Nigeria: Central Bank Of Nigeria Issues Draft Cybersecurity Guideline For Deposit Money Banks (DMB) And Payment Service Provider (PSP)

Last Updated: 3 December 2018
Article by Ridwan Oloyede


The Central Bank of Nigeria (CBN) recently published a draft guideline on cybersecurity for Deposit Money Banks (DMB'S) and Payment Service Providers (PSP's). The guideline is borne out of the persistent and increasing cyber-attacks on financial institutions and platforms in the country. The increased sophistication of attacks has resulted in the huge financial losses, loss of trust with the potential risk of exploitation of design vulnerabilities, identity theft, malware attack, and malicious use that post risks to security and safety of individuals. Cyberattack exposes organisations to the loss of intellectual properties and trade secret; online fraud and financial crimes, theft of personally identifiable information (PII); financial manipulation; disruption in production or services, and reduced trust for online activities. This is dire for the expansion of financial institutions seeking wider financial inclusions for millions of unbanked Nigerians.

The CBN is empowered under the Central Bank of Nigeria Act and Banks and Other Financial Institutions Act (BOFIA) to issue guidelines to regulate the nation's financial institutions and service providers in the country. The guideline is a commendable response to an exigent problem plaguing the nation's cyberspace. Nigeria is witnessing a burgeoning growth in its banking sector and fintech space with increasing record transactions. Payant, a payment platform recently announced recording over 1 billion naira worth of transaction on its platform in less than two years.

Section 5 of Cybercrimes Act criminalises attack on sectors designated as critical national infrastructure punishable by imprisonment term not less than 15 years without an option of fine. Part 7.5 of the National Cybersecurity Policy designates financial services sectors amongst other sectors as National Critical Information Infrastructure (NCII).


The guideline is divided into six parts namely, Cybersecurity Governance and Oversight, Cybersecurity Risk Management Programme, Cyber Resilience Assessment, Cybersecurity Operational Resilience, Metrics, Monitoring & Reporting, and Compliance with Statutory and Regulatory Requirements.

The framework seeks to establish a minimum cybersecurity baseline to be put in place by DMB's and PSP's. It serves as guidance for the implementation of their cybersecurity policy towards enhancing their resilience in the face of growing threat and attacks. The guideline puts cybersecurity at the forefront and should be fully integrated into organisations overall business and management objectives and strategy.

It is survival.

It is the duty of the Board of Directors to ensure compliance with all statutes, regulations, and the guideline. Non-compliance with the guideline shall attract sanction from the apex bank. CBN is charged with the responsibility to monitor, ensure compliance andenforcement of the framework. The guideline will take effect from 1st August 2018.


  • The Board of Directors has overall responsibility for the DMB/PSP's cybersecurity programme and the development of a cybersecurity strategy, and policy. The cybersecurity framework must "align policies, business and technological approaches to address cyber risks and clearly define all cybersecurity roles and responsibilities".
  • The Board of Directors is responsible for providing oversight, leadership and resources to ensure that cybersecurity governance becomes an integral part of corporate governance. They are to integrate cybersecurity into business functions across all operational level and with the overall business goals and objectives.
  • The senior management team shall be responsible for the implementation of the Board's approved cybersecurity policies, standards and the delineation of cybersecurity responsibilities and the Chief Information Security Officer (CISO) will be in charge of day-to-day cybersecurity activities and mitigation of risk. DMB's and PSP's will have to set up compliance, internal audit, and risk management unit.
  • DMB's and PSP's shall incorporate cyber risk management with their institution-wide risk management framework and governance requirements to ensure consistent management of risk across the institution which should be founded on the understanding of threats, vulnerabilities, risk profile and level of risk tolerance of the organisation.
  • DMB's and PSP's need to build and strengthen cyber resilience. These include constant evaluation of security posture, inherent risks in business operations, visibility to emerging threats to information assets, the capability to swiftly respond and recover from cyber-incidents, and efficacy of existing controls to mitigate the identified risks.
  • DMB's and PSP's shall submit a cybersecurity self-assessment and prompt report of threat and attack to the Director, Banking Supervision Department of the Central Bank of Nigeria bi-annually not later than February 28th and August 31st endorsed by the board and signed by the CISO. This should not overlap with the provision of Section 21 of the Cybercrimes Act requiring reporting of threat and attack to the Nigerian Computer Emergency Response Team (ngCERT).
  • The guideline encourages PSP's and DMB's to obtain cyber insurance package to mitigate risk and devise incidence response plan and strengthen resilience.
  • The guideline provides informative references to COBIT, ISO, and NIST. The guideline also includes a reference template to for assessment test and reporting


  • Nigeria currently has over 147 million mobile phone subscribers, with internet penetration at over 100 million users. This includes a rising number of non-internet subscribers utilising the Unstructured Supplementary Service Data (USSD) platform.
  • According to Serianu 2017 Cybersecurity report, Cybercrime cost Nigeria $649 million, a significant rise from $550 million the previous year. In 2017, Nigeria ranked third in the world for cybercrime according to the Nigerian Communication Commission (NCC), the West-African nation only surpassed by the U.S. and the U.K.
  • The Nigerian Electronic Fraud Forum (NeFF) in its 2017 report has put the value of electronic banking fraud cases over the last three years at N5.571 billion. Fraud via ATM channels rose from N355.89 million in 2015, to N497.643 million in 2017. Mobile payment fraud rose to N347.645 million in 2017.
  • In a 2016 report, Serianu reported that Nigerian financial institutions were hit with more online scams, Automated Teller Machine (ATM) skimming, identity theft, and customised malware targeting critical mobile and Internet banking infrastructure.
  • According to the Global Cybersecurity Index (GCI) by the ITU, that measures the commitment of countries to cybersecurity across industries and sectors. Nigeria ranks 46th globally and 5th in Africa. The country is also grouped alongside 77 other countries in Maturing stage of Cybersecurity development.
  • On the part of the government, the office of the National Security Adviser (NSA) pursuant to Section 42 of the Cybercrimes Act 2015, the Nigerian Computer Emergency Response Team (ngCERT) has been established, which serves as the Coordination Centre responsible for managing cyber incidents in Nigeria.


The CBN is charged with the responsibility to enforce compliance and mete out sanctions under the guideline. The guideline is considered a subsidiary legislation. A subsidiary legislation is made pursuant to the power conferred by a principal legislation (The CBN Act and BOFIA in this context).The Nigerian Court in the case of Best Njoku & Ors v Chief Mike Iheanatu (2008) LPELR – 3871 has held that "subsidiary legislation generally has the force of law and it derives its authority from the substantive legislation". This is further strengthened by the provisions of Section 18 of the Interpretations Act.

This might imply that beyond the sanctions that can be issued by the CBN, individuals affected by a breach could bring an action against culpable financial institution; if the individual can be establish that the breach affected their rights and freedom. Consequently, DMB's and PSP's will have to bring their cybersecurity practice into conformity with the guideline.


The guideline is a good step and a commendable one, the author believes other industry regulators will take a cue from the CBN's innovation to protects consumers. DMB's and PSP's should build resilience and sharpen capability to anticipate, detect, recover and contain attacks. They need to build their security architecture, regular training of staff, and immersing cybersecurity culture in the workplace, vendor/third party security vetting, access control, regularly test vulnerability and data loss prevention.

Nigeria currently lacks a definite legislative framework and practical regulatory guidance from industry regulators. In 2015, the country enacted the Cybercrimes (Prohibition and Prevention) Act that criminalises a considerable number of Cybercrimes prevalent in the country. While the legislative effort was a good move, it has not stemmed the tide of attacks and the machinery for implementation appears to be technologically aback.

The country urgently requires a data protection framework to make organisations more responsible and diligent about security. There is no civil remedy under any extant law or regulations for victims of cyberattack currently in Nigeria as we have seen in other climes. The guideline is a positive step going forward.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

Similar Articles
Relevancy Powered by MondaqAI
In association with
Related Topics
Similar Articles
Relevancy Powered by MondaqAI
Related Articles
Up-coming Events Search
Font Size:
Mondaq on Twitter
Mondaq Free Registration
Gain access to Mondaq global archive of over 375,000 articles covering 200 countries with a personalised News Alert and automatic login on this device.
Mondaq News Alert (some suggested topics and region)
Select Topics
Registration (please scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of

To Use you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions