Fintech Regulatory Guide – Country by Country (Africa)

Country-by-Country Legal & Compliance Snapshot for Fintechs

“One Continent. Many Rules. One Legal Team to Guide You.”

This guide gives fintech founders, legal teams, and investors an at-a-glance overview of the regulatory frameworks governing fintech services in Africa’s top emerging markets. Whether you’re launching a payment app, crypto exchange, lending product, or wallet platform—Clinton Consultancy provides tailored support to guide you through the complexity.

 Ghana

  • Regulator: Bank of Ghana

  • Key Law: Payment Systems and Services Act, 2019

  • Licenses:

    • Electronic Money Issuer (EMI)

    • Payment Service Provider (PSP) – Standard or Enhanced

  • Requirements:

    • Local entity, minimum paid-up capital (varies by license tier)

    • Local director & data storage requirements

  • Crypto: No formal framework yet; cautiously unregulated

  • KYC/AML: Required; enforced via BoG and Financial Intelligence Centre

 Nigeria

  • Regulator: Central Bank of Nigeria (CBN)

  • Key Law: CBN Guidelines on Mobile Money Services, Payments System Vision 2025

  • Licenses:

    • Mobile Money Operator (MMO)

    • Payment Service Bank (PSB)

    • Switching & Processing License

  • Requirements:

    • Strict capital thresholds (?2B+ for PSBs)

    • Local incorporation required

  • Crypto: Officially banned from regulated financial institutions

  • KYC/AML: High-priority enforcement through EFCC and NFIU

Kenya

  • Regulator: Central Bank of Kenya (CBK)

  • Key Law: National Payment System Act, 2011 & CBK Licensing Framework

  • Licenses:

    • Payment Service Provider (PSP)

    • Digital Credit Provider (for lending platforms)

  • Requirements:

    • CBK licensing mandatory

    • Separate approval required for foreign investment

  • Crypto: No formal licensing; regulatory sandbox optional

  • KYC/AML: Required under Proceeds of Crime & Anti-Money Laundering Act

 Sierra Leone

  • Regulator: Bank of Sierra Leone (BSL)

  • Key Law: Financial Services Act, Bank of Sierra Leone Act

  • Licenses:

    • EMI licenses are issued, but the sector is still developing

    • Mobile money offered largely through telecoms

  • Requirements:

    • Strong focus on local partnerships

    • Emerging guidelines; legal reform in progress

  • Crypto: Unregulated

  • KYC/AML: Required; FIC Sierra Leone oversees compliance

Rwanda

  • Regulator: National Bank of Rwanda (BNR)

  • Key Law: Law No. 048/2010 on Electronic Transactions and Guidelines for PSPs

  • Licenses:

    • PSP license (with fintech-specific categories)

    • Credit scoring and e-money also licensed separately

  • Requirements:

    • Requires local entity and application through BNR

  • Crypto: Permitted through regulatory sandbox

  • KYC/AML: Strong framework and compliance review process

 South Africa

  • Regulator: South African Reserve Bank (SARB) + FSCA

  • Key Law: Financial Sector Regulation Act, National Payment System Act

  • Licenses:

    • Payment clearing house participation

    • Financial services licenses for lending or crypto

  • Requirements:

    • Complex, layered licensing based on activity

    • Financial Advisory and Intermediary Services (FAIS) Act may apply

  • Crypto: Declared financial products under FSCA oversight

  • KYC/AML: Strong FIC Act regime with SARB monitoring

Summary Table

Country Primary Regulator Licensing Required Crypto Position AML/KYC Enforced
Ghana Bank of Ghana EMI, PSP Unregulated but monitored ? Yes
Nigeria CBN MMO, PSB, Switch Banned in financial institutions ? Yes
Kenya CBK PSP, DCP Sandbox optional ? Yes
Sierra Leone BSL EMI emerging Unregulated ? Yes
Rwanda BNR PSP, fintech-specific Sandbox approved ? Yes
South Africa SARB, FSCA Layered licensing Financial product (regulated) ? Yes