An Appraisal Of The EFCC Act 2004 In Dealing With Financial Crimes In Nigeria – Jonah Uyo – Obong  (Part 1)

ABSTRACT

Financial crime is a menace constantly plaguing many nations of the world and Nigeria is not an exception. In 2002, the FATF (Financial Action Task Force), an inter-governmental body responsible for combating money laundering globally, reported that Nigeria has been non-cooperative in the fight against money laundering. It was on this premise that the Economic and Financial Crimes Commission (Establishment) Act 2002 was enacted by the Obasanjo led administration to fight against money laundering. The Act was repealed by the EFCC Act 2003 and then subsequently the EFCC Act 2004. This paper will appraise the effectiveness of the Act in combating financial crimes. This paper employs the doctrinal methodology and finds, among other things, that the provision of section 14 (2) of the Act which empowers the Commission to compound offences, does not serve as a deterrent against financial crimes, though a faster means to dispense with cases by the Commission, it does not stop the commission of financial crimes but rather encourages the commission of financial malpractice. Furthermore, this paper finds that the Act allows the Commission to accept monetary gifts and property from a person or an organization. This paper recommends that the provision of Section 14 (2) should be applied with caution to avoid abuse and the Commission should desist from relying on the Section for plea bargain in releasing criminals which is not the contemplation of the aforesaid Section. Also, that Section 35(3) of the Act should be expunged from the Act because as an anti-graft agency, accepting monetary gifts can undermine the integrity of the Commission in the fight against financial crimes especially cases involving politically exposed persons.

1. INTRODUCTION

Among the most difficult challenges inherited by the Nigerian democratic government in 1999 was excessive corruption[1]. To tackle corruption and financial crimes, the Obasanjo led administration enacted the Economic and Financial Crimes Commission (Establishment) Act 2002 which was subsequently repealed by the EFCC Act 2003 and then same was further repealed by the EFCC Act 2004 which is subsisting till date. The Act and other laws such as the Money Laundering Act[2], the Advanced Fee Fraud and Other Related Offences Act[3], Independent and Corrupt Practices & Other Related Offences Act[4], the Failed Banks (Recovery of Debt and Financial Mal-practices in Banks) Act (As Amended)[5]were established to combat corruption and financial crimes particularly the EFCC Act which was enacted as a response to the report published by the FAFT (Financial Action Task Force)in 2002 over Nigeria’s non-cooperativeness in the fight against money laundering globally[6].

The Act established the Economic and Financial Crimes Commission designated as the Financial Intelligence Unit (FIU) in Nigeria, charged with the responsibility of co-ordinating the various institutions involved in the fight against money laundering and enforcement of all laws dealing with economic and financial crimes in Nigeria[7]. Therefore, the primary role of the Commission is to investigate and prosecute economic and financial crimes, such as advance fee fraud, money laundering and misapplication and misappropriation of publicfunds etc[8]. The Act consist of 47 sections, 7 parts and 1 schedule. To evaluate the significance or effectiveness of the Act, it will be in order to consider the performance of the Commission which was established by the Act to carry out the prescribed provisions of the Act. In a recent public sensitization lecture at the University of Abuja, the newly appointed Executive Chairman of the Commission, Mr Ola Olukoyede disclosed that the Commission secured 3,175 convictions and recovered N156,276,691,242.30 (One Hundred and Fifty-six Billion Two Hundred and Seventy-six Million Six Hundred and Ninety-one Thousand Two Hundred and Forty-two Naira Thirty Kobo) between 29 May 2023 and May 29, 2024 when President Bola Ahmed Tinubu assumed office[9].However, the Commission has had to suffer some losses as well as being plagued with challenges such as interference with the activities of the Commission by politically exposed persons, internal challenges within the Commission, weak judicial system, fraudulent practices by defence attorneys, delay in prosecution due to immunity guaranteed by the Constitution etc [10].

This paper is divided into 9parts; part 1 is the introduction, part 2 deals with financial crime and its impact in Nigeria, part 3 covers the functions and powers of the Commission, part 4 highlights the offences and penalties prescribed by the Act, part 5 analyses the effectiveness of the Act in combating financial crimes, part 6 examines the challenges with the administration of the EFCC Act in combating financial crimes, part 7 deals with the comparison between Nigeria, France and Ireland in combating financial crimes, part 8 is the conclusion and part 9 is the recommendation.

2. FINANCIAL CRIME AND ITS IMPACT IN NIGERIA

Prior to the enactment of the Act of 2002 as amended by the EFCC Act 2004, there was no comprehensive definition of what constitutes financial crime. Section 46 of the Act[11]defines financial crime as the non-violent criminal and illicit activity committed with the objectives of earning wealth illegally either individually or in a group or organized manner thereby violating existing legislation governing the financial actions of a government and its administration and includes any form of fraud such as: money laundering, embezzlement, bribery, looting and any form of corrupt malpractices, illegal arms deal, smuggling, human trafficking and child labour, illegal oil bunkering and illegal mining, tax evasion, foreign exchange malpractice including counterfeiting of currency, theft of intellectual property and piracy, open market abuse, dumping of toxic waste and prohibited goods etc. Financial crimes are crimes committed not only with the intention of getting financial benefit but they are targeted directly on funds and financial instruments. Although there is no significant line between financial and economic crimes, not all financial crimes are economic crimes. Financial crimes may be carried out by individuals, corporations, or organized crime groups. Victims may include individuals, corporations, governments and an entire economy.[12]

In recent years, it has given Nigeria a bad name in international finance circle to the extent that Nigerian government had to respond with the establishment of the Economic and Financial Crimes Commission and the Independent Corrupt Practices and Other Related Offences Commission to deal with the enormous negative consequences of financial crimes. This can be seen from the consistent ranking of Nigeria as one of the most corrupt countries in the world by the Corruption Perception Index (CPI) since its inception in 1995 and also the listing of Nigeria as non-cooperative country and territory by the FAFT in 2001[13]. Financial crimes have a negative consequence on the Nigerian economy with over N85 billion recovered so far through government directed efforts; there is no doubt that financial crimes remain a serious threat to Nigeria’s quest for development.[14]

Some of the financial crimes associated with Nigeria include: cheque fraud, that is, suppression, dub cheques, diversion of proceeds, cheque kitting etc. unauthorized credits, telex, transfer frauds, electronic payment fraud, advanced fee fraud, embezzlement etc. these crimes were noted to have contributed significantly to the failure of the Nigerian Project. It has also been noted that the lack of political will to fight financial crimes, lack of adequate training exposure, incentives to law enforcement agencies, failure of sanctions, phenomenal advances in technology and permissiveness of criminal conduct in Nigeria are major encouraging factors in economic and financial crimes.[15]

3. FUNCTIONS AND POWERS OF THE COMMISSION

The Act provides for both the functions and special powers of the Commission. The functions of the Commission are expressly provided for in the Act[16]. Section 6 (m) and Section 46 of the Act vest in the EFCC the function and duty of investigating and prosecuting persons reasonably suspected to have committed economic and financial crimes[17]. The special powers of the Commission include:

1. To cause investigations to be conducted as to whether any person, corporate body or organization has committed an offence under this Act or other law relating to economic and financial crimes.[18]
2. to cause investigations to be conducted into the properties of any person if it appears to the Commission that the person’s life style and extent of the properties are not justified by his source of income[19].

In addition to the powers conferred on the Commission by the Act, the Commission shall be the coordinating agency for the enforcement of the provisions of[20] –

1. the Money Laundering Act 2004
2. the Advance Fee Fraud and Other Related Offences Act 1995
3. the Failed Bank (Recovery of Debt and Financial Mal-practices in Banks) Act as amended
4. the Bank and Other Financial Institutions Act 1991, amended
5. Miscellaneous Offences Act and
6. Any other law or regulation relating to economic and financial crimes, including the Criminal Code and Penal Code.

It is worthy of note that sub-section (2) of Section 7 of the Act allows the Commission to investigate and prosecute economic and financial crimes under the existing legislation, such as the Constitution, particularly Section 419[21]. The Section empowers the EFCC to enforce other existing penal statutes. The EFCC Act is an Act that was promulgated to stem the scourge of advance fee fraud[22].  Indeed, the effect of the combined provisions of Sections 6(b), 7(1)(a), (2)(f) and 13(2) of the EFCC (Establishment) Act leaves no doubt that the EFCC has the power to investigate, enforce and prosecute an offender under any other statute in so far as the offence relates to the commission of economics and financial crimes.[23]

4. OFFENCES AND PENANLTIES PRESCRIBED BY THE ACT
   • Offences relating to Financial Malpractice[24]:

Section 14 provides for offences relating to financial malpractices. This section provides that an officer of a bank or non-financial who fails or neglects to secure compliance with the provisions of this Act or fails to secure the authenticity of any statement submitted pursuant to the provisions of this Act commits an offence  and is liable upon conviction to 5 years imprisonment or a fine of N500,000 or both. Section 14(2) provides for powers of the Commission to compound any offence. Compounding crime consists of the receipt of some property or other consideration in return for an agreement not to prosecute or inform on one who has committed a crime[25]. The content of the provision in Section 14(2) of the Economic and Financial Crimes Commission Act, 2004 is that the following factors are present: the EFCC has the power to compound an offense; the offence compounded must be one that is punishable under the EFCC Act; the EFCC can accept money in compounding the offense; the sum of money the EFCC can accept must be that which must exceed the maximum amount to which that person would have been liable to pay if he had been convicted of that offence.[26]

• Offences in relation to Terrorism[27]:

A person who wilfully provides or collects by any means, directly or indirectly, any money from any other person with intent that the money shall be used or is in the knowledge that the knowledge that the money shall be used for any act of terrorism, commits an offence under this Act and is liable on conviction to imprisonment for life[28]. Any person who commits a terrorist act or participates in or facilitates the commission of a terrorism act commits an offence under this Act and is liable on conviction to imprisonment for life.[29] Any person who makes funds, financial assets, economic resources or financial or other related services available for use by any other person to commit or attempts to commit, facilitate or participate in the commission of a terrorist act is liable on conviction to imprisonment for life.[30]

• Offences relating to False Information:[31]

Any person who, in the discharge of his duty under this Act gives information that is false in any material particular to any other act in relation thereto, commits an offence under this Act and the onus shall be on him to prove that he exercised due diligence to prevent the commission of the offence having regard to the nature of his function and circumstances. Anyone found guilty shall be liable to imprisonment for a term not less than 2 years and not more than 3 years, provided that where the offender is a public officer, the penalty shall be imprisonment for a term not less than 3 years and not more than 5 years.

• Offences in relation to Economic and Financial Crimes and Penalties[32]

A person who engages in the acquisition, possession or use of property knowing at the time of its acquisition, possession or use that such property was derived from any offence under this Act, engages in the management, organization or financing of any of the offences under this Act, engages in the conversion or transfer of property knowing that such property is derived from any offence under this Act or engages in the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to or ownership of property knowing that such property is derived from any offence under this Act, commits an offence under this Act and is liable on conviction to imprisonment for a term not less than 2 years and not exceeding 3 years.

• Disclosure of Assets and Properties by an Arrested Person[33]

Where a person is arrested for committing an offence under this Act, such person shall make a full disclosure of all his assets and properties by completing the Declaration of Assets Form as specified in Form A of the Schedule to this act. Failure to make full disclosure of his assets and liabilities or knowingly makes a declaration that is false or neglects or refuses to make a declaration or furnish any information in the Declaration Form, commits an offence under this Act and is liable on conviction to imprisonment for a term not exceeding 5 years.

• Offences in relation to Forfeiture Orders[34]:

Any person who, without due authorization by the Commission, deals with, sells or otherwise disposes of any property or asset that is the subject of an attachment, interim order or final order commits an offence and is liable on conviction to imprisonment for a term of five years without the option of a fine. Any manager or person in control of the head office or branch of a bank, other financial institution or designated non-financial institution who fails to pay over to the Commission upon the production to him of a final order commits an offence under this Act and is liable on conviction to imprisonment for a term of not less than one year and not more than three years, without the option of a fine.

• Power to Receive Information Without Hindrance:[35]

The Commission shall seek and receive information from any person, authority, corporation or company without let or hindrance in respect of offences it is empowered to enforce under this Act. A person who wilfully obstructs the Commission or any authorized officer of the Commission in the exercise of any of the powers conferred on the Commission by this Act or fails to comply with any lawful enquiry or requirements made by any authorized officer in accordance with the provisions of this Act commits an offence under this Act and is liable on conviction to imprisonment for a term not exceeding five years or to a fine not below the sum N500,000 or to both such imprisonment and fine.

• Protecting Informants and Information etc and Penalty for False Information:[36]

Any person who makes or causes any other person to make to an officer of the Commission or to any other Public Officer in the course to the exercise by such public officer of the duties of his office, any statement which to the knowledge of the person making the statement or causing the statement to be made is false or intended to mislead or is untrue in any material particular or is not consistent with any other statement previously made by such person to any other person having authority or power under any law to receive or require to be made such other statement notwithstanding that the person making the statement is not under any legal or other obligation to tell the truth, shall be guilty of an offence and shall on conviction be liable to a fine not exceeding N100,000 or to imprisonment for a term not exceeding 2 years or both.

5. EFFECTIVENESS OF THE ACT IN COMBATING FINANCIAL CRIMES

Section 1(1) of the Act[37] provides for the establishment of the Commission with its functions outlined in Section 6 of the Act. The EFCC Act vests the Commission with exhaustive and sweeping anti-corruption functions, which include investigating financial crimes and adopting measures for the identification, tracing, freezing, seizure and confiscation of the proceeds of terrorist activities and economic and financial crimes. The EFCC Act also ascribes a wide and open-ended definition to the term economic and financial crimes, which necessitates it (the Commission) to liaise with several other law enforcement agencies.[38]This paper opines that the provisions of the Act cannot be effectively achieved without the Commission.[39] It is the Commission that carries out the provisions of the Act. Therefore, the effectiveness or otherwise of the Act in combating financial crimes is dependent on the extent to which the Commission applies the provision of the Act in prosecuting and combating financial crimes.

Since the establishment of EFCC, the Commission has been able to recover moneys from alleged corrupt officials. EFCC in 2017 and 2018 has achieved tremendous success, for instance in January 2017, EFCC directed two directors of Ontario Oil and Gas Limited to make restitution of 754 million naira (US$2,464,952), and they were also sentenced to 69 years by Justice Latifat Okunmu of Lagos State High Court. In February 2017, the Commission has recovered N3.04 billion naira (US$9,803,921) from Andrew Yakubu, former Group Managing Director of NNPC. Two ex-governors, Joshua Dariye and Jolly Nyame of Plateau and Taraba States were each convicted and sentenced by a Federal Capital High Court to 14 years imprisonment. Thus the 473 billion naira ($153,744,336) recovered in 2017 included the US$43 million recovered from an apartment in Osborne Towers in Lagos, and money recovered from Allison Madueke (the former Minister of Petroleum). Payment of US$1,044,724 to 20 whistleblowers who provided information that led to the recovery of over 11.6 billion naira in 2017. From May 2003 to June 2004, EFCC recovered money and assets of over N700 billion and arrested over 500 on advance fee fraud cases.

From 2010 to 2014, EFCC recovered N65.3 billion (US$360 million). Between January 2015 and November 2018, EFCC secured 703 convictions. Out of these convictions, 103 and 194 were in 2015 and 2016, respectively. Cases of advance fee fraud accounted for 54% of offences investigated by the EFCC in 2015, while in 2014 and 2013 the Commission investigated 59% each in both years. 33% of the cases were federal-related investigations, 58% and 9% were for state and local governments, respectively. However, most of these prosecutions were targeted at opponents and were being subjected to frequent political interference and are often seen as an arm of the incumbent government without an independent mandate[40]. While corrupt public officials in Nigeria appeared to be protected from the anti-graft institutions as long as the president desired, whereas oppositions or non-loyalists are being terrified by those institutions.[41] In an effort to repatriate stolen money from abroad that was diverted during Abacha’s administration between 2002 and February 2020, the sum of $4.6 billion (N1.4 trillion) was repatriated to Nigeria. Despite these achievements, EFCC has been accused of not informing the public about the status of cases of many governors, whether such cases have been settled out of court or not.[42]

Currently, the EFCC is seeking to arraign the former governor of Kogi State, Yahaya Bello before the Federal High Court, Maitama, Abuja whose arrest was forestalled by the Kogi State High court. The State High court ruled that the attempt to arrest, detain and prosecute the estranged governor unjustly without proper investigation was a breach of his fundamental right.[43]The former governor is being prosecuted by the EFCC on 19 counts bordering on alleged money laundering, breach of trust, and misappropriation of funds to the tune of N80.2 billion.[44]The anti-graft commission had declared Bello wanted after his successor, Governor Usman Ododo allegedly whisked him away on April 17, 2024, preventing EFCC operatives to arrest Bello when they laid siege to his Abuja residence. The Commission has also received a refund of the sum of $760,910 by the American International School Abuja for an advanced school fees paid to the school by Yahaya Bello.

The EFCC has filed fresh charges, including alleged fraudulent foreign exchange allocation of $2 billion, against former CBN governor, Godwin Emefiele. In the fresh 26-count charge filed at the Lagos State High Court in Ikeja, the anti-graft agency said Mr. Emefiele, while being CBN Bello, governor, arbitrarily allocated foreign exchange in the aggregate sum of $2 billion.[45] In the Abuja case, the Abuja Anti-Corruption Court Commission, EFCC, accused the former CBN governor of criminal conspiracy, conferring undue advantage, and breach of trust, among Court others, but Ododo, theft, range Mr. Emefiele denied the allegations originally captured in six counts. He was first arraigned on 28 November 2023 before the EFCC amended the charges necessitating a re-arraignment. The Commission, in the amended charges, increased the number of counts from 6 to 20. The offences, according to the arresting EFCC, contravened the provisions of Sections 17 and 19 of the Corrupt Practices and Other Related Offences Act, fee 2000, as well as Sections 315, 363 and 364 of the Penal Code.

The Chairman of the Economic and Financial Crimes Commission (EFCC), Ola Olukoyede, has said that the anti-graft agency recovered N30 billion in the case involving former Minister of Humanitarian Affairs and Poverty Alleviation, Betta Edu[46]. The Minister was suspended following the approval of N545.2 million into a private account. Following the development, the president ordered an investigation into the allegations and subsequently suspended her from office.[47] The Commission says it has not absolved any of the suspects facing investigations over allegations of corruption perpetrated at the Ministry of Humanitarian Affairs, Disaster Management and Social Development.[48]

In addition, there are a plethora of reported cases of commission of financial crimes by individuals. The acts that constitute the commission of this crime ranges from fraud, identifying theft to even obtaining by false pretense. For instance, a report showing the conviction of 8 internet fraudsters, also referred to as ‘yahoo yahoo boys’ by the Federal High Court sitting in Calabar, Cross River State, on two count separate charges bordering on criminal impersonation, identity theft and obtaining by false pretense.[49] Another instance can be seen in the arrest of ex-bankers for fraud to the tune of N4.2 million by the Commission.[50] These are among the many cases handled by the commission to curtail the widespread financial crimes in the country.

[1]I. Ahmed, ‘Economic and Financial Crimes Commission (EFCC) and Anti-Corruption Crusade in Nigeria: Success and Challenges’ [2021] 4 GIJMSS <> accessed 5 June 2024

[2] 2004

[3] 1995

[4] 2000 No 5 Laws of the Federation of Nigeria

[5]1994

[6]EFCC, History of EFCC, <http://www. efcc.gov.ng/efcc/about-us-new/history-of-efcc> accessed 6 June 2024

[7]Section 1 (1) (C) EFCC Act 2004

[8]KayodeOladele, ‘The Legal Basis For Relevance, Role and Existence of EFCC – A Rejoinder to Agbakoba’ (2023) <https://www.thecable.ng/the-legal-basis-for-relevance-role-and-existence-of-efcc-a-rejoinder-to-agbakoba/amp/> accessed 9 June 2024

[9]D. Oyewale, ‘EFCC secures 3,175 convictions, recovers N156 billion in one year’ Premium Times (Nigeria)

[10]I. Umar ‘Challenges of the Economic and Financial Crimes Commission and Their Influence on Adoption of Forensic Accounting: A Conceptual Framework’ (2016) QRC  <https://www.google.com/url?sa=t&source=web&rct=j&opi=89978449&url=https://qualitative-research-conference.com/download/proceedings-2016/37-ibrahim%2520umar%2520105 109.pdf&ved=2ahUKEwiq1qC7q86GAxXpTkEAHaBcALMQFnoECB0QAQ&usg=AOvVaw1va9o35qnjgsXf8UQK1ZoJ>  accessed 7 June 2024

[11]Economic and Financial Crimes Commission (Establishment) Act 2004

[12]Ikhu-Omorege Sunday and Enimola Henry Bamidele, ‘Financial Crime and its Implications on Banks Performance in Nigeria: A General Appraisal’ International Journal of Sciences: Basic and Applied Research <https://www.core.ac.uk> accessed 26 June 2024

[13]Ibrahim Umar, Rose Shamsiah Samsudin, Mudzamir Mohammed, Ascertaining the Effectiveness of the Economic and Financial Crimes Commission (EFCC) in Tackling Corruptions in Nigeria (2018) Journal of Financial Crime <https://doi.org/10.1108/JFC-01-2017-003> accessed 2 July 2024

[14]Onipe Adabenege Yahaya, Impact of Financial Crimes on the Nigerian Economy, <https://www.researchgate.net/publication/358769842> accessed 26 June 2024

[15]ibid

[16]Section 6 (a)-(q) EFCC Act 2004

[17]Kalau v FRN &Ors (2016) LPELR – 40108 (SC); Section 7 (1) (a)

[18] Section 7 (1) (a) EFCC Act 2004

[19]ibid (b)

[20]Ibid (2) (a)(b)(c)(d)(e)(f)

[21]Nwude v. FRN &Ors(2015) LPELR – 25858  (CA)

[22]Ibid

[23]Nwobike v FRN (2021) LPELR – 56670 (SC)

[24]Section 14 of EFCC Act 2004

[25]Black’s Law Dictionary (9^thedn, Thomas Reuters, St Paul MN 2009)

[26]Romrig (Nig) Ltd v FRN (2017) LPELR-43834 (SC)

[27]Section 15 EFCC Act 2004

[28]Ibid (1)

[29]Ibid (2)

[30]Ibid (3)

[31]Section 16 EFCC Act 2004

[32]Section 18 (1)(a)(b)(c)(d) and (2) EFCC Act 2004

[33]Section 27 EFCC Act 2004

[34]Section 32 EFCC Act 2004

[35]Section 38 EFCC Act 2004

[36]Section 39 EFCC Act 2004

[37]EFCC Act 2004

[38]Emilia Onyema et al, The Economic and Financial Crimes Commission and the Politics of (in) Effective Implementation of Nigeria’s Anti-corruption Policy, (2018) <https://eprints.soas.ac.uk/31283> accessed 1 July 2024

[39]Jonah, Uyo-obong Ime, B.L, LL b (Hons)(Calabar); in private practice with Phoenix & Volge LP 100 Marian NLC building, Calabar, Cross River State. Email: uyobongjonah8@gmail.com

[40]Onyema et al, ‘The Economic and Financial Crimes Commission and the Politics of Effective Implementation of Nigeria’s Anti-corruption Policy’ ACE SOAS Paper No. 7/2018 <https://ace.soas.ac.uk> 1 July 2024

[41]Musa I. ‘Assessment of the Effectiveness of Anti-corruption Institutions in the Federal Public Service of Nigeria’(Doctoral dissertation, Ahmadu Bello University 2011) <http://www.kubanni.abu.edu.ng//> accessed 1 July 2024

[42]ibid

[43]Dennis Erezi, Court restrains EFCC from arresting, prosecuting Yahaya Bello, The Guardian <https://guardian.ng/court-restrains-efcc-from-arresting-prosecuting-yahaya-bello/> accessed 6 July 2024

[44]KayodeOyero, Yahaya Bello: EFCC confirms receipt of $760,000 from Abuja American School, Channels https://www.google.com/amp/s/www.channelstv.com/2024/04/27/yahaya-bello-efcc-confirms-receipt-of-760000-from-abuja-american-school/amp/  accessed 6 July 2024

[45]AmehEjekwonyilo, EFCC to Arraign Emefiele on Fresh Fraud Charges, Premuim Times, <https://www.premuimtimesng.com> accessed 6 July 2024

[46]Kingsley Nwezeh, EFCC Probing 50 Bank Accounts Linked To Betta Edu’s Stashed Funds Case, Recovers N30bn, Arise News <https://www.arise.tv/efcc-probing-50-bank-accounts-linked-to-betta-edus-stashed-funds-case-recovers-n30bn/> accessed 6 July 2024

[47]ibid

[48]Ameh Ejekwonyilo, Betta Edu SadiyaFarouq, Others Not Yet Cleared of Alleged Fraud-EFCC, Premium Times <https://premiumtimesng.com/news/top-news/686059-betta-edu-sadiya-farouq-others-not-yet-cleared-of-alleged-fraud-efcc.html> accessed 6 July 2024

[49] Lovina Anthony, ‘EFCC Secures Conviction of 8 Internet Fraudsters in Uyo’, Daily Post <https://dailypost.ng/2024/06/22/efcc-secures-conviction-of-8-internet-fraudsters-in-Uyo/> accessed 24 June 2024

[50] Adetutu Sobowale, ‘EFCC Arrest Ex-bankers For N4.2m Fraud’, Punch <https://punchng.com/efcc-arrests-ex-bankers-for-n4.2m-fraud/> accessed 23 June 2024