VASPA Charts a Path with NFIU on Financial Information Sharing

Strategic Highlights of VASPA’s Position Paper

Submitted within the NFIU’s 14-day consultation window, VASPA’s position paper sets out nine prioritized principles designed to guarantee that the information-sharing mechanism operates on solid legal footing, protects compliant operators, and delivers actionable intelligence:

1. Robust Legal & Governance Foundations: Calls for an explicit statutory legal basis, formal sign-off from the Nigeria Data Protection Commission (NDPC), and clear safe harbor and indemnity provisions to protect participating institutions acting in good faith.
2. Trust & an Equal Partnership: Asserts that the PPP must treat VASPs as collaborative allies rather than suspects, ensuring that information shared in good faith is never weaponized outside the partnership’s scope to take punitive action against sharing institutions.
3. Typology-First Scope & Data Minimization: Mandates that routine sharing prioritize emerging typologies, behavioral red flags, and trends rather than case-sensitive, commercially sensitive, or technical infrastructure data.
4. Two-Way Intelligence & Actionable Feedback: Proposes a bi-directional intelligence loop where the NFIU shares regular typologies and actionable trends back to participants, alongside constructive feedback on rejected compliance reports.
5. Operational Security & Strict Access Controls: Demands vetted communication channels, rigorous audit trails, clear approval hierarchies, and clear protocols for data handling at rest and in transit.
6. Uniform Value & Inter-Regulatory Standing: Recommends that compliant standing verified by fellow regulators (such as the SEC) serve as a shield within the PPP, ensuring that the platform protects compliant participants and mitigates customer-facing reputational risk.
7. Phased, Voluntary, and Sustainable Implementation: Codifies the voluntary nature of participation in the charter, allowing obligations and scope to expand steadily as institutional trust and technical infrastructure mature.
8. High Data Quality Standards: Prioritizes actionable, high-quality intelligence over high-volume reporting, encouraging enhanced cross-functional compliance collaboration within participating entities.
9. VASPA as the Sector Coordinating Partner: Establishes VASPA as the recognized coordinating body for the VASP constituency—mirroring established trade bodies in banking and insurance—to run first-line onboarding, co-develop crypto-specific typology guides (e.g., mixers, privacy coins, synthetic identity, and BVN/NIN mismatches), and host quarterly liaison working sessions.

Emphasizing the strategic importance of the initiative to the broader digital economy, Franklin Peters, Executive Chair of VASPA, stated:

“True market resilience requires that industry operators and financial intelligence authorities move in lockstep. Our proactive engagement with the NFIU and the British High Commission demonstrates that the virtual asset sector is not merely seeking a seat at the table—we are actively helping construct the governance architecture for financial integrity. By establishing a balanced, two-way intelligence framework, Nigeria is setting a continental benchmark where compliance and innovation reinforce each other rather than collide.”

The paper also highlighted the future complementary role of VASPA’s Africa Passporting Working Group, which is developing a verified partnership credential to support cross-border trust and credentialing among licensed African VASPs over time.

VASPA has confirmed its intention to nominate representatives to the inaugural PPP cohort and looks forward to reviewing the draft MoU, Charter, and Operating Manual as the partnership transitions from design to operational execution.