Bank Holding Company Regulation in Kenya, Nigeria and South Africa: A Comparative Inventory and a Call for Pan-African Regulation

Abstract

An overview of the regulation of bank holdings in three African jurisdictions (Kenya, Nigeria, South Africa), from a comparative legal perspective (EU and US), identifying regulation of a banking group's parent on the basis of ten identified elements of holding regulation, and calling for action to harmonise African bank holding regulation or adopt pan-African regulation. Submitted for publication in a law journal.

Keywords: bank holdings, African banking regulation, Kenya, Nigeria, South Africa, banking supervision, US Bank Holding Manual, EU Single Rulebook, ECB, EBA, UMOA prudential framework, SADC, East African Community, African Union, dispositif prudentiel UMOA