In a February 5, 2021 letter, the Central Bank of Nigeria (CBN) warned all banks in the country that that they are prohibited from dealing in cryptocurrencies or facilitating payments for cryptocurrency exchanges.  Thus, all banks and other financial institutions were directed to identify persons transacting in or operating cryptocurrency exchanges and make sure that such accounts were closed.  The letter included a warning that breaches of the directive would “attract severe regulatory sanctions.”

After the letter attracted much criticism from the very active cryptocurrency community within Nigeria, the CBN issued a press release on February 7, 2021, explaining its position.  The CBN first pointed out that there was nothing new in its February 5 letter in that all banks in the country had earlier been forbidden, through CBN’s circular dated January 12, 2017, not to use, hold, trade and/or transact in cryptocurrencies.

The CBN explained that its position on cryptocurrencies is not an outlier as many countries, central banks, international financial institutions, and distinguished investors and economists have also warned against its use.  The press release quoted Warren Buffet as saying that cryptocurrency is “rat poison squared.”  The CBN also pointed to the supposed dark side of cryptocurrency, saying:

The very name and nature of “cryptocurrencies” suggests that its patrons and users value anonymity, obscurity, and concealment. The question that one may need to ask therefore is, why any entity would disguise its transactions if they were legal. It is on the basis of this opacity that cryptocurrencies have become well-suited for conducting many illegal activities including money laundering, terrorism financing, purchase of small arms and light weapons, and tax evasion.

Although press release also stated that its actions were not in any way, shape or form inimical to the development of FinTech or a technology-driven payment system, the CBN made clear its distaste for cryptocurrency.  It said, “the CBN has no comfort in cryptocurrencies at this time and will continue to do all within its regulatory powers to educate Nigerians to desist from its use . . . “

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David Zaslowsky is partner in the Litigation Department of Baker McKenzie's New York office. He helps companies solve complex commercial disputes in arbitration and litigation, especially those involving cross-border issues and Section 1782 discovery. David has a degree in computer science and, as a result, has worked on numerous technology-related disputes, including, most recently, those involving blockchain and artificial intelligence. In April 2025, Attorney Intel named David one of the top 25 blockchain lawyers in the country. He is the editor of the Firm's blockchain blog and co-editor of the firm's International Litigation & Arbitration Newsletter. David has been included for a number of years in the Chambers USA Guide and Chambers Global Guide for his expertise in international arbitration. He also sits as an arbitrator and is on the roster of arbitrators for a number of arbitral institutions. David sits on the Board and chairs the governance committee of the New York International Arbitration Center, and is a founding member of the International Arbitration Club of New York. For over 35 years, he has written and spoken often on the subjects of arbitration and international litigation.