in implementation.
Originally published as a Regcompass Newsletter
Inside CBN's Risk-Based Cybersecurity Framework for OFIs
The CBN issued an exposure draft of the Risk-Based Cybersecurity Framework for Other Financial Institutions. This article provides a bird's eye view of the framework and offers a prognosis of its impact on OFI operations in Nigeria.
Originally published as a Regcompass Newsletter
Areas where the Ugandan Parliament got it wrong with the Sexual Offences Bill
An analysis of the legislative missteps in Uganda's Sexual Offences Bill, examining how poorly drafted legislation can undermine the rights it purports to protect.
Originally published on African Liberty
Nigeria must develop a Legal Framework against Deceptive Advertisement
Why Nigeria's consumer protection regime needs a dedicated legal framework to address deceptive advertising practices.
Originally published on African Liberty
Nigeria's Forex Crisis shows that Legal Incentives are insufficient for Investors
Legal incentives alone cannot attract or retain foreign investment when macroeconomic fundamentals are unstable.
Originally published on African Liberty
Africa needs a Free Market and Strong Property Rights to Solve its Food Security Problems
Market-based approaches and enforceable property rights remain the most effective path to food security in Africa.
Originally published on African Liberty