Report Of Investigation By Anti-Corruption Network On Kogi State And Governor Yahaya Bello

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The Anti-Corruption Network is a registered Non-governmental, Non- religious, Non-political, Non-profit oriented organization. It is set up to fight all forms of corruption in Nigeria through enlightenment campaigns, educational materials, exposition of crime and corrupt activities of persons, groups, government, etc.
The Anti-Corruption Network has so far served as the voice of the voiceless and masses who are suffering the negative concomitant effects of corruption. We make bold to say that before the establishment of this Network, there was virtually no group or non- governmental organization with the passion, zeal and sincerity of purpose to confront corruption practices in Nigeria. The Network frontally investigates, exposes and informs Nigerians on all forms of corrupt practices in Nigeria, by Nigerians for Nigerians.
In line with the Anti-Corruption Network mission statement which is to build a Nigeria Society with zero tolerance for corruption, re-establish moral philosophy, transparency, accountability, integrity and respect for human dignity in order to attain good governance and social justice, the Anti-Corruption Network has painstaking uncovered huge financial fraud carried out by the Governor of Kogi and his cohorts.
Anti-Corruption Network discovered the following fraudulent/corrupt practices in the Kogi State Government expenditures for 2016, 2017, 2018 and 2019 ranging from award of contracts to non-legal persons, award of contracts without due process, circumvention of procurement procedures, suspicious payments made without specific breakdown, money laundering, borrowing from non-capital market, fraudulent loan, award of contracts to companies with vested interests, payment without transaction description, award of contracts to non-existing companies and many others.
FRAUDULENT/CORRUPT PRACTICES IN THE KOGI STATE GOVERNMENT EXPENDITURE FOR 2016
AWARD OF CONTRACTS TO NON-LEGAL PERSONS
1. Anti-Corruption Network discovered that OVIDI COMMUNICATION LTD received N50,000,000 (Fifty Million Naira) from Kogi State Govt House Admin Zenith Bank account number 1010662710 into its GTB account number 124217682 on 6/10/2016.
Further scrutiny on the Corporate Affairs Commissions website shows that the company is inactive hence ineligible to be awarded contracts. Therefore, the award of a contract/payment of N50,000,000 (Fifty Million Naira) to the company on 6/10/2016 contravenes Part IV Section 16(6) of the Public Procurement Act 2007 which requires that companies eligible for contract award should possess the necessary professional and technical qualifications, financial capability, equipment and other relevant infrastructure etc’.
IRREGULARITIES IN CONTRACT AWARD
2. BESPOQUE BUSINESS SOLUTION LIMITED with Registration Number 1002615 and registered address at PLOT NO.8925 New GRA, Makurdi, Benue. The company was incorporated in MAKURDI, Nigeria on 22nd December 2011 and it is owed by Kuma Augustine Kwaghtse, a traditional ruler in Ushongo.
The company received a total of N74,378,483.20 (Seventy Four Million, Three Hundred and Seventy Eight Thousand, Four Hundred and Eighty Three Naira, Twenty Kobo) in 2016 from the Kogi State Internal Revenue Service Zenith Bank account Number 1014856973.
The Anti-Corruption Network investigation in respect of this transaction revealed the following:
a. It was found that there was no transaction description for the money paid to the company’s account contrary to the provisions of the law with a possible conflict of interest in its award. Public procurement law that encourages competitive bidding and advertisement in two national dallies was breached, thus: Section 24 (1) public procurement Act 2007 states that “Except as provided by this Act, all procurement of goods and services by all entities shall be conducted by open competitive bidding”.
Similarly, Financial Regulations 2921 (i) states that “Except as exempted under the procurement Act, all procurement of goods, works and services shall be by way of open competitive bidding by which is meant that all contractor/ supplies shall be subject to the same level playing ground…”
AWARD OF CONTRACT TO COMPANY WITH VESTED INTEREST
3. ROT-SHADE GLOBAL RESOURCES LIMITED with RC No. 472938 was incorporated in Lokoja, Nigeria on 18 Feb 2003 with Company’s registered office address as No 2, Okene/Kabba Road, Lokongoma Phase I, Lokoja, Kogi. The company is owned by Rotimi Bolufemi who is the man Friday of the current Deputy Governor, Edward Onoja, right from his days as Chief of Staff. He does most of the jobs as a front for Onoja alongside Geeony Kleeners and Aminu Jioh (Jimoh-Fancy Movement), they run errands for the Government.

Rotimi is described as an inner caucus member of the New Direction Agenda, as the Yahaya Bello government is called. He also runs a foundation called Rot-Shade Helplink Initiative (RHI). Our Organisation, Anti-Corruption Network also discovered that Rotimi Bolufemi is an APC chieftain.
Rot-Shade Global Resources Limited received a total of
N266,625,000 (Two Hundred and Sixty-Six Million, Six Hundred and Twenty-Five Thousand Naira) sent from Access Bank account number 703377205 belonging to the Kogi State Joint Account Allocation Committee (Statutory Revenue Account).
Anti-Corruption Network investigation revealed that the company received the said sum in trenches of N88,875,000 (Eighty-Eight Million, Eight Hundred and Seventy-Five Thousand Naira) six times on 5/31/2016 totaling N533,250,000 (Five Hundred and Thirty-Three Million, Two Hundred and Fifty Thousand Naira) twice on 10/4/2016, 30/11/2016, 30/12/2016, 10/31/2016 and finally on 12/13/2016 it received N126,000,000 (One Hundred and Twenty Six Million Naira), all totaling N533,250,00 (Five Hundred and Thirty-Three Million, Two Hundred and Fifty Thousand Naira).
The Anti-Corruption Network investigation in respect of this transaction revealed that:
a. The funds paid to the company in the guise of contract award may have been diverted as there was no description of its intended use or purpose.
4. Anti-Corruption Network discovered that payment was made on 12/6/2016 from the Kogi State Government House Admin Zenith bank Account 1010662710 to persons whose business with the State Government could not be confirmed. The persons include: Simon
Ojochide Achuba, the former Deputy Governor of Kogi state who received N12,133,794.00 (Twelve Million One Hundred and Thirty- Three Thousand, Seven Hundred and Ninety-Four Naira); Abdulraheem Abubakar Danagana received N21,016,960.00 (Twenty- One Milion, Sixteen Thousand, Nine Hundred and Sixty Naira); Umar Mohammed Angulu received N19,854,462.00 (Nineteen Million, Eight Hundred and Fifty-Four Thousand, Four Hundred and Sixty- Two Naira); while Suleiman A. Usman received N10,754,462 (Ten Million, Seven Hundred and Fifty-Four Thousand, Four Hundred and Sixty-Two Naira). Checks show that the payments made on a single day amounting to N63,759,678 (Sixty Three Million, Seven Hundred and Fifty-Nine Thousand, Six hundred and Seventy-Eight Naira) for undisclosed purpose did not contain any breakdown of costs.
Adequate supporting descriptions were not made available to prove if the payment were genuine and valid charges on the public purse. This is a failure of Gov. Yahaya Bello to ensure that appropriate payment documentation and due process is complied with before payments.
The Anti-Corruption Network investigation in respect of this transaction revealed that:
a. There was no appropriate payment documentation and due process before payments. This is contrary to Financial Regulation 603 which states “All vouchers shall contain full particulars of each service such as dates, numbers, quantities, distances and rates…. and will invariably be supported by relevant documents such as LPOs, invoices, special letters of authority, time sheets, rates etc.”.
Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 of 9th April, 2013 state that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
CIRCUMVENTION OF PROCUREMENT PROCEDURES/SUSPECTED MONEY LAUNDERING
5. Anti-Corruption Network discovered that ABDULSALAMI HUDU received cheque payments following orders from Governor Yahaya Bello up to the sum of N3,790,000,000 (Three Billion, Seven Hundred and Ninety Million Naira) the Kogi State Government House Administration (Operation) with Access Bank account Number 0793190623 and Kogi State Government House Admin Zenith Bank Account Number 1010662710.
Anti-Corruption Network also discovered that most of the cheques were made in tranches of N10,000,000 (Ten Million Naira). On the 24/10/16 Abdulsalami Hudu cashed a check of N10,000,000 (Ten Million Naira) 15 times. On 30/11/16 he cashed a cheque of N10,000,000 (Ten Million Naira) 26 times. On 21/12/16 Abdulsalami Hudu cashed N10,000,000 (Ten Million Naira) 33 times, two days later on 23/12/16 he cashed same amount 30 times with other payments on other days in 2016 between 4 to 10 times in a day with no specified description for the purpose of the funds.
Anti-Corruption Network suspects that Abdulsalami Hudu is a Cash cow and Chief money launderer to Governor Yahaya Bello as he also runs a company Messer Ojubape Limited; a private company limited by shares with RC No. 1087036 which majors in Petroleum products sales and distribution, incorporated on 21st December 2012, under a registered office address at Plot 50, Phase II, Housing Estate Lokoja, Kogi. This violates Section 2(a) which also bars a public officer from engaging or participating in the running of any private business, profession, or trade.”
The Anti-Corruption Network investigation in respect of this transaction revealed that:
a. There was no specified description for the purpose of the funds. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”. Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasize that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
6. Anti-Corruption Network discovered that UMAR COMFORT OLUFUNKE received cheques following orders from Governor Yahaya Bello up to the sum of N749,000,000 (Seven Hundred and Forty-Nine Million Naira) from the Kogi State Govt. House Admin Zenith Bank Account Number 1010662710.
Anti-Corruption Network also discovered that most of the payments were made in tranches of N10,000,000 (Ten Million Naira). On the 11/10 /16 Umar Comfort cashed N10,000,000 (Ten Million Naira) 5 times. On 2/11/16 and 3/11/16 she cashed N10,000,000 (Ten Million Naira) 8 times respectively. On 23/12/16 Umar Comfort cashed N10,000,000 (Ten Million Naira) 30 times totaling N300,000,000 (Three Hundred Million Naira) , six days later, on 29/12/16 she cashed same amount 10 times in a day totaling N100,000,000 (One Hundred Million Naira) with no specified description for the purpose of the funds.
Despite the likelihood of being a public servant under the employment of the Kogi state government, Anti-Corruption Network suspects that Umar Comfort is a Cash cow and Chief money launderer to Governor Yahaya Bello.
The Anti-Corruption Network investigation in respect of this transaction revealed that:
a. There was no specified description for the purpose of the funds. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”. Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
FRAUDULENT/CORRUPT PRACTICES IN THE KOGI STATE GOVERNMENT EXPENDITURE FOR 2017
AWARD OF CONTRACT WITHOUT DUE PROCESS
7. Section 24 (1) public procurement Act 2007 states that “Except as provided by this Act, all procurement of goods and services by all entities shall be conducted by open competitive bidding”.
Similarly, financial regulation 292(I) states “Except as exempted under the procurement act, all procurement of goods, works and services shall be by way of open competitive bidding by which is meant that all contractors/suppliers shall be subjected to the same level playing ground. The format for submission of bids, the deadline for submission and the pre-determined criteria for evaluation shall not vary from one contractor/supplier to the other; they shall be same”.
Anti- Corruption Network discovered that the following companies received various amounts in contracts without adherence to Section 24(1) of the Public Procurement Act 2007 financial regulation 292(I).
i. SOUTHBRIDGE INTEGRATED SERVICES LIMITED received a total of N624, 000,000 (Six Hundred and Twenty Four Million Naira) contract payment in 2017 from the Kogi State IGR Lead Access bank account number 704856897.
ii. ROT-SHADE GLOBAL RESOURCES LIMITED received a total of N711, 000,000 (Seven Hundred and Eleven Million Naira) contract payment in 2017 from the Kogi State Joint Account Allocation Committee (Statutory revenue account) without open bidding and advertisement in at least two national dallies.
iii. PRIMETAX CONSULTING received a total of N129, 491,000 (One Hundred and Twenty Nine Million, Four Hundred and Ninety One Thousand Naira) contract payment from Kogi State Internal Revenue Service (operations account) First Bank account number 2031924290 without open bidding and advertisement in at least two national dallies.
iv. MESSOS SATIMAIHA NIGERIA LIMITED received a total of N51, 156,740 (Fifty One Million, One Hundred and Fifty Six Thousand, and Seven Hundred and Forty Naira) contract payment from Kogi State Statutory Revenue Zenith Bank account number 1014558813 without open bidding and advertisement in at least two national dallies.
v. AMIRCO UNIVERSAL CONCEPT received a total of N45, 000,000 (Forty Five Million Naira) contract payment from Kogi State Statutory Revenue Zenith Bank account number 1014558813 without open bidding and advertisement in at least two national dallies.
vi. MO-TEX ENGINEERING received a total of N22,500,000 (Twenty Two Million, Five Hundred Thousand Naira) contract payment from Kogi State Statutory Revenue Zenith Bank account number 1014558813 without open bidding and advertisement in at least two national dallies.
vii. MAMSONS CONSTRUCTION COY LIMITED received a total of N94,500,000 (Ninety Four Million, Five Hundred Thousand Naira) contract payment from Kogi State MANR CBN CACS PROG Zenith Bank account number 1014783341 without open bidding and advertisement in at least two national dallies.
BORROWING FROM NON-CAPITAL MARKET
8. SYCAMORE CONSULTING LIMITED was incorporated to carry on taxation, accounting and financial advisory services ONLY. Anti- Corruption Network discovered that Sycamore Consulting Limited loaned KogI State Government a total of N3,900,000,000 ( Three Billion, Nine Hundred Thousand Naira) in batches of N1,000,000,000 (One Billion Naira) with the last batch as N1,900,000,000 ( One Billion, Nine Hundred Thousand Naira ) on the 23rd June, 2017 paid into the Kogi State IGR DSRA Access Bank Account.
Anti-Corruption Network also discovered that Sycamore Consulting Limited loaned Kogi State Government N11,905,000,000 (Eleven Billion, Nine Hundred and Five Million Naira) on 30th June, 2017 paid into the Kogi State IGR DSRA Access Bank Account Number , which is exactly a week after the first billions of loan. By whatever means and form, style or character, Sycamore Consulting Limited is not authorized by law to loan money to anyone as it is not a financial institution neither is it a player in the Capital Market and non capital market. The purported loan to Kogi State is viewed as the company being a conduit pipe to Gov. Yahaya Adoza Bello. The total assets of the ‘borrowing company’ is not up to N1 billion, yet it borrowed the State Government N3.9 billion IN A DAY.
On 25th July 2017, the sum of N287, 975,645.87 (Two Hundred and Eight-Seven Million, Nine Hundred and Seventy-Five Thousand, Six Hundred and Forty-Five Naira, Eighty-Seven Kobo) was paid back to Sycamore Consulting Limited by the Kogi State Government from its IGR DSRA account. One month after, on 24th August, 2017, the sum of N287, 975,645.87 (Two Hundred and Eight-Seven Million, Nine Hundred and Seventy-Five Thousand, Six Hundred and Forty-Five Naira, Eighty-Seven Kobo) was paid again into Sycamore Consulting Limited by the Kogi State Government from its IGR DSRA account Following that, on 25th September, 2017, the sum of N258, 000,000 (Two Hundred and Fifty-Eight Million Naira) was paid into Sycamore consulting Limited by the Kogi State Government from its IGR DSRA account. Finally on 23rd November, 2017, the sum of N200, 000,000 (Two Hundred Million Naira) was paid into Sycamore Consulting Limited by the Kogi State Government from its IGR DSRA account.
The Anti-Corruption Network investigation in respect of this transaction revealed that:
a. The Sycamore Consulting Limited loan to Kogi State was fraudulent and contrary to the Investments and Securities Act (ISA) 2007. Section 29 provides for borrowing by rising of internal loans through issuance of securities in the form of Registered Bonds or Promissory Notes by States, Local Governments and other Government Agencies.
Section 222 of ISA went further to define the bodies to which ISA provisions apply, to include: State Governments and the Federal Capital Territory, Abuja; Local Governments; Any statutory body established by the Law of a State or Local Government; Any company which is wholly or partly owned by a State or Local Government.
CIRCUMVENTION OF PROCUREMENT PROCEDURES
9. ABDULSALAMI HUDU withdrew a total sum of N3, 120, 000, 000 (Three Billion One Hundred and Twenty Million Naira) in 2017 from the Kogi State Government House Admin with the account Number 1010662710.
Anti-Corruption Network discovered that Governor Yahaya Bello paid large tranches of cash to Hudu on the various dates: On 8 /30/2017, N10, 000, 000 (Ten Million Naira) was transferred 40 times totaling N400, 000, 000 (Four Hundred Million Naira); On 8 /3/17, N10, 000, 000 (Ten Million Naira) was transferred 25 times totaling N250, 000, 000 (Two Hundred and Fifty Million Naira); On 13/7/17, N10, 000, 000 (Ten Million Naira) was transferred 21 times totaling N201, 000, 000 (Two Hundred and One Million); On 7/20/17, N10, 000, 000 (Ten Million Naira) was transferred 19 times totaling N190, 000, 000 (One Hundred and Ninety Million); On 21/7/17, N10, 000, 000 (Ten Million Naira), was transferred 14 times totaling it N140, 000,000 (One Hundred and Forty Million).
Anti-Corruption network also discovered that the total withdrawal from the Kogi State Government House Admin Zenith Bank account in 2017 is N5, 215, 868, 752.00 (Five Billion Two Hundred and Fifteen Million, Eight Hundred and Sixty Eight Thousand, Seven Hundred and Fifty Two Naira) while Abdulsalami Hudu withdrew N3, 120, 000, 000 (Three Billion, One Hundred and Twenty Million Naira).
The Anti-Corruption Network investigation in respect of this transaction revealed that:
a. There was no specified description for the purpose of the funds. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
CIRCUMVENTION OF PROCUREMENT PROCEDURES
10.UMAR COMFORT OLUFUNKE withdrew a total sum of N320, 000, 000 (Three Hundred and Twenty Million Naira) in 2017 from the Kogi State Government House Admin Zenith Bank account Number
1010662710.
Anti-Corruption Network discovered that Governor Yahaya Bello paid large tranche of cash as paid to Umar Comfort Olafunke in a day on various dates: On 7/21/17, N10, 000, 000 (Ten Million Naira), was transferred 14 times totaling N140, 000,000 (One Hundred and Forty Million); On 7/4/17, N10, 000, 000 (Ten Million Naira), was transferred 9 times totaling N90, 000, 000 (Ninety Million Naira).
The Anti-Corruption Network investigation in respect of this transaction revealed that:
a. There was no specified description for the purpose of the funds. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
FRAUDULENT/CORRUPT PRACTICES IN THE KOGI STATE GOVERNMENT EXPENDITURE FOR 2018
CIRCUMVENTION OF PROCUREMENT PROCEDURES/MONEY LAUNDERING ACTIVITIES
11. Anti-Corruption Network discovered that ABDULSALAMI HUDU withdrew a total sum of N12,310,000,000 (Twelve Billion, Three Hundred and Ten Naira) between 1st February, 2018 to 31st December, 2018 from the Kogi State Government House Administration (Operation) Zenith Bank account Number 1010662710.
Anti-Corruption Network discovered that the following transactions were made by Absulsalami Hudu:
i. On 2nd May, 2018, withdrawals were made from Kogi State Government House Administration Zenith Bank account in tranches of N10, 000,000 (Ten Million Naira) up to 41 times totaling N410, 000,000 (Four Hundred and Ten Million Naira) in a day;
ii. On 1st August, 2018, withdrawals were made from Kogi State Government House Administration Zenith Bank account in tranches of N10, 000,000 (Ten Million Naira) up to 37 times totaling N370, 000,000 (Three Hundred and Seventy Million Naira) in a day;
iii. On 30th January, 2018 withdrawals were from Kogi State Government House Administration Zenith Bank account made in tranches of N10, 000,000 (Ten Million Naira) up to 35 times totaling N370, 000,000 (Three Hundred and Seventy Million Naira) in a day;
iv. On 31st January, 2018, withdrawals were from Kogi State Government House Administration Zenith Bank account made in tranches of N10, 000,000 (Ten Million Naira) up to 33 times totaling N330, 000,000 (Three Hundred and Thirty Million Naira) in a day;
v. On 1st January, 2018, withdrawals were from Kogi State Government House Administration Zenith Bank account made in tranches of N10, 000,000 (Ten Million Naira) up to 30 times totaling N300,000,000 (Three Hundred Million Naira) in a day.
These withdrawals amongst numerous others were made by Abdulsalami Hudu, despite the likelihood of being a public servant under the employment of the Kogi state government. Governor Yahaya Bello directed Abdulsalami Hudu to withdraw a total of N12,310,000,000.00 (Twelve Billion, Three Hundred and Ten Million Naira) in cash (across the counter) and cheques for unknown reasons. Anti-Corruption Network also discovered that, the total debit from the Kogi State Government House Administration account in 2018 was N19, 642,631,438.56 (Nineteen Billion, Six Hundred and Forty-Two Million, Six Hundred and Thirty-One Thousand, Four Hundred and Thirty-Eight Naira, Fifty-Six Kobo) and Abdulsalami Hudu withdrew a total of N12, 310,000,000 (Twelve Billion, Three Hundred and Ten Million Naira) which was more than 60% of the total debits from the Kogi State Government House Administration account.
The Anti-Corruption Network investigation in respect of this transaction revealed that:
a. There was no specified description for the purpose of the funds. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular
No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
CIRCUMVENTION OF PROCUREMENT PROCEDURES
12. Anti-Corruption Network in the course of investigation discovered that COMFORT UMAR OLUFUNKE withdrew a total of N490,000,000.00 (Four Hundred and Ninety Million Naira) from Kogi State Government House Administration (Operation) Zenith Bank account number 1010662710.
It was also discovered that on 23rd January, 2018 Comfort Umar Olufunke withdrew the sum of N10,000,000 (Ten Million Naira) up to 35 times totaling N350,000,000.00 (Three Hundred and Fifty Million Naira), following that, on 9th February, 2018 another withdrawal of N10,000,000 (Ten Million Naira) up to 5 times giving a total of N50,000,000 (Fifty Million Naira), also on 27th April, 2018 another withdrawal of N10,000,000 (Ten Million Naira) up to 5 times giving a total of N50,000,000 (Fifty Million Naira) and finally on 30th April,2018 the last withdrawal of N10,000,000 (Ten Million Naira) up to 4 times was made giving a total of N40,000,000 (Forty Million Naira).
The Anti-Corruption Network investigation in respect of this transaction revealed that:
a. There was no specified description for the purpose of the funds. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
WITHDRAWAL ABOVE THRESHOLD AND CIRCUMVENTION OF PROCUREMENT PROCEDURES
13.Anti-Corruption Network discovered that JIMOH AMINU O. withdrew a total of N300,000,000.00 (Three Hundred Million Naira) from Kogi State Government House Admin Zenith Bank account number 1010662710 with amounts exceed the threshold allowed in law.
Investigation showed that:
i. On 18th May, 2018, Jimoh Aminu withdrew a total of N10,000,000 up to 5 times totaling N50,000,000 (Fifty Million Naira);
ii. On 11th October, 2018 the sum of N10,000,000 (Ten Million Naira) was withdrawn 10 times a total of N100,000,000 (One Hundred Million Naira);
iii. On 12th October, 2018 he withdrew N10,000,000 (Ten Million Naira) up to 6 times giving a total of N60,000,000 (Sixty Million Naira);

  1. On 19th December, 2018 he withdrew N10,000,000 (Ten Million Naira) up to 4 times giving a total of N40,000,000 (Forty Million Naira);
    v. And another N10,000,000 (Ten Million Naira) withdrawn on 24th December, 2018 up to 5 times giving a total of N50,000,000 (Fifty Million Naira).
    The Anti-Corruption Network investigation in respect of this transaction revealed that:
    a. There was no specified description for the purpose of the funds. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
    Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
    SUSPECTED MONEY LAUNDERING TRANSFER
    14. Anti-Corruption Network found that Governor Yahaya Bello ordered the transfer of a total of N100,000,000 (Hundred Million Naira) to PHILIP OMEIZA SALAWU in three tranches of N40,000,000 (Forty Million Naira) on 1/30/2018; N10,000,000 (Ten Million Naira) on 1/30/2018 and N50,000,000 (Fifty Million Naira) on 8/6/2018 from the Kogi State Statutory Revenue Account Number 1014558813 in Zenith Bank.
    Anti-Corruption Network also discovered that Philip Salawu is the former Deputy Governor of Kogi State and contested for the Kogi State governorship seat in 2015 under the Labour Party. Philip O. Salawu who is likely a Civil Servant with Kogi State Civil Service received the transfers without any transaction description attached to it.
    The Anti-Corruption Network investigation in respect of this transaction revealed that:
    a. There was no specified description for the purpose of the funds. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
    Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
    SUSPECTED MONEY LAUNDERING TRANSACTION
    15. Anti-Corruption Network found that Governor Yahaya Bello ordered the transfer of a total of N735,596,904 (Seven Hundred and Thirty Five Million, Five Hundred and Ninety Six Thousand, Nine Hundred and Four Naira) to SANUSI BELLO IBRAHIM without description with the highest sum as N134,101,935 (One Hundred and Thirty-Four Million, One Hundred and One Thousand, Nine Hundred and Thirty- Five Naira) on the 18th December, 2018 from the Kogi State Government House Zenith Bank Account Number 1010662710.

The Anti-Corruption Network investigation in respect of this transaction revealed that:
a. There was no transaction description attached to the transactions. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
CIRCUMVENTION OF PROCUREMENT PROCEDURES 16.Anti-Corruption Network found that ABDULGANIYU BADAMASUIY withdrew a total of N182,250,000 (One Hundred and Eighty Two Million, Two Hundred and Fifty Thousand Naira) with the highest sum as N44,000,000 (Forty-Four Million Naira) on 9th November, 2018 from the Kogi State Government House Account Number
1010662710 in Zenith Bank.
The Anti-Corruption Network investigation in respect of this transaction revealed that:
a. There was no specified description for the purpose of the funds. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
FRAUDULENT/CORRUPT PRACTICES IN THE KOGI STATE GOVERNMENT EXPENDITURE FOR 2019
17. LUKFLY OVER LIMITED with Rc No.: 1439538, is a limited liability company registered on 20th September 2017 under part A of CAMA with its registered address at Plot 11X4 Behind Late Abubakar Audu’s House, GRA. This company is owned by SANNI AGUVA MOSES, the Senior Special Assistant (SSA) to the Governor of Kogi State on Youth and Women Mobilization.
The said company received various amounts from the Kogi State Government House Admin account totaling N40,000,000.00 (Forty Million Naira) paid from Zenith Bank account number 1010662710. The amounts were received in 4 tranches of N10,000,000 (Ten Million Naira) on 19/03/2019, 19/3/2019, 10/10/2019 and 1/10/2019 respectively. The funds were confirmed received in the Company’s Zenith Bank account number 0788765812.
The Anti-Corruption Network investigation revealed the following:
a. That this company was not declared in Mr Sanni Aguva Moses’ Code of Conduct Bureau form which contravenes Section 11(1) of the Fifth Schedule, Part 1 of the 1999 Constitution, which provides that “Subject to the provisions of the Constitution, every public officer shall three months after coming into force of this Code of Conduct or immediately after taking office and thereafter: (a) at the end of every four years, and (b) at the end of his term of office, submit to the Code of Conduct Bureau a written declaration of all his properties, assets and liabilities and those of his unmarried children under the age of eighteen years”.
b. That Mr. Sanni Aguva Moses uses the company to run private business contrary to Section 2(a) which bars a public officer from engaging or participating in the running of any private business, profession, or trade.”
c. Lastly, there was no specific detail of the purpose of the funds paid to Lukfly Over Limited.
18. MOTOR HAUL LIMITED, Rc No.: 472938 is a Limited Liability Company registered on 18th February 2003 under part A of CAMA with its registered address at Plot 8906b Utako District, Berger Junction, Abuja, FCT, Abuja. The Company is owned by OZIGI ABEL, a Senior Special Assistant Project Liaison and Management Office (PLMO)-Office of the Governor of Kogi State.
Motor Haul Limited received a total of N400,000,000.00 (Four Hundred Million Naira) sent from Zenith Bank account number 1010662710 belonging to the Kogi State Government House Admin.
The Anti-Corruption Network investigation revealed the following:
a. That this company was not declared in Ozigi Abel’s Code of Conduct Bureau form which contravenes Section 11(1) of the Fifth Schedule, Part 1 of the 1999 Constitution that provides as follows “Subject to the provisions of the Constitution, every public officer shall three months after coming into force of this Code of Conduct or immediately after taking office and thereafter: (a) at the end of every four years, and (b) at the end of his term of office, submit to the Code of Conduct Bureau a written declaration of all his properties, assets and liabilities and those of his unmarried children under the age of eighteen years”.
b. That Ozigi Abel uses the company to run private business contrary to Section 2(a) which bars a public officer from engaging or participating in the running of any private business, profession, or trade.”
AWARD OF CONTRACT TO COMPANY WITH VESTED INTEREST
19. DE-KOGI GOGGLE PRODUCTION, Rc No.: 2265950 is a Business name registered on 17th July 2013 under part B of CAMA. The Business name is owned by NWOGU BARIKISU, a Senior Special Assistant to
the Governor of Kogi State.
Anti-corruption Network discovered that De-Kogi Goggle Production received a total of N270,000,000 (Two Hundred and Seventy Million Naira) in 2019 from Kogi State Govt House Admin Zenith Bank account number 1010662710.
The Anti-Corruption Network investigation revealed the following:
a. That this company was not declared in Nwogu Barikisu’s Code of Conduct Bureau form which contravenes Section 11(1) of the Fifth Schedule, Part 1 of the 1999 Constitution that provides as follows “Subject to the provisions of the Constitution, every public officer shall three months after coming into force of this Code of Conduct or immediately after taking office and thereafter: (a) at the end of every four years, and (b) at the end of his term of office, submit to the Code of Conduct Bureau a written declaration of all his properties, assets and liabilities and those of his unmarried children under the age of eighteen years”.
b. That Nwogu Barikisu uses the company to run private business contrary to Section 2(a) which bars a public officer from engaging or participating in the running of any private business, profession, or trade.”
c. As a business name, it is not eligible to receive such amount of money.
d. Lastly, there was no transaction details were written in the bank’s analysis concerning the purpose of the money making it vague and easy to be diverted and embezzled.
PAYMENTS WITHOUT TRANSACTION DESCRIPTION 20.Anti-Corruption Network also discovered that FALALA CONSTRUCTION AND INTERIOR DÉCOR LIMITED received a total of N336,000,000 (Three Hundred and Thirty Six Million Naira) in 2019 from Kogi State Govt House Admin Zenith Bank account number 1010662710.
The Anti-Corruption Network investigation revealed that:
a. There was no transaction description for the amount paid to the company by the Kogi State government. Public procurement law that encourages competitive bidding and advertisement in two national dallies was breached, thus: Section 24 (1) public procurement Act 2007 states that “Except as provided by this Act, all procurement of goods and services by all entities shall be conducted by open competitive bidding”.
Similarly, Financial Regulations 2921 (i) states that “Except as exempted under the procurement Act, all procurement of goods, works and services shall be by way of open competitive bidden by which is meant that all contractor/ supplies shall be subject to the same level playing ground…”
IRREGULARITIES IN CONTRACT AWARD
21. AILO NIGERIA LIMITED, RC No. 82783 is a Limited Liability Company registered on 8th April 1986 under Part A of CAMA with its registered address at No. 16 College Road, Ankpa, Kogi State. The company is owned by Ibrahim Ocheja who represented Kogi East Senatorial District in the National Assembly and a member of the All Progressive Congress.
AILO Nigeria Limited received a total of N63,569,147 (Sixty Three Million Five Hundred and Sixty Nine Thousand One Hundred and Forty Seven Naira) in 2019 from the Kogi State Government Project Acct with Zenith Bank account Number 1015581403.
The Anti-Corruption Network investigation revealed the following:
a. That there were so many irregularities in award of the contract to this company which contravenes Section 24 (1) public procurement Act 2007 that states as follows “Except as provided by this Act, all procurement of goods and services by all entities shall be conducted by open competitive bidden”. Similarly, Financial Regulations 2921 (i) states that “Except as exempted under the procurement Act, all procurement of goods, works and services shall be by way of open competitive bidding by which is meant that all contractor/ supplies shall be subject to the same level playing ground…”
c. That the Senator may have used his son as fronts for the company in other to avoid public scrutiny.
d. Lastly, there is no transaction description for the money paid to the company’s account contrary to the provisions of the law.
22. SEC EQUIPMENT AND COMMUNICATIONS NIGERIA LTD, RC No. 2015663 and registered address at Surulere, Lagos is an Israeli company involved in major sectors of the Nigerian economy including agriculture, security, communication etc. The Company received the total sum of N905,955,451 (Nine Hundred and Five Million Nine Hundred and Fifty Five Thousand Four Hundred and Fifty One Naira) in 2019 from Kogi State IGR DSRA domiciled with Access Bank account number 00736262941 and Kogi State IGR Main Account number 0710013288.
The Anti-Corruption Network investigation revealed the following:
a. That No description was given for the purpose of this fund in the account statement investigated by Anti-Corruption Network.
b. Anti-Corruption Network also discovered that this company seems to be a channel through which funds are laundered by Governor Yahaya Bello, as a director listed in the company is a Switzerland based company indicted in Panama papers. The Directors listed in the company are: Shlomo Elia, Prince Ton Euroinvest Inc, Solomon S. Popoola, Joyce N.Popoola, Docar A. Smart, Nwokocha Nwokecha (Secretary). investigation shows that Prince Ton Euroinvest Inc is a foreign company located in LIC, Andre Zolty 8C; Avenue De Champel 1206; Geneva Switzerland indicted in Panama papers leak.
AWARD OF CONTRACTS TO NON-EXISTING COMPANIES
23. Anti-Corruption Network discovered some irregularities in the payment of these companies:
i. Bright Eyes Montessori School received N25,000,000 (Twenty-Five Million Naira) from Kogi State VAT account number 0703377229 in 2019 on 27/05/2019.

  1. Top Gas Petroleum Company received the sum of N6,277,500 (Six Million Two Hundred and Seventy-Seven Thousand Five Hundred Naira) from Kogi State IGR Main Account on 30/04/2019.
    iii. 2 Top Tuny Nigeria Enterprises was paid the sum of N5,000,000 (Five Million Naira) from Kogi State IGR Main Account on 4/10/2019.
    iv. Tower Building Product was paid the sum of N5,300,000 (Five Million Three Hundred Thousand Naira) from Kogi State Joint Acct Allocation Committee DSRA Access bank account number 0712750840on the 27/05/2019.
    The above listed companies are not registered with the Corporate Affairs Commission (CAC) as monitored on its website, consequently, they are not eligible to be awarded any contract or receive monies from the State. Part IV Section 16(6) of the Public ProcurementAct2007 which requires that companies eligible for contract award should possess the necessary professional and technical qualifications, financial capability, equipment and other relevant infrastructure etc’. also Financial Regulations 2009 state in part “All bidders in a contract for public procurement must show proof of eligibility for the award of contract…”
    CIRCUMVENTION OF PROCUREMENT PROCEDURES 24.Anti-Corruption Network investigation revealed that ABDULSALAMI HUDU withdrew a total sum of N3,530,000,000 (Three Billion Five Hundred and Thirty Million Naira) the Kogi State Government House Administration (Operation) with Access Bank account Number 0793190623 and Kogi State Govt House Admin Zenith Bank Account Number 1010662710.
    It was also observed that the withdrawals were made in tranches of N10,000,000 (Ten Million Naira) from 4 to 10 times in a day with the highest being the withdrawal of N10,000,000 (Ten Million Naira) thirty times on 01/08/2019 totaling N300,000,000 (Three Hundred Million Naira) with no specified description in the bank statement.
    The Anti-Corruption Network investigation in respect of this transaction revealed that:
    b. There was no specified description for the purpose of the funds. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
    Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
    CIRCUMVENTION OF PROCUREMENT PROCEDURES
    25. Anti-Corruption Network found that AMINU JIMOH withdrew a total of N520,000,000.00 (Five Hundred and Twenty Million Naira) from Kogi State Govt House Administration (Operation) Zenith Bank account number 0793190623 with amounts exceeding the threshold
    allowed in law.
    Anti-Corruption Network also discovered that on 08/03/2019 Aminu Jimoh withdrew the sum of N10,000,000 (Ten Million Naira) 10 times totaling N100,000,000 (One Hundred Million Naira) by cheques with number 000000000059, 000000000048, 000000000046 etc at Zenith Bank Lokoja branch.
    The Anti-Corruption Network investigation in respect of this transaction revealed that:
    a. There was no specified description for the purpose of the funds. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
    Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
    WITHDRAWAL ABOVE THRESHOLD AND CIRCUMVENTION OF PROCUREMENT PROCEDURES
    26. Anti-Corruption Network found that ABDUL GANIYU withdrew a total of N176,000,000.00 (One Hundred and Seventy Six Million Naira) from Kogi State Government House Admin Zenith Bank account number 1010662710 with amounts exceeding the threshold allowed in law.
    Checks showed that on 10/05/2019, Abdul Ganiyu withdrew the sum of N60,000,000 (Sixty Million Naira) in 2 tranches of N30,000,000 (Thirty Million Naira) in raw cash, while on 01/10/2019 and 3/19/2019 he also withdrew N29,000,000 (Twenty-Nine Million Naira) and N29,000,000 (Twenty-Nine Million Naira) in 2 tranches of raw cash across the counter each totaling N118,000,000 (One Hundred and Eighteen Million Naira) which contravenes the Central Bank’s policy cash-based policy.
    The Anti-Corruption Network investigation in respect of this transaction revealed that:
    a. There was no specified description for the purpose of the funds. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
    Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
    CIRCUMVENTION OF PROCUREMENT PROCEDURES/POSSIBLE KICK BACKS PAYMENT
    27. Anti-Corruption Network found that AHMED OKARA
    ABDULMUMEEN withdrew a total sum of N40, 000, 000 (Forty Million Naira) in 2019 from the Kogi State Govt House Admin Zenith Bank Account Number 1010662710 in 2 tranches of N20,000,000 (Twenty Million Naira) on 19/3/2019.
    The Anti-Corruption Network investigation in respect of this transaction revealed that:
    a. There was no specified description for the purpose of the funds. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
    Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
    CIRCUMVENTION OF PROCUREMENT PROCEDURES/MONEY LAUNDERING
    28. Anti-Corruption Network discovered that MOMOH ABDUL LASIS withdrew a total sum of N82, 740, 000 (Eighty Two Million Seven Hundred and Forty Thousand Naira) in 2019 from the Kogi State Government House Admin Zenith Bank Account Number 1010662710.
    Our Organisation, Anti-Corruption Network also observed that Governor Yahaya Bello paid N13,485,000 (Thirteen Million, Four Hundred and Eighty-Five Thousand Naira) in 2 tranches totaling N26,970,000 (Twenty-Six Million Nine Hundred and Seventy Thousand Naira) to Momoh Abdul Lasis on 9/03/2019 and another N27,885,000 (Twenty-Seven Million Eight Hundred and Eighty-Five Thousand Naira) in two tranches totaling N55,770,000 (Fifty-Five Million Seven Hundred and Seventy Thousand Naira) on 13/02/2019 to a Guaranty Trust Bank owned by Momoh.
    The Anti-Corruption Network investigation in respect of this transaction revealed that:
    a. There was no transaction description explaining the purpose of the funds sent to Momoh Lasis by Gov Yahaya Bello.. The funds may have been laundered or diverted for other uses other than for public good. This is contrary to Treasury Circular No. TRY/A2&B2/2009/OAGF/CAD026/V of 24th March 2009 which states that “All procurement of stores and services exceeding N200,000.00 shall be made only through the award of contract”.
    Similarly, Treasury Circular Ref. No. TRY/A2&A3/2013 OAGF/CAD/026/V.1/188 OF 9th April, 2013 emphasized that, “cash advance in excess of N200,000.00 should not be granted to any officer for procurement of goods and services but the procurement should be given out as a contract”.
    Having carried out such rigorous investigation, we therefore call upon the law enforcement agencies to further investigate these issues raised and bring the perpetrators to book. The above is just a tip of the iceberg and let the sound of the music pass on to other States of the federation that we shall be uncovering various fraud perpetrated in other States. We shall no longer keep silent and allow the government of the day engages in Executive rascality and lawlessness. In an unjust society, silence is also a crime and we urging the law enforcement agencies not to be silence in view of this overwhelming evidence against the perpetrators.

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