In December 2020, the Central Bank of Nigeria (CBN) issued the circular on new licence categorisation for the Nigerian payments systems (the “New Categorisation Circular”). Pursuant to the New Categorisation Circular, companies seeking to combine activities under the switching and mobile money operations (MMO) are only permitted to do so only under a holding company structure with the subsidiary entities clearly delineated to prevent comingling.
It was against this backdrop that the CBN issued the Guidelines for Licensing and Regulation of Payments Service Companies Holding Companies in Nigeria (the “PSHC Guidelines”). The PSHC Guidelines sets out the regulatory requirements for setting up and operating a payments service companies holding company (“PSHC”) in Nigeria, to prevent commingling of funds and activities, and promote an efficient and credible payments system.
