International Lawyers Project
UK Global Anti-Corruption Sanctions Regime Workshop for Nigerian Civil Society
Corruption in Nigeria
Nigeria ranks 154th out of 180 countries on Transparency International’s 2021 Corruption Perception Index (CPI), down five places from its 2020 ranking.
Over the years, there have been numerous corruption scandals in Nigeria, including pension scams affecting 141,790 people; an aviation minister using over £45,000 of state funds to buy an armoured car; $15 million in cash being delivered by Nigeria via private jet to a South African arms company and $1.1 million from state oil proceeds shared-out between private individuals.
A particular feature of Nigerian corruption is ‘Godfatherism’, in which wealthy individuals use money and influence to win support for their preferred candidates, gaining favours in return once they reach office.
UK links to Nigerian Corruption
There are historical ties between the UK and Nigeria, with Nigeria receiving its independence on 1st October 1960. Many Nigerian elites and their embezzled funds have been welcomed by London’s financial institutions. Nigeria ranks fourth in a Transparency International UK list of the top 10 countries where corruption cases have a UK nexus.
Another example is Finance Uncovered’s graphic, which reveals the purchasing of London properties by Nigerian politicians and business figures using offshore secrecy vehicles. Finance Uncovered estimates that, in the last 30 years, at least 233 houses and apartments were bought by 166 offshore shell companies with a combined worth today of £350 million.
Who has the UK Sanctioned from Nigeria so far?
The UK Global Anti-Corruption Sanctions allow the UK Foreign Minister to sanction (designate) individuals and entities they believe there is ‘reasonable cause to suspect’ of being involved in corruption. Once designated, the individual or entity is barred from entering the UK and all of their assets in the UK and its overseas territories are frozen.
Despite the clear connection between the UK and Nigiera, and numerous corruption scandals, only one Nigerian individual and three entities have been sanctioned by the UK, all of which were sanctioned for terrorist activities, rather than corruption. To date, the UK has not used its anti-corruption sanctions regime to target any Nigerian kleptocrats.
Training Nigerian Anti-Corruption Activists on Corruption Sanctions Tools
The Africa Network for Environment and Economic Justice (ANEEJ), a leading anti-corruption NGO in Nigeria, requested ILP’s assistance in organising a virtual workshop for them and 21 other Nigerian anti-corruption NGOs to provide an overview and training on the UK Global Anti-Corruption Sanctions Regime. On 18th August 2022, Oliver Windridge, an international sanctions lawyer, conducted the workshop for 33 Nigerian anti-corruption activists and senior staff members from Nigerian anti-corruption NGOs.
The ILP-ANEEJ workshop aimed to address the issue of extensive grand-corruption in Nigeria. The country is often plagued by an inability to hold corrupt officials and elected leaders accountable for bribery, tax evasion and related crimes. The UK government encourages NGOs on-the-ground where corruption is taking place to make submissions to them. Accordingly, the UK Global Anti-Corruption Sanctions Regime offers hope to civil society in Nigeria that there are international enforcement tools that they can use.
Oliver Windridge beginning the workshop on the UK Global Anti-Corruption Sanctions Regime
During the workshop, ILP provided:
an introduction and overview of the Sanctions Regime;
training on how to use both the UK Global Human Rights and Anti-Corruption Sanctions Regimes to increase accountability for corruption between Nigeria and the UK;
knowledge to equip the participants on how to make strong submissions to the UK government for sanctions;
a description of cases of the individuals who have been designated under the UK Sanctions Regimes and US Global Magnitsky regime already;
advice on the practicalities of how submissions can be made and how they can be made confidentially or in a manner which helps to protect anti-corruption activists, their sources and whistle-blowers.
ILP’s lawyers also took part in a lively 30 minute Q&A session using examples of his experience of making submissions for corruption.
For a briefing note with FAQs on the UK Global Anti-Corruption Sanctions Regime produced for civil society activists click here.
For the full recording of the workshop click here
See below for a download link to the presentation slides for the workshop.