Govt. Lottery Guidelines
Notes for Legal Team
Internal Review & Compliance Checklist
01
Key Compliance Requirements
These policy drafts cover the core areas but must undergo thorough review before final publication.
02
Nigerian Compliance Review
- Confirm full alignment with Nigeria Data Protection Regulation (NDPR)
- Verify compliance with National Lottery Commission (NLC) licensing requirements
- Ensure alignment with FIRS tax and withholding guidelines
03
Regulatory Body Sign-off
- Obtain formal approval from the National Lottery Commission (NLC)
- Review for any state-specific lottery board requirements
- Confirm required wording or mandatory clauses
04
Banking & Payment Partner Requirements
- Review with payment processors (Flutterwave, Paystack, etc.)
- Include specific clauses on liability and chargeback handling
- Confirm KYC/AML requirements are sufficiently covered
05
Additional Areas for Review
- Regional Variations — Prepare for possible state-specific adjustments if expanding
- AML/KYC Clauses — Expand based on latest EFCC and FIRS guidance
- Dispute Resolution — Confirm arbitration process and reference to specific regulatory body (e.g., NLC Board of Arbitration)
06
Next Steps
All policies should be reviewed and approved by qualified Nigerian legal counsel specializing in gaming/lottery regulations before going live.
