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”.
Hi there every one, here every one is sharing these kinds
of knowledge, so it’s pleasant to read this webpage, and I used to pay a quick visit
this weblog daily.
Hello there I am so thrilled I found your blog
page, I really found you by mistake, while I was looking
on Yahoo for something else, Anyways I am here now and would just like to say kudos for a tremendous post and a all
round thrilling blog (I also love the theme/design),
I don’t have time to read through it all at the moment but I have bookmarked it and also
added in your RSS feeds, so when I have time I will be back to read a lot more,
Please do keep up the excellent work.
I blog quite often and I seriously appreciate your content.
The article has truly peaked my interest. I will book mark your site and keep checking for new details about once a week.
I subscribed to your Feed as well.
Know Аbout Lip Eczema аnd Hоw to Sootthe Ιt
Ꮋere iss my homepage – 3 Ways CBD Can Help Your Pet
you’re truly a excellent webmaster. The website loading speed
is amazing. It kind of feels that you’re doing any distinctive
trick. Furthermore, The contents are masterwork.
you have done a fantastic activity in this topic!
Hi there, і rеad youг blog from time to time and i own a
similаr оne and i ᴡas just curious іf ｙоu get a ⅼot
of spam remarks? Ӏf ѕo hօw ԁο ｙou ѕtop it, any plugin orr anythіng yoս can recommend?
I get so much latｅly it’ѕ driving mе mad sߋ
any hеlp iss verｙ mᥙch appreciated.
Ꮋere іѕ my webpage: htpps://smmpanelkings.ｃom (http://moval-library.org/__Media__/js/netsoltrademark.php?d=htpps%3a%2f%2fsmmpanelkings.com)
Good day! I could have sworn I’ve visited thos site before but after looking at some
of thhe pksts I realized it’s new to me. Anyhow, I’m definitely happy I stumbled upon it aand I’ll be book-marking it
and checkling back regularly!
Here is my homepage … Midas Manifestation sound frequencies
7star hd movies
#VernonWells
Thank you for any other informative web site. Where else
may just I am getting that type of info written in such an ideal manner?
I have a venture that I’m simply now running on, and I’ve
been on the glance out for such info.
What’s up to every one, the contents present at this web page are genuinely amazing
for people knowledge, well, keep up the good work fellows.
Appreciation to my father who told me about this website, this website is actually amazing.
My web-site :: เครื่องย่อยเศษอาหาร
It’s truly very complex in this full of activity life to listen news on TV, therefore I just use web for that reason, and get the latest information.
Just wish to say your article is as amazing. The clarity
in your post is simply great and i could assume you are an expert on this subject.
Fine with your permission allow me to grab your feed to keep updated with forthcoming post.
Thanks a million and please continue the gratifying work.
Hi there, everything is going sound here and ofcourse every one is sharing
facts, that’s really excellent, keep up writing.
[url=https://avodart.digital/]generic for avodart[/url] [url=https://ciprotabs.online/]ciprofloxacin online[/url] [url=https://diclofenac.digital/]voltaren gel uk[/url] [url=https://suhagra.directory/]suhagra 50 mg tablet online purchase[/url] [url=https://buyaugmentin.digital/]amoxicillin capsules 500mg price in india[/url]
A person necessarily lend a hand to make significantly posts I might state.
This is the very first time I frequented your web page and up to now?
I surprised with the analysis you made to create this actual put up incredible.
Excellent process!
I every time spent my half an hour to read this web site’s posts daily along with a mug of coffee.
Hi, everything is going well here and ofcourse every one is sharing
facts, that’s in fact fine, keep up writing.
Thank you so much for the help!!! I am having lots of
fun playing with all the GraphicMama puppets.
If some oone wishes to bbe updated with latest technologies afterward hee must be pay a quick visit this site and bee up to date
everyday.
webpage
You not only will experience his wonderful intelpect and massive information of movie history, however his unimaginable humility as nicely.
14. Roxxy Palace September Spins Tournament – twejty
fifth August 2013 to twenty fifth September with a $100
prize. The next situs judi now affords signup rewaards to each one of many
ultra-trendy avid gamers on this web site considering
that just one comes up with any issue on this website on the subject of wgering then you
possibly can certainly very simply email or call your internet
service providers on this internet page.
Excellent article. I am facing a few of these issues as well..
hi!,I love your writing very a lot! share we keep
up a correspondence more about your post on AOL?
I need an expert in this area to resolve my problem. Maybe
that is you! Looking ahead to peer you.
My blog; 먹튀검증
Hello! I’m at work surfing around your blog from my new iphone 3gs!
Just wanted to say I love reading your blog and look forward to
all your posts! Carry on the great work!
If you wish for to take a great deal from this post then you have to apply such
techniques to your won website.
H᧐w Is CBD Beneficial For Athletic Performance? Helps Үou to Fight with Spring Allergies?
Good day! Iknow this is somewhat off topic but I was wondering if
you knew where I could find a captcha plugin for my comment
form? I’m using the same blog platform as yours and I’m having difficulty finding one?
Thanks a lot!
My web blog: free printable weekly calendar september
WOW just what I was looking for. Came here by searching for
Savannah Airport Shuttle to Okatie
It’s actually a nice and helpful piece of info. I am satisfied that
you simply shared this useful information with us.
Please stay us up to date like this. Thank you for sharing.
free fire top up
free fire diamond top up
free fire top up 5 rupees
free fire top up centre
free fire top up centre 100 bonus
free fire diamond top up hack
free fire top up bonus
free fire top up center
free fire top up 10 rupees
free fire top up 10 rs
free fire top up redeem code
free fire top up india
free fire top up app
free fire top up free
redeem code for free fire top up
free fire top up site
free fire top up pakistan
free fire top up website
free fire top up diamond
free fire top up codashop
free fire top up link
free fire top up discount
free fire top up bonus website
free fire top up free redeem code
free fire top up paytm
free fire top up games kharido
free fire top up 5 rupees 100 diamonds
free fire top up offer
free fire top up 10 rupees 100 diamonds
free fire top up event
free fire top up 20 rupees
how to top up in free fire without money
free fire top up 40 rupees
free fire top up double diamond
free fire top up 40 rs
free fire top up list
free fire top up credit card
free fire top up online
free fire top up image
free fire top up app download
free fire top up center easypaisa
how to topup in free fire in pakistan
highest top up in free fire
free fire top up garena
how to free fire top up
free fire top up in free
free fire top up recharge
online free fire max top up
gamekharido.in free fire top up
free fire top up with redeem code
free fire top up 50 diamonds
free fire top up google pay
free fire top up 2020
free fire top up apk
free fire top up discount website
free fire top up 100 bonus diamond
free fire top up video
free fire top up free app
online free fire top up
free fire top up game
free fire top up with mobile balance
free fire top up kyu nahi ho raha hai
how to get free topup in free fire
free fire top up 1 diamonds
free fire top up low price
free fire top up sim card
free fire top up bank account
free fire top up airdrop
free fire top up google play
free fire top up refund
free fire top up debit card
free fire top up kota shop
free fire top up 29 rupees
free fire top up 30 rupees
free fire top up apk download
free fire top up app india
free fire top up system
free fire top up p
free fire top up rate
free fire top up dotkom
free fire top up kaise karte hain
free fire top up monthly membership
free fire 800 diamond top up
free fire top up rupees
free fire top up hack apk
free fire top up kaise kare
free fire top up indonesia
free fire top up with jazzcash
free fire top up 50 rupees
free fire top up karna
how to check free fire top up history
free fire top up balance
free fire top up membership
free fire top up sim
free fire top up atm card
free fire top up google
free fire top up tamil
free fire top up 500 diamonds
free fire top up by easypaisa
free fire joseph top up
free fire top up weekly membership
free fire top up 200 bonus
free fire top up 2021
free fire top up 10
free fire top up offer today
free fire top up official
top up free fire xl
free fire top up number
free fire top up sale
how to free fire top up recharge
free fire top up new
free fire top up 80 rupees
free fire top up vpn
free fire top up pakistan easypaisa
game zone free fire top up
free fire top up using google play
free fire top up google play balance
free fire top up 200 diamonds
free fire top up option
free fire top up upi
how to make free fire top up
free fire top up history
is free fire top up safe
cara top up free fire yang murah
free fire top up today
codashop in free fire top up
free fire top up level up
free fire 600 diamond top up
free fire top up uid
free fire top up pakistan telenor
app for free fire top up
free fire top up daraz
free fire top up 100 diamonds
free fire top up level up pass
paytm to free fire top up
free fire top up 50 rupees 150 diamond
free fire top up easypaisa
free fire top up download
free fire top up vodafone billing
free fire top up from google play
free fire top up vodafone sim
free fire top up rs 10
free fire top up account
free fire top up vodafone
free fire top up jio sim
free fire top up top up
what is free fire top up
how to do free fire top up from paytm
free fire top up brazil
free fire top up 400 rupees
free fire 80 diamond top up
how free fire diamond top up
free fire top up easy
how free fire top up
free fire top up name
in free fire top up
free fire top up bangladesh
free fire top up paypal
free fire top up mod apk
free fire top up king
free fire top up 50
free fire top up visa card
free fire top up sasta
free fire top up load
top up free fire yang murah
free fire top up from esewa
how do free fire top up
free fire 3x topup center
free fire top up emote
how to get free fire top up
free fire top up north america
free fire top up house
top up free fire 3000
free fire top up nigeria
free fire top up online india
free fire top up online paytm
free fire top up center jazz cash
free fire top up how to do
how to top up in free fire with easypaisa
free fire diamond top up quora
free fire top up up
how to top up free fire in free
zz top up free fire
top up free fire pulsa xl
top up free fire diskon 99
free fire top up 2022
free fire diamond top up jazz cash
free fire top up voucher
free fire top up 200 rupees
free fire top up jazz cash
free fire top up nepal
free fire top up 90 discount
free fire top up karne ka tarika
free fire top up how
free fire top up 30
free fire top up midasbuy
top up free fire diskon 90
free fire top up not working
free fire top up my
free fire top up website pakistan
free fire top up glitch
free fire top up telenor
free fire top up pk app
top up free fire pulsa 3
free fire top up kaise kiya jata hai
free fire top up in pakistan
free fire top up 400
top up free fire 70 diamond
free fire top up zone
paypal to free fire top up
free fire top up ru
free fire top up with zong
zsda free fire top up
free fire top up jazz billing
free fire double diamond top up 40 rupees
free fire top up russia
free fire 300 diamond top up bd
free fire top up by jazz cash
free fire top up uae
free fire top up jazz balance
top up diamonds free fire cashback 90
free fire top up pakistan jazz
free fire top up 50 off
free fire top up through jazz cash
free fire top up zone bd
top up diamonds free fire 3000
free fire top up 10 rs india
free fire top up bonus pakistan
free fire top up login
top up free fire yang paling murah
free fire top up 40 rupees redeem code
top up free fire my xl
free fire top up zong billing
free fire top up elite pass
free fire top up ufone
free fire top up easypaisa account
free fire top up thailand
free fire top up from jazz cash
free fire top up xyz
free fire top up in pk
free fire top up through easypaisa
free fire top up max
free fire top up website pk
top up free fire 70 diamond 10000
free fire top up 60 rupees
free fire top up pakistan zong
tempat top up free fire yang paling murah
codashop for free fire top up
free fire top up service
free fire top up free pakistan
free fire top up my telenor
free fire top up my zong
free fire top up center yusufpur dighi khurd bihar
free fire top up hutch
qiwi free fire top up
free fire top up qatar
free fire top up umobile
cara top up free fire pulsa xl
free fire top up on easypaisa
free fire top up youtube
free fire top up link easypaisa
top up free fire di my xl
top up diamond free fire yang murah
free fire top up trinidad
free fire top up kpk
why free fire top up is not working
free fire top up nagad
free fire top up easypaisa pk
free fire top up free apk
free fire top up error
free fire top up zong
top up zone free fire garena
free fire top up in pakistan telenor
free fire top up 40 rupees paytm
top up diamonds free fire diskon 90 percent
top up free fire 70 dm
codashop free fire top up 40 rupees
free fire top up vpn india
free fire top up center zong
free fire top up uk
top up free fire yang termurah
code for free fire top up
free fire top up 30 rupees redeem code
free fire top up in jazz cash
penis enlargement
I am really thankful to the holder of this web site
who has shared this wonderful article at at this place.
Vulvodynia & CBD
Ꭺlso visit mу wweb page: Broad Spectrum CBD: Find The Right Method For You
Hey there, I think your blog might be having browser compatibility issues.
When I look at your website in Ie, 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!
Asking questions are genuinely pleasant thing if you
are not understanding anything completely, but this post presents pleasant
understanding even.
We’re a group of volunteers and opening a new scheme
in our community. Your web site provided us with valuable information to work on. You’ve done a formidable job and our whole community will be grateful to you.
Today, while I was at work, my cousin stole my apple ipad and tested to see if it can survive a forty foot drop, just so she can be a youtube sensation. My iPad is now destroyed
and she has 83 views. I know this is entirely off topic but I had to share it with someone!
Why Is Protein Bar CBD Ꮐetting Ꮇore Popular
My site – Thought Leaders In Food & Ag Speaker Series | Grow North
I really love your blog.. Very nice colors & theme. Did you make this
site yourself? Please reply back as I’m wanting to
create my own blog and would love to learn where you got this from or exactly what
the theme is named. Thanks!
Excellent article! We will be linking to this
great content on our website. Keep up the good writing.
Having read this I thought it was really informative.
I appreciate you finding the time and effort to
put this article together. I once again find myself personally spending a lot of time both
reading and leaving comments. But so what,
it was still worthwhile!
When I originally commented I clicked the “Notify me when new comments are added” checkbox and now each time
a comment is added I get four emails with the same comment.
Is there any way you can remove people from that
service? Thanks a lot!
hi!,I like your writing very much! proportion we communicate more approximately your post on AOL?
I require a specialist on this space to resolve my problem.
May be that is you! Looking forward to see you.
What i don’t understood is in truth how you are now not really much more
well-preferred than you might be now. You are very intelligent.
You understand therefore considerably in the case
of this topic, produced me for my part believe it
from a lot of various angles. Its like women and men aren’t involved unless it’s something
to do with Woman gaga! Your personal stuffs nice. Always care
for it up!
I am really happy to read this blog posts which consists of lots of valuable
information, thanks for providing such data.
I appreciate, lead to I found exactly what
I used to be taking a look for. You’ve ended my four day long hunt!
God Bless you man. Have a great day. Bye
It’s really a great and helpful piece of info.
I am happy that you shared this helpful info with us.
Please keep us informed like this. Thanks for sharing.
Thanks in favor of sharing such a good thinking, paragraph is pleasant,
thats why i have read it entirely
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 post or vice-versa?
My blog covers a lot of the same topics as yours and I
think we could greatly benefit from each other. If you might be interested feel free to send me an email.
I look forward to hearing from you! Great blog
by the way!
all the time i used to read smaller content that also clear
their motive, and that is also happening with this article which I am reading at this time.