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.

Type
14 pieces
Topic
Note5 min

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?

AML/CFTFintech Policy
July 2023

Originally published on Medium

Essay9 min

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.

Comparative LawCriminal Justice
April 2020

Originally published on Medium

Essay12 min

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.

Regulatory PolicyFintech Policy
April 2022

Originally published as a Regcompass Newsletter

Essay10 min

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.

Regulatory PolicyData Protection
November 2021

Originally published as a Regcompass Newsletter

Essay8 min

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.

Regulatory PolicyFintech Policy
August 2021

Originally published as a Regcompass Newsletter

Essay7 min

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.

Regulatory Policy
February 2022

Originally published as a Regcompass Newsletter

Essay18 min

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.

Regulatory PolicyVirtual Asset Regulation+1
October 2021

Originally published as a Regcompass Newsletter

Essay10 min

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.

Regulatory PolicyData Protection
September 2021

Originally published as a Regcompass Newsletter

Essay8 min

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.

Comparative LawCriminal Justice
May 2021

Originally published on African Liberty

Essay7 min

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.

Regulatory PolicyComparative Law
April 2021

Originally published on African Liberty

Essay8 min

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.

Regulatory PolicyFintech Policy
February 2021

Originally published on African Liberty

Essay7 min

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.

Regulatory Policy
August 2020

Originally published on African Liberty