• Provided legal advisory and regulatory support to an American Multinational Corporation regarding the modification of its tariff, through this support, the client was able to successfully increase its tariff, which led to a uniform increase in tarrif prices by 50%.
• Advised on the sale and lease back of MTN Nigerian Communications Limited’s (MTNN) Mobile Network Towers to HIS. The deal saw a sale by MTNN of over 9,000 mobile network towers, the total value of the transaction was approximately USD1.8 billion naira. The remit of our legal advice included, a review of all transaction documents, including but not limited to corporate authorisation (directors and shareholders); working with offshore counsels in respect of special purpose vehicles established by MTNN, the sale and purchase agreement, deed of transfers, shareholder specific obligations (the minority shareholders are all incorporated in various jurisdictions), regulatory filings amongst others, condition precedent to closing and payment.
• Advised an Italian company providing mental health support services on medical devices, AI and privacy regulatory requirements applicable with respect to the launch of its mental health support app/website.
• Led the team that advised Google on the landing of ‘Equiano’ in Nigeria through legal and regulatory advisory support. Equiano is a state-of- the-art submarine internet cable connecting Africa with Europe, Equiano starts in western Europe and runs along the west coast of Africa, Portugal and South Africa. Key activities included advising on legal and regulatory issues pertaining to Submarine Cable Infrastructure licensing regime and advising and reviewing the Landing Party Agreement between Google and West Indian Ocean Cable Company (WIOCC) a prominent digital backbone company.
• Provided legal and regulatory support to a UAE based multinational telecommunications company on the regulatory framework for the establishment of a data centre in Nigeria and procuring the requisite approval from the National Information Technology Development Agency (NITDA). The instruction included: (a) undertaking legal and regulatory due diligence relating to a proposed carve out of data centre business from an existing telecommunication business and infrastructure; (b) advising on structuring and phasing of the proposed transaction, including the governance and capitalisation of the proposed business entity; (c)advised on the incorporation of the appropriate SPV for the proposed carve out; (d) advising and supporting the client through the regulatory approval process.
• Advised international fashion brand on its African/Nigerian focused fashion e-commerce platform project, as part of its effort to expand to Africa for more global retail reach including but not limited to competition, data protection, tax, import and other compliance obligations. Advised on the legal and regulatory framework for establishing an e-commerce business in Nigeria. Provided all round legal services to the client from its conception stage, through the development to launch stage.
• Part of the team that advised an international social media snd video platform in respect of the launch of the TikTok products/features, highlighting the red flags and proposing suggestions to the feature in line with the applicable Nigerian laws.
• Advised an American entertainment conglomerate and its Ireland partners on intellectual property rights (folklore) for its first all African focused animated anthology.

TELECOMMUNICATION

• Advising an American Multinational Corporation in respect of its satellite and internet services in Nigeria. This involves advising the client in all its telecommunications regulatory dealings in Nigeria including pre and post launch regulatory compliance, drafting and reviewing of various documents.
• Provided legal advisory and regulatory support to an American Multinational Corporation regarding the modification of its tariff, through this support, the client was able to successfully increase its tariff, which led to a uniform increase in tarrif prices by 50%.
• Provided legal advisory to global digital communications company regarding its proposed entry into the Nigerian telecoms market to provide numbering services particularly on the applicability/suitability of various proposed business models for the provision of VOIP services with PSTN connectivity capacity using Nigerian issued numbers.
• Provided legal advisory and regulatory support services to UAE based telecommunication conglomerate on its acquisition of an International Application- To- Person (A2P)  from the Nigerian Communications Commission (NCC). Key activities included, advising on the relevant application documents, including reviwing and spot-checking the documents to ensure compliance with the relevant laws.
• Advised a multinational communications and media company in respect of its proposed program to promote its wireless services to individuals in Nigeria desirous of relocating to Canada in the near future.
• Provided legal advisory and regulatory support to an international AI-powered company in respect of the regulatory landscape for the provision of its services to Nigerian wholesale Mobile Network Operators (MNOs) in their relationship with the Mobile Virtual Network Operators (MVNOs). Advised the client in respect of the regulatory landscape for the provision of its cloud-based billing as a service to Nigerian wholesale mobile network operators in their relationship with the MVNOs.
• Advising Telewyz on various contractual agreements with other multinational companies in respect of providing B2B services to the clients for the provision of telecommunication services under its MVNO license.
• Advised Verizon on the provision of its GIO services in Nigeria. Key activities included, advising on the licencing requirement needed to be complied with by Verizon for the provision of its GIO services in Nigeria; and the legal requirements on permanent roaming that may impact or require additional compliance steps by Verizon for the provision of its GIO services in Nigeria.
• Provided legal advisory and regulatory support to a multinational telecommunications company regarding the renewal of its Internet Service Provider (ISP) License with the NCC.
• Provided legal and regulatory support to a UAE based multinational telecommunications company on the regulatory framework for the establishment of a data centre in Nigeria and procuring the requisite approval from the National Information Technology Development Agency (NITDA). The instruction included: (a) undertaking legal and regulatory due diligence relating to a proposed carve out of data centre business from an existing telecommunication business and infrastructure; (b) advising on structuring and phasing of the proposed transaction, including the governance and capitalisation of the proposed business entity; (c)advised on the incorporation of the appropriate SPV for the proposed carve out; (d) advising and supporting the client through the regulatory approval process.
• Advised on the sale and lease back of MTN Nigerian Communications Limited’s (MTNN) Mobile Network Towers to HIS. The deal saw a sale by MTNN of over 9,000 mobile network towers, the total value of the transaction was approximately USD1.8 billion naira. The remit of our legal advice included, a review of all transaction documents, including but not limited to corporate authorisation (directors and shareholders); working with offshore counsels in respect of special purpose vehicles established by MTNN, the sale and purchase agreement, deed of transfers, shareholder specific obligations (the minority shareholders are all incorporated in various jurisdictions), regulatory filings amongst others, condition precedent to closing and payment.
• Led the team that advised Google on the landing of ‘Equiano’ in Nigeria through legal and regulatory advisory support. Equiano is a state-of- the-art submarine internet cable connecting Africa with Europe, Equiano starts in western Europe and runs along the west coast of Africa, Portugal and South Africa. Key activities included advising on legal and regulatory issues pertaining to Submarine Cable Infrastructure licensing regime and advising and reviewing the Landing Party Agreement between Google and West Indian Ocean Cable Company (WIOCC) a prominent digital backbone company.
• Made a presentation on the NIGERIA REGULATORY LANDSCAPE, NIGERIA ECONOMIC OUTLOOK AND 2025 FOCUS: TELECOMMUNICATION (FIBRE) IN VIEW, with particular emphasis on the Nigeria critical national information infrastructure protection framework and the impact on fibre business in Nigeria.
• Advised and provided legal support to UAE based telecommunication conglomerate on its acquisition of the National Long-Distance Operator (NLDO) license for its fibre operation business in Nigeria including ensuring compliance with its license obligations.
• Advised several multinationals Stream Video On Demand (SVOD) providers on the impact of the Nigeria Broadcasting Code on their service offerings in Nigeria including the requirements for license/permits.
• Advised Ayoba on the applicable telecommunications licenses and approvals required for offering Value Added Services (VAS), as well as the applicable telecommunications, advertisements and lottery laws.
• Advised a multinational Chinese telecommunication company on the regulatory framework for the provision of telecommunication products and services in Nigeria.
• Provided legal advisory support to a major telecommunications company following allegations by the apex financial regulatory agency on the illegal repatriation of foreign exchange by the company to some of its offshore investors. The scope of the services included (i) a review into the Company’s historical capital and shareholding structure movements; and (ii) advising on the legal and regulatory framework for (a) the importation of capital; (b) the application for and issuance of certificates of capital importation; and (c) payment and repatriation of dividends by the company.
• Advised a leading technology company in the world on the landing of submarine internet cable in Nigeria. Key activities included advising on legal and regulatory issues pertaining to Submarine Cable Infrastructure licensing regime; advising and reviewing the Landing Party Agreement.
• Currently advising an international satellite company, in connection with its expansion into Nigeria. The scope of legal services provided to the company covers its proposed operations and the grant of landing rights as well as advising on the current regulatory obligations on international satellite operators in Nigeria as well as the terms and conditions for the provision of the service.
• Advised a French multinational telecommunications corporation on the proposed deployment of Point of Presence (PoP) in Nigeria.
• Provided legal advice on a proposed initiative by a major mobile network operator in Nigeria that involves the use of telecoms insights to enhance the lending decision process for financial institutions.
• Advised an international cloud computing software services company with respect to Application to Person(A2P) messaging service in Nigeria. Specifically, on the various regulatory filings, restrictions, and regulatory obligations related to offering SMS capabilities/communication channels/voice messaging service as part of an online service in Nigeria.
• Advises several multinational technology companies from time to time on the procurement of relevant licenses and/or approvals from the relevant regulatory authority and engaging with the regulatory authority on a “No-name” basis on behalf of clients.
• Regularly manages regulatory stakeholders for clients in the telecommunication, media and technology space.

TECHNOLOGY & INNOVATION

• Advised Microsoft on legal issues pertaining to hosting data centre in Nigeria, data security, data centre infrastructure and ensuring compliance with the relevant laws and regulators.
• Provided a comprehensive advice to an international cloud computing software services company in respect of regulatory conformity reqiurements, approvals and compliance obligations as it relates to its products/equipment specifically, radio frequency device and telecommunications requirements, technical regulations applicable to electronics and information technology, energy efficiency regulations on products.
• Advised a multinational company in respect on regulatory requirments for advertising in Nigeria and compliance with Advertising laws in Nigeria.
• Advised a multinational video gaming company on setting up an e-shop in Nigeria. The advisory included advising on data protection, advertising and other legal considerations for setting up the e-shop in Nigeria.
• Providing legal advisory services to  Chapel Hill Denham (CHD) in respect of a contractual dispute (Software License, Implementation and Maintenance Agreement) involving the interpretation of the terms of an agreement (non-performance/breach termination), and possible remediation options
• Advised one of the leading multi-national betting companies in the world on the regulatory framework for the gaming and betting industry in Nigeria.
• Advised one of the world’s leading providers of reinsurance, insurance and other forms of insurance-based risk transfer, on the licensing and registration requirement(insurance mediation/advisory and any ESG licensing requirements on service companies), choice of law in a cross-border transaction as it relates to the risk digital service platform offering in Nigeria.
• Advised Microsoft on the legal and regulatory framework applicable to the provision of some of its products offering in Nigeria. Provided relevant support in respect of its technology product development, importation, certification and use in Nigeria.
• Advised Microsoft regarding its Communication Platform as a Service (CPaaS) called Azure Communication services (ACS), we advised on the relevant telecommunications requirements for licensing and registration. We also advised on data localization, data retention and cross border transfer of data relating to users of ACS in Nigeria. Advised Microsoft on legal issues pertaining to hosting data centre in Nigeria, data security and ensuring compliance with the relevant laws and regulators.
• Advised a multinational technology client on a new health search feature being developed to enable users to access online medical content via an informational card that highlights symptoms and treatments for certain diseases or conditions. The task also included advising the company on the laws applicable to medical devices in Nigeria and potential regulatory and liability issues which may arise in connection with the online health search feature.
• Advised international fashion brand on its African/Nigerian focused fashion e-commerce platform project, as part of its effort to expand to Africa for more global retail reach including but not limited to competition, data protection, tax, import and other compliance obligations. Advised on the legal and regulatory framework for establishing an e-commerce business in Nigeria. Provided all round legal services to the client from its conception stage, through the development to launch stage.
• Provided legal advice to one of the leading social media apps in the world in respect of the applicable legal and regulatory framework for OTT services in Nigeria, including but not limited to monetization of the company’s products and services alongside advising on geo-blocking within Nigeria.
• Advised a multinational technology company on a search engine for online medical contents, developed to enable users to access online medical content via an information card that highlights symptoms and treatment for certain diseases and medical conditions.
• Advised a major telecommunication company in respect of digital current and anticipated regulations that may affect online freedom of expression and information (including data sharing and retention), privacy and security.
• Provided legal advice to one of the leading social media apps in the world on the legal framework for employer health and safety obligationsto remote workers in Nigeria.
• Provided legal advice to a multinational technology company with respect to the legal and regulatory framework governing the labelling of its products in Nigeria.
• Provided legal advice to an international music streaming platfform on various enforcement and compliance developments around the NITDA Code of Practice for Interactive Computer Service Platforms/Intermediaries, specifically relating to the impact of the code on the introduction of various interactive features as part of its setrvice offering in Nigeria.
• Part of the team that advised Paul Hastings LLP in respect of the legal considerations and restrictions of the use of thermal cameras in Nigeria. This included advising on data protection restrictions and obligations, risk analysis, requirements for the importation of thermal cameras in Nigeria, etc
• Part of the team that advised Microsoft regarding the Usage of Artificial Intelligence Technology in Nigeria Bill and its implications for Microsoft if and when passed. Also advised Microsoft Nigeria on its partnership with the Ministry of Communications, Innovation and Digital Economy for the Nigerian Artificial Intelligence (AI) strategy development. This advisory included drafting an idea map and strategy for the AI strategy development.
• Advised Microsoft on the implications and possible impact of the Cybercrimes Act 2015 Amendment Bill on the technology landscape and Microsoft Business (Cloud and AI).
• Advised an international social media and video platform in respect of its launch of the its products/features, highlighting the red flags and proposing suggestions to the feature in line with the applicable Nigerian laws.
• Advised a multinational technology on the applicable regulations with respect to its proposed launch of consumer and small business credit analytics products in Nigeria.
• Advised a multinational technology and manufacturing company in respect of the proposed launch of the its Club app in Nigeria.
• Advised a Confidential Client on import controls, regulatory requirements and legal compliance measures relevant to the importation of hi-res thermal imaging technology products into Nigeria.
• Advised a Confidential Client with respect privacy and competition matters related to the bundling of its subscription services in Nigeria and migration existing subscribers to the new subscription bundle.

DATA PRIVACY

• Drafted a Whitepaper for Microsoft Nigeria on salient/key provisions of the Nigeria Data Protection Act (NDPA), 2023 and the technology and services deployed by Microsoft to assist stakeholders comply with provision of the NDPA.
• Advised Standard Chartered Bank (UK) on implementing a risk-based approach to contracting in the context of sharing/transferring personal data. This encompassed advising on the relevant Nigerian data protection framework, specifically addressing contractual strategies for sharing/transfer of personal data.
• Advised an international cloud computing software services company in respect of reviewing its due diligence questionnaire and provided relevant updates on the applicable data protection laws as well as practical guidance on required compliance obligations.
• Advised Microsoft on the applicable data protection legal and regulatory framework and requirements for the registration of its entities in Nigeria.
• Currently advising one of the top financial service provider in Nigeria on its Data Protection and compliance requirement. This includes (i) providing a remediation plan for the rectification of data breach (ii) holistic review of data protection/privacy policies, documents, agreements for its products and subsidiary companies (iii) review of its products and services operations, (iv) providing recommendations on best practice and remedial actions for identified gaps in compliance in relation to the products and practices of the bank, (v) liaising with the regulators on behalf of the bank, (vi) drafting and revising key data protection and privacy related documents including policies, notices, processes, and practices of the bank to ensure compliance with the NDPA etc
• Advised Teleperformance on data protection and privacy compliance including, assisting with the registration of the company as a Data Controller and Processor of Major Importance (DCPMI).
• Advised Microsoft on the Nigeria Data Protection Act, General Application and Implementation Directive (GAID) and its impact on Microsoft business in Nigeria.
• Advised Simmons & Simmons on Nigeria’s data protection landscape for its Data Transfer Assessment Tool, CtrlTransfer.
• Provided data protection advisory services and support to Memorial Sloan Kettering Cancer Center (MSKCC)); Assisted the company with registration as a DCPMI with the Nigeria Data Protection Commission (NDPC) in compliance with the NDPA, 2023.
• Advised and reviewed Angola cables’ privacy policy, acceptance and use policy to ensure compliance with Nigerian privacy laws.
• Reviewed an international airline privacy documents and agreements in respect of a deployment tool in Nigeria to ensure compliance with Nigeria data protection laws.
• Advised Bloomberg on data privacy compliance obligations under the Nigeria data protection laws.
• Advised a multinational Oil and Gas company in respect of compliance with the Nigeria Data Protection Act.
• Advised a multinational technology corporation on legal issues and requirement with regards to selling online services and/or hosting data centers and storing data in Nigeria.
• Advised an international education services company regarding consent requirements and direct marketing under the Nigeria Advertising laws and other relevant laws.
• Part of the team that advised an American multinational conglomerate on the Nigeria Data Protection Commission, Guidance Notice on Data Controllers and Data Processors of Major Importance (DCPMI).
• Providing legal support to one of the largest social media platforms in the world with respect to enforcement investigations by the Nigeria Data Protection Commission.
• Advised Hyatt International with respect to restrictions and compliance requirement applicable to cross border transfer of personal and financial data.
• Advised Barclays Bank (UK) in relation to the extraterritorial application of Nigeria Data Protection Laws and the compliance obligations deriving thereunder in relation to processing the biometric data of Nigerian citizens.

MEDIA AND ENTERTAINMENT

• Advised an American entertainment conglomerate and its Ireland partners on intellectual property rights (folklore) for its first all African focused animated anthology.
• Advised an international social media platform on the advertising, promotional and data protection requirements/consideration for the proposed launch of the program. Reviewed the tentative gameplay and activity rules for their CSI platform and advised on the risks and feasibility of the game rules in Nigeria.
• Advised an international social media platform on the launch of an advertisement tool to be used by content creators in its application in Nigeria.
• Advised a mutinational technology conglomerate in respect of the deployment of an automobile infotainment system in Nigeria.
• Advised a global telecommunications company on its advertising regulatory compliance obligation relating to the promotion of its wireless telephone services in Nigeria.
• Advised a multinational video sharing and social media platform in relation to the launch of its Ad-offline feature in Nigeria.
• Provided legal advisory to a music streaming platform covering advertisement activations, obligations and compliance in Nigeria, specifically as it relates to online advertisement as well as on legal and regulatory framework applicable to the provision of its in Nigeria.
• Advised a record label company regarding the recruitment of a label manager including guidance on industry standard compensation.
• Advised a Confidential Client on the legal considerations including potential legal risks, obligations, requirements and procedures in establishing a production studio to produce video content for streaming and downloading in Nigeria.
• Provided legal support to an American multinational technology company in relation to its Music product subscription offering in Nigeria through the use of telecommunications short-code in the value added services ecosystem in Nigeria.
• Advised Tencent in relation to legal and regulatory considerations including copyright, trademark and other laws prescribing standards with respect to software which are relevant to the deployment of a web browser to be pre-installed in cars which are to be imported and sold in Nigeria.
• Advised a Confidential Client on the legal and regulatory requirement relevant to the operation of an e-shop for digital products in Nigeria.
• Advised a Confidential Client with respect to legal, regulatory and cultural sensitivities consideration applicable to content appearing on a soon to be launched online health and wellness platform/app.

LEGAL/REGULATORY POLICY FORMULATION

• Contributed periodically to the World Bank Global Data Regulation Survey, with a focus on the Nigerian jurisdiction. We provided the world bank with the resources and insight into the Nigerian Data Protection eco system for the purpose of developing a global regulation diagnostic, which seeks to identify the challenges in the way it measures and develops its indicators.
• She led the team that developed the NCC’s Lawful Interception of Communications Regulation 2019 to regulate lawful interception of communications, collection and disclosure of intercepted communications in Nigeria.
• Provided comments and inputs on the NITDA Code of Practice for Interactive Computer Service Platforms/Internet Intermediaries 2022 which was developed by the NITDA to safeguard the interest of Nigerians and non-Nigerians living in Nigeria regarding activities conducted in the digital ecosystem.
• Provided comments and inputs on the draft Nigeria Data Protection Bill 2022 which has now been enacted as the Nigeria Data Protection Act (NDPA) 2023, the first principal law governing data privacy and protection in Nigeria.
• Sumbo and her team contributed to the Nigerian Bar Association Section on Legal Practice (NBA-SLP) guidance notes/guidelines on the use of technology in the legal profession. These includes, (a) Guidelines for the use of Artificial Intelligence in the legal profession in Nigeria, (b) Data Privacy Guidance for lawyers in Nigeria and (c) Guidance Note on the Implementation of Information Technology Solutions for law firms and legal departments in Nigeria, which were published in 2024.
• She led the team that provided legal advisory support to Microsoft Nigeria regarding the Control of the Usage of Artificial Intelligence Technology in Nigeria Bill and its implications for Microsoft operations when passed. Her team also advised Microsoft Nigeria on its partnership with the Ministry of Communications, Innovation and Digital Economy for the Nigerian National Artificial Intelligence (AI) strategy development. This advisory included drafting an idea map and strategy for the AI Strategy development.