Circles of impunity Of Aid Workers Sexual Violence On Victims In Africa

Armoured UN vehicles in the road, men wearing blue helmets on board, with some people in the foreground
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I first visited the North Kivu region of the Democratic Republic of Congo (DRC) in 1994 during the genocide in neighbouring Rwanda. In Goma’s emergency hospital, I witnessed rows and rows of rape survivors who had fled across the border.

A quarter-century later, it is hurting again in the same place, for the same reason: sexual violence. But what is different is that the alleged perpetrators are humanitarians, sent to save the community from a deadly Ebola outbreak. The humanitarian workers are said to have demanded sexual favours from women and girls trying to make a few dollars from low-level work in international agencies.

The initial exposé in 2019, including testimony by victims, pushed the World Health Organization to investigate its DRC operations belatedly in 2020. The consequent Independent Commission report took yet another year. It identified at least 83 alleged perpetrators, mostly Congolese but also foreign employees. This is just the tip as survivors are usually reticent to come forward.

Many women were forced to have sex without condoms, several had children and others were coerced to get abortions. The psychosocial impacts and stigmatisation of affected women ruined families.

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The report paints an appalling wider picture of prevailing sexual exploitation and abuse. Sexual exploitation is the misuse of power and trust to take sexual advantage of a more vulnerable or dependent person. When this leads to actual or threatened physical intrusion, it constitutes sexual abuse (including rape).

Sexual violence and attacks on healthcare were rife in the eastern DRC. Undeterred, the WHO resolved to do better in its Ebola response after heavy criticism of its poor performance in the 2014-16 West African Ebola outbreak. So, it expanded rapidly – eventually deploying 2,800 personnel.

These factors explain the context but not excuse the WHO’s careless deployment of unvetted, untrained staff, and management systems that initially played down complaints of sexual misdeeds, created bureaucratic obstacles for victims to be heard, and delayed timely investigation and correction.

This appalling failure has re-focused wider attention on the sexual misconduct that surfaces with disgraceful regularity in humanitarian, development, and peacekeeping operations worldwide. They get away with it because victims are routinely ignored, there is little accountability of perpetrators, and there are few costs for institutions that shield them.

Regular incidents in the aid sector

Sexual exploitation and abuse are widely prevalent. Egregious examples included criminal abuse by Oxfam staff in Haiti, some of whom moved from one country to another including Chad and DRC. There was also senior-level sexual misconduct at Save the Children. The Red Cross Red Crescent has not been immune with allegations of misconduct among its 192 National Societies and at the International Committee of the Red Cross and International Federation of Red Cross and Red Crescent.

Other UN bodies – including the UN refugee agency and the World Food Programme -– were among 40 agencies implicated in a food-for-sex scandal in West Africa.

The response is almost standard: the organisation apologises, promises to do better, and appoints sexual exploitation and abuse focal points. They make more regulations, design further guidelines, push gender equality, and institute greater staff training.

These are all recommended good practices. But, to avoid public embarrassment that undermines donor funding, the culprits are often not prosecuted. Instead, they are quietly fired or contracts are not extended.

Indeed, non-disclosure exit agreements or privacy rights mean that data on offenders are often not shared, allowing perpetrators to join another unsuspecting organisation and re-offend. Negligent managers on whose watch such things happen may get a mild rap or move to another role. They may even be promoted. The circle of impunity is thereby completed.

Peacekeeping operations

Peacekeeping operations have a long history of predatory sexual culture. Underage girls were kidnapped, raped and prostituted by UN and NATO personnel in Kosovo. In Bosnia, UN police officers operated a sex trafficking ring. More recently, peacekeepers from Gabon and France behaved horribly in the Central African Republic. But the record for rape and abuse by UN peacekeepers is in Congo: 700 of 2,000 worldwide allegations over 12 years.

The UN’s database shows that abusers come from all continents. Africans are prominent as both victims and abusers, indicating the high prevalence of both peacekeeping missions on the continent and African force contributions to them.

The UN is not short on rhetoric around sexual abuse and exploitation. It has a zero tolerance policy, a high-level Special Coordinator, a much-hyped strategy complete with its “circle of leadership”, a Conduct and Discipline Service, and many risk management tools and training. There is also as a do-no-harm Voluntary Compact signed by 103 states.

This impressive array is empowered by at least seven Security Council and General Assembly Resolutions and many statements issued by numerous high-level meetings.

Set up to fail

The system has commendable intent but is set up to fail. The UN has little authority other than to send home the errant peacekeepers. Few get disciplined by their home authorities; often cases are simply not investigated or are closed for “lack of evidence”.

The UN is usually reluctant to offend its Member States on whom it depends for peacekeepers. Serial abusers can get recycled from operation to operation. Cash-strapped nations can get their ill-trained and ill-disciplined militaries subsidised through deployment fees from the massive UN peacekeeping budget. Fragile states may also prefer to keep their soldiers abroad rather than making coups at home.

Meanwhile, the victim is left high and dry, without even the consolation of seeing her abuser held to account. Fearing that it would open the floodgates, the UN does not compensate victims who have suffered at the hands of its agents. The injustice is self-evident. The irony is that she has more likelihood of redress from a domestic court in a poorly governed nation with a weak legal system, than in the zone of international operations governed by immunity and impunity.

That is why what the WHO does now is of crucial importance. Its director general is commended for commissioning his own independent probe. He also earned trust by releasing its findings openly, without editing. He has boldly taken ultimate responsibility for his employees’ misdeeds.

What must change

The WHO remains under the microscope as it brings longer-term internal changes to prevent recurrence. Meanwhile, it must not tarry to make immediate amends. Three elements are crucial.

First and foremost, the victims must receive meaningful financial compensation, beyond medical and psychosocial support.

Second, everything must be done to trace the perpetrators and bring them to court.

Third, WHO managers who did not ensure a safe work environment must be held publicly accountable and incur penalties commensurate with their share of the responsibility for failure.

7 Sins of the Creative Brief

Why having a bad creative brief—or no brief at all—can sink an advertising campaign.

Advertising is hard. Launching a successful campaign in market requires a near-perfect confluence of brand strategy, media planning, and creative execution. Advertising can be thought of as a series of intricate gears that must turn with precision to have the clock strike at the right time; one gear out of place can make the entire clock lose time.

For this reason, it is no wonder that advertising often fails to achieve the impact marketers hope to see. Here, we discuss one insidious cause of poor advertising: “Seven Sins of the Creative Brief.” Brands that lead with a bad creative brief—or no brief at all—can often cause campaigns to unwind before they’ve even begun.

Most people with a modicum of exposure to advertising, brand management, or agencies are familiar with the creative brief: the core strategic document that is meant to guide the creative team on the preparation of the advertising execution. The problem is there’s a lot more to it than just knowing what a creative brief is or wanting a good brief. Where do people go wrong?

Sin #1: No Brief.

Perhaps the cardinal sin is the failure to develop a creative brief. We hear lots of reasons for this—not enough time; the creative team “already knows” this tactic and doesn’t “need” a brief. This reasoning has three key issues. Internally, the brief-development process forces marketers to understand what it is they need to accomplish and the strategic path to that end. Where will the growth come from? Externally, the creative team is flying blind without any guidance and their odds of landing on something impactful to your customer is up to chance. And finally, paradoxically, the lack of a brief frequently leads to longer development times, as teams debate what’s “right.” With no clear strategic stake in the ground, ideas are reworked on the basis of subjective feedback.

Sin #2: Poor Objectives.

In our various work with others’ briefs, we see objectives such as “make a digital campaign” or “increase sales.” These are poor and impoverished objectives because they do not convey what this specific advertising is meant to do. Increased sales can be a desirable outcome, but do the work to understand what metrics need to be moved and by how much to accomplish that business goal.

Sin #3: Targeting Everyone.

We bet this one resonates with a lot of readers. You ask your boss who the target is, and the response is, “Everyone.” The reality is the idea that we should target everyone is neither realistic nor sensible for most brands in most categories. Consumers are different—they have distinct functional and psychological needs—and this means you have to talk to them differently to be persuasive. Moreover, targeting everyone means you have a nearly inexhaustible media budget, which is out of reach for most brands. Let’s focus our energy and resources on the folks most likely to generate returns.

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Sin #4: The Lack of Insight.

The best advertising connects with the target customers because it shows understanding of their needs and pain points. However, obtaining insight is an involved process—it takes time to truly know your consumer. As a result, we see people try to cut corners. The problem is when they are wrong—and they often are—the creative team lacks a powerful way to connect with customers.

Sin #5: Overpacking Positioning.

Why should people buy your product? “Because it is durable, safe, fun, exciting, relaxing, eco-friendly, built by great people, etc.” All too often, brands take a shotgun approach to talking about everything they do well—and, as a result, their messages have no real teeth. When you say five things, you say nothing. Great positioning is having a focus on the key benefit that speaks to the insight about your customer.

Sin #6: Shiny-Object Syndrome.

“We need a TikTok strategy.” No, you need a strategy. TikTok may be a useful tactic to employ in the execution of that strategy. As new opportunities emerge, we see brands chasing the “shiny object” as opposed to starting with the strategy. New media channels can present exciting opportunities, to be sure, but don’t get caught chasing tactics. Chase your customer.

Sin #7: Bad Measurement.

The final sin is an interesting one. In an age where digital channels allow more measurement—exposure, click-through, and even purchase rates—brands routinely fail at measurement. How does this happen? The sin is not in a failure to measure, but in measuring without a plan. All too often, we see brands discussing their measurement strategy after the campaign. As a result, they are often not even set up to ask the right questions, and thus the results they get from measurement have little utility.

The Jihadist Genocide of Christians in Nigeria Intensifies

What several international observers have for years characterized as a ‘pure genocide’ of Christians in Nigeria has reached new levels. ‘We have never seen an evil government in this country like the one of today. The government is fully in support of

Source: The Jihadist Genocide of Christians in Nigeria Intensifies

Mental Health, A Neglected Pandemic

Pope Francis prays for those with mental illness and victims of suicide

Antoine Mekary | ALETEIA

Kathleen N. Hattrup10/10/21

The pandemic has made a tremendous tragedy even worse.

On the occasion of World Mental Health Day, Pope Francis turned his thoughts to those with mental illness and to victims of suicide.

After praying the midday Angelus on October 10, he said:

I would like to remember our brothers and sisters who suffer from mental illness, and also victims – often young people – of suicide. Let us pray for them and their families, so that they are never left alone, or discriminated against, but instead are welcomed and supported.

One billion people affected worldwide

In a message published this October 10 for World Mental Health Day, the Prefect of the Dicastery for Integral Human Development, Cardinal Peter Turkson, expressed concern that the pandemic had exacerbated the suffering of people with mental illnesses.

“It is estimated that before the Covid 19 pandemic, nearly a billion people around the world suffered from mental disorders,” he said, lamenting that the pandemic has exacerbated the difficulties.

Deploring the very wide disparities in the management of these diseases across the world – in some countries, “between 75% and 95% of people with mental disorders cannot access mental health services” – the Ghanaian cardinal pleaded for a strengthening of the health system, “in particular by supporting organizations engaged in scientific research on mental illnesses and by promoting models of social inclusion.”

Pandora Papers: Sitting Nigerian Governor Bagudu Amasses Dirty Billions And Hiding It

The sitting Governor of Kebbi State, North west Nigeria and one of the strong  backers of President Muhammadu Buhari has been exposed for corruptly amassing billions of dollars and hiding same in tax havens.
God, Save Nigerians from corrupt leaders!
Mr Bagudu was helped by British firms as he worked to conceal the huge wealth he made as a key member of the Abacha plunder machine.


ELEVEN years ago, Abubakar Bagudu, the current governor of Kebbi State, but then a senator, dispatched a delegation to Singapore in search of a new haven to shelter his controversial wealth, which is a target of ongoing forfeiture proceedings by the United States Department of Justice.

Investigators say the huge funds, warehoused offshore, is part of billions of dollars Mr Bagudu helped the Sani Abacha family to steal from Nigeria in the 1990s.

Referred by Farrer and Co., a prestigious centuries-old London law firm that has represented the British royal family, Mr Bagudu’s choice of secrecy provider in Singapore was Asiaciti Trust, an entity notorious for helping clients hide behind opaque offshore trusts to launder dirty money across borders.

The  Monetary Authority of Singapore, MAS, imposed a fine of one million and a hundred thousand dollars on Asiaciti in July 2020 for “serious breaches” of Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) regulations between 2007 and 2018.

When on February 23, 2010, Mr Bagudu’s delegation – comprising his brother, Ibrahim Bagudu, and London lawyer, Ben Davies, from Byrne and Partners, now a part of PCB Byrne – met with Asiaciti’s officials, they registered his preference for a new structure of secrecy to oil the flow of his dirty wealth for the benefits of himself and his family.

In 1997, some 13 years earlier, Mr Bagudu had structured offshore holdings Ridley Trust and Ridley Group in notorious tax and secrecy havens, Guernsey and the British Virgin Islands, positioning himself as the unseen but ultimate beneficiary. But in 2010, he wanted to terminate the Ridley structure and transfer his assets into another structure, hence the need for Asiaciti’s service in Singapore.

The reason, according to a 2010 Asiaciti memo, was control. As noted in the memo, Ibrahim told the February 2010 meeting that his brother, Mr Bagudu – “the client” – had become “disillusioned” with institutional and independent trustees (of the Ridley Trust) as they (he and his brother) had no control over their action or inaction and suggested they feared they could lose the hidden assets.

He then insisted that any new trustee arrangements to be erected in Singapore “must ensure that the family cannot lose ‘control’ of the assets.”

In the months that followed, 99 million euros in cash and securities was then transferred from Ridley to a new structure enabled by Asiaciti, which brushed aside red flags about Mr Bagudu’s controversial background and source of his wealth. Asiaciti acted with advice from Farrer and Co. and Byrne and Partners, now a part of PCB Byrne, documents showed.

Sani Abacha
Sani Abacha

Mr Bagudu is long known to have played an instrumental role in the Abacha conspiracy to steal and launder billions of dollars belonging to Nigeria. But how he set up complicated structures of secrecy to hide stolen money as well as the role of his enablers, including prestigious British law firms and Serious Organised Crimes Agency (SOCA) the predecessor of the National Crimes Agency (NCA), has never been crystal clear.

Pandora Papers investigation – led by the International Consortium of Investigative Journalists, including more than 600 journalists, including some from PREMIUM TIMES, and about 150 news organisations around the world – uncovered financial secrets, including those of politicians, former and serving public officials, including known and suspected kleptocrats such as Mr Bagudu. Involving 11.9 million leaked records, which journalists sifted through for two years, the Pandora Papers project is the biggest collaborative transnational investigation in the history of journalism.

The leaked records came from 14 offshore services firms from around the world who help clients set up shell companies and design opaque structures to conceal their financial dealings.

The Bagudu Blue structure

As documents showed, Asiaciti helped Mr Bagudu to set up a multi-layered structure with footprints in at least three countries, namely Singapore, Cook Islands, and the United Kingdom. At the head of the structure is Blue Holdings Trust, registered in Cooks Island as a “purpose trust” to “wholly” own a Singapore-incorporated private trust company, Blue PTC Pte Ltd., with Mr Bagudu’s brother, Ibrahim, and an Asiaciti nominee as directors.

The Blue PTC Pte Ltd is in turn the trustee of two family trusts – Blue Family Trust (1) and Blue Family Trust (2). Under each trust, then, is a Singapore family-owned investment holding company, FHIC, Blue Holdings (1) Pte Limited, and Blue Holdings (2) Pte Limited, respectively.

Each of the FHIC has an investment account with Waverton Investment Management, formerly JO Hambro Investment Management, and James Hambro and Partners, both London-based firms. Assets kept with the two firms are now frozen, according to U.S. court documents. America has been at the forefront of helping Nigeria recover the Abacha loot, saying that hundreds of millions of dollars stolen were laundered through banks under its jurisdiction.

The beneficiaries of each of the family trusts and the corresponding investments domiciled in London were Mr Bagudu, his wife, seven children, and his brother, Ibrahim.

In September 2010, according to minutes of some meetings we reviewed, a sum of 99 million euros was moved from Ridley through the Blue PTC in Singapore to the investment accounts in London and distributed as follows:

Blue Holdings (1) (17,007,016 euros): Waverton – seven million euros; James Hambro – 10,007,016 euros.

Blue Holdings (2) (81,841,163 euros): Waverton – 23 million euros; James Hambro – 58,841,163 euros.

 Source Of Funds: Bagudu and the Abacha plunder machine

The systematic plunder of Nigeria by the Abacha family as well as the worldwide hunt for the stolen funds, worth billions of dollars, is reckoned to be one of the worst cases of kleptocracy and offshore shenanigans in the world.

Between 1998, when Mr Abacha suddenly died, and 2020, 3.6 billion U.S. dollars have been recovered from the Abacha family and their most prolific bagman, Mr Bagudu, now a governor in Nigeria’s impoverished Kebbi State.

The 163 million U.S. dollars recovery from Jersey in 2003 directly involved Mr Bagudu, who then negotiated a deal with the U.S. and Jersey to return the funds to Nigeria in exchange for Jersey’s withdrawal of an extradition request and his free return to Nigeria. He spent six months in American federal prison in Houston while awaiting extradition to Jersey. The deal to return the $163 million was to avoid that extradition.

Also, the latest recovery – 308 U.S. dollars from Jersey in 2020 – was laundered by Mr Bagudu.

Mr Bagudu was involved with all the offshore front companies and bank accounts – from the British Virgin Islands to Ireland, Switzerland, England, Guernsey, and Jersey – used to steal and launder billions of dollars belonging to Nigeria under the Abacha regime as a director, signatory on accounts or prime beneficiary, according to U.S. court documents and incorporation filings from the Pandora Papers leaks.

In stealing the funds, Mr Abacha set up what Africa Confidential described as a “Plunder Machine,” involving his family, officials, and associates such as Mr Bagudu, complemented by established western and local banks and offshore enablers.

In pushing for the forfeiture of stolen funds laundered through the U.S., American investigators said the criminal network used fraudulent schemes to make dirty money, according to court documents.

Central Bank of Nigeria
Central Bank of Nigeria

One was “security vote fraud,” whereby Mr Abacha and his National Security Adviser Ismaila Gwarzo and others were said to have stolen more than two billion U.S. dollars  by “fraudulently and falsely representing that the funds were to be used for national security purposes.” Between 1994 and 1998, they were said to have made over 60 false claims of “security emergencies” to withdraw huge funds from the Central Bank of Nigeria, then headed by Paul Ogumah.

“Rather than use the funds for national security purposes, the stolen money was transported out of Nigeria and deposited into accounts controlled by General Abacha’s associates, including Mohammed Abacha and Mr Bagudu,” the court in Washington, D.C. was told.

Other schemes were bribery and a dramatic conspiracy by Mr Abacha’s son, Mohammed, and Mr Bagudu to lend money stolen from Nigeria back to Nigeria “with zero risks and at an enormous profit” by using proceeds of the security vote fraud to purchase hundreds of millions of dollars of U.S. dollar-denominated Nigerian bonds, called Nigerian Par Bonds, NPBs.

As part of the Brady Bond programme of the 1980s, the NPBs were U.S. dollar-denominated securities whose interest payments were guaranteed by the U.S. Treasury. The Brady Bond programme was created to help developing countries – like Nigeria – holding substantial debt to restructure their debt into bonds. Nigeria first offered the NPBs in 1992.

In another scheme, the conspirators were also said to have defrauded Nigeria of more than 282  million U.S. dollars by causing the government to repurchase Nigeria’s own debt from one of their companies for more than double what Nigeria would have paid to repurchase the debt in the open market.

According to American investigators, the initial funding of Mr Bagudu’s Ridley’s account at Credit Agricole Indosuez, London, to the tune of 90 million U.S.  dollars in 1998 was from the Par bonds and the debt-buy-back fraud.

The Ridley assets were later transferred to the Blue structure facilitated by Asiaciti and are the outstanding defendant assets being targeted for forfeiture by the United States, court documents showed.

The U.S. filed its forfeiture litigation in 2014. It said, then, the assets held by the Blue holdings, traceable to the old Ridley structure, and domiciled in London investment portfolios held with Waverton and James Hambro, were last valued at a total of 96 million euros.

Mr Bagudu’s brother, Ibrahim, continues to claim the assets, seeking to prevent their forfeiture to Nigeria, court documents showed.

In a reply to written questions by The Guardian of UK in conjunction with PREMIUM TIMES and ABC of Australia, Nicola Boulton of PCB Byrne, Mr Bagudu’s lawyers said “all monies held by the Blue Trusts are lawfully held,” citing a 2003 settlement between Mr Bagudu and the Nigerian government under then-President Olusegun Obasanjo.

Mr Bagudu is yet to respond to further inquiries PREMIUM TIMES sent to him three weeks ago as part of the reporting for this story.

Keeping the Bagudu Dirty Money Flowing – The Enablers

Barely a week after Mr Bagudu’s delegation’s initial visit to Singapore in February 2010, Asiaciti determined that he “has a somewhat controversial background,” making references to his association with the Abacha family and his involvement in “extensive litigation between 2000 and 2006, both criminal investigations and civil claims,” Asiaciti’s internal memo showed.

Despite this determination, as well as the awareness that Mr Bagudu’s had since 2003 admitted to financial irregularities as he agreed to return about 163 million US dollars to Nigeria to avoid extradition to Jersey from the U.S., Asiaciti accepted Mr Bagudu as a client in 2010.

The Monetary Authority of Singapore, MAS, slammed Asiaciti with a fine of one million and a hundred thousand dollars in 2020 for the company’s anti-money laundering and anti-terrorism financing failures between 2007 and 2018, covering the period the company helped Mr Bagudu set up the Blue structure to shelter assets said to have been made from the plunder of Nigeria.

“We maintain a strong compliance programme and each of our offices have passed third-party audits for Anti-Money Laundering & Counter-Financing of Terrorism practices in recent years,” Asiaciti said in a written reply to ICIJ over the Pandora Papers. “However, no compliance programme is infallible – and when an issue is identified, we take necessary steps with regard to the client engagement and make the appropriate notifications to regulatory agencies.”

In defending its role, when questioned by authorities following the unsealing of the indictment against Mr Bagudu by the U.S. in 2014, Asiaciti said, “Farrer & Co, a prestigious London law firm, who acts for the Royal Family had accepted the explanations provided and was prepared to act for him, having strict UK CDD requirements.” This was contained in a defence Asiaciti wrote to the regulator.

Indeed, as documents showed, between Byrne and Farrer and Co., Asiaciti was advised that Mr Bagudu would not be a problematic client and that the funds he sought to shelter were not derived from criminal sources.  That turned out to be false.

In an April 2010 memo to press for the acceptance of Mr Bagudu as a client, Bernard O’Sullivan of Byrne said there were no outstanding claims to Mr Bagudu’s assets and that, in 2003, Nigeria, then led by President Olusegun Obasanjo, reached a “global settlement” with Mr Bagudu.

The settlement Mr O’Sullivan referred to was that which was executed when Mr Bagudu agreed to return about 163 million U.S. dollars to Nigeria in 2003. Mr O’Sullivan attached a copy of an August 8, 2003, confidential statement by Mr Obasanjo to withdraw all claims from criminal and civil proceedings against Mr Bagudu.

This defence was restated in Byrne’s reply following Pandora Papers reporting. “Mr Bagudu reached a compromise with the FRN (Nigeria) in 2003 by which all claims against him and his family were ended and the FRN received cash and certain rights,” Byrne’s Mr Boulton said.

Mr Obasanjo, who entered the settlement agreement with Mr Bagudu, could not be reached to comment for this story as he was said to be travelling in Ethiopia. But sources close to him said it was a “pragmatic step” by the administration that was then desperate to recover stolen funds and that believed Mr Bagudu could help disclose where the funds were stashed. In return, Mr Obasanjo then signed the settlement ending all claims, globally, against Mr Bagudu.

Mr Boulton said Mr Bagudu helped Nigeria recover at least one billion dollars following Mr Abacha’s death.

As documents suggest, between the time the Blue structure was created in 2010 and when its assets were frozen in 2014, 4.6 million dollars or $6.8 million euros was disbursed for Mr Bagudu’s children’s education and the “generous” lifestyle his family “was accustomed to”.

The transferred sum included one hundred thousand dollars annuity to his brother Ibrahim and another three million U.S. dollars moved into Ibrahim’s bank account for “investment in real estate and property development in Abuja.”

In one case in 2013, Farrer and Co helped Bagudu ensure funds were distributed to his family and resisted Asiaciti’s “level of scrutiny”, an attempt at enhanced due diligence.

In an email, Diana Davidson of Farrer and Co. wrote that Mr Bagudu’s brother Ibrahim was “not entirely happy at the level of scrutiny being sought at the sole discretion of Asiaciti”.

In response, an Asiaciti’s client services official said they were “in no way inferring that the distribution requests are suspicious in any way,” and reminded Ms Davidson that Mr Bagudu was a politically exposed person, PEP, thus the transfers he sought required enhanced due diligence.

A breakdown of disbursements showed that 100 thousand U.S. dollars were advised to be paid out for Mr Bagudu’s “son’s school fees” days after Farrer and Co’s Ms Davidson helped him pressure Asiaciti.

But beyond the role played by British firms in the Bagudu shenanigans, the British public service institution was also involved, documents suggested.

In a  witness statement in 2015, Asiaciti said Farrer and Co and Byrne & Partners received consent from the UK’s Serious Organised Crime Agency, SOCA,  now the National Crimes Agency (NCA), to facilitate the restructuring of Mr Bagudu’s offshore holdings in 2010.

“A protective disclosure was made to SOCA in the UK and their consent was obtained to the resettlement of the Ridley Trust into the Blue Family Trusts before funds were transferred from Ridley Group Limited to Blue Holdings 1 Pte. Ltd and Blue Holdings 2 Pte. Ltd,” Asiaciti’s Karen Hanlong submitted.

Years later, NCA started working with the U.S. to hunt the assets held by Mr Bagudu from the Abacha plunder of Nigeria.