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
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Regulator: Bank of Ghana
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Key Law: Payment Systems and Services Act, 2019
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Licenses:
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Electronic Money Issuer (EMI)
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Payment Service Provider (PSP) – Standard or Enhanced
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Requirements:
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Local entity, minimum paid-up capital (varies by license tier)
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Local director & data storage requirements
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Crypto: No formal framework yet; cautiously unregulated
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KYC/AML: Required; enforced via BoG and Financial Intelligence Centre
Nigeria
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Regulator: Central Bank of Nigeria (CBN)
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Key Law: CBN Guidelines on Mobile Money Services, Payments System Vision 2025
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Licenses:
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Mobile Money Operator (MMO)
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Payment Service Bank (PSB)
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Switching & Processing License
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Requirements:
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Strict capital thresholds (?2B+ for PSBs)
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Local incorporation required
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Crypto: Officially banned from regulated financial institutions
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KYC/AML: High-priority enforcement through EFCC and NFIU
Kenya
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Regulator: Central Bank of Kenya (CBK)
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Key Law: National Payment System Act, 2011 & CBK Licensing Framework
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Licenses:
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Payment Service Provider (PSP)
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Digital Credit Provider (for lending platforms)
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Requirements:
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CBK licensing mandatory
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Separate approval required for foreign investment
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Crypto: No formal licensing; regulatory sandbox optional
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KYC/AML: Required under Proceeds of Crime & Anti-Money Laundering Act
Sierra Leone
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Regulator: Bank of Sierra Leone (BSL)
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Key Law: Financial Services Act, Bank of Sierra Leone Act
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Licenses:
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EMI licenses are issued, but the sector is still developing
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Mobile money offered largely through telecoms
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Requirements:
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Strong focus on local partnerships
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Emerging guidelines; legal reform in progress
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Crypto: Unregulated
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KYC/AML: Required; FIC Sierra Leone oversees compliance
Rwanda
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Regulator: National Bank of Rwanda (BNR)
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Key Law: Law No. 048/2010 on Electronic Transactions and Guidelines for PSPs
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Licenses:
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PSP license (with fintech-specific categories)
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Credit scoring and e-money also licensed separately
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Requirements:
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Requires local entity and application through BNR
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Crypto: Permitted through regulatory sandbox
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KYC/AML: Strong framework and compliance review process
South Africa
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Regulator: South African Reserve Bank (SARB) + FSCA
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Key Law: Financial Sector Regulation Act, National Payment System Act
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Licenses:
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Payment clearing house participation
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Financial services licenses for lending or crypto
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Requirements:
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Complex, layered licensing based on activity
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Financial Advisory and Intermediary Services (FAIS) Act may apply
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Crypto: Declared financial products under FSCA oversight
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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 |
