For years, Nigeria’s banks have been doing something Nigerian businesses have historically struggled to do; they take Nigerian capital, Nigerian expertise and Nigerian brands beyond Nigeria’s borders and turn them into continental businesses.
Nigeria’s banking presence now exists across many African countries, from Accra and Banjul to Nairobi, and from London to other international financial centres; Nigerian banking groups have built subsidiaries, acquired institutions and deployed executives and technical specialists across markets. It has been one of the more remarkable stories of Nigerian corporate expansion.
But a new development in The Gambia suggests that the next phase of that African banking story may be considerably more complicated.
The Central Bank of The Gambia has directed commercial banks operating in the country to begin a phased replacement of non-Gambian employees with suitably qualified Gambian nationals, with the transition to be completed by December 31, 2026.
The directive followed an industry-wide review by the regulator, which it said found a “relatively high number” of non-Gambian employees working beyond formally recognised expatriate arrangements.
The affected institutions include subsidiaries of Nigerian financial groups such as Access Bank, GTBank, FirstBank and Zenith Bank, alongside Ecobank.
The Central Bank of The Gambia has made clear that the directive applies across the banking industry and has not accused any individual bank of breaching the rules. That distinction matters.
This is not simply a story about Nigerians being asked to leave The Gambia. It is a story about what African countries increasingly expect from foreign-owned businesses operating within their economies.
For Nigerian banks, it may also mark the start of a tough rethink of whether they will keep building African banking empires using a model in which personnel from Nigerian headquarters routinely fill critical managerial, technical, and operational roles.
The Gambia appears to be saying that the answer cannot be yes forever. And perhaps Africa is beginning to ask the same question.
The Nigerian banking industry has every reason to be proud of its continental expansion. The transformation has been extraordinary. Nigerian banks that once operated primarily within a domestic market now have businesses spanning multiple African jurisdictions and, in some cases, major international financial centres.
Recent analysis of the overseas operations of Access Bank, First HoldCo, Zenith Bank, UBA and GTCO showed that 10 international operations alone had combined assets of about N40.66 trillion at the end of 2025. That expansion has carried Nigerian capital, technology, financial products, management systems and professional expertise into other African economies.
But expansion creates a responsibility beyond balance sheets. When a Nigerian bank opens a subsidiary in another African country, the immediate objective is naturally to build a profitable and efficient institution. Yet the host country also expects something else: jobs, skills, management experience, technology transfer and the development of a local financial-services ecosystem. That is where The Gambia’s latest directive becomes important.
The Central Bank says banks must not merely replace foreign employees. They must make appropriate arrangements for skills transfer and ensure that critical institutional knowledge is not lost during the transition. In other words, the regulator is not saying foreign expertise has no place. It is saying foreign expertise must eventually produce local expertise. That is a fundamentally different proposition.
The Gambia’s Labour Act 2023 already provides for this principle. Where an employer receives an expatriate quota, the law requires a Gambian counterpart to understudy the expatriate, with the broader objective of transferring knowledge, technology and skills. It also restricts expatriate quotas where the required expertise already exists locally.
The Central Bank’s latest intervention therefore appears less like a sudden anti-foreigner policy and more like an attempt to enforce an existing localisation framework. That should make Nigerian banks uncomfortable but not necessarily angry. It should make them reflective. Because the real question is not why The Gambia wants Gambians running more Gambian banking operations. The real question is why, after years of African expansion, some critical positions may still depend heavily on personnel imported from the parent company’s home market. That question extends far beyond The Gambia.
Nigeria has become one of Africa’s biggest exporters of banking talent. Nigerian bankers have built careers in Ghana, Sierra Leone, Liberia, The Gambia, Kenya, Rwanda, Uganda and other markets. This has been good for Nigerian professionals and good for the internationalisation of Nigerian banking.
But there is another side. If the same Nigerian institution repeatedly exports Nigerian managers into its African subsidiaries without building equally strong local succession pipelines, it may successfully export the bank without fully developing the banking ecosystem around it. That is the contradiction. A bank can be African in geography but remain Nigerian in human capital. The distinction may soon matter more.
African regulators are becoming increasingly conscious of the relationship between foreign investment and local economic participation. Countries want international capital, but they also want local professionals to occupy positions of responsibility. They want subsidiaries that are not simply branches of foreign corporate cultures but institutions that understand, employ and develop the people of the markets in which they operate.
The Gambian regulator’s directive therefore deserves to be watched carefully by every Nigerian bank with ambitions beyond Nigeria. Because what happens in Banjul may eventually influence conversations in other capitals.
The regulatory message is particularly significant because it does not demand an abrupt operational rupture. The banks have been given until December 31 to complete the transition while maintaining continuity and transferring institutional knowledge. That places the responsibility squarely on the banks. They must identify which positions genuinely require expatriate expertise. They must identify Gambians capable of assuming those responsibilities. Where the skills do not yet exist, they must develop them.
And where the skills already exist, the argument for importing foreign personnel becomes considerably harder to sustain.
For Nigerian banks, this should trigger a much broader review of their continental talent strategy. Instead of asking only, “Who can we send from Lagos?” the question should increasingly be, “Who can we develop in Banjul?”
Instead of measuring international expansion only by assets, branches, deposits and profits, perhaps banks should also measure the number of local professionals they have developed into senior risk officers, chief technology officers, treasury executives, compliance specialists, finance directors and managing directors. That would be a different definition of African banking success. And it may be the definition that matters in the next decade.
There is also an uncomfortable lesson for Nigeria. Nigeria has historically benefited from the movement of its professionals across Africa. Nigerian bankers, accountants, lawyers, engineers, consultants and other professionals have built careers across the continent.
If African countries increasingly insist on localising strategic positions, Nigerian businesses will have to adapt to a world in which continental expansion can no longer rely indefinitely on the export of Nigerian personnel. That is not necessarily a bad thing.
It could force Nigerian companies to become better developers of local talent wherever they operate. It could also create a new generation of African executives who understand their local markets while benefiting from the systems, technology and institutional knowledge of larger international groups. That is what genuine knowledge transfer should produce.
The danger is in treating localisation as merely a compliance exercise. If banks simply replace foreign employees with local employees before transferring the underlying knowledge, the exercise could become cosmetic.
A risk-management position is not localised merely because the person occupying the chair has changed nationality. The institution must retain the expertise. The local employee must have the training, authority, experience and institutional exposure required to perform the role effectively. Otherwise, localisation becomes a headcount exercise rather than capacity building.
This is why the December deadline should not be viewed merely as a staffing deadline. It is a test of succession planning. It is a test of whether African banking groups have been genuinely developing local human capital or merely deploying experienced personnel from headquarters whenever a specialised role becomes difficult to fill. And it is a test of the meaning of “African banking”.
For years, the dominant narrative has been that Nigerian banks conquered Africa. Perhaps that narrative now needs to mature. The future may not belong simply to banks that can enter the most African markets. It may belong to banks that can enter those markets, understand them, invest in them, develop local professionals and eventually allow those professionals to lead. That is a more difficult model. But it is also a more sustainable one.
The Gambia’s directive should therefore not be dismissed as a narrow labour-market dispute or reduced to a headline about Nigerian bankers losing their jobs. The bigger story is about the evolution of African capitalism. Foreign capital is welcome. Foreign expertise is valuable. Cross-border banking is necessary. But host countries increasingly want something more enduring than foreign money and foreign managers. They want ownership of knowledge. They want career pathways for their citizens. They want their professionals to sit at the decision-making table. And they want foreign companies operating in their countries to leave behind stronger institutions than they found.
For Nigerian banks, that presents both a challenge and an opportunity. The challenge is that a business model built around moving experienced Nigerian personnel across borders may become increasingly difficult to sustain. The opportunity is that Nigerian banks can become genuine continental institutions by building African talent at scale.
The question, ultimately, is no longer whether Nigerian banks can build banks across Africa. They already have. The question is whether they can build Africans who can run them. The Gambia has just made that question impossible to ignore.
Blaise, a journalist and PR professional, writes from Lagos and can be reached via: blaise.udunze@gmail.com
