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”.
Thanks for the auspicious writeup. It in reality was a
amusement account it. Glance complex to far added agreeable from you!
However, how could we keep in touch?
Peculiar article, totally what I needed.
Hi there! I’m at work browsing your blog from my new apple iphone!
Just wanted to say I love reading through your blog and look forward to all your posts!
Carry on the fantastic work!
Simply want to say your article is as astounding. The clearness
in your post is simply cool and i could assume you are an expert on thiks subject.
Fine with your permission allow me to grab yur RSS feed to keep upated
with forthcoming post. Thanks a million and please keep up
the enjoyable work.
My website – How To Manifest Your Dreams Into Reality
Hi, everything is going perfectly here and ofcourse every one is sharing information, that’s genuinely
good, keep up writing.
Howdy! This is kind of off topic but I need some help from an established blog.
Is it very hard to set up your own blog? I’m not very techincal
but I can figure things out pretty quick. I’m thinking about creating my own but I’m not
sure where to start. Do you have any points or suggestions?
Thanks
Hello would you mind stating which blog platform you’re using?
I’m looking to start my own blog soon but I’m having
a tough time deciding between BlogEngine/Wordpress/B2evolution and Drupal.
The reason I ask is because your design seems different then most blogs
and I’m looking for something completely unique.
P.S Sorry for being off-topic but I had to
ask!
I do not know if it’s just me or if perhaps everyone else encountering issues with
your site. It seems like some of the text on your posts are running off the screen. Can someone else please
comment and let me know if this is happening to them too?
This may be a problem with my browser because I’ve had this happen previously.
Appreciate it
Welcom to javslutmom.net Enjoy free JAV porn milf videos, movies on thecollection of lustful
madam with lots of hot sex scenes
You can find sex video japan your most favorite Japan Porn Stars here and enjoy
their performing. With a lot of milf japanese mom same as rin okae, yumi
kazama hagi azusa kano ai tanaka nene…etc…
website that offers every sex fan popular jav amateur, jav Uncensored, jav censored updated daily in HD quality with best jav actrees.
You can watch lots of different Japanese Asian pornand so much hot
milf japanese sexualy is waitting you enjoy
I don’t even understand how I ended up right here, however I assumed this submit
was once great. I don’t know who you might be but certainly you’re going to a famous
blogger if you aren’t already. Cheers!
Also visit my web blog Xn Ob 0bug 00s 4ydqyne 3igqa 332f 7ld
For hottest information you have to go to see world wide web and
on web I found this website as a most excellent website for most up-to-date
updates.
It’s really very complicated in this full of activity life to listen news on Television, thus I only use internet for that purpose, and obtain the most up-to-date
information.
Hello, its pleasant article concerning media
print, we all know media is a impressive source of data.
My brother recommended I might like this blog.
He was entirely right. This post truly made my day. You cann’t imagine simply how much time
I had spent for this information! Thanks!
Fantastic website you have here but I was curious if
you knew of any user discussion forums that cover the same topics discussed in this article?
I’d really love to be a part of online community where
I can get comments from other knowledgeable individuals that share the same interest.
If you have any recommendations, please let me know. Thanks!
Fastidious response in return of this query with real arguments and explaining everything concerning that.
Hello everyone, it’s my first visit at this website, and post is actually fruitful in favor of me, keep up posting
these articles.
Thank you for the good writeup. It in fact was a amusement account it.
Look advanced to far added agreeable from you! However, how can we communicate?
How are you able to throw a Arkham asylum themed social gathering?
A Streaming media participant can be either an integral a
part of a browser, a plug-in, a separate program, or a
devoted device, similar to Apple Tv, Roku Player, iPod, and many others.
Video recordsdata might also include embedded
gamers. Yes, the USSR had many “focus camps” however they
had been mainly pressured labour camps, their was 53 separate
camps and 423 labour colonies. What have been the
names and areas of the Nazi concentration camps and
extermination camps? If by Nazi you might be asking if Geiger
was a member of the National Socialist Party, then Yes he was.
If you are so minded, you can even buy and sell shares, or improve the amount of cash you are diverting from your
checking account every month to purchase new investments.
Pac-Man Defense – The target company turns around and buys a considerable amount
of stock in the buying firm – if you are going to eat me,
I’m going to eat you too. Rather than face Horseshoe Falls in wood or steel because the earlier daredevils had
carried out, Jean Lussier spent his life financial savings ($1,500)
on a large rubber ball that will protect him throughout
the experience and on the rocks below.
Hello! I know this is kinda off topic however , I’d figured I’d ask.
Would you be interested in exchanging links or maybe guest authoring a
blog article or vice-versa? My blog goes over a lot of the same subjects as yours and I
believe we could greatly benefit from each other.
If you happen to be interested feel free to send me an e-mail.
I look forward to hearing from you! Awesome blog by the way!
Does your blog have a contact page? I’m having a
tough time locating it but, I’d like to send you an email.
I’ve got some recommendations for your blog
you might be interested in hearing. Either way, great site and I look forward to seeing it improve over time.
Hello to all, how is everything, I think every one is getting more from this web page, and your views are nice in favor of new viewers.
Thank you for the auspicious writeup. It in fact was a amusement account it.
Look advanced to more added agreeable from you! However, how could we communicate?
Travel Jember
I all the time used to study post in news papers but now as I am a user of
web therefore from now I am using net for articles,
thanks to web.
Stop by my web-site; visisharp
Heya! I’m at work surfing around your blog from my new iphone 3gs!
Just wanted to say I love reading through your blog and look forward to all your posts!
Carry on the superb work!
Terrific article! This is the kind of information that
are supposed to be shared across the internet.
Disgrace on the search engines for now not positioning this put up upper!
Come on over and seek advice from my website .
Thanks =)Travel Jember
بهترین مارک تشک ایرانی لایکو و بهترین
مارک تشک ایرانی 12 نفره و بهترین مارک تشک ایرانی مناسب و بهترین مارک تشک ایرانی ژل شستشوی صورت
Successful consumers can have full license
of the works. People who’ve been promoting their artworks for
200 (U.S.) dollars simply get up and see their works sold
for 40,000 dollars,” Yusuf, 24, told Reuters at his house studio. “NFTs are now bringing formidable alternatives to these artists to commercialize their work, secure
their work on the blockchain, attach sensible contracts to their
work, which govern the best way the work is sold and resold,” Peterside instructed Reuters. “There are life-changing alternatives on the NFT platforms.
Aforesaid are some motive which a main member might confront whereas accessing prime
amazon membership. You may get Amazon Prime Membership free preliminary for
multi month. Later you need to pay for the membership.
Most Prime members pay for the 12 months up front. On the off probability that you have purchased into prime with out a
preliminary, you can get a discount. Or, catch a novel movie at Austin’s own Alamo Drafthouse Theater (409 Colorado at 4th St), the place you can try a enjoyable
flick and order one thing to eat and drink whereas you are watching it from Alamo’s fun movie-themed full menu.
This problem may run over any nice shopper of amazon while making
an acquisition of an merchandise whether on the amazon site or
amazon shopping utility.
سرویس خواب عروس ضرر دارد و جدیدترین مدل سرویس خواب دخترانه جوان و عکس سرویس خواب
فانتزی عروس و تخت خواب امپراطور چیکو و تخت خواب دخترانه صورتی شیک و تولید کننده سرویس خواب در تهران نوزاد و قیمت تخت خواب
کشودار
Hey There. I found your weblog using msn. That is an extremely
well written article. I will be sure to bookmark it and return to
read extra of your helpful information. Thank you for the post.
I will certainly return.
Hurrah, that’s what I was seeking for, what a stuff! present here at this web site, thanks admin of this
web page.
Wonderful goods from you, man. I’ve understand your stuff previous to and
you’re just too magnificent. I really like what
you have acquired here, really like what you’re stating and the way in which you say it.
You make it enjoyable and you still take care of to keep it sensible.
I can not wait to read much more from you.
This is really a terrific web site. vape pens china (http://www.szgreenvape.com) pens vendor
It’s a pity you don’t have a donate button! I’d without a doubt donate to this outstanding blog!
I guess for now i’ll settle for book-marking and adding your RSS
feed to my Google account. I look forward to fresh updates and will share
this website with my Facebook group. Talk soon!
Hey there, I think your website might be having browser
compatibility issues.
When I look at your blog site in Chrome, it looks fine but
when opening in Internet Explorer, it has some overlapping.
I just wanted to give you a quick heads up! Other
then that, superb blog!
Wow, wonderful blog layout! How long have you been blogging for?
you make blohging look easy. The overall look of
your website iss fantastic, lett alkone the content!
my page How To Manifest Into Reality
If you are going for most excellent contents like I do, just go to see
this web page every day as it presents feature contents,
thanks
Greetings from Ohio! I’m bored to death at work so I decided to check out
your site on my iphone during lunch break. I enjoy the info you present here and
can’t wait to take a look when I get home. I’m amazed at how fast your blog
loaded on my phone .. I’m not even using WIFI, just 3G
.. Anyways, great site!
I’m curious to find out what blog system you
happen to be working with?
I’m having some minor security problems with my latest blog and
I’d like to find something more
risk-free. Do you have any solutions?
This is a great tip especially to those new to the blogosphere.
Simple but very accurate info… Many thanks for sharing
this one. A must read article!
I’m not that much of a online reader to be honest but your sites really nice,
keep it up! I’ll go ahead and bookmark your website to come back down the road.
Cheers
It’s a shame you don’t have a donate button! I’d definitely donate to this fantastic blog!
I guess for now i’ll settle for book-marking
and adding your RSS feed to my Google account.
I look forward to brand new updates and will share this site with my Facebook group.
Chat soon!
I got this web page from my friend who informed me about this web site and now this
time I am browsing this website and reading very informative posts
at this place.
What’s up, I want to subscribe for this website to take most recent updates, so where
can i do it please help out.
I didn’t know that.
Hi there, I discovered your blog by means of Google while searching for a similar subject,
your site came up, it appears great. I’ve bookmarked it in my
google bookmarks.
Hi there, just became alert to your weblog via Google, and
found that it’s truly informative. I am gonna be careful for brussels.
I will be grateful if you happen to proceed this in future.
A lot of folks will be benefited from your writing.
Cheers!
Useful info. Lucky me I discovered your site by accident, and I
am stunned why this twist of fate didn’t came about in advance!
I bookmarked it.
Ӏ really like reading tһrough a post that ⅽan maкe people think.
Also, tһank you f᧐r permitting mee to cߋmment!
my blog; sοϲіаⅼ meɗiɑ maｒкеtіng,
I always used to study article in news papers but now as I am a user of net so from now I am using net for articles, thanks to
web.
► Sekabet giriş – çevrimiçi bahis için büyük bir markadır ve tüm Türkiye de çok güvenilir olarak bilinir.
Mevcut ürünlerin kalitesi olağanüstü olduğu için büyük itibarı sebepsiz değildir.
İlki, büyük sporlar ve ligler için harika bir kapsama sahip olan oyun içi bahis bölümüyle birlikte çevrimiçi spor bahis
sitesidir.
Sekabet Için Giriş Yap
sekabet anasayfa
● Bir de dünyanın en büyük yazılım geliştiricilerinden seçtiği slot oyunlarıyla öne çıkan çevrimiçi
casino var.
● Sekabet poker odası da Microgaming Network’te olduğu ve çok fazla trafik
aldığı için fena değil. Ve son olarak, sanallar heyecan verici oyunlarla bahis hareketini her zaman canlı tutar.
● Sekabet.com’a hızlı bir bakış, web sitesinin mevcut çok
sayıda bahis seçeneğini ele almak için güzel bir şekilde
düzenlendiğini gösterir.
● Genel stil genellikle ürünlerden birinden, genellikle yeni bir çevrimiçi slot oyunundan ilham alır,
ancak oldukça ince kalır.
● Web sitesi farklı dillerde mevcut olduğundan, dünyanın farklı yerlerinden oyuncular katılmaya davetlidir.
Contents hide
1 ▼ Sekabet giriş ve kayıt:
2 ▼ Sekabet giriş bilgileri:
3 ▼ Sekabet giriş ve lisans:
4 ▼ Sekabet giriş yazılım ve oyun çeşitleri:
5 ▼ Sekabet giriş ve mobil uygulama:
6 ▼ Sekabet giriş ve güvenlik:
7 ▼ Sekabet giriş ve bonuslar:
8 ▼ Sekabet giriş de sadakat programı:
8.1 ۞Aşamalı Jackpotlar
9 ▼ Sekabet müşteri hizmeti:
10 Sonuç olarak:
▼ Sekabet giriş ve kayıt:
► Sekabet bahis sitesine kayıt olmak ve bir hesap oluşturmak çok basittir.
Sekabet’e giriş ve sağlanan olanak ve hizmetlerden yararlanmak için kayıt sürecini dikkatli bir şekilde geçirmeniz gerekir.
● Kullanıcı önce Sekabet’e giriş yapmalı ve ardından sayfanın sağ
köşesinde yer alan kayıt seçeneğine tıklamalıdır.
Site giriş yöntemleri farklıdır ve siz Google de adresini arayarak
veya sosyal medya hesaplarından Sekabet’in güncel giriş adresine ulaşma imkânınız var.
Sekabet Giriş için Tıklayın! [Doğru, Güncel Adres]
● Tıkladıktan sonra kayıt sayfasına girer. Bu bölümde ad ve soyad, doğum tarihi,
ülke adı, şehir, adres, e-posta, cep telefonu numarası gibi bilgiler istenmektedir.
Kullanıcı, tüm alanlara bilgileri doğru girmelidir.
On sekiz yaşından küçük kişilerin bu siteye kaydı yasaktır.
● Sekabet sitesine kayıt olmak için diğer bahis sitelerine göre
daha basit bir süreçten geçeceksiniz, sayfanın üst kısmındaki kayıt ol butonuna tıklayarak kayıt formunu sizin için açabilirsiniz.
● Sekabet bahis sitesindeki kayıt formu diğer
tahmin sitelerinden farklıdır, ilk sayfada e-posta ve şifre bilgileriniz, ardından ikinci sayfada telefon numarası, ulusal kod vb.
bilgiler size sorulacaktır. Sekabet giriş sizin 5 dakikanızı alır
ve sizi hiç yormaz.
Once once more, the buyer would pay a price based on how
a lot computing energy it used. Include as much information as potential about the
shopper who’s providing the testimonial. After filing for bankruptcy, the court docket will determine
an acceptable trustee who will take over the affairs of the enterprise.
When filing a bankruptcy petition, the court will expect the filer to
submit a detailed plan on how they intend to repay their debts.
Through debt reorganization, businesses can simply pay off their debts and have the
unpaid amount written off in a authorized manner. A chapter 11 Monterey business homeowners ought to know, gives businesses with a debt reorganization possibility.
Depending on the value and businesses you handle, this might only
cause to exceed the web value requirements inflicting your certification to be delayed
or denied. You’ll do that using Google safety technologies
aligned to safety greatest practices and industry necessities.