A Nigeria-focused fintech company engaged InnReg to support the launch and compliance structuring of a global payments platform built around stablecoin technology. The platform is designed to unify fiat and stablecoin transactions in a single wallet, enabling users to send, receive, and spend money across borders in seconds rather than days.
Targeting freelancers, remote workers, global professionals, and small businesses, the solution aims to reduce costs associated with cross-border transactions, eliminate traditional banking delays, and provide flexible payout options in either stablecoins or local currency. With added features such as virtual and physical cards, automated payroll for contractors, and transparent fee structures, the platform positions itself as both a B2B and B2C enabler for the future of international remittances and treasury management in Nigeria and beyond.
Objective
The client’s objective was to develop a compliance program that would allow it to operate a cross-border remittance and stablecoin-based payments platform while mitigating regulatory risks in both the United States and Nigeria. In particular, the company sought to align its Nigerian operations with the requirements of the Central Bank of Nigeria (CBN), the Nigeria Data Protection Commission (NDPC), and other relevant authorities.
The overall goal was to provide the client with a scalable compliance foundation that would enable its international remittance and stablecoin products to launch and grow sustainably in Nigeria’s evolving regulatory environment.
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Challenges
The engagement presented a complex regulatory landscape. The client’s business model, which combines cross-border fiat remittances with stablecoin transactions, places it at the intersection of multiple oversight regimes.
In Nigeria, activities such as currency conversion, remittance processing, and stablecoin transfers triggered licensing and supervisory expectations from the CBN, the Securities and Exchange Commission (SEC), and the Nigerian Financial Intelligence Unit (NFIU). Operating without alignment to these requirements would have exposed the business to penalties, banking restrictions, and potential shutdowns.
Anti-money laundering and counter-terrorism financing obligations also posed significant challenges. The client needed to implement KYC/CDD processes across diverse user bases in both the US and Nigeria, while also preparing for FATF Travel Rule compliance in crypto transactions.
In parallel, compliance risks extended to data protection under Nigeria’s Data Protection Act, cybersecurity under the Cybercrimes Act, and consumer protection rules under the FCCPC.
InnReg's Solution
InnReg provided compliance support across both US and Nigerian operations, with workstreams that included:
Agent-Model Compliance Framework (US):
Developed policies and procedures addressing AML/CFT, fraud prevention, KYC, recordkeeping, advertising review, and vendor oversight.
Created escalation workflows and compliance training materials.
Integrated compliance requirements into user-facing and back-office processes.
Nigeria-Specific Compliance Program:
Drafted procedures consistent with CBN rules for cross-border remittances and disbursement methods (bank deposit or cash pickup only).
Developed policies covering NDPC data protection requirements and NFIU fraud prevention standards.
Addressed SEC guidance applicable to stablecoin-related activities.
Incorporated FCCPC consumer protection standards into terms of use and disclosures.
Regulatory Risk Assessment:
Identified exposures across licensing, AML/CFT, data protection, operational, and tax categories.
Documented mitigation steps such as reliance on licensed partners, maintenance of designated bank accounts, and monitoring of regulatory developments
Technology and Vendor Activities:
Advised on compliance-related aspects of vendor and partner evaluation, contract negotiation, and system integrations.
Produced vendor management procedures, change management protocols, and updated terms of use to reflect applicable regulatory requirements.
This solution provided the client with an operational compliance infrastructure capable of supporting current payments and stablecoin services while positioning the business for future regulatory changes.
Client Results
Within the first phase of the engagement, the client established a complete compliance framework for its US agent-model operations, including documented policies, vendor management controls, and second-line AML/KYC procedures. This allowed the company to demonstrate readiness to banking and financial institution partners while preparing for launch.
For Nigerian operations, the client established a structured program aligned with the requirements of the CBN, SEC, NDPC, and NFIU. The regulatory risk assessment provided a clear view of exposures related to licensing, AML/CFT, data protection, and consumer protection, with practical steps for mitigation.
By combining policy development, risk mapping, and technology integration, InnReg helped the client build the foundation to operate cross-border remittance and stablecoin services in a highly regulated and evolving environment.
How Can InnReg Help?
InnReg can help your crypto-oriented business understand and comply with regulatory requirements across the globe. Reach out today to start the conversation with an InnReg expert.
