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Expert Calls for Risks Mitigation on Mobile Payment
Emmanuel Okoegwale, principal consultant at MobileMoneyAfrica, has said that there need proper understanding of the risk involved in providing financial services through the mobile phone to banked and unbanked populations using the agent networks.
Okoegwale’s call came on the heels of the expected licensing of applicants from financial institutions and independent providers forming consortia eagerly to provide mobile payment in the country.
He told Nigeria CommunicationsWeek that the mobile payment industry will change the way consumers interact with financial services and make payments.
According to him, mobile financial services will include consumer accounts information, updates, alerts, bill payments, person to person transactions and remittances.
Okoegwale said to achieve this that there are several risks to be dealt with and mitigated with workable and proven approaches in a new entrant country like Nigeria.
He said, the outcomes of not putting mitigants in place might be severe and will determine the success of the outcomes.
According to him, there are numerous risks like systemic, reputation, liquidity, legal and operational.
The consumer is to be protected and potential effects of risks mitigated so as to establish service level that can protect them. In situation where there are shortcomings, the consumer will be faced with some situations that might have significant negative effect on service delivery.
Scenario One
Customer is charged illegal side fees that are not authorized by the mobile money provider?
Agents are signed on to serve the provider as the last mile to the customer and most customer facing transactions will take place at the agent point. Agents can take advantage of customers’ illiteracy or limited pricing information to charge extra charges. This presents operational and reputational risk for the providers.
The mitigation for the above will include, providers using picture based simple diagrams to explain fees charges for different service levels and must be conspicuously displayed at all agent locations. This should also be translated into different local languages and mandatory pricing disclosures must be strictly managed at agent locations.
In case of customers attempt to seek pricing clarification from provider aside the agents, providers support centres should be accessible and able to provide such information in a clear and easily understood format.
Scenario Two
Provider’s Agent collected cash from client but fails to provide e-money or transfers the amount to recipient bank account or desired third party.
Agent receives funds from a service user but misdirects funds to the agent’s own benefit. This situation could arise in one of two ways:
The consumer could be an existing customer without their phone with them, so they would not receive the transaction confirmation while with the agent.
The consumer may not be a customer but requests that the agent sends money to an existing customer, so does not receive independent phone confirmation of the transaction.
Mitigation:
Require that service users receive, and know they have a right to receive, clear confirmation that funds have been received and where they have been directed. This may include a paper receipt, if the customer does not have a phone. Service providers should also enforce transaction log books to be signed off by the agent and end users. This can be the only evidence that will be available for a future audit trail.
End user education and awareness that users should have their cell phone available to ensure receipt of transaction Confirmations. Cell battery level should be checked before transactions and sms inbox availability is key.
The above scenario is a Reputational risk which could also lead to legal risk.
Scenario Three
Individual poses as agent to collect deposits or payments from unsuspecting customers. Some criminal elements will take advantage of the new systems to defraud end users by posing as agents especially in the rural outpost or busy commercial centres to pose as agents.
First steps is to rely on the end users education to transact only at recognized and registered agent location with consistent and verifiable Agent ID which is clearly displayed at the agent location and in some cases where rogue agents are on the increase, providers may adopt a colour code same method used by Mobile network operators at airtime vendors outlets.
Ability for any user to check status of agents anytime should be build into the system. Some agents might had been decommission or deactivated but are still actively trading. Simple sms solutions like sending agent ID to a short code should be provided. Example,send LAG 027 to short code 3030 ( where Lag means Lagos, 027 – Agent Number).
The regulator will also update agent list on a periodic basis and make such information available to the public.
Above represents an operation, reputational and legal risk for the provider.
Federal Inland Revenue Service (FIRS) has announced that the National Identification Number (NIN) issued by the National Identity Management Commission (NIMC) will automatically serve as the Tax Identification Number (Tax ID) for all Nigerian citizens, while registered businesses will use their Corporate Affairs Commission (CAC) registration numbers.
FIRS
The disclosure was made during a public awareness campaign on the new tax laws posted on X (formerly Twitter) on Monday.
According to the Service, the Nigeria Tax Administration Act (NTAA), which comes into force in January 2026, mandates the use of Tax IDs for certain financial and commercial transactions, including bank account ownership.
FIRS explained that the measure is part of efforts to unify all previously issued Tax Identification Numbers (TINs) by both the federal and state revenue services into a single identifier.
“For individuals, your NIN automatically serves as your Tax ID, while for registered companies, your CAC RC number is used. You do not need a physical card; the Tax ID is a unique number linked directly to your identity,” the Service stated.
The agency noted that the requirement has been in place since the Finance Act of 2019 but has now been strengthened under the NTAA to ensure compliance and ease of administration.
Officials emphasized that the reform would simplify tax processes, reduce duplication, and improve transparency in Nigeria’s tax system.
The Service added that the integration of NIN and CAC numbers into the tax framework would also enhance data accuracy, curb tax evasion, and streamline the monitoring of taxable activities across the country.
Tax experts have described the development as a significant step toward modernizing Nigeria’s revenue administration, noting that it aligns with global best practices where national identity systems are linked to tax compliance.
The FIRS urged Nigerians to ensure that their NINs and CAC registration details are up-to-date, stressing that the identifiers would be required for transactions such as property purchases, contract awards, and access to certain financial services once the NTAA takes effect
The United States will begin a partial suspension of visa issuance to Nigerians from January 1, 2026, following a new presidential proclamation aimed at strengthening border and national security.
The US Mission in Nigeria announced on Monday that the restriction will take effect at 12:01 a.m. Eastern Standard Time in accordance with Presidential Proclamation 10998, titled ‘Restricting and Limiting the Entry of Foreign Nationals to Protect the Security of the United States.’
According to the mission, Nigeria is one of 19 countries affected by the measure.
Others listed are Angola, Antigua and Barbuda, Benin, Burundi, Cote d’Ivoire, Cuba, Dominica, Gabon, The Gambia, Malawi, Mauritania, Senegal, Tanzania, Togo, Tonga, Venezuela, Zambia and Zimbabwe.
The proclamation provides for a partial suspension of visa issuance covering nonimmigrant B-1/B-2 visitor visas, as well as F, M and J student and exchange visitor visas.
It also applies to immigrant visas, though with limited exceptions.
The statement read in part, “Effective January 1, 2026, at 12:01 a.m. EST, in line with Presidential Proclamation 10998 on “Restricting and Limiting the Entry of Foreign Nationals to Protect the Security of the United States,” the Department of State is partially suspending visa issuance to nationals of 19 countries – Angola, Antigua and Barbuda, Benin, Burundi, Cote D’Ivoire, Cuba, Dominica, Gabon, The Gambia, Malawi, Mauritania, Nigeria, Senegal, Tanzania, Togo, Tonga, Venezuela, Zambia, and Zimbabwe – for nonimmigrant B-1/B-2 visitor visas and F, M, J student and exchange visitor visas, and all immigrant visas with limited exceptions.”
US officials clarified that the policy does not apply to all travellers. Exemptions include immigrant visas for ethnic and religious minorities facing persecution in Iran, dual nationals applying with passports from countries not affected by the suspension, and Special Immigrant Visas for eligible US government employees.
Other exempted categories include lawful permanent residents of the United States and participants in certain major international sporting events.
The US government emphasised that the proclamation applies only to foreign nationals who are outside the United States on the effective date and who do not hold a valid US visa as of January 1, 2026.
“Foreign nationals, even those outside the United States, who hold valid visas as of the effective date are not subject to Presidential Proclamation 10998. No visas issued before January 1, 2026, at 12:01 a.m. EST, have been or will be revoked pursuant to the Proclamation,” the statement added.
Visa applicants from affected countries may continue to submit applications and attend interviews. However, the US Mission noted that such applicants “may be ineligible for visa issuance or admission to the US” under the new rules.
The announcement comes amid a series of recent US policy decisions that have raised concerns among Nigerians seeking to travel, study or migrate to the country.
In October, the United States added Nigeria back to its list of countries accused of violating religious freedom, citing persistent insecurity and attacks on Christian communities. This was followed by Nigeria’s inclusion on a revised US travel ban list that imposed partial entry restrictions on Nigerians.
The US has also tightened immigration and visa policies affecting Nigerians. Earlier this year, the validity of most non-immigrant visas issued to Nigerians was reduced to single-entry visas with a three-month duration.
The pre-action notice was signed by Emmanuel Okpara, Esq., Litigation and Compliance Director, and Mus’ab Awwal Mu’az, Esq., secretary of the Association’s Steering Committee.
The dispute stemmed from a consent judgment delivered on November 3, 2025, by Justice J.K. Omotosho of the Federal High Court, Abuja, in Suit No: FHC/ABJ/CC/355/2025 between Meta Platforms, Inc. and the NDPC.
Following investigations conducted under the Nigeria Data Protection Act (NDPA), 2023, the NDPC had issued a Final Order against Meta Platforms, Inc., finding “widespread violations of the data protection and privacy rights of approximately 61 million Nigerians,” and imposing a remedial fine of USD 32,800,000.
The pre-action notice was signed by Emmanuel Okpara, Esq., Litigation and Compliance Director, and Mus’ab Awwal Mu’az, Esq., Secretary of the Association’s Steering Committee.
The dispute stemmed from a consent judgment delivered on November 3, 2025, by Justice J.K. Omotosho of the Federal High Court, Abuja, in Suit No: FHC/ABJ/CC/355/2025 between Meta Platforms, Inc. and the NDPC.
Following investigations conducted under the Nigeria Data Protection Act (NDPA), 2023, the NDPC had issued a Final Order against Meta Platforms, Inc., finding “widespread violations of the data protection and privacy rights of approximately 61 million Nigerians,” and imposing a remedial fine of USD 32,800,000.
The NDPC investigation stemmed from a petition filed at the commission on August 14, 2023, against Meta Platforms Inc. by the convener of Personal Data Protection Awareness Initiative, Ozoemena Nwogbo, regarding violation of the Nigeria Data Protection Act.
After its investigation, NDPC found Meta Platforms Inc. wanting and, on February 18, 2025, issued nine Final Orders against Meta Platforms Inc.
NDPC’s Order
The NDPC’s order nine reads, “Meta shall pay the naira equivalent of 32,800,000 USD (Thirty-two million, eight-hundred thousand United States Dollars) as a remedial fee. The naira equivalent shall be at the rate determined by the Central Bank of Nigeria.
“The details of the account for payment of the remedial fee are as follows: Account Name: Nigeria Data Protection Commission Fund Account. Account Number: 0020331265048 (300131267). Use RTGS for payment.”
The NDPC added, “Note that Meta has a right to seek a judicial review of this decision. The Commission will closely monitor Meta’s remediation process and its impact on data subjects for upwards of six months.”
However, the Final Order was subsequently set aside through Terms of Settlement, which were adopted by the court as a consent judgment on November 3, 2025, following a suit marked FHC/ABJ/CS/355/2025, filed by Meta Platforms Inc. against the NDPC.
Part of the Terms of Settlement entered between NDPC and Meta Platforms Inc. reads, “The applicant (Meta Platforms Inc.) and the respondent (NDPC) have come to a mutual settlement agreement that resolves the dispute underlying the applicant’s originating Summons.
“Pursuant to this agreement: (I) the applicant has agreed to provide specific remedial consideration to the respondent in support of protecting the rights of data subjects in Nigeria; and (II) the respondent has inter alia agreed to set aside and waive any rights to enforce or take steps to enforce the Final Orders against the applicant.”
The settlement terms specifically read, “In the light of the foregoing: The applicant wholly and completely terminates, abandons, withdraws, and discontinues the Originating Summons as well as any and all claims against the respondent connected to or arising from the matters or the subject matter thereof, except as the parties have otherwise agreed.
“The respondent: (I) sets aside the Final Orders against Meta; and (II) save and except as the parties have otherwise agreed, fully and firmly releases and discharges Meta from any and all claims, demands, actions, causes of action, contracts, obligations, suits, debts, costs, liabilities, which the respondent ever had, may now have, or May hereafter claim to have against Meta in respect of the matters.”
Association Alleges Illegality In Settlement
But the Data Privacy Lawyers Association contended that the consent judgment was entered into unlawfully, arguing that it was done without lawful statutory authority, in violation of the Nigeria Data Protection Act, 2023, and in derogation of the constitutional right to privacy guaranteed under Section 37 of the Constitution of the Federal Republic of Nigeria, 1999 (as amended).
The Association further said the action was taken “to the grave prejudice of millions of affected Nigerians and the public interest, as well as the Federal Government of Nigeria.”
In the notice, the Association warned that unless the issues raised are urgently addressed within the statutory notice period, it would approach the Federal High Court to seek multiple reliefs.
These include an order setting aside, vacating, and nullifying the consent judgment on grounds of fraud, collusion, material non-disclosure, lack of statutory authority, and violation of the NDPA, 2023.
It is also seeking a declaration that the consent judgment is “null, void, unconstitutional, and of no legal effect,” as well as a declaration that the NDPC lacks statutory authority to waive, compro
Other reliefs sought include an order restoring and reviving the Final Order against Meta Platforms, including the $32.8 million fine, and an order restraining any further reliance on or enforcement of the consent judgment.
The Association also asked the court for other orders the Court may deem fit in the interest of justice, public accountability, and the protection of constitutional rights.
In the interest of transparency and accountability, the Association urged the NDPC to provide a written explanation of the legal basis for entering into the Terms of Settlement, clarify the statutory authority relied upon to waive the remedial fine and set aside the Final Order, and take steps to remedy the issues raised.
The letter, the Association said, constitutes the requisite pre-action notice under applicable law.
It warned that unless the concerns are satisfactorily addressed within 30 days of receipt of the notice, it will proceed to institute legal proceedings without further recourse.
mise, or extinguish liabilities, sanctions, or remedial fines arising from established violations of the Act.
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