Anti-Corruption Network discovers fraudulent/corrupt practices in the Kogi State Government expenditures for 2016, 2017, 2018 and 2019

ANTI-CORRUPTION NETWORK INVESTIGATION REPORT ON KOGI
STATE AND GOVERNOR YAHAYA BELLO.
The Anti-Corruption Network is a registered Non-governmental, Nonreligious, 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 nongovernmental 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

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
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
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.

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 ThirtyThree Thousand, Seven Hundred and Ninety-Four Naira);
Abdulraheem Abubakar Danagana received N21,016,960.00 (TwentyOne 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 SixtyTwo 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
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”.

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

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 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
SYCAMORE CONSULTING LIMITED was incorporated to carry on
taxation, accounting and financial advisory services ONLY. AntiCorruption 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

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
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”.

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
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).

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) iv. 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
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 ThirtyFive 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”.

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

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, NwokochaNwokecha (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 (TwentyFive Million Naira) from Kogi State VAT account number
0703377229 in 2019 on 27/05/2019 ii. 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”.

Anti-Corruption Network discovers fraudulent/corrupt practices in the Kogi State Government expenditures for 2016, 2017, 2018 and 2019 added by Gideon Ayodele on February 26, 2021
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Anti-Corruption Network discovers fraudulent/corrupt practices in the Kogi State Government expenditures for 2016, 2017, 2018 and 2019

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