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United States prosecutors have provided details of how Nigeria’s former minister of petroleum, Diezani Alison-Madueke, and her two business cronies, Jide Omokore, and Kola Aluko, lavished billions of naira on property and luxury items in the U.S. and United Kingdom.
In a civil forfeiture notice filed by the U.S. Department of Justice, DoJ, on Friday, prosecutors detailed how Messrs. Aluko and Omokore allegedly conspired to bribe the former minister, purchasing property worth millions of dollars in London for Mrs. Alison-Madueke and her family.
The two are accused of buying a total of four residential properties in and around London worth 11.45 million, and furnishing them with luxury items, including art work.
Read below full details of court processes filed by the Department of Justice.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
Plaintiff,
– v.-
THE M/Y GALACTICA STAR, BEING A
65-METER MOTOR YACHT BUILT BY
HEESEN SHIPYARDS WITH
INTERNATIONAL MARITIME
ORGANIZATION NUMBER 9679830,
AND REGISTERED UNDER THE LAWS
AND FLAG OF THE CAYMAN ISLANDS
AT THE PORT OF GEORGE TOWN,
INCLUDING ALL FIXTURES, FITTINGS,
MANUALS, STOCKS, STORES,
INVENTORIES, AND EACH LIFEBOAT,
TENDER, AND OTHER
APPURTENANCE THERETO,
INCLUDING, BUT NOT LIMITED TO,
THE TENDER BOAT RECORDED AS A
7.5 METER DARIEL “GUEST TENDER”
WITH ID/SERIAL NO. DRLDT759G313,
AND ANY PROPERTY TRACEABLE
THERETO;
ANY AND ALL FUNDS, PROCEEDS,
CASH, OR BENEFITS TO BE
DISBURSED OR OTHERWISE OWING
TO ONE57 79 INC., OR TO ITS
SUCCESSORS OR ASSIGNS, OUT OF
ANY SURPLUS FUNDS RESULTING
FROM THE FORECLOSURE AUCTION,
TO BE HELD ON OR ABOUT JULY 19,
2017, OF REAL PROPERTY LOCATED
IN NEW YORK, N.Y., AND COMMONLY
KNOWN AS 157 WEST 57TH STREET,
UNIT 79, NEW YORK, N.Y. 10019;
REAL PROPERTY LOCATED IN NEW
YORK, N.Y., COMMONLY KNOWN AS
1049 FIFTH AVENUE, UNITS 11B AND
12B, NEW YORK, N.Y. 10032, AND ALL
APPURTENANCES, IMPROVEMENTS,
AND ATTACHMENTS LOCATED
THEREON, AND ANY PROPERTY
TRACEABLE THERETO;
REAL PROPERTY LOCATED IN
MONTECITO, CALIF., COMMONLY
KNOWN AS 807 CIMA DEL MUNDO
ROAD, MONTECITO, CALIF. 90077,
AND ALL APPURTENANCES,
IMPROVEMENTS, AND
ATTACHMENTS LOCATED THEREON,
AND ANY PROPERTY TRACEABLE
THERETO;
REAL PROPERTY LOCATED IN
MONTECITO, CALIF., COMMONLY
KNOWN AS 815 CIMA DEL MUNDO
ROAD, MONTECITO, CALIF. 90077,
AND ALL APPURTENANCES,
IMPROVEMENTS, AND
ATTACHMENTS LOCATED THEREON,
AND ANY PROPERTY TRACEABLE
THERETO;
ALL RIGHTS AND INTERESTS HELD
BY RIVERMOUNT INTERNATIONAL
LTD., OR ITS AFFILIATES OR
ASSIGNEES, IN THE SUBORDINATED
CONVERTIBLE PROMISSORY NOTE
EXECUTED BETWEEN CROSS
HOLDINGS, INC., AND RIVERMOUNT
INTERNATIONAL LTD., DATED ON OR
ABOUT JULY 15, 2015, AS VARIED OR
AMENDED BY THE PARTIES
THERETO, AND ALL PROPERTY
TRACEABLE THERETO;
Defendants In Rem
Comes now the Plaintiff, the United States of America, through its undersigned attorneys,
and alleges, upon information and belief, as follows:
I.
NATURE OF THE ACTION
1. This is an action in rem to forfeit approximately $144 million in assets, and any
property traceable thereto, derived from an international conspiracy to obtain lucrative business
opportunities in the Nigerian oil and gas sector in return for corruptly offering and giving millions
of dollars’ worth of gifts and benefits to the former Nigerian Minister for Petroleum Resources,
Diezani Alison-Madueke (“ALISON-MADUEKE”); and to subsequently launder the proceeds of
the illicit business opportunities into and through the United States.
2. From in or about April 2010 until in or about May 2015, ALISON-MADUEKE–
who was often referred to as “the Madam” or “Madam D”–was Nigeria’s Minister for Petroleum
Resources. In that role, she was responsible for overseeing Nigeria’s state-owned oil company,
the Nigerian National Petroleum Corporation (“NNPC”).
3. As alleged herein, Kolawole Akanni Aluko (“ALUKO”), Olajide Omokore
(“OMOKORE”), and others: (i) conspired to and did purchase millions of dollars in real estate in
and around London, U.K., for the use and benefit of ALISON-MADUEKE and her family; (ii)
conspired to and did provide more than one million dollars in furniture, artwork, and other
furnishings purchased within the Southern District of Texas, and shipped, in part, to London and
Abuja, Nigeria, for the use and benefit of ALISON-MADUEKE and her family; and (iii) conspired
to and did otherwise fund a lavish and privileged lifestyle for ALISON-MADUEKE and her
family.
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4. As further alleged herein, ALISON-MADUEKE, in return for such improper
inducements, used her influence as the Minister for Petroleum Resources to steer to companies
beneficially owned by ALUKO and OMOKORE the award of multiple Strategic Alliance
Agreements (“SAAs”) with an NNPC subsidiary.
5. As further alleged herein, the companies that received these SAAs were unqualified
and either improperly performed their obligations or, in some instances, failed entirely to perform.
Nevertheless, these companies received more than $1.5 billion in revenues through the sale of
Nigerian crude oil.
6. As further alleged herein, ALUKO and OMOKORE laundered their illicit revenues
into and through the United States and, in particular, used these revenues to acquire the Defendants
In Rem.
7. As further alleged herein, ALUKO and OMOKORE used a series of shell
companies and layered financial transactions to conceal the nature, location, source, and/or
ownership of the proceeds of the unlawful conduct and of the Defendants In Rem purchased with
such proceeds.
8. As property constituting, derived from, or traceable to the proceeds of “specified
unlawful activity,” as that term is defined in 18 U.S.C. § 1956(c)(7), or a conspiracy to commit
“specified unlawful activity,” and as property involved in money laundering violations of 18
U.S.C. §§ 1956 and 1957, the Defendants In Rem are subject to forfeiture under 18 U.S.C.
§§ 981(a)(1)(A) and 981(a)(1)(C).
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II.
THE DEFENDANTS IN REM
9. This is an action by the United States of America seeking forfeiture of all right,
title, and interest in the following property (collectively, the “Defendants In Rem”):
(a) The M/Y Galactica Star, being a 65-meter motor yacht built by Heesen
Shipyards with International Maritime Organization number 9679830, and
registered in the Cayman Islands at the Port of George Town, including all
fixtures, fittings, manuals, stocks, stores, inventories, and each lifeboat,
tender, and other appurtenance thereto, including, but not limited to, the
tender boat recorded as a 7.5 meter Dariel “guest tender” with ID/Serial No.
DRLDT759G313, and any property traceable thereto (hereinafter the
“GALACTICA STAR”);
(b) any and all funds, proceeds, cash, or benefits to be disbursed or otherwise
owing to One57 79 Inc., or to its successors or assigns, out of any surplus
funds resulting from the foreclosure auction to be held on or about July 19,
2017, of real property located in New York, N.Y., and commonly known as
157 West 57th Street, Unit 79, New York, N.Y. 10019, as more fully
described in Attachment A (hereinafter the “157 WEST 57TH STREET
SURPLUS PROCEEDS”);
(c) real property located in New York, N.Y., commonly known as 1049 Fifth
Avenue, Units 11B and 12B, New York, N.Y. 10032, as more fully
described in Attachment B, and all appurtenances, improvements, and
attachments located thereon, and any property traceable thereto (hereinafter
the “1049 FIFTH AVENUE UNITS”);
(d) real property located in Montecito, Calif., commonly known as 807 Cima
del Mundo Road, Montecito, Calif. 90077, as more fully described in
Attachment C, and all appurtenances, improvements, and attachments
located thereon, and any property traceable thereto (hereinafter “807 CIMA
DEL MUNDO ROAD”);
(e) real property located in Montecito, Calif., commonly known as 815 Cima
del Mundo Road, Montecito, Calif. 90077, as more fully described in
Attachment D, and all appurtenances, improvements, and attachments
located thereon, and any property traceable thereto (hereinafter “815 CIMA
DEL MUNDO ROAD”);
(f) all rights and interests held by Rivermount International Ltd., or its affiliates
or assignees, in the Subordinated Convertible Promissory Note executed
between Cross Holdings, Inc., and Rivermount International Ltd., dated on
or about July 15, 2015, as varied or amended by the parties thereto, and all
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property traceable thereto (hereinafter the “CROSS HOLDINGS
PROMISSORY NOTE”).
III.
JURISDICTION AND VENUE
10. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1345 and 28
U.S.C. § 1355(a).
11. Venue is proper in this district pursuant to 28 U.S.C. § 1355(b)(1)(A) because acts
and omissions giving rise to forfeiture took place in the Southern District of Texas.
12. This action in rem for forfeiture is governed by 18 U.S.C. §§ 981 and 983, the
Federal Rules of Civil Procedure, and the Supplemental Rules for Admiralty or Maritime Claims
and Asset Forfeiture Actions.
IV.
STATUTORY BASIS FOR FORFEITURE
13. The Defendants In Rem are subject to forfeiture pursuant to 18 U.S.C.
§ 981(a)(1)(C) because they constitute or are derived from proceeds traceable to a violation of an
offense constituting a “specified unlawful activity” or a conspiracy to commit such an offense.
“Specified unlawful activity” is defined in 18 U.S.C. § 1956(c)(7) to include an offense against a
foreign nation involving “bribery of a public official, or the misappropriation, theft, or
embezzlement of public funds by or for the benefit of a public official,” see 18 U.S.C.
§ 1956(c)(7)(B)(iv); any felony violation of the Foreign Corrupt Practices Act (“FCPA”), see
18 U.S.C. § 1956(c)(7)(D); or any violations of 18 U.S.C. §§ 1343 (wire fraud), 2314 (interstate
transportation of stolen property), and 2315 (interstate receipt of stolen property), see 18 U.S.C.
§§ 1956(c)(7)(A) & 1961(1).
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14. The Defendants In Rem are also subject to forfeiture under 18 U.S.C.
§ 981(a)(1)(A) because they constitute property involved in a transaction or attempted transaction
in violation of 18 U.S.C. § 1957, or are traceable to such property. Section 1957 prohibits the
conducting of a monetary transaction with property valued at over $10,000 that is known to be
criminally derived and which constitutes the proceeds of “specified unlawful activity,” including
the proceeds of an offense against a foreign nation involving “bribery of a public official, or the
misappropriation, theft, or embezzlement of public funds by or for the benefit of a public official,”
see 18 U.S.C. § 1956(c)(7)(B)(iv); of any felony violation of the FCPA, see 18 U.S.C.
§ 1956(c)(7)(D); or of any violations of 18 U.S.C. §§ 1343 (wire fraud), 2314 (interstate
transportation of stolen property), and 2315 (interstate receipt of stolen property), see 18 U.S.C.
§§ 1956(c)(7)(A) & 1961(1).
15. The Defendants In Rem are further subject to forfeiture pursuant to 18 U.S.C.
§ 981(a)(1)(A) because they constitute property involved in a transaction or attempted transaction
in violation of 18 U.S.C. § 1956(a)(1)(B), or are traceable to such property. Section 1956(a)(1)(B)
prohibits the conducting of a financial transaction with property known to be the proceeds of
unlawful activity with the intent to conceal the nature, location, source, ownership, or control of
the proceeds of a specified unlawful activity, including the proceeds of an offense against a foreign
nation involving “bribery of a public official, or the misappropriation, theft, or embezzlement of
public funds by or for the benefit of a public official,” see 18 U.S.C. § 1956(c)(7)(B)(iv); of any
felony violation of the FCPA, see 18 U.S.C. § 1956(c)(7)(D); or of any violations of 18 U.S.C.
§§ 1343 (wire fraud), 2314 (interstate transportation of stolen property), and 2315 (interstate
receipt of stolen property), see 18 U.S.C. §§ 1956(c)(7)(A) & 1961(1).
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16. The Defendants In Rem are further subject to forfeiture pursuant to 18 U.S.C.
§ 981(a)(1)(A) because they constitute property involved in a transaction or attempted transaction
in violation of 18 U.S.C. § 1956(a)(2), or are traceable to such property. Section 1956(a)(2)
prohibits transferring funds known to be the proceeds of unlawful activity from a place outside the
United States to a place in the United States, with knowledge that the transfer is designed in whole
or in part to conceal the nature, location, source, ownership, or control of the proceeds of a
specified unlawful activity, including the proceeds of an offense against a foreign nation involving
“bribery of a public official, or the misappropriation, theft, or embezzlement of public funds by or
for the benefit of a public official,” see 18 U.S.C. § 1956(c)(7)(B)(iv); of any felony violation of
the FCPA, see 18 U.S.C. § 1956(c)(7)(D); or of any violations of 18 U.S.C. §§ 1343 (wire fraud),
2314 (interstate transportation of stolen property), and 2315 (interstate receipt of stolen property),
see 18 U.S.C. §§ 1956(c)(7)(A) & 1961(1).
17. The Defendants In Rem are further subject to forfeiture pursuant to 18 U.S.C.
§ 981(a)(1)(A) because they constitute property involved in a conspiracy to violate 18 U.S.C.
§§ 1956 or 1957, in violation of 18 U.S.C. § 1956(h).
18. A representative selection of relevant offenses against a foreign nation as referred
to in ¶¶ 13-17 are set forth in Attachment E.
V.
RELEVANT PERSONS AND ENTITIES
19. On information and belief, the United States alleges the following facts.
20. Diezani ALISON-MADUEKE is the former Nigerian Minister for Petroleum
Resources who served in that position from in or about April 2010 through in or about May 2015.
In that role, ALISON-MADUEKE was responsible for overseeing NNPC. In her capacity as
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Minister for Petroleum Resources, ALISON-MADUEKE was a “foreign official” as that term is
defined in the FCPA, see 15 U.S.C. §§ 78dd-1(f)(1)(A), 78dd-2(h)(2)(A), and 78dd-3(f)(2)(A).
21. The Nigerian National Petroleum Corporation is Nigeria’s state-owned oil
corporation through which the Federal Government of Nigeria regulates and participates in the
country’s petroleum and hydrocarbons industry. The NNPC was owned and controlled by the
Nigerian government and performed government functions, and thus was an “instrumentality”
within the meaning of the FCPA, see 15 U.S.C. §§ 78dd-1(f)(1)(A), 78dd-2(h)(2)(A), and 78dd-
3(f)(2)(A).
22. The Nigerian Petroleum Development Company (“NPDC”) is the wholly-owned
operating subsidiary of NNPC. The NPDC was owned and controlled by the Nigerian government
and performed government functions, and thus was an “instrumentality” within the meaning of the
FCPA, see 15 U.S.C. §§ 78dd-1(f)(1)(A), 78dd-2(h)(2)(A), and 78dd-3(f)(2)(A).
23. Kolawole Akanni ALUKO is a Nigerian citizen whose last known residential
address was in Porza-Lugano, Switzerland. ALUKO and OMOKORE (see below) are the
beneficial owners of and have control over ATLANTIC ENERGY HOLDINGS LTD. along with
that company’s subsidiaries and affiliates–including ATLANTIC ENERGY DRILLING
CONCEPTS NIGERIA LTD. and ATLANTIC ENERGY BRASS DEVELOPMENT LTD.
ALUKO was also, at all times relevant to this complaint, a director and beneficial owner of
TENKA LTD. and is the 100% owner of EARNSHAW ASSOCIATES LTD.
24. Olajide OMOKORE is a Nigerian citizen living in Lagos, Nigeria, and is a
business partner of ALUKO. With ALUKO, OMOKORE is a beneficial owner of and has control
over ATLANTIC ENERGY HOLDINGS LTD. along with that company’s subsidiaries and
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affiliates–including ATLANTIC ENERGY DRILLING CONCEPTS NIGERIA LTD. and
ATLANTIC ENERGY BRASS DEVELOPMENT LTD.
25. ATLANTIC ENERGY HOLDINGS LTD. (“AEH”) is a company incorporated
in the British Virgin Islands with registered address of 325 Waterfront Drive, Omar Hodge
Building, Wickham’s Cay, Road Town, Tortola, B.V.I. AEH is beneficially owned, directly or
indirectly, by ALUKO and OMOKORE.
26. ATLANTIC ENERGY (BRASS) LTD. is a company incorporated in the British
Virgin Islands with the same registered address as AEH: 325 Waterfront Drive, Omar Hodge
Building, Wickham’s Cay, Road Town, Tortola, B.V.I. Upon information and belief, ATLANTIC
ENERGY (BRASS) LTD. is beneficially owned, directly or indirectly, by ALUKO and
OMOKORE.
27. ATLANTIC ENERGY DRILLING CONCEPTS NIGERIA LTD. (“AEDC”)
is a company incorporated in Nigeria with registered address of Plot 1267 Ahmadu Bello Way,
Garki, Abuja, Nigeria. OMOKORE is a registered director of AEDC. AEH owns 49,999,999 of
50,000,000 shares of AEDC.
28. ATLANTIC ENERGY BRASS DEVELOPMENT LTD. (“AEBD”) is a
company incorporated in Nigeria with registered address of 32A Ademola Adetokunbo Street,
Victoria Island, Lagos, Nigeria. OMOKORE is a registered director of AEBD. ATLANTIC
ENERGY (BRASS) LTD. owns 9,999,999 of 10,000,000 shares of AEBD.
29. TENKA LTD. (“TENKA”) is a company incorporated in the United Kingdom
with registered address of No. 1 London Bridge, London SE1 9BG, U.K. During all times relevant
to this complaint, the directors of TENKA were ALUKO and his wife. Upon information and
belief, TENKA is beneficially owned by ALUKO.
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30. EARNSHAW ASSOCIATES LTD. (“EARNSHAW”) is a company
incorporated in the British Virgin Islands with registered address of 24 De Castro Street, Akara
Building, Wickham’s Cay 1, Road Town, Tortola, B.V.I. ALUKO owns 100% of EARNSHAW.
31. CO-CONSPIRATOR #1 is a dual citizen of the United States and Nigeria whose
principal residence is in Topanga, Calif.
32. CO-CONSPIRATOR #2 is a Nigerian citizen and a former resident of the United
States who maintained a residence in Potomac, Md.
33. CO-CONSPIRATOR #3 is a dual citizen of the United States and Nigeria and a
former resident of the United States who maintained a residence in Oakland, Calif.
VI.
FACTS
A. Strategic Alliance Agreements and Oil Mining Leases
34. Prior to 2010, NNPC participated in a joint venture with the subsidiary of a major
international oil company (the “IOC Subsidiary”) for the development and production of oil and
gas in connection with eight oil mining leases (“OMLs”). In particular, the joint venture held
interests in and operated OMLs 26, 30, 34, and 42 (the “Forcados OMLs”) and OMLs 60, 61, 62,
and 63 (the “Brass OMLs”).
35. The IOC Subsidiary owned 45% of the joint venture, with the remainder owned by
NNPC. In 2010, however, the IOC Subsidiary chose to divest itself and sold its minority stake to
various indigenous Nigerian entities.
36. With the IOC Subsidiary’s departure, NNPC became responsible for financing and
operating the OMLs. It assigned this task–along with its 55% majority stake–to its own
operating subsidiary, NPDC. However, NPDC lacked the in-house technical expertise and the
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financial resources to fund and operate the OMLs. NPDC therefore sought to enter into Strategic
Alliance Agreements to partner with outside parties who could both finance and provide technical
assistance for the operation of the OMLs on NPDC’s behalf.
B. ALISON-MADUEKE Was Instrumental in the Award of the Lucrative Forcados
SAAs (OMLs 26, 30, 34, and 42) to AEDC
37. AEDC was incorporated in Nigeria on or about July 19, 2010, approximately three
months after ALISON-MADUEKE was appointed Minister for Petroleum Resources.
38. On or about March 8, 2011, AEDC first expressed its interest in entering into an
SAA in a letter to NPDC. Less than three weeks later, on or about March 28, 2011, ALUKO,
acting on behalf of AEDC, attended a meeting with NPDC representatives to discuss a possible
SAA award.
39. Within another three weeks, on or about April 20, 2011, AEDC and NPDC entered
into SAAs for OMLs 26 and 42. These SAAs were signed by OMOKORE on behalf of AEDC.
40. Approximately one month later, on or about May 25, 2011, AEDC and NPDC
entered into two more SAAs for OMLs 30 and 34. These SAAs were also signed by OMOKORE
on behalf of AEDC. (The four SAAs for OMLs 26, 30, 34, and 42 are herein collectively referred
to as the “Forcados SAAs.”)
41. NPDC’s award of the Forcados SAAs to AEDC was done with the knowledge and
support of ALISON-MADUEKE and at her direction. For example, in a recorded conversation
between ALISON-MADUEKE and ALUKO, ALISON-MADUEKE acknowledged that “we
stuck our necks out regarding the SAA and we supported it.” See infra ¶ 118.
42. A February 2014 report prepared by the then-governor of the Central Bank of
Nigeria determined that AEDC “had neither the technical expertise nor the capital to develop the
joint venture, but [was] none-the-less able to lift crude and retain the proceeds . . . up to 70% of
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the profit of the Joint Venture.” The report concluded that the arrangement was set up “for the
purpose of acquiring assets belonging to the [Federal Republic of Nigeria] and transferring the
income to private hands.”
(1) Terms of the Forcados SAAs
43. The Forcados SAAs required AEDC to pay non-recoverable entry fees prior to the
SAAs’ taking effect. The value of the entry fees was to be determined based on the estimated
probable oil and gas reserves within the area covered by the Forcados OMLs.
44. In addition, the Forcados SAAs each required AEDC to pay $350,000 per year to
NPDC for the first five years of the agreements. These funds were to be used for the provision of
training facilities for NPDC staff.
45. Finally, the Forcados SAAs required AEDC to “provide all the funds required for
NPDC’s 55% share of Petroleum Operating Costs.” Upon information and belief, NPDC’s share
of the operating costs for the Forcados OMLs, during the period from March 2011 through
December 2015, was at least $1,400,000,000.
46. In return for meeting its obligations under the Forcados SAAs, AEDC would be
entitled to recover the cost of financing NPDC’s share of the operating costs (as described in the
preceding paragraph) and would be further entitled to a share of NPDC’s profit as determined by
profit-sharing formulae contained in the SAAs.
47. AEDC’s entitlements were payable in-kind. That is, AEDC would receive
allocations of available oil sufficient to cover the amounts due as cost-recovery and profit.
(2) AEDC’s Performance Under the Forcados SAAs
48. Upon information and belief, AEDC substantially failed to perform under the
Forcados SAAs. In particular, upon information and belief, AEDC did not fulfill its requirement
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to fund training facilities for NPDC staff, leading to an outstanding obligation of approximately
$5,600,000.
49. Furthermore, AEDC failed to cover NPDC’s share of the Forcados operating costs.
Upon information and belief, of the more than $1,400,000,000 required to finance such costs,
AEDC made contributions of only approximately $305,108,522.43.
50. Despite AEDC’s failure to fulfil its obligations under the Forcados SAAs, AEDC
was, upon information and belief, allocated and permitted to lift and sell, for its own benefit,
twenty-one cargoes of crude oil valued at approximately $677,238,673.
C. ALUKO, OMOKORE, and Others Conspire to Purchase £11,530,000 Worth of
London Real Estate for the Benefit of ALISON-MADUEKE
51. Concurrent with the negotiations for and the award of the Forcados SAAs, ALUKO
and OMOKORE, acting in concert with CO-CONSPIRATORS #1 and #2, purchased and
refurbished several multi-million dollar properties in the London area for the benefit of ALISONMADUEKE
and her family members. ALUKO, OMOKORE, and CO-CONSPIRATORS #1 and
#2 provided these properties to ALISON-MADUEKE for the corrupt purpose of inducing her to
use her influence within the Ministry of Petroleum Resources, the NNPC, and the NPDC to direct
the award of business opportunities to entities under their control and beneficial ownership,
including the award of the Forcados SAAs to AEDC.
(1) 96 Camp Road, Gerrards Cross, Buckinghamshire, SL9 7PB
52. On or about January 27, 2011, i.e., less than two months before AEDC officially
approached NPDC about the first of the Forcados SAAs, a Seychelles company named Miranda
International Ltd. purchased a property known as “the Falls” for £3,250,000. The Falls is located
just outside London at 96 Camp Road, Gerrards Cross, Buckinghamshire SL9 7PB.
53. Miranda International Ltd. is beneficially owned by OMOKORE.
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54. ALUKO engaged a construction company (the “Construction Company”) to
upgrade and maintain the plumbing, electrical, air conditioning, and audio-visual systems at the
Falls.
55. OMOKORE and ALUKO purchased and improved the Falls for the exclusive use
of ALISON-MADUEKE and her family.
56. A mobile telephone recovered at the known residences of ALISON-MADUEKE
and her mother contained digital photographs of ALISON-MADUEKE present inside the Falls.
57. Furthermore, during the relevant period, ALISON-MADUEKE–who was
addressed at the property as “the Madam”–was the only person who occupied the property.
58. Individuals who provided services at the Falls addressed its occupant as “the
Madam” or were told that the person they worked for was known as “the Madam.”
59. Finally, on or about October 8, 2013, ALUKO used his American Express card to
purchase two identical exercise machines at Harrods in London. The machines were purchased
for £10,926 each. One was to be delivered to the known London address of ALISON-MADUEKE;
the other was to be delivered to the Falls.
(2) 39 Chester Close North, London NW1 4JE
60. On or about March 24, 2011–i.e., just four days before ALUKO met with NPDC
officials to discuss AEDC’s interest in an SAA–a British Virgin Islands company called Mortlake
Investments Ltd. was used to purchase real property at 39 Chester Close North, London NW1 4JE
(“39 Chester Close North”) for £1,730,000.
61. Mortlake Investments Ltd. is beneficially owned by ALUKO.
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62. The real estate company Daniel Ford & Co. assisted in the purchase of 39 Chester
Close North. The same company assisted in the purchase of additional properties as detailed
below. See infra ¶¶ 65 & 70.
63. ALUKO engaged the Construction Company to undertake extensive alterations and
renovations at 39 Chester Close North, including the installation of an elevator. An employee of
the Construction Company (“Construction Company Employee #1”) has stated that the intended
occupants of 39 Chester Close North were ALISON-MADUEKE’s mother and son. Construction
Company Employee #1 personally met ALISON-MADUEKE on at least two occasions at the
property and, on one of those occasions, ALISON-MADUEKE selected stone flooring and
countertops to be installed in the bathrooms.
64. At some point in 2015, Construction Company Employee #1 was informed that
ALISON-MADUEKE’s mother and son would not be moving into 39 Chester Close North after
all, and the Construction Company was instructed to remove the elevator and return the property
to its original condition. The property was sold on or about July 22, 2015, for £2,224,000.
(3) 58 Harley House, Marylebone Road, London NW1 5HL
65. On or about March 28, 2011–i.e., the same day ALUKO was meeting with NPDC
officials to discuss AEDC’s interest in an SAA–a Seychelles company, Rosewood Investments
Ltd., was used to purchase real property at 58 Harley House, Marylebone Road, London NW1
5HL (“58 Harley House”) for £2,800,000.
66. Rosewood Investments Ltd. is beneficially owned by CO-CONSPIRATOR #2.
67. The same real estate agency used to purchase 39 Chester Close North, i.e., Daniel
Ford & Co., assisted in the purchase of 58 Harley House.
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68. As with 39 Chester Close North, ALUKO engaged the Construction Company to
provide renovation services at 58 Harley House. On or about August 9, 2011, a second employee
of the Construction Company (“Construction Company Employee #2”) forwarded by email to
ALUKO design plans for the kitchen at 58 Harley House. ALUKO subsequently forwarded this
email, including the design plans, to ALISON-MADUEKE.
69. In addition, Construction Company Employee #1 was introduced to ALISONMADUEKE
at 58 Harley House, on which occasion the employee was told ALISON-MADUEKE
was “the architect.”
(4) Flat 5 Park View, 83-86 Prince Albert Road, London NW8 7RU
70. On or about March 29, 2011–i.e., the day after ALUKO met with NPDC officials
to discuss AEDC’s interest in an SAA–another Seychelles company called Colinwood Ltd. was
used to purchase real property at Flat 5 Park View, 83-86 Prince Albert Road, London NW8 7RU
(“Flat 5 Park View”) for £3,750,000. The purchase was financed, in part, by a loan obtained from
FBN Bank (UK) Ltd. by CO-CONSPIRATOR #1.
71. The same real estate company used to purchase 39 Chester Close North and 58
Harley House, i.e., Daniel Ford & Co., also assisted in the purchase of Flat 5 Park View.
72. As with both 39 Chester Close North and 58 Harley House, ALUKO engaged the
Construction Company to perform significant renovations at Flat 5 Park View. Construction
Company Employee #1 personally met ALISON-MADUEKE at Flat 5 Park View where she was
present for a discussion of interior design plans. In addition, design plans for Flat 5 Park View
were later found at the known London residence of ALISON-MADUEKE’s mother.
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D. Living and Lifestyle Expenses for ALISON-MADUEKE
(1) Rental Payments
73. Beginning in August 2011 and continuing through January 2014, ALUKO and a
company beneficially owned by him, Tracon Investments Ltd. (“Tracon”), made a total of at least
£537,922 in rental payments for two central London residences both located at 22 St. Edmunds
Terrace, London NW8 7QQ. The first residence, Flat 19, was occupied by ALISON-MADUEKE
during this time period. The second residence, Flat 6, was occupied by ALISON-MADUEKE’s
mother during this time period.
74. The rental payments were made in the following approximate amounts, on or about
the following dates, from the following payors:
TABLE 1
Date Payor Amount
Aug. 30, 2011 ALUKO £49,000.00
Dec. 14, 2011 ALUKO £10,216.00
Dec. 14, 2011 ALUKO £44,811.00
Feb. 24, 2012 ALUKO £39,347.50
May 11, 2012 ALUKO £29,900.00
May 11, 2012 ALUKO £39,347.50
Sept. 12, 2012 ALUKO £87,075.00
Feb. 4, 2013 Tracon £30,375.00
Mar. 28, 2013 ALUKO £29,900.00
Mar. 28, 2013 ALUKO £39,375.00
June 21, 2013 ALUKO £30,375.00
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Sept. 30, 2013 ALUKO £70,000.00
Jan. 22, 2014 Tracon £8,300.00
Jan. 22, 2014 Tracon £29,900.00
TOTAL £537,922.00
75. Upon information and belief, the above payments were made corruptly by, on
behalf of, or at the direction of ALUKO for the purpose of benefiting ALISON-MADUEKE and
her mother in return for ALISON-MADUEKE’s having improperly influenced the award of the
Forcados SAAs to AEDC and in anticipation of or in return for her improperly influencing the
award of the Brass SAA, see infra ¶¶ 105-117, to AEDC and AEBD.
(2) Transportation Services
76. During the period from at least December 2012 through at least July 2014, ALUKO
and his beneficially-owned company TENKA made at least £393,274.32 in payments to a car hire
company (the “Chauffeur Company”). During that same time period, a company beneficially
owned by OMOKORE, Energy Property Development Ltd., paid at least £4,424.40 to the
Chauffeur Company.
77. The payments were made to the Chauffeur Company in the following approximate
amounts, on or about the following dates, by the following payors:
TABLE 2
Date Payor Amount
Dec. 28, 2012 ALUKO £6,171.06
Jan. 11, 2013 TENKA £6,115.92
Feb. 14, 2013 TENKA £10,664.50
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Mar. 8, 2013 TENKA £25,000.97
Apr. 8, 2013 TENKA £27,999.30
June 7, 2013 TENKA £25,524.51
June 11, 2013 Energy Prop. Dev. £1,475.22
June 13, 2013 Energy Prop. Dev. £1,072.02
July 8, 2013 ALUKO £77,605.78
July 17, 2013 Energy Prop. Dev. £1,877.16
Oct. 15, 2013 ALUKO £74,420.32
Dec. 3, 2013 TENKA £4,410.48
July 28, 2014 TENKA £35,362.48
July 29, 2014 TENKA £99,999.00
TOTAL £397,698.72
78. Upon information and belief, the above payments were made corruptly by, on
behalf of, or at the direction of ALUKO and OMOKORE for the benefit of ALISON-MADUEKE
and/or her family, in return for ALISON-MADUEKE’s having improperly influenced the award
of the Forcados SAAs to AEDC and in anticipation of or in return for her improperly influencing
the award of the Brass SAA, see infra ¶¶ 105-117, to AEDC and AEBD.
79. In particular, the director of the Chauffeur Company has stated that in or around
June 2014 he was assaulted in the hallway outside of ALISON-MADUEKE’s known residence at
Flat 19, 22 St. Edmunds Terrace, London NW8 7QQ, by two men known by the director to be
ALISON-MADUEKE’s associates. This assault occurred as the director of the Chauffeur
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Company was attempting to deliver a letter concerning approximately £224,000 in unpaid services
provided by his company to ALISON-MADUEKE.
80. The director of the Chauffeur Company has further stated that, upon hearing the
commotion, ALISON-MADUEKE herself appeared and instructed her associates to settle the
unpaid bill. As the preceding table indicates, roughly one month after the hallway assault, TENKA
paid a total of £135,361.48 to the Chauffeur Company.
E. Furniture Purchases in Houston, Tex. for the Benefit of ALISON-MADUEKE
(1) Purchases by OMOKORE and CO-CONSPIRATOR #1
81. An employee of a furniture store located within the Southern District of Texas in
Houston, Tex., (“Houston Furniture Store #1”) has stated that ALISON-MADUEKE visited his
showroom on multiple occasions. During those visits, ALISON-MADUEKE would identify
specific items of interest to her, which the employee (“Furniture Store Employee”) would
photograph. During her various visits to Houston, ALISON-MADUEKE would spend many hours
over the course of two or three days reviewing furniture in Houston Furniture Store #1. Afterward,
the Furniture Store Employee would visit ALISON-MADUEKE at her hotel room in Houston to
review the photographed items. ALISON-MADUEKE would then narrow down the selections to
those she wished to be purchased.
82. ALISON-MADUEKE’s purchases were always paid for by someone else. In
particular, the Furniture Store Employee recalled that CO-CONSPIRATOR #1 was the first person
to visit the store and to pay for ALISON-MADUEKE’s selections.
83. Upon information and belief, ALISON-MADUEKE was present in Houston, Tex.,
to deliver a keynote address at Rice University in late September 2010, departing Houston for
Nigeria on September 29, 2010. This trip occurred roughly five months after ALISONCase
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MADUEKE assumed her role as Minister for Petroleum Resources and roughly two months after
the incorporation of AEDC.
84. Coinciding with ALISON-MADUEKE’s visit to Houston, CO-CONSPIRATOR
#1 charged $12,867 and $25,000 in two separate transactions at Houston Furniture Store #1 on or
about September 27, 2010. On or about October 7, 2010, CO-CONSPIRATOR # 1 charged an
additional $3,022 at Houston Furniture Store #1. Upon information and belief, these purchases
comprised items selected by ALISON-MADUEKE and were intended for her benefit.
85. In or around the same time as the purchases made at Houston Furniture Store #1,
CO-CONSPIRATOR #1 also made significant purchases at another Houston furniture showroom
(“Houston Furniture Store #2”). In particular, a Nevada-based limited partnership under the
control of CO-CONSPIRATOR #1 wired a total of $197,600 to Houston Furniture Store #2 in two
separate transactions on or about September 30, 2010, and October 1, 2010. Upon information
and belief, these payments were in settlement of approximately $200,000 worth of purchases
signed for by OMOKORE on or about September 27, 2010, at Houston Furniture Store #2.
86. Subsequently, on October 7, 2010, Houston Furniture Store #2 drew up two
additional sales invoices in OMOKORE’s name in the total amount of $23,703.50. On the
following day, October 8, 2010, CO-CONSPIRATOR #1 emailed photographs of the items listed
on these additional sales invoices directly to ALISON-MADUEKE. On October 9, 2010,
ALISON-MADUEKE responded by email to CO-CONSPIRATOR #1: “thx. cabinet is the
correct one.”
87. Subsequently, on October 13, 2010, CO-CONSPIRATOR #1 authorized Houston
Furniture Store # 2 to charge his Nevada company another $23,703.50 as payment for the
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additional furniture purchases made in OMOKORE’s name and discussed, via email, directly with
ALISON-MADUEKE.
88. Upon information and belief, in October 2010 CO-CONSPIRATOR #1 arranged
with Houston Furniture Store #1 to combine the recent purchases made by himself and
OMOKORE from both stores and to ship the merchandise to OMOKORE in Lagos, Nigeria.
89. At least one of the items purchased in OMOKORE’s name, and paid for by COCONSPIRATOR
#1, has been matched by vendor number, item number, and store-issued control
number to furniture discovered in ALISON-MADUEKE’s residence in Abuja, Nigeria.
90. Upon information and belief, OMOKORE and CO-CONSPIRATOR #1 made their
purchases at Houston Furniture Stores #1 and #2 in and around September and October 2010 and
subsequently arranged for the shipment of certain of those purchases to Nigeria for the corrupt
purpose of benefitting ALISON-MADUEKE and inducing her to improperly influence the award
of, inter alia, the Forcados SAAs to AEDC.
(2) Purchases by CO-CONSPIRATORS #2 and #3
91. On or about May 3, 2011, CO-CONSPIRATOR #2 purchased a total of $53,636.79
worth of furniture from Houston Furniture Store #2. These purchases included, among other
things, the following items:
TABLE 3
Control No. Description Price (w/o tax)
1564774 Luigi XVI Sideboard $10,829.00
1373385 George III Console $2,999.00
1479702 Jappaned Secretaire $5,508.00
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92. CO-CONSPIRATOR #2 returned to Houston Furniture Store #2 on or about the
following day, i.e., May 4, 2011, and purchased another $53,890.08 worth of merchandise.
93. On March 31, 2012, CO-CONSPIRATOR #3 purchased $27,068.99 worth of
merchandise at Houston Furniture Store #2. On or about April 4, 2012, CO-CONSPIRATOR #3
returned and purchased another $5,756.73 worth of merchandise from the same store.
94. In or around May 2012, the items purchased by CO-CONSPIRATORS #2 and #3,
as described in ¶¶ 91-93, were pooled into two shipping containers and shipped to the attention of
CO-CONSPIRATOR #3 in London. The descriptions and control numbers contained on the
packing lists match exactly the descriptions and control numbers on the sales records of Houston
Furniture Store #2, including those specifically identified in Table 3 above. The total value of the
shipped furniture, exclusive of sales tax or shipping fees, was $123,987.
95. On or about August 23, 2012, a representative of a U.K. moving and storage
company emailed the Construction Company Employee #1 regarding “[CO-CONSPIRATOR
#3]’s Containers.” Construction Company Employee #1 forwarded this email to ALUKO.
96. Subsequently, the Construction Company assisted in the delivery of multiple items
of furniture to 58 Harley House, including the three items identified in Table 3 above.
97. Thus, ALUKO and CO-CONSPIRATORS #2 and #3 conspired to and did purchase
furniture from Houston Furniture Store #2 and arranged for the shipment and delivery of some
portion of those items to 58 Harley House, a property that ALUKO and CO-CONSPIRATORS #2
and #3 had previously purchased and refurbished for the benefit and use of ALISON-MADUEKE
and her family.
98. Upon information and belief, ALUKO and CO-CONSPIRATORS #2 and #3
undertook to purchase and deliver furniture to 58 Harley House for the corrupt purpose of inducing
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ALISON-MADUEKE to use her influence, or rewarding her for having used her influence, within
the Nigerian Ministry for Petroleum Resources, NNPC, and NPDC to direct the award of business
opportunities to entities under the control of ALUKO and CO-CONSPIRATORS #2 and #3,
including the award of the Forcados SAAs and the Brass SAA to AEDC and AEBD.
(3) Purchases by ALUKO
99. The Furniture Store Employee further recalled that ALUKO visited the Houston
store to pay for some of ALISON-MADUEKE’s selections, and the Furniture Store Employee
kept ALUKO’s cellular telephone number in his own telephone under the descriptor “Kola Aluko
Madame D.”
100. On or about May 4, 2012, ALUKO purchased $446,607.29 worth of goods from
Houston Furniture Store #1. Later that month, in payment for his May 4, 2012, purchases, ALUKO
wired $461,500 to Houston Furniture Store #1 from a bank account ending in -090038 held in his
name at LGT Bank (Schweiz) AG in Switzerland (the “LGT -090038 Account”).
101. Also on May 4, 2012, ALUKO purchased an additional $262,091.47 worth of
furniture at Houston Furniture Store #2. On June 1, 2012, ALUKO wired $280,595.81 to Furniture
Store #2 from his LGT -090038 Account as payment for the purchases.
102. In or around March 2013, Houston Furniture Store #1 arranged a shipment of
furniture comprising a subset of items from ALUKO’s May 2012 purchases at both Houston
Furniture Store #1 and Furniture Store #2. The shipment was sent from Houston to Lagos, Nigeria.
The consignee was Chijioke Isiolu. Upon information and belief, Isiolu is a Nigerian attorney who
represents OMOKORE.
103. At least one item of furniture purchased by ALUKO as part of his May 4, 2012,
purchases from Houston Furniture Store #2 has been matched by vendor number, item number,
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and store-issued control number to furniture discovered in the Abuja residence of ALISONMADUEKE.
104. Upon information and belief, ALUKO made his May 2012 purchases at Houston
Furniture Stores #1 and #2 and arranged for the shipment of certain of those purchases to Nigeria
in or around March 2013 for the corrupt purpose of benefitting ALISON-MADUEKE in return for
ALISON-MADUEKE’s having improperly influenced the award of the Forcados SAAs to AEDC
and in anticipation of or in return for her improperly influencing the award of the Brass SAA, see
infra ¶¶ 105-117, to AEDC and AEBD.
F. The Brass SAA (OMLs 60, 61, 62, and 63)
105. On or about December 17, 2012–i.e., while ALUKO, OMOKORE, and COCONSPIRATORS
#1, #2, and #3 were in the midst of purchasing and refurbishing multiple highvalue
properties for the use and benefit of ALISON-MADUEKE and otherwise financing her
living and lifestyle expenses–NPDC awarded to AEDC a new SAA for OMLs 60, 61, 62, and 63
(the “Brass SAA”).
106. On or about February 14, 2013, AEDC entered into a novation agreement pursuant
to which it transferred all of its rights and obligations under the Brass SAA to AEBD.
(1) Terms of the Brass SAA
107. The Brass SAA, like the earlier Forcados SAAs, imposed certain obligations on
AEBD and, in return, entitled AEBD to a share of the oil and gas produced under the Brass OMLs.
108. In particular, the Brass SAA, required AEBD to pay a non-recoverable entry fee.
Per the terms of the SAA, the value of the entry fee was to be determined based on the estimated
probable oil and gas reserves within the area covered by the Brass OMLs. Upon information and
belief, the entry fee should have been at least $120,000,000.
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109. Per the terms of the Brass SAA, commencement of the agreement was contingent
“upon the payment of the entry fee by ATLANTIC,” i.e., by AEDC or, after the novation, AEBD.
110. In addition, the Brass SAA required AEBD to pay $350,000 per year to NPDC for
the first five years of the agreement for the provision of training facilities for NPDC staff.
111. Finally, the Brass SAA required AEBD “to provide all funds required by NPDC’s
60% share of Petroleum Operating Costs.” Upon information and belief, NPDC’s share of the
operating costs for the Brass OMLs, during the period from December 2012 through December
2015, was at least $1,700,000,000.
112. In return for meeting its obligations under the Brass SAA, AEBD would be entitled
to recover the cost of financing NPDC’s share of the operating costs (as described in the preceding
paragraph) and would be further entitled to a share of NPDC’s profit as determined by a profitsharing
formula contained in the SAA.
113. AEBD’s entitlements were payable in kind. That is, AEBD would receive
allocations of available oil sufficient to cover the amounts due as cost-recovery and profit.
(2) AEBD’s Performance Under the Brass SAA
114. Both AEBD and AEDC failed entirely to meet their obligations under the Brass
SAA. Neither company ever paid the required entry fee; neither company ever made payments
towards the NPDC training facilities; and neither company provided any funds to finance NPDC’s
share of the operating costs of the OMLs.
115. Despite this complete failure of AEBD and AEDC to meet any of their obligations
under the Brass SAA, NPDC nevertheless allocated to AEBD fifteen cargoes of oil, comprising
more than 7,000,000 barrels of crude oil. Over the course of a year, AEBD subsequently sold
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these allocations to Glencore Energy UK Ltd. (“Glencore”) for $811,297,883.11, collectively.
1
As
detailed below, see infra Table 6, Glencore’s payments to AEBD occurred between April 5, 2013,
and April 8, 2014.
116. Rather than use the proceeds of its oil liftings to meet its obligations under the Brass
SAA, AEBD retained the revenues and diverted them for the benefit of ALUKO and OMOKORE,
and, upon information and belief, for the benefit of ALISON-MADUEKE.
117. Upon information and belief, neither ALUKO nor OMOKORE ever intended to
fulfill their or their companies’ obligations under the Brass SAA but, nevertheless, with the
assistance of ALISON-MADUEKE, induced NPDC to enter into the agreement under the false
and fraudulent pretense that they intended to and would fulfill their obligations.
G. ALISON-MADUEKE’s Recorded Conversation with ALUKO
118. On or about May 14, 2014, ALISON-MADUEKE recorded a conversation between
herself and ALUKO. In the conversation, ALISON-MADUEKE acknowledged her role in
steering SAAs to AEDC.
ALISON-MADUEKE: You and Jide [i.e., OMOKORE] had some of the most support
that we could possibly give. At a time when we’re not doing
anything else, we stuck our necks out regarding the SAA and we
supported it. [INAUDIBLE] How the two of you have ruined it
is incredulous and incredible to all of us.
I spoke to you several times about your general behavior,
acquisition of assets, etc., asking you to be a bit more careful
because [INAUDIBLE] will start following you. I remember we
had this open discussion more than once. You kept telling me
that there was no issue because you did it in a certain way, you
did it in a certain–and I kept telling you that it doesn’t matter
how you do it. Once you start acquiring, acquiring, acquiring at
a certain level, then you’ll be–whether you like it or not,
whether it was done in the most transparent–you understand?–
1 Glencore, according to its website, is a “one of the world’s largest global diversified natural
resource companies.”
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manner or not, because they will want to trace where it came
from. This is an age of terrorism.
119. In particular, ALISON-MADUEKE criticized ALUKO for the purchase of the
yacht GALACTICA STAR.
ALISON-MADUEKE: If you want to hire a yacht, you lease it for two weeks or
