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Restoring asset declaration as a tool of public accountability 15 Jan 2026

The abrupt resignations in December 2025 of Farouk Ahmed and Gbenga Komolafe, the chief executives of Nigeria's two principal oil and gas regulatory agencies, sent shockwaves through the energy sector and ignited a broader conversation about accountability in public service. While both officials cited their own reasons for their departures, the timing was unmistakable: it followed incendiary allegations by Aliko Dangote, Africa's richest man, who accused Ahmed of corruption, claiming he had spent over $7 million on his children's education in Switzerland – expenditures allegedly inconsistent with a civil servant's legitimate earnings.

Dangote's petition to the Independent Corrupt Practices and Other Related Offences Commission (ICPC), which he made public, listed names, schools, and specified sums with forensic precision. Within days, both Ahmed and Komolafe tendered their resignations. To many observers, the sequence suggested that where institutional mechanisms had languished, private power – wielded by a man with evident commercial interests in the outcome, had catalysed action with startling efficiency.

This raises a troubling question: if it requires the intervention of a billionaire industrialist to expose alleged misconduct by public officials, what does this say about the effectiveness of Nigeria's asset declaration regime? More pointedly, if the Code of Conduct Bureau (CCB), empowered by law to monitor and verify the wealth of public officers, cannot preemptively detect such glaring discrepancies, has the system become a procedural formality rather than a substantive safeguard against corruption? The key distinction lies in who drives accountability. If the CCB, responding to its own verification processes or credible complaints from any source, had initiated these investigations independently, the system would be vindicated. That it required a billionaire's very public campaign suggests the system is broken, capable of responding to pressure from the powerful but not functioning as designed.

Nigeria's asset declaration framework is enshrined in the Fifth Schedule to the 1999 Constitution (as amended) and operationalised through the Code of Conduct Bureau and Tribunal Act. The CCB is constitutionally mandated to receive, examine, retain, and make available for public inspection the asset declarations of all public officers. The law requires that public officers declare their assets, along with those of their spouses and unmarried children under 18, within three months of assuming office; periodically every four years; and within three months of leaving office.

In theory, the legal architecture exists. It shifts the burden of proof onto public officers to justify unexplained wealth, unlike general criminal prosecutions, where the state must prove theft or fraud. Yet, theory and practice diverge sharply. The Guardian Newspaper, in an article published in May 2025, cited a report by civil society organisation Fixing the Future, which revealed that over 94 per cent of Nigerian public officials fail to fully comply with asset declaration requirements. Successful prosecutions remain vanishingly rare. Indeed, the highest-profile case in the Bureau's history – the 2015 prosecution of former Senate President Bukola Saraki on 18 counts of false asset declaration – ended in acquittal.

The Ahmed-Dangote case exposes the central paradox of Nigeria's asset declaration regime: the system generates data but rarely delivers accountability. Ahmed, as the Chief Executive Officer of a federal regulatory authority, was required by law to declare his assets upon assuming office in 2021. If, as Dangote alleges, he spent millions of dollars beyond his legitimate means during his tenure, these discrepancies should have been flagged during the CCB's routine verification processes. They were not.

This enforcement deficit has multiple causes. First, the CCB has suffered from chronic capacity constraints. With responsibility for monitoring over five million public officers across federal, state, and local government levels, the Bureau has historically lacked the personnel, technology, and resources for systematic verification. The recent introduction of an online asset declaration system and the establishment of a Financial Investigation and Fraud Analysis Unit represent steps forward, but these reforms are nascent and their impact unproven.

Second, political interference has historically undermined the Bureau's independence. As Human Rights Watch documented in its 2011 report “Corruption on Trial”, Nigeria's anti-corruption agencies – including the CCB and its sister institutions – have often operated with “apparent political selectivity”. Cases proceed or stall according to political expediency rather than the strength of evidence. The perception that prosecutions target political opponents while shielding allies corrodes public confidence and emboldens would-be violators.

Third, the legal framework itself contains ambiguities and loopholes. While public officers must declare assets, verification protocols remain opaque. What triggers an investigation? How are lifestyle audits conducted? Which red flags prompt referral to the Tribunal and other anti-corruption agencies? The absence of clear, publicly available standards creates space for inconsistent application and selective enforcement.

The role Dangote played in forcing accountability raises profound concerns about the privatisation of public interest enforcement. There is no question that Dangote's intervention achieved what the CCB could not or would not: it compelled scrutiny of a public official's wealth and triggered consequences. But the manner in which accountability was secured is deeply problematic. First, Dangote is not a disinterested citizen exercising civic duty. His petition to the ICPC followed a protracted commercial dispute with the Nigerian Midstream and Downstream Petroleum Regulatory Authority (NMDPRA) over import licenses, product quality standards, and allegations that the regulator was colluding with international traders to undermine his $20 billion refinery. 

The timing and specificity of Dangote’s allegations suggest they were strategic – deployed to neutralise regulatory opposition rather than solely motivated by public interest. Without either determining or challenging the veracity or credibility of Dangote's claims, it is important to raise the question: Should accountability in public office depend on whether a powerful private actor has the motive, resources, and platform to pursue it? What about misconduct by officials whose decisions do not impact billionaire industrialists? Are those violations destined to go undetected? 

Furthermore, allowing private interests to drive public accountability invites abuse, capable of inciting malicious accusations designed to remove inconvenient regulators and weaponising corruption allegations in commercial disputes.  The process of investigation – and not necessarily the outcome – can quickly become the punishment, and anyone with sufficient power and motivation can trigger the process.

The dysfunction of Nigeria's asset declaration regime is remediable. Other jurisdictions have demonstrated that public wealth monitoring can be both rigorous and effective when properly structured. First, declarations are not to be merely filed but actively scrutinised. Random audits, lifestyle investigations, and periodic reassessments should be conducted as a matter of course, not only when media scandals erupt or powerful interests complain. Nigeria's CCB must transition from a passive repository of forms to an active investigative agency.

Second, asset declarations should be genuinely public. While Nigerian law theoretically allows citizen inspection of declarations, practical barriers make access nearly impossible. Digitisation and online publication of declarations – redacting only genuinely sensitive information – would enable civil society, journalists, and researchers to conduct independent scrutiny. Transparency itself becomes a deterrent, as officials who know their declarations will be examined by thousands of eyes are less likely to falsify.

Third, enforcement must be swift and predictable. The slow pace of the Code of Conduct Tribunal proceedings undermines deterrence. The Saraki case dragged on for nearly two years before his acquittal. Protracted legal battles send the message that even when caught, consequences are uncertain and distant. Establishing clear timelines for investigations and adjudications, coupled with interim measures such as suspension pending investigation, would enhance the system's credibility.

Furthermore, the CCB itself must be insulated from political interference. Security of tenure for CCB leadership, transparent appointment processes, adequate budgetary independence, and parliamentary oversight mechanisms would strengthen the Bureau's capacity to act impartially. The perception that the CCB serves as an instrument of political vendetta rather than a neutral enforcer of public standards is as corrosive as actual corruption. The Bureau also needs forensic accountants, international liaison capabilities, and subpoena powers to compel production of records. Without these tools, the CCB cannot distinguish between legitimate explanations and elaborate fabrications. 

Moreover, the broader governance ecosystem must be reformed. Asset declaration is only one element of public sector integrity. Competitive and merit-based recruitment, transparent procurement processes, strong internal audit functions, whistleblower protections, and a vibrant free press all complement asset declaration in creating a culture of accountability. Where these elements are weak – as they manifestly are in Nigeria – asset declaration alone cannot stem corruption.

The Ahmed-Komolafe resignations carry implications beyond the individuals involved. It has exposed the hollowness of the asset declaration regime, but it has also created political space for reform. The ongoing investigations by the ICPC must be conducted thoroughly, transparently, and expeditiously. Dangote's allegations should be rigorously tested. If substantiated, prosecution must follow. If refuted, Ahmed deserves vindication, and Dangote should face consequences for false accusations. The outcome matters less for these individuals than for establishing that the system works.

Also, the CCB should conduct an immediate audit of its verification processes. The National Assembly should also revisit the Code of Conduct Bureau and Tribunal Act to address identified gaps. Mandatory timelines for investigations, clear verification standards, enhanced international cooperation mechanisms, digitisation mandates, and whistleblower protections should be codified. Civil society organisations, professional associations, and the media must also intensify scrutiny of public officials' wealth. While private actors cannot replace state institutions, they can supplement them. Investigative journalism, public interest litigation, and civil society monitoring have historically played crucial roles in exposing corruption worldwide. The dependence on Dangote's intervention should catalyse, not discourage, broader civic engagement.

The swift resignations of Farouk Ahmed and Gbenga Komolafe offer a superficial appearance of accountability. But surface appearances deceive. Accountability achieved through the intervention of a commercial titan with evident interests in the outcome is not genuine institutional accountability. It is patronage inverted – the exercise of private power in public matters. That such interventions sometimes serve the public interest does not validate them as sustainable governance mechanisms. Accountability, in such a system, becomes a matter of luck and power rather than law and design. That is not sustainable for a nation aspiring to development, integrity, and justice.

True accountability emerges from functional institutions that operate predictably, impartially, and effectively, regardless of who is watching. It requires an asset declaration regime that proactively detects discrepancies, investigates allegations thoroughly, and imposes consequences consistently. It demands regulatory independence, insulated from both political interference and commercial pressure. It necessitates a culture in which public service is understood as a sacred trust, not an opportunity for enrichment.

Funmilayo Odude is a Partner at Commercial and Energy Law Practice (CANDELP).