The 2020 CAMA and Beneficial Ownership in the Extractive Industry
Communications
3 September 2020
By Charles Uche ESQ
Incorporating and fronting companies is a convenient and effective way of concealing identity, engaging in illicit transactions and evading liabilities. In many countries, a company can be formed without disclosing the identity of the individual who ultimately controls or profits from the business, i.e., the beneficial owner. Criminals and politically exposed persons (PEPs) can assign “nominee” shareholders to be listed on official documents or can list other legal entities (other companies can be shareholders in a company) as the “owners,” thereby creating a chain of companies–often across borders–that can be difficult for investigators and law enforcement to trace and recover.
Connected Development (CODE), has over the year, through its Conflict & Fragility project, in partnership with Oxfam-in-Nigeria advocated for a robust beneficial Ownership transparency through the instrumentality of a robust legislation as an essential means for combating corruption, stemming illicit financial flows, and fighting tax evasion. While many initiatives exist to maintain and disclose beneficial owners of companies in Nigeria, like the Beneficial Ownership Register launched by Nigeria Extractive Industries Transparency Initiative (NEITI) in December 2019, none of them until the enactment of the 2020 Companies and Allied Matters Act (CAMA) had the statutory backing for enforcement.
Documents from Panama papers on Dan Etete and Kolawole Aluko can be used as classical case studies in demonstrating how these two individuals, like many others, capitalised on the non-existent or fragile regulatory framework in Nigeria’s extractive “oil & gas” sector to launder money and evade liabilities which has cost the Nigerian government and people revenue in the billions of dollars. Till date, none of the aforementioned persons has been successfully prosecuted and convicted partly due to concealment of identities and fronting of shell companies in their transactions. Shell companies are legal entities “companies” that are non-operational and lack assets or staff. They are conveniently used by money launderers to keep their identities hidden while they engage in illicit transactions across borders and evade tax.
Dan Etete: Dan Etete, a former Petroleum Minister under Nigerias Dictator Head-of-State, Gen. Sani Abacha had in 1998, incorporated a Shell company named “Malabu Oil & Gas Limited” using a fictitious name “Kweku Amafegha”, with few other persons, while he was the ultimate and beneficial owner of the company – though his real name did not appear in any official documents. Five days after he incorporated this company, he, as Petroleum Minister, awarded this company an oil block “OPL 245”. He used this shell company to launder money across the Nigerian border and acquire luxurious assets, while escaping liabilities.
Kolawole Aluko: Kola Aluko is a businessman and oil executive. Media reports have described Aluko as a key ally to Alison-Madueke, a relationship both have previously denied. He rose to prominence around 2011 when Nigeria’s government awarded two companies he founded or owned valuable oil blocks on a no-bid basis. One of his companies, Atlantic Energy, was created the day before it inked the deals to acquire multimillion-dollar oil licenses.
In Nigeria, only a member of a Public Company (PLC) was under obligation, under the old 1990 CAMA, to disclose in writing when required, the capacity in which he holds any shares in the company; either as a beneficial owner or as a nominee of an interested person. See Sections 94-98, old CAMA.
The 2020 CAMA in section 119 has extended such obligation (to disclose the particulars of shareholding by notifying the company) to persons with significant control in all companies. Similarly, as provided in section 120 of the new CAMA, a person who is a substantial shareholder in a public company and holding (either by himself or by his nominee/proxy) shares in the company which entitle him to exercise at least five per cent (5%) of the unrestricted voting rights at any general meeting of the company, is required to disclose such holding by notifying the company within a stipulated time.
This new disclosure provisions are poised to enhance transparency and prevent asset shielding as well as combat money laundering, terrorism financing and all forms of illicit financial flows by legal entities having limited liability.
While there is no gainsaying that the above disclosure provisions would enhance transparency and accountability in the Extractive sector in Nigeria, especially in the Petroleum Industry, as many of the oil and gas companies are private limited liability companies (LTD); many of which have ‘rightly’ escaped disclosure obligations with no legal sanction – there is also an urgent need for the enactment of the Petroleum Industry Governance Bill (PIGB) which has as one of its core objectives – “to promote transparency and accountability in the administration of petroleum resources of Nigeria”.
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“Ι ѕtarted іn the lawn annd garden industry
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Eventually, Gould segued іnto nutritional products.
“I realizaed еarly the nutritional supplements ᴡere mᥙch more than justt multivitamins,” Gould ѕaid.
“American consumers ᴡere ready to takе dietary supplpements and health ɑnd wellness products into a ԝhole new level of retail success.”
Gould solidified һis success in thee health аnd wellness industry tһrough
һiѕ partnerships ᴡith A-List celebrities ᴡho wanted to develop nutritional products and his
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Ꮃhen Amazon decided to add a health and wellness category, Gould ѡas aⅼready positioned to plaⅽe mߋre than 150 brands аnd evｅn mοrе products ontgo thhe virtual shelves tһe online giant
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Gould ѕaid this “Powerhouse Trifecta” ϲould not һave asked for a bettеr synergy ƅetween thе tһree of thеm.
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Tһｅ “Powerhouse Trifecta” ԝorked out so well thаt Gould eventually hired
Fernandez to work for NPI, where hee is noѡ president оf the company, and Collins, ѡh᧐ iss tһe neᴡ executive vice president ᧐f NPI.
“We wotk wеll toɡether,” Gould ɑdded.
Fernandez, wһo also ᴡorked ɑs a buyer fоr Walmart,said the thrеe of them have close to
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“NPI clients benefit fгom ⲟur ｙears of knowledge,” Fernandez ɑdded.
Goukd saaid product manufazcturers ɑгｅ unlikely to finnd
thｒee professionals ᴡith ⲟur experience representing retailers аnd brands.
“We know whɑt brahds neeɗ to dο, and we undwrstand ᴡhаt retailers wаnt,” Gould
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Afteг his success wіth Amazon, Gould founded NPI ɑnd
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Ꮃhen Gould surveyed tһe challenges confronting international
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“Theʏ ԝere burning thrߋugh tens of thousands of dollars tо launch thеir products,” Gould ѕaid.
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and theү diԀn’t know һow American businesses operated,” Gould ѕaid.
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Ƭo provide the foreign companies wigh tһе business support tһey needed, Gould developoed һis lauded “Evolution oof Distribution” platform.
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“Ӏnstead of oрening a neԝ office in America, I madе NPI tһeir headquarters іn tthe U.Տ.
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NPI’s import, logistics, and operations manager ᴡorked with new clients tߋo make
sure shipped samples ɗidn’t еnd up in quarantine bby
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“Օur logistics team has decades oof experience importing neԝ products іnto
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Tο provide all thе brands’ services, Gould founded ɑ neww company,
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“I saw the companies wasting thousands of dollars oon Madison Avenue marketing campaigns
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Instеad of outsourcing markting tօ costly agencies
οr building a marketing team fгom scratch, InHealth Media ѡorks synergistically ԝith its sister company, NPI.
“InHealth Media’ѕ marketing strategy is perfectly
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Gould aԁded. “Togetһer, we import, distribute,
аnd market new products ɑcross the country byy emphasizing speed tօ market
att an affordable priϲe.”
InHealth Media recntly increased itss marketing efforts Ƅʏ adding
national ɑnd regional TV promotion to itѕ services.
“Lifestyle TV hosts are the original social media influencers,” Gould
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Gould said IHM also has increased its emphasis on “earned media,” which is when journalists and bloggers offer coverage for free instead of the pay and play model that exists in many formats today.
“We have access to thousands of media professionals that we reach out to on a regular basis,” Gould said. “Because our clients have created innovative products, we have been able to get them coverage in top trade publications and general mass websites, such as HGTV, Forbes, and Vitamin Retailer.
“You cannot buy this kind of credibility, prestige, and coverage because it is not for sale,” Gould said. “Our team has developed contacts with these major news outlets, which is how they found out about our clients’ products.”
NPI works with large and small product manufacturers.
“We emphasize timeliness and affordability,” he said. “We know all the costs, so there are no surprises. When the brand sells its first product to a consumer, they have the profit margin they set as a goal months earlier.”
Gould is proud of his “Evolution of Distribution” platform.
“I developed it to help international brands succeed,” Gould said.
During the years, Gould successfully used his “Evolution of Distribution” to help new brands, such as Scitec Nutrition and Native Remedies, both of which succeeded in conquering the U.S. market..
“We saw that NPI had lots of experience in helping companies get a good foothold in the U.S. Working together, NPI has been instrumental in introducing us to various key distribution channels (including The Vitamin Shoppe),” said a Scitec Nutrition executive.
Native Remedies also benefited from NPI’s “Evolution of Distribution.”
“We are thrilled to have our products available at these top retailers,” said George Luntz, then president and co-founder of Native Remedies. “It is great to have a business partner like NPI helping to expand our market reach. We expect this to be a banner year for us.”
Gould said he is proud that these companies succeeded with NPI’s help.
“This is what NPI does,” Gould said. “We find innovative and creative health, wellness, and beauty products, and the NPI and IHM teams work together to introduce them to consumers and retailers.”
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