Adedeji Olowe

The poor and vulnerable are the people fairness and consent matter most to, yet they have the least power to demand either. And it’s worth saying outright that being a brokeass isn’t a license for anyone to take advantage of you. Unfortunately, history is full of exactly that. Wherever there’s a gap in power or information, someone finds a way to profit from the side that can’t push back.

Sadly, in most parts of the world especially in third world countries, poverty and access to credit are like siamese twins, eternally tangled up together in ways that make life a living hell. A large share of the world’s poor stay poor partly because the one thing that could pull them out, formal credit, stays locked behind a door they can’t open.

So hand them credit, then. Problem solved? Not so fast. Most of them show up to that “door” with lean credit history or none at all, no track record for a lender to judge them by, and this gap alone can be enough to seal their fate. 

On the contrary, if we take a look at more advanced nations, say the US for example, FICO built the gold standard for scoring, and while it doesn’t get things right every time, it works often enough that an entire financial system was built on top of it. What FICO does well is synthesise a huge volume of structured data into a single, defensible number, pulling from schemas refined over decades, with fields that map to risk in ways banks have trusted for generations. 

Such infrastructure doesn’t exist across most of Africa, Latin America, and Southeast Asia. It also hardly exists for a new immigrant building a life in a Western country with no local credit history to their name. The data required to make a sound lending decision is either thin, scattered across systems that don’t talk to each other, or simply absent. This is the exact problem I’ve spent years thinking about at Lendsqr. That is, until AI-driven consumer credit scoring models became mainstream.

Where AI fits into the story 

AI’s role here is a specific answer to a specific data problem. To see why,  it helps to pull apart two words people use interchangeably: alternative data and unstructured data. They are not the same thing, and confusing them is where a lot of the AI-and-lending conversation goes wrong before it starts.

Alternative data is any data source outside the traditional credit-reporting menu. Mobile-money transaction histories, airtime top-up patterns, utility-payment records all qualify. Plenty of it still arrives in rows and columns, the same shape as a bank statement, just pulled from a source a credit bureau never touched. A model can read six months of mobile-money inflows and outflows almost the way it reads a repayment history, because the underlying structure isn’t so different.

Unstructured data sits on a separate axis entirely. SMS messages, call logs, voice recordings, photos, a free-form conversation with a loan officer or a chatbot, none of it arrives ready to plug into a scorecard. Something has to read it, listen to it, or parse it first and turn it into a signal a model can use, and that’s where AI earns its keep. A sheet of utility payments could, in principle, be scored by a decades-old statistical method. A folder of someone’s SMS inbox could not, not without a system built to make sense of language at scale.

Data can be alternative and structured at once, like the mobile-money example. It can also be alternative and unstructured at once, like the SMS example. Two different labels, with two different sets of tools required, and treating them as one blur called “AI risk” is how the conversation gets lost.

Fairness is about what the model does with what it sees

Fairness, here, has nothing to do with intent. Nobody at Lendsqr sits down to build a model that penalizes people for their race, gender, or location. Unfortunately, bias moves in more roundabout ways. Say a model discovers that people who let their prepaid airtime balance run down to almost nothing before topping up are more likely to default. Fine, the pattern holds up inside the data. 

But what is it really capturing? It could be income volatility or could be a proxy for a region or income bracket where that habit is simply how people manage scarce cash. The model doesn’t know the difference, and left unchecked it will punish an entire group for a behaviour that has more to do with their circumstances than their creditworthiness.

That’s the difficult question, and it isn’t “does AI have bias.” Every model, human or machine, carries some. The difficult question is whether a model can stay genuinely useful and predictive while still producing outcomes we’re willing to call fair, and that has to be asked variable by variable.

Consent is about what a lender is entitled to learn

Where fairness asks what a model does with information someone already handed over, consent is more of what a lender is entitled to learn from that information in the first place, and AI makes the question uncomfortable in a way older systems never had to take into account.

Take for instance a borrower who agrees to let a lender read their SMS inbox to verify transaction alerts, believing the request is that narrow. If an AI model, built to extract every available signal, is run through the same inbox, income stability can be revealed, other loans the borrower is juggling, spending habits, signs of financial distress, even relationships they never meant to disclose. None of that was on the form they signed, but it sat inside data they’d already agreed to share, waiting for a system capable enough to find it.

So the question stops being “did I consent to you accessing this data.” It becomes “did I also consent to everything you’re capable of figuring out from it.” Those are two different permissions, and most consent flows, ours included, weren’t built with that distinction in mind.

Now for the side of this that gets less airtime. If fairness and consent risk make us uneasy enough to pull back hard on AI and alternative-data scoring, people with thin or non-existent credit history don’t land softly in some cleaner, fairer traditional system. I’ll be honest with you, there is no such system waiting for them. 

A little history on how we got to the AI frontier

The questions around fairness, consent, and who gets left out didn’t begin with today’s credit scoring systems. Every generation has had its own version of this fight. But, to understand where we are now, it helps to look at how we got here.

In 1956, that’s when modern credit scoring began, when engineer Bill Fair and mathematician Earl Isaac built a system on the idea that subjective lending decisions needed to give way to statistical analysis. For years the formula stayed a black box the customer never saw. That began to change in 1974, when the United States adopted the Equal Credit Opportunity Act, prohibiting lenders from denying credit on the basis of race, religion, national origin, sex, marital status, or age. It put scoring systems on notice that however technical they looked on paper, someone still had to answer for the outcomes they produced.

A more consequential shift, for the purpose of this article, was happening far from Wall Street. In 2012 the Commercial Bank of Africa and Safaricom launched M-Shwari in Kenya, giving people with mobile-money accounts but no formal credit history access to loans scored on their transaction and airtime behaviour, reaching millions of first-time borrowers within its first year. 

By 2014 a wave of app-based lenders, Tala (then still called Mkopo Rahisi) and Branch among them, had entered the market, pushing further into unstructured signals like phone metadata and app usage to drive underwriting. This is the tradition Lendsqr sits inside, and it’s where the fairness and consent questions in this article stopped being theoretical for a lot of people who had never had a credit history.

Regulators caught up rather quickly even if not consistently. The EU’s GDPR, in force from 2018, gave consumers new rights over automated decisions made about them and pushed the question of whether an AI model owes a person an explanation into mainstream law. 

In the US, the CFPB confirmed in 2022 that federal anti-discrimination law requires lenders to explain the specific reasons behind a denial, even when relying on complex algorithms, and followed up in 2023 to close the loophole of generic, checklist-style reasons that didn’t reflect why a model made its decision. Using a more powerful model doesn’t buy a lender the right to a vaguer answer. AI is best read as the latest chapter in that history, arguably its most capable one.

So where does that leave us

This debate, unfortunately, doesn’t resolve easily, and I’ve made my peace with that. This piece has sat inside several tensions: alternative data against unstructured data, fairness against consent, exclusion against imperfection. Each one comes down to the same discipline: staying honest about what a model can see, what it can infer, and who could get hurt because of it.

The risk will never completely disappear and I don’t think pretending otherwise helps anybody.

Planes are not perfectly safe either because people still die in plane crashes. Yet nobody seriously argues that the answer is to stop flying. Instead, we continue to make planes safer, again, and again, and again. Today, based on the last five years of commercial aviation data, roughly 99.99998% of flights do not end in a fatal accident. The remaining risk is still real, and every accident still matters, but the answer has been relentless improvement rather than abandoning flight.

By the way, nobody is going to drag me on a helicopter – the risk of that is simply unacceptable to me.

I think AI-driven credit scoring deserves the same treatment.

For millions of people without a conventional credit history, there isn’t a pristine scoring system waiting in the wings if we decide AI makes us uncomfortable. In many cases, there is simply no score, no credit, and no opportunity. So the sensible response cannot be to demand that AI carry zero risk before we’re willing to use it. It should be to build guardrails that keep pushing that risk down.

Explainability is one of them.

If an AI system recommends declining someone, “the model said no” should never be an acceptable answer. A lender should be able to see something closer to: based on signals X, Y, and Z, this borrower has an estimated B% probability of default, compared with K% for comparable borrowers. The reasoning should be visible enough to interrogate, challenge, and, where appropriate, override.

And humans should remain capable of overriding it.

That matters because a score is ultimately a prediction, not a commandment. At Lendsqr, this is already part of how we think about responsible and ethical lending: technology should make the lender better informed, not remove judgment or accountability from the lender.

There should be other guardrails too. Regulators can require explainability. They can require lenders to audit models for unfair outcomes. They can draw a hard line between using data to understand repayment risk and using someone’s vulnerability simply to extract more from them. And as these systems become more capable, those rules will have to become more capable alongside them.

None of this will make AI perfectly fair. None of it will make every inference comfortable. And none of it guarantees that nobody will ever be harmed by a lending decision.

But perfection is the wrong destination to drive to. What should matter is whether we can make these systems safe, explainable, accountable, and fair enough that the enormous benefit of giving previously invisible borrowers a genuine shot at credit outweighs the risks that remain.

I believe we can.

So I will keep building but also stay willing to be told where we’re wrong, because that is how you make the next version safer than the last one.

Ó dàbọ̀.

About seven years ago, a Nigerian fintech found itself on the wrong side of the Central Bank, what we’d call a proper hot okro soup. It was close to losing its license entirely. The Central Bank had decided to make them walk the straight and narrow. Fortunately, word got to the founders before the letter landed.

A frantic phone call to a well-respected bank executive is what surprisingly turned things around. The man flew to Abuja and went to plead their case in person. No lawyer or press statement or strongly worded appeal came close to doing that. They survived because somebody with the right relationship intervened on their behalf. Nothing in that entire saga carried anywhere near that kind of weight.

Of course, the Central Bank didn’t let them off the hook because some big man strolled in. He offered to ensure the fintech remediate their governance and compliance issues within a short period of time. The license was tied to the banker’s 30 years of pedigree.

I’ve thought about that story a lot over the years, because it captures something founders like me don’t want to admit to themselves. The people who decide whether your business lives or dies aren’t always the investors you’re chasing or the customers you’re trying to win over. Sometimes they’re civil servants sitting in an office you’ve never visited, and most of us never bother to find out who they are until we’ve gone to pull the tiger’s tail.

The power regulators hold and why we pretend it isn’t there

Regulators, for the most part, aren’t wealthy people. There are exceptions in certain countries where regulation has become a racket, but broadly speaking, the people writing and enforcing the rules that govern your industry are bureaucrats earning civil servant salaries.

But man, the power they wield is enormous!

You saw it play out during the last World Cup, when Folarin Balogun’s red card got overturned because somebody knew somebody who knew somebody who knew somebody. Football, of all things, isn’t immune to influence and access. Business is no different, and in many ways it’s far less forgiving.

If these people truly have the power to make or unmake your company, why do so many founders walk around completely disconnected from and oblivious of them? We’ll spend months perfecting a pitch for an investor we’ve never met, but never once think to learn the name of the person who runs the department that could shut our business down with a signature.

By law, regulators exist to write regulation, enforce it, and punish whoever wants to make a monkey out of it. That’s the job description, plain and simple. And yet founders everywhere, not just in Africa, tend to operate as if these people don’t exist. We build our businesses, we chase growth, worry about competitors and product and fundraising, and somewhere along the way we forget that there’s an entire arm of government whose sole purpose is to decide what we are and aren’t allowed to do.

The less you know your regulator, the less you understand how much influence they have over your future. Founders who’ve never sat across the table from the people governing their industry tend to underestimate them badly, right up until the day a new policy lands on their desk and blindsides their entire business model.

The relationship should happen long before you need a favor

As a founder or business owner, you need to be deliberate about knowing your regulators and the people who work under them. This doesn’t happen by accident or through a single courtesy visit. I’ll have you know that it’s a relationship you must build over time, the same way you’d build a relationship with a big-pocket customer or a strategic partner. And there’s nothing illegal or shady about wanting to know your regulator or wanting to understand how they think.

The real risk sits on the other side. Skipping this relationship altogether is the genuinely dangerous position to be in. When you know your regulator and the people around them, you start to develop a feel for the kind of regulation that’s coming down the pipeline.

There’s a lot of noise out there, plenty of rumored policy changes and half formed proposals floating around industry circles, but proximity to the people who write the rules gives you a much sharper sense of what matters and what you can safely ignore. You start to understand which lines you can never cross and which grey areas still have room to move. The point isn’t to test boundaries or try to get away with something. It’s to see the regulator’s thinking clearly enough that you stop operating on assumptions.

I know this because I lived it. I started Open Banking Nigeria in 2017, talking directly to the CBN, no license, no mandate, just a group of fintechs who decided to engage properly. The director came to our events, not once but twice. And before long something funny happened. People across the industry started assuming Open Banking Nigeria was some licensed entity, treating us with the kind of respect that comes with a government stamp. It wasn’t. We were a bunch of fintechs who showed up, did the work, and engaged the regulator the way you’re supposed to. That assumption alone tells you how rare proper engagement is. When you do it, people can’t imagine you pulled it off without a title.

There’s another benefit to this closeness, and it pays off slowly but consistently. When you help a regulator succeed at their own job, you build goodwill that shows up later. And this isn’t bribery in any shape or form. It’s sincerely helping the people responsible for regulating your industry do their jobs better.

Every regulator, at some point, taps into industry expertise to figure out how a new policy might land, or how an existing one is performing once it hits the real world. They rely on input, data, and perspective from the very businesses those rules will affect. Being close to a regulator means you’re in the room, or at least in the hallway somewhere, when those conversations are happening. That proximity gives you the chance to positively influence regulation before it’s finalized, and it also gives you the early warning to prepare for whatever’s coming, rather than being caught off guard when it becomes law.

I’ve watched this play out beyond my own work. There’s a story of bankers who engaged their regulators properly and, in doing so, exposed them to technology the regulator hadn’t fully seen yet. That engagement didn’t just protect the banks. It led to better regulation, and it opened room for the whole industry to grow. That’s the part founders miss. Engagement isn’t only defensive but done well, it moves the regulator forward, and everyone downstream of that regulation benefits.

And this repeats across every vertical. The industries where engagement is poor are exactly the ones where regulation and reality are badly misaligned, where you hear the regulated endlessly complaining about rules that make no sense to them, while doing nothing to sit at the table and shape those rules. The complaint is the symptom. Poor engagement is the disease. Show me an industry at war with its regulator and I’ll show you an industry that never bothered to build the relationship before it needed one.

Not all regulators are the same but you need all of them

Regulators exist at different layers, and if you’re only paying attention to the person at the top, you’re missing most of the picture. There are the young regulators just beginning to build their influence within the institution, the ones who’ll be running departments in five or ten years. There are the current regulators themselves, the directors, the governors, the executive vice chairmen who are actively making decisions today. And then there are the ex-regulators, the ones who’ve left the institution but carry the knowledge of how it all works.

You need relationships with all three groups, and I want to spend a moment on the third one because founders tend to underrate it badly. Ex-regulators are frequently very good at what they did, which is often exactly why they end up building consulting practices once they leave. These are the people who know where the “bodies are buried”, so to speak. They understand the internal politics and the figures that drive decisions inside these institutions. When you need direction, they’re often the ones who can point you toward the right person to speak to, or explain why a particular policy is moving the way it is. They also carry political capital they can spend on your behalf when you need someone to open a door that would otherwise stay shut.

If you’re the kind of founder who prefers to sit alone in your office and avoid all of this, you’re putting your business at serious risk. When new regulations are being drafted, your competitors who’ve done the relationship building will be in the room shaping the language, and there’s a real chance those rules get written in a way that disadvantages you and favors them.

The lines you should never cross

There are things you should never, under any circumstances, even with a gun to your head, do when building these relationships.

Never try to bribe a regulator. It’s wrong, unethical and illegal. Beyond the moral higi-haga, it’s also a fast way to destroy your business and possibly get yourself a cold floor in prison with devilish mosquitoes taking turn on you. So treat this as an absolute line rather than a grey area to be negotiated I beg of you.

Never let yourself become a slave to a regulator either. You’re allowed to have principles, and you’re allowed to disagree with a regulator’s position. When you do disagree, there’s no need for hostility or confrontation, but make your stance known clearly and respectfully. A good relationship with a regulator doesn’t require you to agree with everything they say.

Keep the relationship confidential. Regulators generally don’t want their names circulating in industry gossip, and using their name to build your own credibility is one of the worst things you can do to a relationship built on trust. If the governor of a central bank is someone you know well, that’s not something to be dropped casually in conversations to impress other founders or investors. Sharing those details around undermines the very trust that made the relationship valuable in the first place.

If you’re going to give gifts, keep them modest and ordinary. A good book, something small and thoughtful, nothing more. Don’t attempt to influence anyone with expensive items, designers, or by offering to sponsor their children’s abroad school fees. That crosses directly into bribery, however it gets dressed up, and it’s unethical regardless of the language used to justify it.

Sometimes you want to test an idea before committing resources to it, and you can share that with a regulator hypothetically. You might describe something you’re considering doing and ask, purely as a conversation, what their general stance would be. That kind of exchange gives you a read on the regulatory mood that you’ll never find published anywhere online, and it costs you nothing except the willingness to ask.

So how do you start engaging?

Regulators want to succeed at their jobs too, and many of them are working with limited resources or limited in-house expertise to solve problems that are difficult. Be ready to help. Offer guidance where you have relevant expertise, contribute to reports, support industry events and research that helps them make better informed decisions. Anything you do openly and transparently to help a regulator do their job well is fine, and often welcomed.

The trouble only begins the moment you start doing things behind closed doors, covering costs that should never be covered, or slipping into arrangements that blur the line between support and influence peddling. Keep everything visible, keep everything above board, and the relationship will serve you far longer than any shortcut ever could.

Building trust with the people who regulate your industry takes time, and it won’t show up as a line item on any growth chart you present to your board. The founders who treat this seriously instead of something only reserved for crisis moments end up with a seat at the table when the rules of their industry are being drafted, while everyone else finds out about those rules the same way the rest of us find out about a World Cup decision, after the fact, with no say in how it went.

For years, I thought the strongest compliment I could give someone on my team was “we couldn’t run without you.” I used it in performance reviews and on calls with friends (and some enemies) when they asked who my key people were, and I wore it like a badge of honor, both for them and for me, since it meant I had built something worth depending on.

It took me a painfully long time, and a few genuinely stressful stretches where one person being unreachable for a couple of days nearly stalled a launch, to understand that I had it backwards the entire time. “We couldn’t run without you” means I let a few people become the entire company’s heroes, and never built anyone under them who could take it on.

I was celebrating the wrong thing

Every growing company has that one person, sometimes several. It might be an engineer who is the only one who understands the payments system. Or a salesperson who is the rainmaker. We call these people irreplaceable, and we say it with pride, when what we’re really describing is a ticking timebomb. It is easy to slide into this pattern, especially when you are moving fast and stopping to teach someone else the ropes feels like a detour from actually shipping.

I have come to believe heroism in a growing company is a structural failure wearing agbada and kembe of virtue. Behind almost every hero I have ever worked with, there is usually a manager who could not, or would not, develop the people underneath them, whether out of insecurity, laziness, or the very human fear of training your own replacement. I built this exact culture for years before I ever managed to diagnose it in myself.

None of this makes the person carrying all that weight a villain. Most of them are simply chasing efficiency, trying to get things done the fastest way they know, and that instinct is exactly what turns them into a bottleneck. Showing them why that shortcut costs the business more than it saves is part of our job as leaders, and it takes patience rather than blame.

So when it dawned on me that a company’s growth will always have a ceiling when it runs through “special” people, I knew it was time to sit with my thoughts, lease some common sense, and recalibrate before everyone becomes limited by one person’s calendar, since that is a terrifying place to build a business from. 

Why I think about life as a numbers game

Now, in my quest for solutions to salvage the deep mess a business like this can unintentionally land in, I stumbled on what I call the law of networks, and the clearest way I know to explain it is through luck.

Let’s say an averagely sharp person can convert about 5% of the luck that crosses their path into something useful, an opportunity turned into a deal, a chance meeting turned into a partnership, whatever form luck takes for you. If that person has a hundred people in their network, or sees a hundred opportunities over the course of a year, they will convert around five of them. That is the ceiling for someone operating alone, a fixed number no matter how sharp they are.

Imagine that same person with a network of a hundred people, each passing along even half of the opportunities that come their way. Suddenly, you are no longer looking at just a hundred opportunities. You are looking at a much larger pool, and converting the same modest 5% of it produces results that are nowhere close to what one person working in isolation could ever achieve. The 5% conversion rate never changed. What changed was the size of the pool it was applied to, and that is the difference between linear effort and exponential outcomes.

When you are running a business by yourself, whether you are an engineer, a salesperson, or a founder wearing every hat at once, so much depends on you simply staying upright. You get tired or sick. Life happens (and life can be a bitch), in the mundane and the serious ways it always does, and when it does, everything tied to you grinds to a halt along with you. There is no backup plan when everything runs through one person.

But the moment you have a network, the moment you have people you have genuinely invested in and handed real responsibility to, the entire structure stops depending on one link holding and starts holding itself up. It grows exponentially, and it keeps growing on the days you are not in the room.

The math behind working with other people in the room

There is something I have started calling synergy, in the literal sense that 1 + 1 = 5, well past whatever the word has come to mean on a corporate poster. On your own, there is a limit to what you can produce, shaped entirely by your own bandwidth, blind spots, and your own limited hours in a day.

When you bring good people into that picture, whether by hiring them or by deliberately replicating your own capabilities in them, they often grow faster than you did, because engagement surfaces things that solitude never will. There are insights that only become visible through the friction of working alongside someone else, ones neither of you would have arrived at alone.

Think of a time you were stuck on a problem, turning it over in your head with no progress, and then you start explaining it out loud to a colleague, a friend, or someone at your workspace, and somewhere in the middle of that sentence the answer simply appears, from the act of engaging with another mind.

This, ladies and gentlemen, is the compounding effect at work, and there is friction that comes with it. Plenty of us struggle with the more mundane side of this, the part where you have to explain what you do, translate your instincts into something teachable, put language around decisions you have always made by feel. It is an uncomfortable struggle, but it is one worth working through.

The one expectation I have of every senior hire

After building this the wrong way for longer than necessary, here is where I have landed. If you are ever going to build something that outlasts your own energy and attention, whether as a manager or a business owner, you have to replicate yourself deliberately, so your effort compounds into exponential results through the people around you.

Practically, this means every senior person on my team is now measured on one thing above almost everything else: whether the people reporting to them can do a fragment of their job within eighteen months, well beyond approximating it or simply surviving without them for a week. Leaders have to actively recognize this risk in themselves and fight against it, mostly through mentoring people directly and showing them by example.

If that is not happening, what the senior person has built is a monument to their own indispensability, and a monument, by definition, does not scale. I hope this has been useful in some small way. I have my doubts about how many people will go and change how they measure their own team because of it.

If you judged the CBN’s latest payments circular by the online reaction alone, you’d think the entire Nigerian financial service industry has been turned upside down considering every time the Central Bank of Nigeria releases a new circular, two things happen almost immediately: People rush to LinkedIn to declare that everything has changed, and everyone else starts wondering which companies are about to be in trouble.

The latest circular on data localization, Ultimate Beneficial Ownership (UBO) disclosure, and market structure has triggered that very same reaction.

I’ve read through the circular, spoken to people across the financial and fintech ecosystems, and my first reaction was probably less dramatic than most and sincerely it has nothing to do with underestimating the circular, which carries real weight for the industry.

The reason is straightforward: much of what people are discussing today has been in existence for years. What has changed is the CBN’s decision to bring some of these expectations together into a formal policy document, make timelines explicit, and signal that enforcement will become much more deliberate.

So, if you’re expecting a sudden shake-up across Nigerian banks and fintech, you’ll probably be disappointed. If you’re looking at what this means for the country’s long-term financial infrastructure, this circular deserves far more attention than the headlines have given it.

Data localization has always been around

One of the biggest misconceptions I’ve seen since the circular was published is the idea that the CBN has suddenly invented data localization. It hasn’t, and anyone who has spent enough time building regulated financial products in Nigeria knows regulators have always paid close attention to where critical financial data lives, how it is managed, and who ultimately has access to it.

The difference today is that the CBN has decided to state the expectation considerably more clearly. The circular requires financial institutions and payment participants to ensure payment transaction data generated within Nigeria is stored and managed in Nigeria, with full compliance expected by January 1, 2027.

The wording greatly matters here because the circular repeatedly talks about payment transaction data. It does not say every application used by financial institutions must suddenly run from Nigerian infrastructure, rather does it prohibits cloud computing infrastructures like AWS, Microsoft Azure, or Google Cloud. It focuses specifically on payment transaction data.

That distinction matters because I’ve already seen people interpreting the policy far more broadly than the document itself suggests.

Not every system is suddenly affected

When people hear “data localization,” many immediately imagine banks scrambling to move every workload into Nigerian data centres, which isn’t what this circular says.

Banks and fintechs rely on dozens of software systems every single day. Customer support teams use CRMs; Finance teams use accounting software; Employees use email platforms; Internal communication happens over collaboration tools; Product teams manage work using cloud-based applications. Most of those services are still provided by companies like Microsoft and Google.

Even the CBN itself relies on Microsoft products in different capacities, just as many banks continue to rely heavily on Microsoft 365 and many newer fintech companies operate substantial parts of their business on Google’s ecosystem.

If someone tells you every one of those systems now has to move into a Nigerian data centre overnight, they’re reading far more into the circular than is actually written.

The document is much narrower in scope, focused specifically on operators who handle  payment transaction data. Ergo, if your core business involves processing payment transactions in Nigeria, then complying with the localization requirement becomes part of doing business in the market.

All the banks are already running their core banking systems in Nigeria

Another reason I don’t expect the immediate disruption many people are predicting is because much of Nigeria’s payment infrastructure is already local. Take banking, for instance. Virtually every major Nigerian bank already operates its core banking systems within Nigeria and they have been doing that for decades.

The same applies to many of the country’s oldest payment infrastructure companies. NIBSS has always operated locally. Interswitch built its infrastructure long before cloud computing became the default choice. UPS, along with several other legacy players, developed their systems during a period when hosting data outside Nigeria simply wasn’t the standard approach.

History has already done a large part of the work this policy is trying to reinforce. That’s why I don’t expect January 2027 to suddenly produce a wave of emergency migrations across the entire financial industry. The organizations likely to spend the next several months making adjustments are those whose payment processing architecture has become more globally distributed as cloud-native infrastructure became the norm.

For everyone else, compliance may look less like rebuilding everything from scratch and more like tightening existing controls, documenting processes properly, and demonstrating that critical payment data remains where regulators expect it to be.

The UBO requirement isn’t quite new news

The other part of the circular that has generated plenty of discussion is the requirement around Ultimate Beneficial Ownership disclosures. Again, I don’t expect the reaction to match the reality.

If you’ve never gone through a CBN licensing process, this requirement may sound like a major new regulatory burden. However, if you have, your reaction is probably closer to relief that someone finally put this requirement on paper, since it’s been part of the job for years.

Anyone who has raised capital, structured shareholding, applied for licenses, or participated in regulatory engagements with the CBN knows that understanding who ultimately owns and controls a regulated institution has always mattered.

The circular requires institutions to maintain accurate and up-to-date records of their Ultimate Beneficial Owners and make that information available to the CBN when requested.

This aligns with how the regulator has approached financial oversight for a long time. The formalization matters because it creates greater consistency across the ecosystem, but I don’t see it introducing a radically different operating environment for companies that have already been taking compliance seriously.

Building local infrastructure has to start somewhere

One criticism I’ve already heard is that Nigeria simply doesn’t have the infrastructure to support a policy like this.

While we may not have cloud infrastructure at the same scale as AWS, Google Cloud, or Azure. Anyone building modern technology products knows these companies have spent decades investing billions of dollars in global infrastructure, redundancy, networking, and security. Expecting local providers to match that overnight is far from realistic.

But waiting until Nigeria has infrastructure on that scale before introducing policies that encourage local investment doesn’t make much sense either.

Every country that has built strategic digital infrastructure started somewhere. Nobody wakes up one morning with world-class data centres already built. Conditions have to be created that make investing in them worthwhile.

If regulators never communicate that local infrastructure matters, investors have very little incentive to build it. Demand remains weak, capital goes elsewhere, and years later everyone complains that the country still depends entirely on foreign providers.

At some point, someone has to make the first move, and I think that’s what this circular is trying to do. It will almost certainly create additional costs for some operators, and not every implementation will be smooth. But if Nigeria wants critical financial infrastructure to increasingly reside within its borders, then there has to be a starting point.

One thing I’d still like the CBN to fix

If there’s one area where the CBN still falls short, it has very little to do with data localization or beneficial ownership. It’s about discoverability. The CBN regulates one of the most important industries in the country, yet finding authoritative information can still be surprisingly difficult.

Today, if you’re looking for licensed commercial banks, microfinance banks, payment service providers, payment service banks, or other regulated institutions, you’ll often find yourself downloading Excel spreadsheets from different sections of the CBN website.

Those spreadsheets technically contain the information you’re looking for, but they don’t function like modern regulatory infrastructure. They’re difficult to search, harder to integrate into internal workflows, and not particularly friendly for founders, investors, journalists, researchers, compliance teams, or even regulated institutions trying to verify information quickly.

A single authoritative, searchable directory of every regulated entity would fix this. You could search by company name, license category and status, approval date, or registration number. Information could be updated in one place and consumed by everyone as the definitive reference point for all who depend on it.

Somewhere right now, a founder who raised a decent round, built a real product, and had people genuinely rooting for them is in the middle of making a decision that is going to age very badly. They do not know it yet. And the people who were supposed to know it are nowhere to be found.

I have watched this story play out enough times that the shape of it has become familiar. Smart person, good company, real momentum, and then something completely avoidable blows it all up. There is even a running joke in venture circles that landing on Forbes 30 Under 30 is really a jail sentence waiting to happen. Obviously that is an exaggeration, most people on that list worked hard and deserve to be there. But the joke has survived long enough to mean something.

The question I keep coming back to is why these founders mess up, and where everyone who was supposed to be in their corner was when it mattered.

When I reflect on my own career, from being a young person still figuring out how professional environments worked, to eventually sitting on boards myself, one pattern keeps coming back to me. Many of us who occupy board seats are actively failing the founders we are supposed to be leading. By no means are we incompetent in our own fields, we have sadly redefined the role into something much smaller than it is supposed to be. 

The board is the adult in the room

There is a formal answer for why companies have boards. Fiduciary responsibility, shareholder oversight, strategic guidance, all of that exists and matters. But underneath the governance language, a board is also meant to be a room full of people who have already made the expensive mistakes and are in a position to help the people in front of them avoid repeating the same ones. That part seems to have secretly been dropped from the job description.

I know what a board can do for a person’s development because it happened to me, and I can trace almost every meaningful thing I understand about leadership back to specific people and specific rooms.

The first time I found myself on a board that carried real weight was at SystemSpecs, right after returning from Dubai. I walked into a room with Christopher Kolade and Ernest Ndukwe, the man who effectively delivered telecoms to Nigeria at a time when every other infrastructure effort was crumbling under its own weight. These were not accomplished people in the conventional sense alone. They were men whose names meant something, whose conduct meant something, who had clearly decided long ago what kind of people they were going to be and held to it ever since.

Nobody lectured me or handed me a manual. But as I sat in that room, my brain just reset itself.  Because when I was in banking, my idea of team bonding involved taking my colleagues to places I absolutely cannot describe in writing. That version of me was not compatible with the room I had entered, and I knew it without being told. The presence of people I deeply respected did the work that no training program ever could. Nobody needed to catch me being careless, because the thought of it was already unbearable. 

What I learned, and from whom

From SystemSpecs I moved on to start Trium, the corporate venture arm of the Coronation Group, and went back to work with my former boss, Aigboje Aig-Imoukhuede. When I was eventually leaving after four years, I told him he needed to formally issue me a PhD certificate, because what I received during that period was more rigorous than most structured programs could have delivered. And I was not the only one who benefited from being in that orbit. The board around Aigboje was its own institution.

Segun Ogbonlowo was the first person who ever showed me what it looked like to carry oneself properly in a boardroom. Early on, I was in a meeting with Aigboje and I was making my case for something, probably with more confidence than I had earned at the time, and Segun pulled me aside afterward, pulled my ears like an errant school child. He walked me through how a board member is supposed to conduct themselves with their chairman, how you prepare ahead of a meeting, how you listen before you push, how the room functions when everyone is playing their role well. It was direct, private and it changed how I showed up from that point forward.

Bunmi Lawson did something different for me. She laid the foundation of how I think about risk and compliance, in a way that was practical and grounded rather than theoretical. That understanding has traveled with me to every seat I have held since, and I still draw from it more than she probably knows.

What Aigboje himself gave me is harder to compress. It was exposure, full stop. He took me to meetings with the Vice President. He brought me into rooms with the SEC. He let me watch how a person of his standing navigates high-stakes environments, which turned out to be a long and irreplaceable masterclass in how power, preparation, and restraint work in combination. My ability to engage at senior levels on something like open banking did not come from reading about it but came from standing in those rooms and paying close attention.

Paying it forward, one board room at a time 

When I was involved in setting up the board for TeamApt, which most people now know as Moniepoint, I tried to apply what I had absorbed. We brought in Professor Yinka David-West, Chidi Okpala, and Boye Ademola from KPMG. At the time, people seemed to think I was working from some careful, deliberate framework. Mostly I was translating what Aigboje and others had given me into a new context and hoping it would hold. It did, and watching that board find its footing confirmed something I had already begun to suspect.

I saw this up close at Paystack recently, when one of the bright people there was stepping away. When they called me, they spent a good portion of that conversation talking about their experience working with me and how it made them sit up. When I think about the time I have spent on the Paystack board alongside people I respect enormously, and when I hear from those inside the company about what it has meant to work with board members who genuinely show up for them, it confirms the same thing. 

Now, Paystack is already heads and shoulders above most African fintechs. But what that conversation showed me is how much what we bring to a board room, myself and the other board members I deeply respect there, matters. We navigated extremely difficult times together, and I believe some of what we built, the decisions, the process, the discipline, will end up becoming playbooks taught in MBA classes somewhere down the line. 

Too many board members have made peace with doing the minimum

Too many board members have turned their role into a supervisory checkbox. They arrive for quarterly meetings, review decks, approve budgets, and leave. That is compliance cosplaying as leadership, and it leaves out entirely any real investment in the human being sitting across the table. That gap is where founders eventually get into trouble.

Founders, especially first-time founders, are often technically brilliant. They understand their product, their market, their users. What they frequently do not have is the kind of institutional wisdom that only comes from navigating complex organizations over time, from making expensive interpersonal mistakes and surviving them, from watching how seasoned leaders carry pressure without letting it crack their judgment. That wisdom is not available online. It lives in the people around them, specifically in the people on their board, and when those people are not actively transferring it, the founder learns it the hard way. Sometimes very publicly.

This is also not a problem that belongs only to early-stage companies. Governance failures and leadership implosions happen at every stage of growth and in every market. WeWork burned through billions with a board that watched Adam Neumann operate like a one-man religion and said nothing useful until the IPO was already on fire. Theranos had a board full of decorated names who apparently never thought to ask whether the machine actually worked. The geography and the industry keep changing but the shape of the failure stays the same. What matters is whether the people in oversight positions are actually doing the work, or collecting fees and updating their profiles.

Who you put in that room is a decision you will live with

If you are an investor and you place people on a board primarily to protect your equity and represent your interests, you are doing just a measly 10% of the job. The people you send into that room need genuine experience, real standing in the market, and the willingness to do the unglamorous work of developing the people they are serving. 

A founder with nobody in their corner doing real mentorship will eventually make a decision that costs everyone. Maybe it is a regulatory misstep or a culture failure that becomes a public mess. Perhaps it is a board blowup that turns into a cautionary story told at panels for years. These things happen on a predictable schedule at companies whose leadership has not been adequately developed, and the investors who placed inadequate board members into those seats share the outcome whether they acknowledge it or not.

The compounding benefit of doing this well is equally real. Founders who receive genuine development grow into leaders who can eventually sit on someone else’s board, contribute meaningfully, and extend the same investment to the next generation of people coming up.

Mentorship on a board should be mandatory

One-on-ones between board members and founders should be standard practice. Mentorship with specific developmental intent should be part of how a board operates, not an afterthought nobody budgets time for. Where a board does not have the bandwidth to do this internally, it should actively mandate that the company bring in executive coaches or external mentors who can fill the gap. For a founder navigating the role for the first time, that kind of support is infrastructure, and treating it as optional is how you end up reading about them in a forwarded article six months later.

The downstream effects of getting this right show up in measurable ways. Organizational drama decreases, distractions thin out, board meetings become more productive because the people presenting have been developed well enough to hold the room properly. Reports arrive in better shape and investors deal with fewer surprises. The whole system runs cleaner, and the money is considerably safer.

The inverse is equally predictable. If you are on a board right now and you are not doing this work, you are managing a countdown. The founder may be technically sound and working hard, but experience cannot be improvised under pressure, and at some point, that gap will surface in a way that is difficult to reverse after the fact.

I owe everything I understand about how to carry myself in positions of leadership to people who chose to invest in me when it would have been far easier to let me find my own way. Aigboje Aig-Imoukhuede deserves the most credit for that, without any qualification. I also owe a great deal to Segun Ogbonlowo, Bunmi Lawson, Christopher Kolade, and Ernest Ndukwe, each of whom gave me standards worth keeping, through direct intervention or through the simple example of how they showed up. I hope I never get to disgrace any of them.