AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
Choose the law and forum with enforcement in mind: your client's assets are in Nigeria, so whatever you win must be enforced there. A foreign court judgment must be registered in Nigeria, generally within 12 months and only for qualifying courts, while an arbitral award from a New York Convention country can be enforced under the Arbitration and Mediation Act 2023. For many freelancers, arbitration with a clear seat, or Nigerian courts, gives a more practical route than a court in their own country.
Three separate choices
A dispute clause makes three decisions that people often blur together:
- Governing law
- Which country's law decides what the contract means and whether it was broken, for example the law of England and Wales, Ontario or Lagos State
- Forum
- Who decides a dispute: the courts of a named country, or an arbitral tribunal
- Seat (for arbitration)
- The legal home of the arbitration, which decides which courts supervise it and where the award is 'made'
Choosing your own country's law feels safe, but a Nigerian court asked to apply foreign law will need it proved, which adds cost. Choosing Nigerian law makes a Nigerian court's job easier. Which law suits you is a question for a lawyer; the more practical decision for most freelancers is the forum.
If you choose courts in your own country
A judgment from your home court is only useful if it can be enforced against the client's Nigerian assets. A Nigeria guide by Streamsowers & Köhn on the Global Legal Post (April 2026) names two statutes: the Reciprocal Enforcement of Judgments Ordinance 1922 and the Foreign Judgments (Reciprocal Enforcement) Act 1990. It says registration must be sought within 12 months of the judgment unless a superior Nigerian court extends the time, and lists grounds for refusal, including:
- The debtor did not receive notice in time to defend.
- The foreign court lacked jurisdiction.
- The judgment was obtained by fraud or is contrary to Nigerian public policy.
- The judgment is not final and conclusive, or not for a sum of money.
- The application is out of time.
A Mondaq guide from June 2026 adds that the 1922 Ordinance covers UK superior courts and designated Commonwealth courts, that no orders under the 1990 Act exist for many countries including the US, and that a judgment may be enforced in its original currency or in naira at the CBN official rate. A US judgment, on that view, would need a fresh action in Nigeria based on the judgment.
If you choose arbitration
The same Global Legal Post guide says section 60 of the Arbitration and Mediation Act 2023 incorporates the New York Convention for awards made in Convention states arising from commercial relationships. Enforcement can be refused on limited grounds, such as an invalid arbitration agreement, lack of proper notice, a matter that cannot be arbitrated, an award beyond what was submitted, or public policy. Arbitration also lets you choose a seat, a set of rules and a sole arbitrator.
| Option | Strengths | Weaknesses |
|---|---|---|
| Courts where you live | Familiar, local lawyer | Enforcement in Nigeria depends on reciprocity and a 12-month window |
| Nigerian courts (state of the client) | Judgment enforceable directly against Nigerian assets | You need a Nigerian lawyer; timelines vary |
| Arbitration, seat in a Convention state | Award enforceable in Nigeria under the AMA 2023; neutral forum | Arbitrator and institution fees can be high for small claims |
| Lagos small claims (up to ₦5m) | Fast target timetable, low formality | Only for liquidated sums within the limit; a party must be in Lagos or the claim must arise there |
Worked example (illustration only)
A Canadian-based product designer agrees a $40,000 contract with an Abuja company. A clause choosing Ontario courts would give her a judgment that, on the Mondaq view, may face reciprocity questions in Nigeria. Instead she agrees Nigerian law, arbitration seated in Lagos under the AMA 2023, a sole arbitrator, with the Lagos small claims court available for any unpaid invoice below ₦5,000,000. If the company stops paying a $3,000 milestone, she can use small claims for that invoice if its naira value is within the limit, and keep arbitration for larger disputes.
Matching the forum to the contract size
The best clause for a £1,500 logo job is not the best for a £60,000 software build. For small, one-off jobs, the cost of any formal process can exceed the debt, so the practical tools are a deposit, milestone payments and, against a Lagos client, the small claims court for unpaid sums. For mid-sized retainers, Nigerian courts in the client's state, with Nigerian law, keep enforcement simple. For large or long contracts, arbitration with a named institution and seat gives a neutral forum and an award that can travel. Whatever you choose, write the same choice into every contract with that client, including change orders, so there is never a question of which clause applies.
Clauses to include
- Governing law, named precisely (a state or province, not just 'Nigeria' or 'Canada').
- Forum: named courts, or arbitration with seat, rules, number of arbitrators and language.
- A step before formal action, such as 14 days of good-faith negotiation after written notice.
- Currency of payment and of any award, and the exchange rate used for conversion.
- Notices: email addresses for formal notices, so service is not disputed later.
For the collection steps once an invoice is late, see chasing a Nigerian client for late payment, and for currency terms see an FX clause for a Nigerian client retainer.
Where Pryme fits
Clear payment routes reduce disputes. A Pryme Business account can receive a Nigerian client's payment in naira or a foreign currency, and verifiable statements can show exactly what was received and when if a dispute arises.
Questions people ask
Which law should govern my contract with a Nigerian client?
It depends on the deal, but think about enforcement first: the client's assets are in Nigeria, so a Nigerian court or a New York Convention arbitration award is often more practical.
Can a UK judgment be enforced in Nigeria?
A UK superior court judgment can be registered under the 1922 Ordinance, generally within 12 months of the judgment.
Can a US judgment be enforced in Nigeria?
A Mondaq guide says no orders under the 1990 Act exist for the US, so a fresh action on the judgment is usually needed.
Is arbitration worth it for a small freelance contract?
Fees can be high for small sums. Many freelancers combine arbitration for large disputes with small claims for unpaid invoices.
Sources
- Global Legal Post: Enforcement of judgments law guide, Nigeria (Streamsowers & Köhn, Apr 2026) · accessed Oct 2026
- Mondaq: Enforcing UK and US judgments in the Nigerian Federal High Court (24 Jun 2026) · accessed Oct 2026
- Lagos State Practice Direction on Small Claims Court 2023 (copy on lagosmepb.org) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.