Headlines

James Ibori Charges

James Ibori Charges

IN THE FEDERAL HIGH COURT

IN THE KADUNA JUDICIAL DIVISION

HOLDEN AT KADUNA

CHARGE NO: ………………………….…

BETWEEN:

FEDERAL REPUBLIC OF NIGERIA ) COMPLAINANT

AND

1. JAMES ONANEFE IBORI )

2. UDOAMAKA OKORONKWO )

3. MER ENGINEERING NIG. LTD. ) ACCUSED

4 BAINENOX LIMITED )

5. SAGICON NIG. LIMITED )

CHARGES

COUNT 1

That you MR. JAMES ONANEFE IBORI on or about 1st March, 2004 within the jurisdiction of this Honourable Court did transfer the sum of N5,000,000.00 (Five Million Naira) to your personal account at Guarantee Trust Bank (GTB) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 2

That you MR. JAMES ONANEFE IBORI on or about 10th November, 2004 within the jurisdiction of this Honourable Court did transfer the sum of N1,000,000.00 (One Million Naira) to your personal account at Guarantee Trust Bank (GTB) which sum formed part of the funds illegally withdrawn from the account of the

…/2.

CHARGES

– 2 –

Delta State Government and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition) Act 2004.

COUNT 3

That you MR. JAMES ONANEFE IBORI on or about 1st March, 2006 within the jurisdiction of this Honourable Court did transfer the sum of N20,000,000.00 (Twenty Million Naira) to your personal Account at Guarantee Trust Bank (GTB) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 4

That you MR. JAMES ONANEFE IBORI on or about 2nd October 2003 within the jurisdiction of this Honourable Court did procure the PRIME CHAMBERS owned by PROFESSOR AGBE UTUAMA to retain in its account, the sum of N60,000,000.00 (Sixty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of a crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 5

That you MR. JAMES ONANEFE IBORI on or about 28th August, 2003 within the jurisdiction of this Honourable Court did procure the PRIME CHAMBERS owned by PROFESSOR AGBE UTUAMA to retain in its account, the sum of N90,000,000.00 (Ninety Million Naira) which sum formed part of the funds illegally

…/3.

CHARGES

– 3 –

withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of a crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 6

That you MR. JAMES ONANEFE IBORI on or about 24th July, 2003 within the jurisdiction of this Honourable Court did procure the PRIME CHAMBERS owned by PROFESSOR AGBE UTUAMA to retain in its account, the sum of N42,000,000.00 (Forty-Two Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of a crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 7

That you MR. JAMES ONANEFE IBORI on or about 28th June, 2004 within the jurisdiction of this Honourable Court did procure the PRIME CHAMBERS owned by PROFESSOR AGBE UTUAMA to retain in its account, the sum of N4,900,000.00 (Four Million, Nine Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of a crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 8

That you MR. JAMES ONANEFE IBORI on or about 4th June, 2003 within the jurisdiction of this Honourable Court did procure the PRIME CHAMBERS owned by PROFESSOR AGBE UTUAMA to retain in its account, the sum of N90,500,000.00 (Ninety Million, Five Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the

…/4.

CHARGES

– 4 –

Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition) Act 2003.

COUNT 9

That you MR. JAMES ONANEFE IBORI on or about 10th December, 2003 within the jurisdiction of this Honourable Court did procure the PRIME CHAMBERS owned by PROFESSOR AGBE UTUAMA to retain in its account, the sum of N30,150,000.00 (Thirty Million, One Hundred and Fifty Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 10

That you MR. JAMES ONANEFE IBORI on or about 28th April, 2004 within the jurisdiction of this Honourable Court did procure the PRIME CHAMBERS owned by PROFESSOR AGBE UTUAMA to retain in its account, the sum of N14,989,000.00 (Fourteen Million, Nine Hundred and Eighty-Nine Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 11

That you MR. JAMES ONANEFE IBORI on or about 2nd January, 2004 within the jurisdiction of this Honourable Court did procure the PRIME CHAMBERS owned by PROFESSOR AGBE UTUAMA to retain in its account, the sum of N22,000,000.00 (Twenty-Two Million Naira) which sum formed part of the funds

…/5.

CHARGES

– 5 –

illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 12

That you MR. JAMES ONANEFE IBORI on or about 17th May, 2004 within the jurisdiction of this Honourable Court did procure the PRIME CHAMBERS owned by PROFESSOR AGBE UTUAMA to retain in its account, the sum of N20,000,000.00 (Twenty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 13

That you MR. JAMES ONANEFE IBORI on or about 6th May, 2005 within the jurisdiction of this Honourable Court did procure the PRIME CHAMBERS owned by PROFESSOR AGBE UTUAMA to retain in its account, the sum of N7,000,000.00 (Seven Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 14

That you MR. JAMES ONANEFE IBORI on or about 29th January, 2004 within the jurisdiction of this Honourable Court did procure the PRIME CHAMBERS owned by PROFESSOR AGBE UTUAMA to retain in its account, the sum of N2,000,000.00 (Two Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and

…/6.

CHARGES

– 6 –

which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

…/

COUNT 15

That you MR. JAMES ONANEFE IBORI on or about 29th July 2005 within the jurisdiction of this Honourable Court did transfer the sum of N5,567,000.00 (Five Million, Five Hundred and Sixty-Seven Thousand Naira) to Silhouette Travels and Tours Limited which sum formed part of the money illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 16

That you MR. JAMES ONANEFE IBORI on or about 7th June 2006 within the jurisdiction of this Honourable Court did transfer the sum of N2,877,400.00 (Two Million, Eight Hundred and Seventy–Seven Thousand, Four Hundred Naira) to Silhouette Travels and Tours Limited which sum formed part of the money illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 17

That you MR. JAMES ONANEFE IBORI on or about 6th April 2005 within the jurisdiction of this Honourable Court did transfer the sum of N3,203,940.00 (Three Million, Two Hundred and Three Thousand, Nine Hundred and Forty Thousand Naira) to Silhouette Travels and Tours Limited which sum formed part of the money illegally withdrawn from the account of the Delta State

…/7.

CHARGES

– 7 –

Government and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 18

That you MR. JAMES ONANEFE IBORI on or about 7th April, 2005 within the jurisdiction of this Honourable Court did transfer the sum of N5,985,000.00 (Five Million, Nine Hundred and Eighty-Five Thousand Naira) to Silhouette Travels and Tours Limited which sum formed part of the money illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 19

That you MR. JAMES ONANEFE IBORI on or about 21st June 2006 within the jurisdiction of this Honourable Court did transfer the sum of N5,000,000.00 (Five Million Naira) to Silhouette Travels and Tours Limited which sum formed part of the money illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 20

That you MR. JAMES ONANEFE IBORI on or about 3rd February, 2005 within the jurisdiction of this Honourable Court did transfer the sum of N6,000,000.00 (Six Million Naira) to Silhouette Travels and Tours Limited which sum formed part of the money illegally withdrawn from the account of the Delta State Government

…/8.

CHARGES

– 8 –

and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 21

That you MR. JAMES ONANEFE IBORI on or about 29th August 2006 within the jurisdiction of this Honourable Court did transfer the sum of N14,000,000.00 (Fourteen Million Naira) to Silhouette Travels and Tours Limited which sum formed part of the money illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 22

That you MR. JAMES ONANEFE IBORI on or about 19th September, 2003 within the jurisdiction of this Honourable Court did collaborate with CHARTERHOUSE PROJECT AND INVESTMENT LIMITED and ADEBIMPE POGOSON to conceal the genuine origin of the sum of N20,000,000.00 (Twenty Million Naira) which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition) Act 2003.

COUNT 23

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 7th August, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N10,000,000.00 (Ten Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State

…/9.

CHARGES

– 9 –

Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 24

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N7,000,000.00 (Seven Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 25

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N11,000,000.00 (Eleven Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented

…/10.

CHARGES

– 10 –

the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 26

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N9,000,000.00 (Nine Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 27

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N9,000,000.00 (Nine Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

…/11.

CHARGES

– 11 –

COUNT 28

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N10,000,000.00 (Ten Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 29

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N10,000,000.00 (Ten Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 30

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of

…/12.

CHARGES

– 12 –

N4,500,000.00 (Four Million, Five Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 31

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 9th February, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N40,000,000.00 (Forty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 32

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N9,000,000.00 (Nine Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented

…/13.

CHARGES

– 13-

the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 33

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 7th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N20,000,000.00 (Twenty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 34

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N10,000,000.00 (Ten Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

…/14.

CHARGES

– 14 –

COUNT 35

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N20,000,000.00 (Twenty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 36

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N3,000,000.00 (Three Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

…/15.

CHARGES

– 15 –

COUNT 37

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 14th February, 2007 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N2,800,000.00 (Two Million Eight Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 38

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 9th February, 2007 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N10,000,000.00 (Ten Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

…/16.

CHARGES

– 16 –

COUNT 39

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 9th February, 2007 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N20,000,000.00 (Twenty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 40

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 8th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N30,000,000.00 (Thirty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 41

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 14th February, 2007within the jurisdiction of this Honourable Court did collaborate

…/17.

CHARGES

– 17 –

with one another to conceal the genuine origin of the sum of N500,000.00 (Five Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 42

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 26th October, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N10,000,000.00 (Ten Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 43

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 13th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N4,650,000.00 (Four Million, Six Hundred and Fifty Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED

…/18.

CHARGES

– 18 –

and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 44

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 12th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N4,300,000.00 (Four Million Three Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 45

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 13th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N4,700,000.00 (Four Million Seven Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum

…/19.

CHARGES

– 19 –

you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 46

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 12th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N4,500,000.00 (Four Million Five Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 47

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 14th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N3,000,000.00 (Three Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

…/20.

CHARGES

– 20 –

COUNT 48

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 13th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N4,400,000.00 (Four Million, Four Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 49

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 7th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N30,000,000.00 (Thirty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

…/21.

CHARGES

– 21 –

COUNT 50

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 7th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N40,000,000.00 (Forty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 51

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 17th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N20,000,000.00 (Twenty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

…/22.

CHARGES

– 22 –

COUNT 52

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 6th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N4,800,000.00 (Four Million, Eight Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 53

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 6th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N18,000,000.00 (Eighteen Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 54

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 5th February, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of

…/23.

CHARGES

– 23 –

N15,000,000.00 (Fifteen Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 55

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 28th December, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N25,000,000.00 (Twenty-Five Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 56

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 5th January, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N25,000,000.00 (Twenty Five Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of

…/24.

CHARGES

– 24 –

MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition) Act 2004.

COUNT 57

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 5th January, 2007within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N20,000,000.00 (Twenty Million) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 58

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 20th December, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N20,000,000.00 (Twenty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

…/25.

CHARGES

– 25 –

COUNT 59

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 28th December, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N23,000,000.00 (Twenty Three Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 60

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 22nd December, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N17,000,000.00 (Seventeen Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

…/26.

CHARGES

– 26 –

COUNT 61

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 7th August, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N10,000,000.00 (Ten Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 62

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 19th December, 2006 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N50,000,000.00 (Fifty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

…/27.

CHARGES

– 27 –

COUNT 63

That you MR. JAMES ONANEFE IBORI, MER ENGINEERING LIMITED and BAINENOX LIMITED on or about 15th July, 2006 and 20th February, 2007 within the jurisdiction of this Honourable Court did collaborate with one another to conceal the genuine origin of the sum of N641,500,000.00 (Six Hundred and Forty-One Million, Five Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government to offset a loan granted by United Bank for Africa Plc in favour of BAINENOX LIMITED and for the benefit of MER ENGINEERING LIMITED and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 64

That you UDOAMAKA OKORONKWO on or about 9th April, 2003 within the jurisdiction of this Honourable Court did retain in your personal account, the sum of N4,000,000.00 (Four Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government on the instruction of MR. JAMES ONANEFE IBORI and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 65

That you UDOAMAKA OKORONKWO on or about 24th April, 2003 within the jurisdiction of this Honourable Court did retain in your personal account, the sum of N14,000,000.00 (Fourteen Million Naira) which sum formed part of the funds illegally

…/28.

CHARGES

– 28 –

withdrawn from the account of the Delta State Government on the instruction of MR. JAMES ONANEFE IBORI and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 66

That you UDOAMAKA OKORONKWO on or about 3rd June, 2003 within the jurisdiction of this Honourable Court did retain in your personal account, the sum of N28,300,000.00 (Twenty Eight Million, Three Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government on the instruction of MR. JAMES ONANEFE IBORI and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 67

That you UDOAMAKA OKORONKWO on or about 16th June, 2003 within the jurisdiction of this Honourable Court did retain in your personal account, the sum of N20,000,000.00 (Twenty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government on the instruction of MR. JAMES ONANEFE IBORI and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 68

That you UDOAMAKA OKORONKWO on or about 26th June, 2003 within the jurisdiction of this Honourable Court did retain in your personal account, the sum of N2,000,000.00 (Two Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government on the instruction of MR. JAMES ONANEFE IBORI and which sum you knew

…/29.

CHARGES

– 29 –

represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 69

That you UDOAMAKA OKORONKWO on or about 1st September, 2003 within the jurisdiction of this Honourable Court did retain in your personal account, the sum of N15,000,000.00 (Fifteen Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government on the instruction of MR. JAMES ONANEFE IBORI and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 70

That you MR. JAMES ONANEFE IBORI on or about 23rd October, 2003 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N16,500,000.00 (Sixteen Million, Five Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 71

That you MR. JAMES ONANEFE IBORI on or about 3rd December, 2003 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N20,000,000.00 (Twenty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

…/30.

CHARGES

– 30 –

COUNT 72

That you MR. JAMES ONANEFE IBORI on or about 10th December, 2003 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N10,000,000.00 (Ten Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 73

That you MR. JAMES ONANEFE IBORI on or about 23rd October, 2003 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N8,000,000.00 (Eight Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 74

That you MR. JAMES ONANEFE IBORI on or about 28th January, 2004 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N5,700,000.00 (Five Million, Seven Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

…/31.

CHARGES

-31 –

COUNT 75

That you MR. JAMES ONANEFE IBORI on or about 17th June, 2004 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N20,000,000.00 (Twenty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 76

That you MR. JAMES ONANEFE IBORI on or about 8th July, 2004 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N29,720,000.00 (Twenty Nine Million, Seven Hundred and Twenty Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 77

That you MR. JAMES ONANEFE IBORI on or about 16th September, 2004 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N5,000,000.00 (Five Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

…/32.

CHARGES

– 32 –

COUNT 78

That you MR. JAMES ONANEFE IBORI on or about 5th October, 2004 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N10,000,000.00 (Ten Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 79

That you MR. JAMES ONANEFE IBORI on or about 10th May, 2005 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N5,545,000.00 (Five Million, Five Hundred and Forty-Five Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 80

That you MR. JAMES ONANEFE IBORI on or about 13th June, 2005 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N5,860,000.00 (Five Million, Eight Hundred and Sixty Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

…/33.

CHARGES

– 33 –

COUNT 81

That you MR. JAMES ONANEFE IBORI on or about 15th June, 2005 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N10,000,000.00 (Ten Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 82

That you MR. JAMES ONANEFE IBORI on or about 20th July, 2005 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N10,000,000.00 (Ten Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 83

That you MR. JAMES ONANEFE IBORI on or about 29th July, 2005 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N12,800,000.00 (Twelve Million, Eight Hundred Thousand Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

…/34.

CHARGES

– 34 –

COUNT 84

That you MR. JAMES ONANEFE IBORI on or about 17th June, 2005 within the jurisdiction of this Honourable Court did procure one UDOAMAKA OKORONKWO to retain in her account the sum of N20,000,000.00 (Twenty Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2004.

COUNT 85

That you SAGICON NIG. LIMITED on or about 15th July, 2003 within the jurisdiction of this Honourable Court did retain in your personal account, the sum of N5,000,000.00 (Five Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government on the instruction of MR. JAMES ONANEFE IBORI and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 86

That you SAGICON NIG. LIMITED on or about 24th July, 2003 within the jurisdiction of this Honourable Court did retain in your personal account, the sum of N16,500,000.00 (Sixteen Million, Five Hundred Thousand Naira)which sum formed part of the funds illegally withdrawn from the account of the Delta State Government on the instruction of MR. JAMES ONANEFE IBORI and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

…/35.

CHARGES

– 35 –

COUNT 87

That you SAGICON NIG. LIMITED on or about 3rd October, 2003 within the jurisdiction of this Honourable Court did retain in your personal account, the sum of N5,000,000.00 (Five Million Naira) which sum formed part of the funds illegally withdrawn from the account of the Delta State Government on the instruction of MR. JAMES ONANEFE IBORI and which sum you knew represented the proceed of crime and you thereby committed an offence punishable under Section 16 of the Money Laundering (Prohibition ) Act 2003.

COUNT 88

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Double Dip Nigeria Limited to conceal the genuine origin of the sum of N240,000,000.00 (Two Hundred and Forty Million Naira) by using the said sum to buy Afribank shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 89

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Arusha Nigeria Limited to conceal the genuine origin of the sum of N270,000,000.00 (Two Hundred and Seventy Million Naira) by using the said sum to buy Afribank shares in the name of fictitious persons, which sum formed part of

…/36.

CHARGES

– 36 –

the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 90

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Abajin Nigeria Limited to conceal the genuine origin of the sum of N260,000,000.00 (Two Hundred and Sixty Million Naira) by using the said sum to buy Afribank shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 91

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Lugba Nigeria Limited to conceal the genuine origin of the sum of N230,000,000.00 (Two Hundred and Thirty Million Naira) by using the said sum to buy Afribank shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 92

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Mombassa Nigeria Limited to conceal the genuine origin of the sum of N250,000,000.00 (Two Hundred and Fifty Million Naira) by using the said sum to buy Afribank

…/37.

CHARGES

– 37 –

shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 93

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Kent Int’l Limited to conceal the genuine origin of the sum of N220,000,000.00 (Two Hundred and Twenty Million Naira) by using the said sum to buy Afribank shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 94

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Limpopo Nigeria Limited to conceal the genuine origin of the sum of N280,000,000.00 (Two Hundred and Eighty Million Naira) by using the said sum to buy Afribank shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 95

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Jakpa Nigeria Limited to conceal the genuine origin of the sum of N280,000,000.00 (Two Hundred and Eighty Million Naira) by using the said sum to buy Afribank

…/38.

CHARGES

– 38 –

shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 96

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Zaragoza Nigeria Limited to conceal the genuine origin of the sum of N230,000,000.00 (Two Hundred and Thirty Million Naira) by using the said sum to buy Afribank shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 97

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Azania Nigeria Limited to conceal the genuine origin of the sum of N230,000,000.00 (Two Hundred and Thirty Million Naira) by using the said sum to buy Afribank shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 98

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Ogan Global Nigeria Limited to conceal the genuine origin of the sum of N260,000,000.00 (Two Hundred and Sixty Million Naira) by using the said sum to buy Afribank

…/39.

CHARGES

– 39 –

shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 99

That you MR. JAMES ONANEFE IBORI, on or about 31st December, 2004 within the jurisdiction of this Honourable Court did collaborate with one Sandton Nigeria Limited to conceal the genuine origin of the sum of N250,000,000.00 (Two Hundred and Fifty Million Naira) by using the said sum to buy Afribank shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 100

That you MR. JAMES ONANEFE IBORI, on or about 19th November, 2004 within the jurisdiction of this Honourable Court did collaborate with one Global Heritage Int’l to conceal the genuine origin of the sum of N1,000,000.00 (One Million Naira) by using the said sum to buy Afribank shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 101

That you MR. JAMES ONANEFE IBORI, on or about 22nd November, 2004 within the jurisdiction of this Honourable Court did collaborate with one Fortress Const. Co. to conceal the genuine origin of the sum of N1,000,000.00 (One Million Naira) by

…/40.

CHARGES

– 40-

using the said sum to buy Afribank shares in the name of fictitious persons, which sum formed part of the funds of the Delta State Government and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 102

That you MR. JAMES ONANEFE IBORI on or about 31st December, 2004 within the jurisdiction of this Honourable Court did transfer the sum of N5,000,000,000.00 (Five Billion Naira) from the account of Delta State Government to buy shares Afribank using fictitious companies which sum formed part of the funds illegally withdrawn from the account of the Delta State Government and which sum you knew represented the proceed of crime with the aim of concealing the nature of the proceed of the said crime and you thereby committed an offence punishable under Section 14(1) of the Money Laundering (Prohibition ) Act 2004.

COUNT 103

That you MR. JAMES ONANEFE IBORI on or about 25th April, 2007 within the jurisdiction of this Honourable Court made cash payment of the sum of $15,000,000.00 (Fifteen Million Dollars) to the officials of the Economic and Financial Crimes Commission in order to influence their investigations and you thereby committed an offence punishable under Section 15(2)(b) of the Money Laundering (Prohibition ) Act 2004.

Dated this………………………..day of …………………….., 2007.

ISA BATURE GAFAI

LEGAL AND PROSECUTION UNIT,

ECONOMIC AND FINANCIAL CRIMES COMMISSION

2, IBRAHIM TAIWO ROAD,

ASO VILLA, ABUJA

IN THE FEDERAL HIGH COURT

IN THE KADUNA JUDICIAL DIVISION

HOLDEN AT KADUNA

CHARGE NO: ………………………….…

BETWEEN:

FEDERAL REPUBLIC OF NIGERIA ) COMPLAINANT

AND

1. JAMES ONANEFE IBORI )

2. UDOAMAKA OKORONKWO )

3. MER ENGINEERING NIG LTD ) ACCUSED

4 BAINENOX LIMITED )

5. SAGICON NIG LIMITED )

PROOF OF EVIDENCE

Dated this……………………..day of …………………….., 2007.

ISA BATURE GAFAI

LEGAL AND PROSECUTION UNIT,

ECONOMIC AND FINANCIAL CRIMES COMMISSION

2, IBRAHIM TAIWO ROAD,

ASO VILLA, ABUJA

LIST OF EXHIBITS

Complainants statement -Copied
Statement of the accused persons – Copied
Statement of some witnesses – Copied
Other relevant documents/exhibits attached – Copied

LIST OF WITNESSES

1. ISIAYEI CHARLES

2. OGHORO AUGUSTINE EDE

3. CHIEDU EBIE

4. OCHEI ODIAWA

5. OFFICIALS OF UNITED BANK FOR AFRICA PLC (UBA)

6. OFFICIALS OF OCEANIC BANK INTERNATIONAL PLC

7. BELLO YAHAYA

(To give evidence of investigation and tender the necessary Exhibits.

Dated this………………………..day of …………………….., 2007.

ISA BATURE GAFAI

LEGAL AND PROSECUTION UNIT,

ECONOMIC AND FINANCIAL CRIMES COMMISSION

2, IBRAHIM TAIWO ROAD,

ASO VILLA, ABUJA