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Executive Summary:

The second quarter of 2020 has seen the globe continue to navigate the complexity created by the COVID-19 pandemic. These unprecedented times have sparked economic and political crisis across the world, while organisations seek to respond to an increase in cybercrime, and a resurgence of bribery and corruption risk as organisations move entirely online and as people adjust to work from home. Additionally, aid funding intended to combat the effects of the virus constitute a new target for criminals.

Locally, South Africa’s Government has cautiously sought to relax its lockdown restrictions, in an attempt to reignite the economy. The small sense of normality beginning to set in, has seen the Zondo Commission of Inquiry into State Capture resume its hearings on 29 June 2020. Additionally, the much anticipated corruption case against former President Jacob Zuma and the Thales Group, is set to commence imminently. The country’s National Prosecuting Authority has also begun criminal proceedings against the eight individuals accused of racketeering, theft, fraud, corruption and money laundering, which ultimately lead to the collapse of VBS Mutual Bank.

Angola has seen Africa’s richest woman, Isabel dos Santos, attempting to have her assets unfrozen following allegations by Angola’s attorney general of corruption. The Kenyan Government is in the process of implementing harsher corruption and bribery laws, in an attempt to curb corruption within the country.

We trust that you will find this edition informative and we remain at your disposal should you have any queries in this regard. Stay safe.

Anti-Bribery and Corruption Developments
South Africa
Title Summary
(now trading as African Global Operations)
  • On 07 June 2020, former Chief Operations Officer of BOSASA, Angelo Agrizzi (Agrizzi), received a letter of demand in the amount of ZAR 91 million (circa USD 5,381,180) from the liquidators who are in the process of winding-up BOSASA. Agrizzi is stated as being the first executive employee of BOSASA to face financial implications as a result of the corruption alleged to have been perpetrated by BOSASA. As will be recalled, BOSASA is accused of having bribed (or caused bribes to have been paid) to various Government officials, in order to secure various contracts with the Government.1
  • On 03 June 2020, it was reported that the National Council of Provinces had confirmed the provisional suspension of the Chief Magistrate in Pretoria, who was alleged to have received various security-related improvements by BOSASA, valued at ZAR 200,000 (circa USD 11,826). The Minister of Justice, Ronald Lamola, in February, had informed Parliament of the provisional suspension of the Chief Magistrate, pending the outcome of an investigation into his fitness to hold office. The Magistrate’s Commission recommended the suspension after having conducted a preliminary investigation.2
  • On 23 May 2020, it was reported that the head of the investigative directorate of the National Prosecuting Authority (NPA), Hermione Cronjé (Cronjé), informed the Portfolio Committee on Justice and Correctional Services, in Parliament, that various BOSASA related prosecutions are ready to be instituted. Cronjé confirmed that the matters already before court related to BOSASA formed part of the first phase of the NPA’s investigations, and that the second phase relates to evidence led at the Zondo Commission of Inquiry into State Capture.3
  • On 18 June 2020, it was reported that the country’s power utility, Eskom, was making significant progress in dealing with corruption within the utility, as various employees continue to lay complaints of instances of corruption. Eskom’s Chief Executive Officer, Andre De Ruyter, informed Parliament that the utility has also made headway in recovering funds in relation to contracts, which he believes were irregular, which includes a ZAR 5 billion (circa USD 295,669,250) claim against Tegeta, the Gupta-owned mine, which is currently in business rescue.4
  • On 26 May 2020, it was reported that the fraud and corruption case, involving Eskom, was being delayed by an accused (who cannot be named prior to his first appearance in court) based in the United Kingdom (UK), whom the National Prosecuting Authority has admitted is struggling to extradite as a result of the COVID-19 pandemic. The fraud and corruption case is said to involve a ZAR 745 million (circa USD 44,054,718) contract for the installation of two air-cooled condenser units at the utility’s Kusile power station. Along with the UK based accused, four former Eskom senior managers are also co-accused.5
Former President Jacob Zuma 
  • On 17 June 2020, it was reported that former President, Jacob Zuma’s (Zuma), case involving arms company, Thales Group, relating to charges of bribery, is expected to resume in the Pietermaritzburg High Court, under strict COVID-19 regulations.6
  • On 15 June 2020, it was reported that Zuma sought leave to appeal from the country’s apex court, the Constitutional Court, in relation to the decision handed down by the Kwa-Zulu Natal High Court, which found that Zuma had defamed ANC veteran Derek Hanekom (Hanekom). Zuma’s attorneys filed the requisite court papers pleading that there were reasonable prospects of success in relation to Zuma’s case, and that the High Court had failed to recognise that Zuma’s tweet, in which he called Hanekom an apartheid spy, enjoyed the protection contained in section 16 of the Constitution.7
  • On 27 May 2020, it was reported that Zuma’s legal team would reject any plans by the National Prosecuting Authority (NPA) to move Zuma’s corruption trial to 2021, pursuant to having had sight of communications between the NPA and the Kwa-Zulu Natal High Court Judge President. Zuma’s legal team indicated that they would want the trial to commence as soon as possible, and claimed that the NPA wished to postpone the trial in order to amend the original indictment against Zuma to include further charges.8
  • On 26 May 2020, it was reported that Zuma accused the Kwa-Zulu Natal High Court Judge President of having had inappropriate discussions with the NPA relating to his pending corruption trial, with Zuma’s legal team stating that they should have been part of the discussions. The pending corruption trial against Zuma related to the multi-billion Rand arms deal involving arms company, Thales Group. Zuma’s legal team furthermore stated that the discussions between the Kwa-Zulu Natal High Court Judge President and the NPA involved aspects surrounding the NPA’s intention to amend the indictment against Zuma, in order to include a number of payments from Schabir Shaik to Zuma, and that it was therefore inappropriate that the Kwa-Zulu Natal High Court Judge President had knowledge of the NPA’s evidence prior to the commencement of the trial.9
National Prosecuting Authority (NPA)
  • On 24 June 2020, it was reported that the former Chief Financial Officer of the VBS Mutual Bank, Philip Truter (Truter), would no longer appear in court, as had initially been anticipated, as Truter was in quarantine as a result of COVID-19. Truter and seven other co-accused, are facing charges of racketeering, theft, fraud, corruption and money-laundering, which lead to the eventual collapse of the VBS Mutual Bank. The NPA, however, stated that his appearance had been postponed.10
  • On 22 June 2020, it was reported that the company Albatime, together with Chief Executive Officer Kubentheran Moodley, have been restrained from handling their assets amounting ZAR 232 million (circa USD 13,719,053) after the same amount was received by the company as a kickback from the Regiments Group of Companies, relating to contracts that were improperly awarded. It is alleged by the NPA that the payments were made as a reward for the company’s unlawful role in the corrupt scheme.11
  • On 21 June 2020, it was reported that the NPA is investigating the circumstances surrounding the allegations of theft from the Unemployment Insurance Fund COVID-19 relief fund, amounting to ZAR 3.2 million (circa USD 189,228). It is alleged that the funds were unlawfully transferred to an employee of CSG Resourcing, together with other individuals. The funds were required to have been paid to 200 employees of different companies by CSG Resourcing, but was rather paid to an employee who then immediately transferred the amount to various other bank accounts. The NPA was, however, successful in obtaining a preservation order after the funds were paid into the employee’s bank account.12
  • On 19 June 2020, it was reported that the NPA was unsurprised of the eight co-accused involved in the VBS Mutual Bank scandal’s statement of them not being guilty. The NPA indicated that it is prepared to proceed to trial and that the indictment against the eight co-accused connotes a systematic and coordinated looting at VBS Mutual Bank, with looting of nearly ZAR 2.7 billion (circa USD 159,661,395), with all co-accused’s having been alleged to have walked away with vast amounts.13
  • On 18 June 2020, it was reported that the NPA’s Asset Forfeiture Unit was prepared to deal with claims for compensation for victims of the VBS Mutual Bank looting, who suffered losses. The NPA also welcomed the Palm Ridge Regional Court’s decision to place each of the eight co-accused on ZAR 100 000 (circa USD 5,913) bail.14
  • On 10 June 2020, it was reported that the Minister of Justice, Ronald Lamola (Lamola), stated that the NPA was not dependent on the Zondo Commission of Inquiry into State Capture having completed its work, in order to commence with prosecutions surrounding State Capture. Lamola was responding to the Democratic Alliance’s Leon Schreiber, who asked what the Government’s position was in relation to immediately prosecuting those implicated at the Zondo Commission of Inquiry into State Capture. In elaborating on his response, Lamola indicated that the position of the NPA is that criminal investigations and consideration for prosecution is a parallel process to the work of the criminal investigations and consideration for prosecution is a parallel process.15
  • On 01 June 2020, it was reported that President Cyril Ramaphosa (Ramaphosa) appointed Advocates Ouma Rasethaba and Rodney de Kock, as the Deputy National Directors of Public Prosecutions. Additionally, Ramaphosa has appointed Advocate Mthunzi Mhaga as a Special Director of Public Prosecutions in the Office of the National Director of Public Prosecutions. Ramaphosa noted that the appointments were necessary to ensure the proper functioning of the NPA as part of the fight against corruption.16
  • On 23 May 2020, it was reported that the head of the investigative directorate of the NPA, Hermione Cronjé (Cronjé) indicated that allegations of the NPA not progressing various high profile cases was untrue. Cronjé briefed Parliament and stated that the NPA have various high-profile cases that involve the security sector, which are already before court.17
PIC Investigation
  • On 05 June 2020, it was reported that an independent inquiry into the PIC’s Chief Financial Officer, Matshepo More (More), has found that she had served in the interests of the fund manager at the time the PIC had entered into the somewhat controversial deal with Ayo Technology Solutions (Ayo), as having withheld crucial information from the PIC’s Portfolio Management Committee (PMC) regarding the fund manager’s investment with Ayo, did not place the PIC at a disadvantage. As part of an internal investigation instituted by the PIC board, More was charged with signing a settlement memorandum before the PMC had approved the transaction.18
  • On 29 May 2020, it was reported that the Board of Directors of the PIC decided to extend the suspension of More despite the disciplinary inquiry having found her not guilty. More was suspended in March 2019 for her alleged role in various irregularities relating to its investment with Ayo.19
  • On 27 May 2020, it was reported that the PIC had appointed Abel Sithole (Sithole) as its new Chief Executive Officer. Sithole’s appointment seeks to fill the post that had been vacated 18 months ago by his predecessor due to allegations of questionable investment decisions.20
Public Audit Amendment Act
  • On 24 June 2020, it was reported that Deputy Auditor-General, Tsakani Maluleke (Maluleke), provided a grim outlook on the state of municipalities in South Africa, whilst reporting on the local government outcomes for the 2018/2019 financial year. Maluleke indicated that only circa 8% of municipalities had managed to obtain clean audits, with fruitful, wasteful and unauthorised expenditure remaining the largest issue. Maluleke said that just over ZAR 2 billion (circa USD 118,267,700) in fruitless and wasteful expenditure was recorded, while almost ZAR 12 billion (circa USD 709,606,200) of the expenditure was unauthorised.
Public Protector
  • On 29 June 2020, it was reported that the Supreme Court of Appeal had dismissed the Public Protector’s, Busisiwe Mkhwebane’s (Mkhwebane), application for leave to appeal the judgment relating to the Estina Dairy Farm with costs, on the grounds that there was no reasonable prospects of success for Mkhwebane in the appeal.22
  • On 16 June 2020, it was reported that, during a briefing in Pretoria, Mkhwebane reported that her Office had closed 13 reports, citing that her decision to close the investigations was as a result of her office finding that the allegations were unsubstantiated. Of the reports closed, such included:
    • an investigation into allegations that Western Cape Health MEC Nomafrench Mbombo received benefits or sponsorship during a special birthday celebration in 2016; and
    • an investigation into allegations of maladministration and improper conduct in connection with a Master Service Agreement entered into between Eskom and McKinsey Company Incorporated, as well as payments made to Trillian Capital and Partners. Mkhwebane indicated that these allegations were referred to the State Capture Commission, and cited that a High Court had also made a ruling on it.23
  • On 15 June 2020, it was reported that Mkhwebane would be releasing her first media briefing for the 2020/2021 financial year. Mkhwebane indicated that the investigation into the Vrede Dairy Farm project was at an advanced stage, and was expected to be complete by the end of March 2021.24
  • On 09 June 2020, it was reported that Herman Mashaba (Mashaba), the former Mayor of Johannesburg, sought to have Mkhwebane cover his legal fees in his review of her draft report, which shows that Mashaba was guilty of contravening supply chain management policies, had a conflict of interest and made irregular appointments. In her findings, Mkhwebane notes Mashaba’s alleged irregular appointment of former Johannesburg Metro Police Chief, David Tembe, the wrongful extension of a KPMG contract and the irregular funding of an NGO with links to Mashaba’s wife.25
  • On 04 June 2020, it was reported that the High Court in Pretoria held that Mkhwebane’s report, which found that Police Minister Bheki Cele (Cele), had failed in his duties by not providing the protection of whistle-blowers, must be set aside. It is alleged that two whistle-blowers exposed wrongdoing in the Umzimkhulu municipality in KwaZulu-Natal, and that the South African Police Service should have done more to provide the necessary protection for the whistle blowers. In the court’s findings, it agreed with Cele that this is a function which must be exercised by the Department of Justice.26
  • On 27 May 2020, it was reported that the African National Congress’ Secretary General, Ace Magashule (Magashule), was the subject of a criminal complaint to the Hawks, after a representative of the Democratic Alliance filed charges against Magashule for ignoring various irregularities in relation to the contract between the Department of Human Settlements and the Blackhead Consulting/Diamond Hill Joint-Venture in 2014, and that he failed to stop payments being under the contract, which he is alleged to have known were fraudulent.27
  • On 17 May 2020, it was reported that as part of the Public Protector’s Office’s contribution to funding the COVID-19 fiscal support package, it would be facing a further ZAR 58 million (circa USD 3,429,763) cut from its budget, which would have long term effects on its operations.28
Specialised Commercial Crimes Court
  • On 25 June 2020, it was reported that the Hawks have made further arrests in relation to the alleged looting of the VBS Mutual Bank, with the arrest of former Manager: Budget and Treasury of the Merafong Local Municipality, Mattheys Gerhardus Wienekus (Wienekus). Wienekus has been charged with the contravention of the Municipal Finance Management Act in relation to the ongoing investigation into VBS Mutual Bank. It was reported that investigations have revealed that more than ZAR 50 million (circa USD 295,669) was invested with VBS Mutual Bank whilst Wienekus was the acting Chief Financial Officer at the municipality.29
  • On 12 June 2020, it was reported that the Hawks had made an arrest of a South African National Defence Force (SANDF) warrant officer from the Mtubatuba Military Base, in KwaZulu-Natal. It is alleged that the SANDF warrant officer demanded a bribe in the amount of ZAR 50,000 (circa USD 2,956) from a widow, who had asked him to process her husband’s death claim. The SANDF warrant officer has been granted bail and is due to appear in the Durban Specialised Commercial Crime Court on 24 July 2020.30
  • On 29 May 2020, it was reported that two woman were accused of defrauding the KwaZulu-Natal Transport Department of ZAR 1.8 million (circa USD 106,440) after it is alleged that the claimed such for amounts for a road construction project in Umzimkhulu in 2013 that never materialised. The two have been charged with fraud and corruption and are due to appear in the Durban Specialised Commercial Crimes Court.31
  • On 13 May 2020, it was reported that a former technician of the Gautrain had been sentenced to a term of imprisonment of ten years by the Johannesburg Specialised Commercial Crimes Court after he unlawfully installed spyware to various computers at the Gautrain Management Agency in Midrand. The former technician was convicted of 38 counts of contravening sections of the Electronic Communications and Transactions Act, which the court grouped together in accordance with the nature of spyware used.32
South African Government
  • On 29 June 2020, it was reported that Chairperson of the State Capture Commission, Raymond Zondo (Zondo), stated that he wants political leaders and elected officials to inform him at the State Capture Commission, what action they had taken in relation to the allegations of various instances of corruption at State-Owned Entities. Zondo indicated that the former Chairperson of the Passenger Rail Agency of South Africa (PRASA), Popo Molefe (Molefe), had testified at the commission that during his tenure as Chairperson of PRASA, he had briefed the African National Congress’ (ANC) “top six” leadership on the Board’s investigation that revealed significant corruption at PRASA, and that the “top six” did not revert to Molefe on what action would be taken against such acts of corruption.33
  • On 12 June 2020, it was reported that the National Prosecuting Authority’s (NPA) Investigating Directorate, would oppose bail for one of the 16 senior police officers of the South African Police Service (SAPS), who was linked to a ZAR 56 million (circa USD 3,311,495) tender fraud for police vehicle markings, whereby supply chain management officials responsible for awarding the contract in 2017, were allegedly paid kickbacks. The senior SAPS members face various charges of fraud, corruption, theft and money laundering.34
  • On 05 June 2020, it was reported that Gauteng Premier David Makhura (Makhura) denied having any links to businessman Hamilton Ndlovu (Ndlovu), after various allegations surfaced that Makhura had given the go-ahead on a multi-million Rand contract to supply the province with personal protective equipment (PPE) in Ndlovu’s favour. Makhura cited that there has, at all times, been a clean and prudent management of the procurement process to ensure that there is no corruption happening with the procurement of PPE.35
  •  On the 30 May 2020, it was reported that the South African History Archives Trust (SAHAT) was successful in its application against the South African Reserve Bank (SARB), in relation to access to records that may shed light into foreign exchange fraud, Eskom bonds and gold smuggling during Apartheid, after the Supreme Court of Appeal held that the SARB’s refusal for access to the records, was contrary to the provisions of Promotion of Access to Information Act.36
State Capture Commission
  • On 26 June 2020, it was reported that the Zondo Commission of Inquiry into State Capture (Zondo Commission), will resume its hearings on Monday, 29 June 2020, and will continue to hear evidence into allegations of corruption at the Passenger Rail Agency of South Africa (PRASA). Some of the witnesses who will testify at the Zondo Commission include former Chairperson of the Board of Directors, Popo Molefe, Head of Legal, Martha Ngoye, and an estate agent, who is alleged to have sold a certain property to a former official at the agency.37
  • On 22 May 2020, it was reported that the Minister of Justice, Ronald Lamola, noted to Parliament that the Zondo Commission is continuing its work in the background despite the nationwide lockdown as a result of COVID-19. Prior to the implementation of the nationwide lockdown, the Zondo Commission was granted a final extension until March 2021, in order to complete its work.38


Anti-Bribery and Corruption Developments
Sub Saharan Africa
Title Summary
  • On 13 May 2020, it was reported that Africa’s richest woman, Isabel dos Santos (dos Santos), has called to have her assets unfrozen. In a statement, dos Santos indicated that the evidence used to freeze her assets in both Angola and Portugal, following allegations by Angola’s attorney general of corruption, was false. A fake passport was allegedly used as evidence, together with emails regarding a fraudulent investment in Japan. A statement subsequently released by an Angolan prosecutor revealed that the seizure of dos Santos’ assets was not based on the alleged forged identification document, but rather on a decision by the Criminal Chamber of the Supreme Court of Angola to seize the assets and that no such passport copy was used as evidence.39
Democratic Republic of Congo (“DRC”)
  • On 14 June 2020, it was reported that a nine-month investigation lead by The New Humanitarian had been made public, bringing to light a multi-layered scam by Government officials within the DRC of instances of appropriating funds of humanitarian organisations for personal profit. The report includes interviews spanning over two years with employees for the UN, non-profit organisations and aid recipients nationwide, where kickbacks have been demanded from employees, in exchange for lucrative contracts. It is reported that bribes up to the value of up to 30% for contracts between supplies and aid groups have been uncovered The United Nations has made a statement to public, in which they are “carefully considering” the findings in the report.40
  • On 13 May 2020, it was reported that the trial of Vital Kamerhe (Kamerhe) has been adjourned. Kamerhe is accused to have been involved in embezzling a portion of USD 500 million, which was intended to finance major works within the country. Kamerhe is charged with two other defendants, namely, Samih Jammal (Jammal) and Jeannot Muhima Ndoole. Further to the USD 500 million, Kamerhe together with Jammal, is accused of embezzling nearly USD 49 million. Kamerhe has, however, denied even knowing Jammal.41
  • On 28 May 2020, it was reported that the United Kingdom’s Anti-Corruption Summit, held in 2016, required invited Heads of State to commit to selected anti-corruption themes and to provide a timeline for when they would achieve these themes, which has assisted Ghana in meeting their themes between 2016 and 2019. The Ghana Integrity Initiative, which is working alongside the Ghana Anti-Corruption Coalition, is implementing a project called “Making All Voices Count in the 2020 Anti-Corruption Agenda of Political Parties’ Manifestoes”. It is envisaged that this project will help increase the citizen’s voices in their anti-corruption agenda of political parties.42
  • On 15 May 2020, it was reported that the Chairman of the New Patriotic Party, Bernard Antwi-Boasiako, stated that he is of the opinion that before the next general government elections, Mahama and some of his appointees will be tried and jailed for corruption. This follows after it was alleged that Mahama is Government Official 1.43
  • On 27 June 2020, it was reported that the Kenyan Government is in the process of implementing harsher corruption and bribery laws, in an attempt to curb the current statistics within the country. A proposed amendment to the Bribery Act, which is currently being tabled in Parliament, seeks to allow for the imposition of a fine amounting to KSh 5 million (circa USD 46,939) or for a period of imprisonment not exceeding ten years, where an individual is aware of, or suspects bribery taking place and fails to report it. The current legislation, only imposes a responsibility on state officers to report bribery and corruption.44
  • • On 19 June 2020, it was reported that the Statute Law, Miscellaneous Amendments Act 2020 (the Act), now imposes an obligation on the judiciary to determine all cases that involve bribery and/or corruption, to be determined within two years from date of filing. Prior to the enactment of the Act, there was no time-limit for such matters to be determined by. The Act provides that Government officials will automatically be placed on leave if they are investigated in their personal or official capacity and this period shall last until the case has closed, a blanket exemption only applies to the President.45
  • On 27 May 2020, the former manager of the domestic taxes department, Robert Maina Ngumi (Ngumi), has been issued a fine of KSh2 million (circa 18 800 USD) for soliciting and receiving a KSh 15 million (circa USD 141,000) bribe from a businessman in order to reduce his tax arrears six years ago. Should Ngumi fail to pay the fine, he is to serve an 18-month prison sentence.46
  • On 27 May 2020, it was reported that Kenya’s Director of Public Prosecutions (DPP), Noordin Haji (Haji), has responded to allegations that his office has only one case before court relating to charges of corruption between October and December 2019. Haji, in his statement, defended this by stating that in order to bring such cases before court, one must have proof beyond a reasonable doubt and this falls squarely on the shoulders of the prosecution. Haji did not reveal how many cases were active, but cited the case of Migori Governor Okoth Obado who was allegedly involved in embezzling KSh35 million (circa USD 330,000), where the Prosecution was able to successfully freeze the assets of the accused. It was reported that, between October and December 2019, 12 cases were returned by the DPP to the anti-corruption committee while 18 were waiting for approval.47
  • On 22 May 2020, it was reported that there are various corporate bodies in Kenya which are protecting or shielding employees involved in graft or economic crimes, in order to protect their brand within the country.48
  • On 22 May 2020, it was reported that an officer from the Ethics and Anti-Corruption Commission, Richard Topila, and a driver, Kipyegon Kosgei, have been charged with receiving bribes from a traffic officer, George Manyala (Manyala), in order to do away with a case against Manyala, in terms of which he was being investigated for bribery. It is alleged that the bribes amounted to KSh 220,000 (circa USD 2,000).49
  • On 12 May 2020, it was reported that Mozambique’s Constitutional court has declared that the loans made to Proindicus and Mozambique Asset Management (MAM) were invalid, as the country’s Parliament did not provide any approval for such loans, thus rendering them illegal.50
  • On 11 May 2020, it was reported that prosecutors in Mozambique were calling for the dissolution of Proindicus, Ematum and MAM, due to their liquid assets being less than half of the value of the shareholders’ assets. It was reported that these companies’ business activities have been suspended for more than 3 years, after the companies took out various loans in 2013 and 2014 totalling 2.2 billion US dollars from Credit Suisse and VTB, which were guaranteed by the then government. Manual Chang (Chang) endorsed these loans when he had no authority to do so, which culminated in a financial crises within the country. Chang has been detained in South Africa since December 2018, whilst the US is seeking his extradition for trial in New York.51
  • On 29 June 2020, it was reported that a diplomat from the Netherlands, based in Nigeria had been dismissed pursuant to having made public allegations about conduct volving bribery and corruption between the Netherlands and Nigeria. It is alleged that this included the facilitation between the Dutch government and various companies, that have been found operating with corrupt practices.52
  • On 18 May 2020, it was reported that two Chinese nationals have been arrested for attempting to bribe the head of the Economic and Financial Crimes Community (EFCC) with N 100 million (circa 940 000 USD). This was to compromise investigations into a company called China Zhonghao Nig. Ltd. The company is currently under investigation for allegations relating to conspiracy, embezzlement and money-laundering.53
  • On 14 May 2020, it was reported that more details have emerged regarding Nigerian businessman, Abubakar Aliyu (Aliyu), who is allegedly involved in the OPL 245 scandal together with Eni. It was reported that Aliyu withdrew N 24 million in cash (circa USD 225 000), and some of these funds were used to bribe the “Goodluck Jonathan government”, which allegations Aliyu denies.
  • On 11 May 2020, it was reported that the Chief Financial officer of Eni, Mr Massirro Mondazzi, would be required to respond to many issues at Eni’s annual general meeting. This is following many allegations of bribery levelled against the company.
  • On 9 June 2020, it was reported that a new Director of Public Prosecutions, Justice Jane Frances Abodo, has been appointed to address and introduce harsh sanctions on corruption and illicit financial acts committed in Uganda. The appointment was made on 14 April 2020, however, with the onset of the COVID-19 pandemic instituting current and new laws seeking to impose harsher sanctions has been placed on hold.54
  • On 18 May 2020, it was reported that the International Monetary Fund (IMF) would monitor the USD 491,5 million COVID emergency loan it has extended to Uganda. The IMF has indicated that various systems of checks and balances have been put in place to ensure that the loan would not be misappropriated, but rather for addressing the COVID-19 pandemic.55

























































Darryl Bernstein is a partner and head of Baker Mckenzie's Dispute Resolution and TMT Practice Groups in Johannesburg, where he advises on the resolution of complex commercial disputes, regulatory compliance and investigations as well as contentious and non-contentious communications, media, privacy and technology matters. Darryl co-founded disputes-focused firm Rudolph, Bernstein & Associates in 2008 before joining Baker McKenzie with his entire team at the end of 2012. He acts for a wide range of clients listed on the Johannesburg Stock Exchange and on various international exchanges, along with a number of global multinational technology companies, particularly regarding their expansion into Africa.