I
am compelled to make this public statement to address the various allegations
levied against the Central Bank of Nigeria (CBN) and cited as the reasons for
my suspension from office as the Governor of the CBN on the 19th of
February 2014.
·
As a matter of record,
the allegations were made in the following documents:
i. Briefing Note of the Financial Reporting Council of
Nigeria (FRCN) dated 7th June 2013, Ref: PRES/188/T&I/89 to His
Excellency, President Goodluck Ebele Jonathan [the Briefing Note];
ii. The Letter of Suspension dated 19th February
2014, which I received from the Office of the Secretary to the Government of
the Federation; and
iii. The petition dated 9th February 2014 by Mr
Erastus Akingbola.
However,
before I go into the above issues, let me reiterate for the records, the
achievements of the CBN during my tenure as the Governor:
The Record
The Record
Firstly,
let me state that I have been extremely fortunate to have had a solid and
supportive team led by the Deputy Governors and supported by the Departmental
Directors, as well as thousands of hardworking and dedicated staff who must be
given the credit for all that the CBN has achieved. I would also like to acknowledge
for the record, the foundation laid by my predecessor, Professor Charles
ChukwumaSoludo, in a number of areas. The CBN Act, 2007, which he championed,
established the CBN as a truly autonomous entity of the Federation, and made it
possible for us to take the difficult decisions necessary for restoring and
maintaining macroeconomic stability. The FSS 2020 and PSV 2020 documents
provided the principal strategic roadmaps that led to many of the innovations
in payment systems, non-interest banking, financial inclusion, the Asset
Management Corporation, IFRS, Risk-based Supervision, and the like.
Indeed,
it will be impossible for me to review almost five years of revolutionary
change made possible by the work of thousands of employees in the CBN in collaboration
with other Regulators, Banks and Other Financial Institutions and Government
Ministries in this press statement. However, I will mention a few of the key
highlights.
On
monetary policy, the Bank has improved the institutional framework for policy-making.
A properly constituted Monetary Policy Committee (MPC) with a clear
mandate for maintaining stability has been established. The MPC has been
supported by improvements in research, data and forecasting capacity, and we
have also paid attention to clear communication of our objectives to the
market. As a result, headline inflation has remained below 10 per cent since
January 2013, from a peak of 15.1 percent and 13.9 percent in 2008 and 2009
respectively. Core inflation declined from 11.2 per cent in December 2009 to
7.9 percent in December 2013, while food inflation maintained a downward trend
from 15.5 percent in December 2009 to 9.3 percent in December 2013. In addition
to the conventional liquidity management products, the Bank approved financial
products to manage liquidity in non-interest financial institutions. The CBN
also promoted the formation of the financial Markets Dealers Quotations
Over–the-Counter (FQDM OTC) Plc as a self-regulatory OTC operator.
In
the area of safeguarding the value of the local currency and maintaining
stability in the foreign exchange market for the overall sustenance of
macroeconomic stability and growth, the CBN over the period has successfully
maintained a stable exchange rate regime and a robust external reserve position
conducive to sustainable growth and development.
On
the Banking System, I was appointed Governor in the middle of a global
financial crisis when the Nigerian banking system was on the verge of collapse.
The Bank moved swiftly to remove the managing directors and executive directors
of the banks where major corporate governance failures were discovered,
provided liquidity support, pioneered the setting up of the Asset Management
Corporation of Nigeria (AMCON) to purchase non-performing loans,
recapitalize the banks and pilot a process that led to mergers and
acquisitions, as well as recapitalization of all the weak and failing banks. As
a result, all financial soundness indicators – Capital Adequacy, Asset Quality,
Liquidity and Profitability ratios – were normalized. As a result of the
work by the Bank, not a single depositor or creditor lost money in any Nigerian
bank during or after the financial crisis.
In
addition to the quantitative measures, we broke up universal banks and encouraged
the setting up of specialized banks (including the first Non – interest Bank in
the Country’s history), pushed for the adoption of IFRS and Basel 3, enhanced
risk-based supervision, issued Competency Guidelines for the staff in the
banking industry, established a Consumer Protection Department and developed a
Financial Inclusion Strategy and Roadmap, among others for the CBN.
The
Bank implemented policies aimed at reducing the excessive use of cash in the
system to ensure safety, improve efficiency and curb money laundering. The
transformation of NIBSS, the insistence on interoperability of channels,
encouragement of electronic banking, the licensing of Mobile Money Operators,
the Agent Banking and tiered-KYC frameworks have all led to rapid growth in volume
and value of non-cash transaction and enhanced financial inclusion.
The
Bank has played its leadership role in ensuring industry compliance with
environmental sustainability and governance standards, including a strong focus
on women and the handicapped.
The
CBN in the last five years has taken a leading role in providing long-term
low-cost funding to priority sectors of the Nigerian economy in a bid to help
in bringing to reality the Transformation Agenda of the government of your
Excellency. We have provided these funds at single-digit interest rates to
micro, small and medium enterprises, as well as to companies operating in the
power, aviation, and agricultural sectors of the economy, and also to large
industrial enterprises with potential for structural transformation.
The
Bank has invested in human capital, improved staff welfare and attracted and
retained specialized skills in the areas of Banking Supervision, Information
Technology, Shared Services and Risk Management.
On
Financial Performance, the Bank has in the last five years kept a lid on
overheads and cost of currency management. As a result, the Bank has continued
to produce sterling results and contributed substantially to the Federal
Budget. In the five years, 2009 – 2013, the Bank contributed N376
billion to the Federal Budget as Internally Generated Revenue (IGR).Based
on 2012 financials alone, we paid N80 billion to the Ministry of
Finance. On the basis of the 2013 results and at the request of the
Coordinating Minister of the Economy (CME), we paid N159 billion
to the Ministry of Finance in February this year; the same month the audited
accounts of the CBN were approved by the Committee of Governors (COG).
Indeed, due to the precarious position of Government finances, the CBN in
February 2014, upon the request of the CME, gave the Ministry a further
‘Advance IGR’ of N70 billion in anticipation of 2014 profits.
May
I add that, in 2008, the year before my appointment, the CBN contributed N8
billion to the Federation Account. Although the Bank is not a profit-centre, in
the first four years of my term, the Bank alone contributed 75 percent of the
total IGR paid by MDAs leading to commendation by the House Committee on
Finance at several Public Hearings.
Recognitions
As a result of these achievements of my colleagues and staff, we received numerous recognitions consistently throughout my tenure from highly-regarded publications. These awards are based on a competitive process where analysts and economists rank Central Bank Governors across regions and the globe.
In 2010, The Banker Magazine, a publication of Financial Times in London, named me Best Central Bank Governor in the World and Best in Africa. At the Annual World Bank/IMF Meetings, Emerging Markets, a publication of Euromoney Institutional Investor named me Best Central Bank Governor in Sub-Saharan Africa for 2009, 2010 and 2012. The African Banker Magazine named me Best Central Bank Governor in Africa, 2012. This is in addition to being named Forbes Africa Person of the year 2011 and listed by TIME as one of the 100 most influential people in the world, 2011.
As a result of these achievements of my colleagues and staff, we received numerous recognitions consistently throughout my tenure from highly-regarded publications. These awards are based on a competitive process where analysts and economists rank Central Bank Governors across regions and the globe.
In 2010, The Banker Magazine, a publication of Financial Times in London, named me Best Central Bank Governor in the World and Best in Africa. At the Annual World Bank/IMF Meetings, Emerging Markets, a publication of Euromoney Institutional Investor named me Best Central Bank Governor in Sub-Saharan Africa for 2009, 2010 and 2012. The African Banker Magazine named me Best Central Bank Governor in Africa, 2012. This is in addition to being named Forbes Africa Person of the year 2011 and listed by TIME as one of the 100 most influential people in the world, 2011.
I
have always regarded these honours not as personal accolades, but as a tribute
to our nation and the committed and resourceful women and men of CBN.
response to the allegations in
relation to my suspension
- On Wednesday 10th March 2014, I submitted a Memorandumto His Excellency, Mr President, with supporting documentation,effectively addressing all the allegations contained in the FRCN Briefing Note, the Letter of Suspension and the Akingbola Petition.
- Having submitted my response to the President, I am further compelled, following the recent press briefing and comments by the Senior Special Adviserto the President on Media, as well as numerous other references to the allegations in both local, international and online media, to put to the public my responses, in the interest of transparency, accountability and my responsibility to the Nigerian people.Let me also state that I saw the FRCN “Briefing Note” for the first time when it was attached to the suspension letter. At no time was this report sent to the CBN either by the President or the FRCN for comments or explanations. As for the Akingbola petition, it is a rehash of baseless allegations he has been making since 2010 which apparently he must have been asked to reproduce on February 9, ten days before the suspension. It is indeed strange that the CBN Governor can be suspended based on allegations written by a man who ran his bank into the ground and against whom judgement has been obtained in a London court, and who furthermore is facing criminal prosecution at home for offences including criminal Theft.
- A careful examination of the allegations contained in the FRCN Briefing Note to Mr President, will show that each of the allegations could easily have been resolved by a simple request for clarification or more careful review. There is no doubt that if the CBN had received the Briefing Note, which was prepared in June 2013, all the misconceptions, misrepresentations and erroneous inferences contained therein would have been cleared.
- I am publishing these responses to enable the general public see that each and every allegation levelled against the CBN under my leadership is false and unfounded, and that many of the allegations were malicious and fabricated, having been designed to mislead the President into believing that the Management of the Central Bank was guilty of misconduct and recklessness.
- Having provided detailed explanations, backed by verifiable documents, it is my sincere wish that His Excellency, Mr President, in line with his adherence to fairness and justice, will apply the same rationale and rigour to other agencies of the Federal Government that have had serious allegations and queries levied against them, and prevail upon them to provide responses and explanations with the same level of clarity and transparency.
- In closing, I would like to place on record the dogged professionalism and patriotism of the staff of the CBN. They have, over the years, conducted themselves very creditably, and discharged their duties with the highest integrity.
*
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Memorandum Responding to THE FRCN ALLEGATIONS
1. Corporate
Governance
Briefing Note
Allegation 1:that there is weak corporate governance at the CBN on
account of the fact that the office of the Governor is fused with that of the
Chairman of CBN’s Board of Directors.
Response:
i.This allegation ignores the fact
that global best practice is that the Governor of the central bank is the
Chairman of the Board of Directors of the central bank. See Annexure
A, which shows the composition of the Board of Directors of central banks
in over 55 different countries.
2. Alleged
Fraudulent Activities
Payments to NSPMP
Briefing Note Allegation 2:that the CBN’s breakdown of
“Currency Issue Expenses” for 2011 and 2012 indicated that it paid the Nigerian
Security Printing and Minting Plc(NSPMP) N38.233 Billion in 2011 for
printing of banknotes, whereas the entire turnover of NSPMP was N 29.370
Billion.
Response:
i. The expense item of N38.233 Billion to NSPMPwas
made up as follows:
a. N28.738Billion
payment to NSPMP in 2011;
b. N6.587Billion
accrued liability in 2011 but paid in 2012 when deliveries were received; and
c. N2.829Billion
audit adjustment journal entry into the account at the end of 2011 in respect
of prepayments to NSPMP.
ii. See Annexure
Bfor the evidence of payment to the NSPMP. Evidently, the
difference between the numbers in the financial statements of CBN and NSPMP is
a simple reflection of timing differences between recognition of expenses by
the CBN and income recognition by the NSPMP, with both entities applying
conservative accounting policies.
3. Charter Fees
Briefing Note
Allegation 3: that the CBN made fictitious payments to (a) Emirate
Airlines: N0.511 Billion which allegedly does not fly local charter in
Nigeria; (b) Wing Airline: N0.425 Billion which allegedly is not
registered with the Nigerian Civil Aviation Authority (NCAA); and (c)
Associated Airline: N1.025 Billion which allegedly did not have a
turnover of up to a billion naira in 2011.
Response:
i. The CBNneither engaged, paid nor claimed to have paid
Emirates Airlines. Rather, the CBN engaged andentered intoan Air Charter
Services Agreementwith Emirate Touch Aviation ServicesLimited, which is
a local Nigerian charter service company.A simple enquiry by FRCN would have
clarified and avoided this misrepresentation.
ii. With respect to
Wings Aviation Limited,the CBN contracted Wings Aviation Limited,which
changedits name to Jedidiah Air Limited on 21August 2009 but only notified the
CBN of the change on 28 February 2012.Please, see Annexure C for the
letter from Jedidiah Air Limited notifying the CBN of the change of name.Here
also, a simple enquiry by FRCN would have made this clear.
iii. With respect to
Associated Air Limited,the CBN did in fact pay a total of N1.025 Billion
to Associated Airline Limited.See Annexure D for the schedule of
payments made to Associated Airline Limited.It is worth stating that the
CBN is not responsible for how the company reports its turnover.
4. Deposit for
Shares in Bank of Industry (BoI)
Briefing Note Allegation 4: that the CBN is yet to receive the share certificate
for investments made in the Bank of Industry (BoI) since September 2007
and that the leadership of the CBN was not worried about the delay.
Response:
i. On 20 August
2009, shortly after I assumed office, I directed that a reconciliation exercise
be carried out by the CBN on all its investments in parastatals and companies.
Thereafter, the CBN wrote various letters to the Bank of Industry requesting
for its share certificates. See AnnexureE for the letters from the
CBN requesting for the certificate.
ii. On 20 September
2009, the BoI wrote to the CBN explaining that the delay in the issuance of the
share certificates was as a result of the BoI seeking a concession on the
payment of stamp duty and other statutory fees from the Corporate Affairs
Commission and the Federal Inland Revenue Service (FIRS) with respect to the
investment by the CBN and the FMF. See Annexure F for the letter from
the BoI.Also find attached the letter dated 21 February 2013 forwarding the
Share Certificate asAnnexure G as well as the certificate for the
Debenture as Annexure H.
iii.
It
is evident that as at the time theFRCN Briefing Note was written, the share
certificate and debenture certificate were already in the possession of the
CBN. A simple check by the FRCN would have answered the query.
5. Currency
Issue Expenses
Briefing Note
Allegation 5:that the expenses made by the CBN on account of currency
issues and sundry currency charges for the years 2011 and 2012 were identical
and therefore difficult to understand.
Response:
i.
It
is incorrect to say that the expenses in 2011 and 2012 were identical. The
sundry currency charges amounted to N1.68 Billion in 2011 and N1.87
Billion in 2012. This expense related to amounts paid to Travelex under an
agreement to import foreign exchange for licensed BDCs. On the other hand,
Currency Issue Expenses totalled N1.15 Billion in 2011 and N1.28
Billion in 2012, relating to expenses borne by the different branches and
currency centres of the CBN in the movement and handling of cash.
6. Facilities
Management
Briefing Note
Allegation 6: that the CBN’s leadership uses this head of expense
(Facilities Management) to capture what ordinarily should have been accounted
for as their benefits-in-kind for tax purposes. It also alleges that this head
of expense is used for ‘fraudulent activities’ based on the inclusion of items
such as “Profit from sale of Diesel”.
Response:
i. The CBN outsources the management and maintenance of
its landed properties across the 36 States of the Federation and the FCT. This
involves three service areas: engineering services, building services and
environmental services. These are operational costs relating principally to
head offices, branches, currency centres and training institutes.
ii. On the specific allegation of ‘fraudulent activities’,
based on profits from the sale of diesel,it should be noted that the CBN’s
Facilities Management Agreements clearly include the supply of diesel for the
operation of generators to power CBN offices in 51 locations across the 36
States and the FCT. The Diesel is paid for at pump price, while overhead and
profit at 10% is paid to the service providers. This overhead and profit is
presumably what the FRCN erroneously regarded as “profits from the sale of
diesel”. These profits do not go to the CBN but to the service providers,
which is why they are an “expense item”. The CBN does not operate in any sector
of the petroleum industry.
7. Fixed Assets
Clearing Account
Briefing Note
Allegation 7:that the expenses under the Fixed Assets Clearing Account
comprise properties acquired by the CBN without any expectation to derive
future economic benefits and are written off by the CBN on a yearly basis.
Response:
i. Fixed Assets Clearing Account is
used by the CBN to record the procurement of fixed assets, physical items and
projects-related expenditure for the CBN, using the IT application Oracle ERP.
However, some items, which do not qualify as fixed assets under the
capitalisation policy of the CBN, are sometimes posted into this account.
ii. The
transactions are periodically reviewed for the purpose of capitalizing those
which qualify under the Capitalization Policy and posting such to the
respective Fixed Asset Account and Fixed Asset Register with tag numbers. All
other assets which do not qualify are expensed through income and expenditure
accounts at the end of the year.
8. Operation of
Foreign Bank Accounts
Briefing Note
Allegation 8: that foreign bank accounts that were closed down were
still operational in the General Ledger for over six months after the accounts
had been confirmed closed by the offshore banks.
Response:
i. The balances on these accounts
simply reflected the fact that the process of the transfer of gains and losses
on them had not been concluded, hence their existence in the General Ledger.
The process of closing the accounts has since been concluded and the journals
evidencing closure are available in the CBN.
9. Unreconciled
Real Time Gross Settlement Clearing Account
Briefing Note
Allegation 9:that the Real Time Gross Settlement (RTGS) Account had
longstanding unreconciled items which could not be substantiated.
Response:
i. These items
resulted fromepileptic operations of the RTGS system due to frequent system
downtime, which in turn resulted in failure to seamlessly effect funds
transfer. These items have since been reconciled and we have put in place an
upgraded and more robust RTGS system, which would minimise reoccurrence.
10. Missing
Stockpiles of Foreign Currency
Briefing Note Allegation 10:that the external audit revealed
debit/credit balances of sundry foreign currencies without the physical stock
of foreign currencies at the CBN Head Office.
Response:
i. Generally, losses or gains may arise
out of the account balances, which in turn, may be occasioned by exchange rate
differentials. In either event, once crystalized, the net position is then
posted to the Foreign Assets Revaluation Account. As such, as at 20 February
2014, there was no physical stock of currency missing at the CBN.
11. Alleged
Wastefulness
Briefing
Note Allegation 11:that
the CBN has been wasteful in its expenditure incurred in the course of 2012.
Response:
i. This allegation is clearly at variance with the reality
of the financial performance of the CBN under my leadership. For example, in
the year 2008, just before I took over office at the CBN, the contribution of
the CBN to the Federation Account was N8Billion. Based on the 2012
annual accounts, our contribution rose tenfoldto N80Billion,while in
2013, our contribution, based on the audited accounts, was N159Billion.
ii. It is noteworthy that inthe 5 yearsof my tenure as CBN
Governor (2009 – 2013), the CBN has contributed N376Billion to the
Federal Budget as IGR (Internally-Generated Revenue). Indeed in 2012, the House
of Representatives Committee on Finance publicly commended the CBN for being
the highest contributor of revenues to the FGN among MDAs - accounting for 75%
of the total IGR contributed by MDAs between 2009 and 2012. The CBN has been
able to achieve this through prudent management of costs, including currency
expenses and overheads. For example, we brought down currency expenses from N50.8
Billion in 2009 to N29.08 Billion in 2012.
iii. It is worthy noting that the Ministry of Finance has
already receivedits IGR from the CBN in full, based on our 2013 accounts and
the Ministry even requested and received an advance of N70Billion in
anticipation of surplus that is yet to be earned for 2014. With this level of
prudent financial performance, it is puzzling to imagine the basis for the
levied allegation of “Wastefulness”. It must be underscored that central banks
all over the world are not considered as profit centres. The primary task of
the CBN is the attainment of price stability rather than revenue generation.
However, the CBN under my leadership has strived to deliver on its key mandate,
while also maximising revenues for government.
12. Promotional
Activities
Briefing Note Allegation 12:that the sums expended on
promotional efforts of the CBN in 2012 were too high.
Response:
i. The allegations do not suggest that proper procedure
was not complied with in making the referenced expenditure. The Board of the
CBN approved all the promotional expenses.
ii. In the year
under review, 2012, the CBN initiated several reforms and policies in the
execution of its statutory mandate of promoting a sound financial system in
Nigeria. Some of these policies included:
iii. the
introduction of the Cashless Lagos Initiative and mobile banking;
iv. thePower and
Aviation Intervention Fund (PAIF) campaign, for which the FG took credit. The
PAIF campaign helped to stimulate growth in the power sector and raise investor
confidence generally;
v. the National
Microfinance Development Strategy; and
vi. theNigerian
Incentive-Based Risk Sharing System for Agricultural Lending (NIRSAL) and the
Commercial Agriculture Credit Scheme (CACS), which supported the FG’s renewed
focus on the development of agriculture as a major income earner for the
country.
vii. Essentially,
what are characterized as ‘promotional’ were actually necessary education,
enlightenment and awareness campaigns and conferences on initiatives which
were, and remain,essential to economic growth, expansion of financial inclusion
and the achievement of the policy objectives of the CBN and the FG.
13. Training
&Travel Expenses
Briefing Note Allegation 3: that CBN’s expenses in relation to
training and travel went up from N7.65 Billion to N9.24 Billion.
Response:
i. In 2012, the Board of the CBN took the strategic
decision to invest in the development and training of CBN staff across all
departments. We trained our staff in the most prudent manner possible and this
led to the outstanding achievements recorded by the CBN during my tenure. We
had to send CBN staff to international finance and regulatory institutions for
training; and overseas training comes at a steep cost.
ii. Furthermore, in 2012, to match the increased need for
bank supervision, CBN staff strength was increased. Thisfurther necessitated
orientation and other training programmes to bring the new entrants up to speed
with the CBN policies and practices.
14. Expenses on
ATM Offsite Policy Change
Briefing Note Allegation 14:that expenses on the ATM offsite
policy change came to N1.045 Billion.
Response:
i. Prior to my appointment as the CBN Governor, the CBN
had initiated a policy of increasing accessibility to financial services
through the use of ATMs. This was geared towards ensuring financial inclusion
for all Nigerians. To achieve this, the CBN licensed independent ATM deployers
(IADs).
ii. However, it soon became apparent that these IADs had
neither the capital nor the capacity to roll out ATMs and manage them at a rate
consistent with our cashless Nigeria ambitions, and that a roll-out on the
scale envisaged would require allowing banks to deploy ATMs outside their
branches. As a result of this change in policy, the IADs incurred losses due to
prior investments made based on the previous policy.
iii. It was therefore in the interest of equity and fairness
that the CBN agreed to negotiate some compensation payable to the IADs after
verification of claims of the IADs by the CBN. The verification process
resulted in the CBN paying only about 40% of the original claims of the IADs.
iv. The implementation of the policy of increasing
accessibility to financial serviceshas been very successful with immense
benefits to the country. It has led to an increase in ATM penetration and
efficiency of the payment system along with all other benefits associated with
this channel.
15. Expenses on
Non-Interest Banking
Briefing Note Allegation 15: that the expenses on Non-Interest
Banking went up from N0.977 Billion in 2011 to N1.359 Billion in
2012 and speculation was made as to whether this had any relationship with the
CBN’s investment in the International Islamic Liquidity Management Corporation
(IILMC).
Response:
i. For the record, this expense item is not connected with
the investment of the CBN in the IILMC. As such, there is no basis to make such
an assumption. Rather, the item relates partially to the CBN’s specialised and
non-interest banking policies and includes other expenses of the Financial
Policy and Regulation Department such as (a) consolidated supervision; and (b)
Consultancy fees for the adoption of IFRS & Basel II/III.
16. Expenses on
Private Guards and Policemen
Briefing Note Allegation 16:that the CBN’s expenses on Private
Guards and Lunch for Policemen went up from N0.919 Billion in 2011 to N1.257Billion
in 2012.
Response:
i. In 2007 (before my tenure), the CBN
adopted a policy to outsource non-core functions, including security services.
This decision enabled the Bank to focus on its statutory mandate and to reduce
its overheads. Accordingly, the CBN retained the services of about thirteen
(13) private security companies to provide access control and security check
services. In 2012, the CBN budgeted N600 Million for security services
but spent N582.2 Million on private guards. See AnnexureI (A-B)
for the breakdown of the costs incurred in this regard.
ii. To complement the efforts of private guards, the CBN
also requested the services of security agencies, in light of the increased
security challenges, especially the activities of the Boko Haram terrorist
group. These security personnel were engaged on a daily basis; and were
attached to (x) senior CBN officials; (y) special assignments such as security
coverage for currency movements; (z) static guard duties at the bank’s premises
nationwide, and other sundry engagements. About 2,406 Policemen are currently
deployed on a daily basis to various branches and other locations of the CBN.
These security personnel were paid a daily lunch and transport allowances
totallingN675.02 Million in the year under review.
17. Project Eagles
The Briefing Note Allegation 17: that the expenses of the CBN on
Project Eagles went up from N63 Million in 2011 to N606 Million
in 2012.
Response:
i. Under Project Eagles, the CBN caters for all expenses
incurred in the course of an internal restructuring of the CBN on the
understanding that central banking, by global standards and best practice
measures, is an ever-evolving enterprise, with constantly changing requirements
and frameworks that require adaptation.
ii. In 2012, the expenses on Project Eagles included the
following internal restructuring initiatives: Strategy Execution Framework
Project, Transformation of the Procurement and Support Services Department,
Transformation of the Finance Department and the NIPOST PPP Project in
collaboration with the Ministry of Communication for the purpose of using
NIPOST locations as outlets for our Financial Inclusion Strategy.
iii. Project Eagles was carefully designed, well budgeted
for and wasapproved by the Board. The objectives are being achieved in light of
the improved efficiency of the CBN.
18. Newspapers,
Books &Periodicals
Briefing Note Allegation 18: that the expenses of the CBN on
newspapers, books and periodicals (excluding CBN’s publications) went up from N1.670Billion
in 2011 to N1.678Billion in 2012.
Response:
i. The CBN’s peculiar status as a regulator underscores the
need for its staff to be informed as to every development that has a bearing,
however tangential, on the object and functions of the CBN in the economy. The
expenses incurred were made in subscriptions for, and acquiring, local and
foreign journals, magazines and periodicals for the CBN. These educational and
information material are directly useful for the operations of the CBN.The
CBNincreased the number of employees entitled to access to newspapers, Books
and periodicals.
19. Legal
&Professional Fees
Briefing Note Allegation 19: that the CBN paid excessive legal
and professional fees of N20.202 Billion in 2011.
Response:
i. The CBN, like any other public entity, is not immune
from liabilities that arise from judgments and orders of the Nigerian courts.
The referenced N20.202Billion spent under this head covered the CBN’s
judgment debt liabilities in the year under review.
ii. Of particular reference is the
judgment of the Supreme Court in the case of Amao v the Central Bank of
Nigeria, [SC 168/2007]delivered on 21 May, 2010, wherein the apex Court
directed that the CBN pay employees of the Bank who had retired prior to 2000,
pension under the harmonised structure introduced by the FG. Note that the
negotiated litigation liability that arose from the above-specified matter was
approximately N19.8Billion. SeeAnnexure J for the judgment
of the Supreme Court in question.
20. Reduced
Expenses on Ethics &Anti-Corruption
Briefing Note Allegation 20: that the CBN, under my watch,
reduced its expenditure on Ethics and Anti-corruption and this reduction is
purportedly an instance of ‘financial recklessness and wastefulness’.
Response:
Response:
i. In response to the need to improve ethical and best
practice standards in its operations to bring it at par with international
standards and the code of conduct requirements, the CBN expended N34Million
in 2011 to develop the Code of Business Ethics and Compliance (COBEC) as well
as the Code of Conduct for staff, the implementation of which spilled over into
2012. This explains why the expenditure dropped from N34 Million to N18
Million.
21. Auditor’s
Fees
Briefing Note Allegation 21: that the CBN paid an additional N140
Million over and above the agreed fees for the external auditors.
Response:
i. The 2012 financial statements of the CBN stated that
the amount paid to the two firms of external auditors for the 2012 financial
year was N200Million. The subsequent graduating revision of the fee was
to the sum of N230Million effective from 2013.
ii. The N140Million purportedly paid to the external
auditors as “additional fees”, was paid as reimbursement of the expenses
incurred by these firms in the execution of their mandate as external auditors
of the Bank for previous audit exercises. See Annexure K for evidence
of payments made to the auditors. Payment of reimbursables is a standard
contractual practice when dealing with professional service firms.
22. Alleged
Abuse of Due Process
The MoU for the Banking Sector Resolution Cost Sinking
Fund
Briefing Note Allegation 22: that the CBN issued treasury bills
using themoney in the Banking Resolution Costs Sinking fund (Sinking Fund)
without the constitution and approval of the Board of Trustees as required
under the MOU signed by the CBN and all the deposit moneybanks operating in
Nigeria.
Response:
i. The contributors to the Sinking Fund are the CBN and
all deposit money banks in the country. All the parties agreed at Bankers
Committee that the monies contributed should be invested in treasury bills for
safety. The CBN, as custodian, simply implemented that agreement. The board of
trustees for Sinking Fund has not been constituted as the legal framework for
the Sinking Fund i.e. the Banking Sector Resolution Cost Fund Bill is still
pending before the National Assembly.
ii. It should be noted that AMCON redeemed its due bonds on
27 December, 2013 from this account.
23. Write off of
N3.85 Billion Loan
Briefing Note Allegation 23: that the leadership of the CBN
wrote-off loans supposedly made to staff members to the tune of N3.85
Billion in 2012.
Response:
i. The write-off above was not made in
favour of CBNstaff. Rather the Board of the CBN approved the write-off of
the loan as forbearance to Heritage Bank on 17 December, 2010 as part of the
process of facilitating its resumption of business as a regional bank. See Annexure
L for the board approval given on 17 December 2010.
24. OverdrawnAccounts
by Ministries, Departments &Parastatals
Briefing Note Allegation 24: that the deposit accounts of
parastatals have debit and overdrawn positions and that this is contrary to
government policy.
Response:
i. MDAs generally maintain bank
accounts with the CBN. Overdrawing of banks accounts is an incidence of
banker–customer relationship. However, the CBN experienced some technical
problems prior to mid-2012, which affected about 6 of the over 1000 bank
accounts maintained by MDAs at the CBN, but the error has been rectified since
the middle of 2012. There were some insignificant over drawings on about
six (6) of the accounts and the attention of the Office of the
Accountant-General of the Federation has been drawn to the matter. See Annexure
Mfor the letter to the Accountant-General and the Accountant-General’s
response ofJanuary 29th, 2014.
25. Investment
in International Islamic Liquidity Management Corporation (IILMC)
Briefing Note Allegation 25:that the investment in the IILMC was
not brought to the attention of His Excellency, Mr President, and was not
within the exception in Section 31 of the CBN Act.
Response:
i. Nigeria, through the CBN, is
signatory to the establishment agreement of the IILMC. Before proceeding with
the investment, I requested for and obtained the written approval of His
Excellency, Mr President,via a letter dated 8 December, 2010. His Excellency,
Mr President would recall that he approved this request on 22.12.10. See Annexure
N.
ii. The investment in question is permitted by Section 24
of the CBN Act, in pursuance of whichit was made as investment of Reservesby
the Reserve Management Department of the CBN. If at any point, the CBN wishes
to divest from the IILMC, one or more of the member central banks will purchase
this investment.
iii. It is worthy of note that in the
letter seeking Mr President’s approval for the investment, it was stated
explicitly that all the member central banks were treating their investment
as part of their external reserves.
iv. It was also alleged that, till the date of the issuance
of the Briefing Note (7th June, 2013), the CBN had not received its
share certificate for the apex Bank’s investment in the IILMC. However, the
said share certificate, dated 6th April, 2013, has indeed been
received and is hereby annexed as Annexure O.
26. Non-adoption
of IFRS Standards
Briefing Note Allegation 26: that the CBN did not comply with
the IFRS accounting standards in preparing its 2012 financial statements.
Response:
i. It has been and remains a cardinal
policy of the CBN to comply with statutory requirements and policy guidelines
of regulators. In recognition of the peculiar nature of the CBN as a central
bank and its peculiar responsibilities, its migration to the IFRS would require
extended time to comply with the Act.
ii. In view of this reality, I wrote the
FRCN via a letter dated 14thFebruary 2013, requesting for a
temporary exemption to allow the CBN prepare the 2012 financial statements
based on the existing financial reporting framework.
iii. The FRCN waived the requirement for
the CBN to comply with the IFRS standards in preparing its 2012 financial
statements by its letter of exemption dated 26 February 2013. See Annexure
Pfor the FRCN’s letter.
iv. In January 2010, the published
Report of the Committee on the Roadmap for the adoption of IFRS in Nigeria (the
Roadmap), allowed Public Interest Entities, in the nature of CBN,to delay
the adoption of the IFRS financial statements until 31 December 2013. See Annexure
Q for the Roadmap.It is probably for the same reason the FRCN itself
did not prepare its audited financial statements in accordance with IFRS for
the year ended 2012.
v. It is worth noting that very few
Central Banks in the world are able to comply with IFRS due to a number of
factors peculiar to the nature of central banking, especially in the following
areas:
a. Accounting
for Change in the value of Gold reserves.
b. Management
of government foreign exchange reserves and exchange rate fluctuations.
c. Disclosure
challenges around monetary policy interventions and its activities as lender of
last resort to financial institutions, and guarantor to government borrowing.
d. Valuation
of assets held in foreign currencies.
e. Challenges
around weekly Treasury Bill sales.
f. Management
of years of deficit after surplus has been transferred to the government in the
year of surplus.
g. Funding
government deficit financing as enshrined in section 38 of the CBN Act 2007.
27. Non-Compliance
with ITF Act
Briefing Note Allegation 27: that the CBN failed to comply with
the ITF Act by not paying the mandatory one per centum of the amount of its
annual payroll to the ITF.
Response:
i. The CBN, at the time, contested in court its obligation
to pay one per centum of its payroll to the ITF on the ground that the CBN is
not engaged in commerce or industry, which under the ITF Act is the basis for
an employer to make payments under the ITF Act.
ii. However, upon further
considerations, the matter was amicably settled by the CBN and ITF. The CBN has
duly complied with the ITF Act and has paid all levies up to the 2012 financial
year. See Annexure R, which bears this out.
28. AUDITING
Briefing Note Allegation 28: that the joint auditors of the
CBN’s financial statement did not certify that the accounts give a true and
fair view of the financial position of the CBN as at 31 December 2012.
Response:
i. Without any iota of evidential proof, and in a most
sweeping statement,the FRCN Briefing Note alleged that the joint auditors’
opinion was a technical qualification; that the accounts should not be relied
upon for decision-making.
ii. To set the records straight, auditors do not certify
accounts but only express opinions on the financial statements.
iii. The joint auditors stated that the CBN’s 2012 financial
statements were properly prepared and accorded with accounting policies and the
provisions of the CBN Act 2007 and other applicable regulations.
iv. The opinion, as expressed by our auditors, is
consistent with what obtains in respect of central banks in a number of other
jurisdictions. We enclose by way of example, a sample of opinions relating to
the central banks of the United States of America, South Africa and Ghana. See
Annexure S. The allegation made by the FRCN in relation to this
aspect of the auditors’ report is troubling when viewed in this light.
29. Non-consolidation
of accounts with Subsidiaries
Briefing Note Allegation 29: that the CBN did not consolidate
its account with those of its subsidiaries.
Response:
i. The CBN does not have subsidiaries and the assumption
that AMCON is a subsidiary of the CBN is wrong. The shares in AMCON are held by
the Federal Government as borne out by Section 2 of the AMCON Act. Furthermore,
the accounting reporting period of the CBN is statutoryand does not coincide
with that of AMCON.
30. Abridgement
of Financial Statements
Briefing Note Allegation 30:that the financial statement was
highly abridged, with poor disclosures of transactions and events of a
financial nature.
Response:
ii. The financial statement cannot by any stretch of the
imagination be described as “highly abridged”. Rather, all transactions in the
financial statement were substantiated and were prepared in line with the CBN’s
framework with all relevant notes, schedules and disclosures copiously made for
clarity.
31. Non-
Challance and AMCON’s Operations
Briefing Note Allegation 31: that AMCON made a loss (after
taxation) of N 2,439,701,422,000 (over N 2.4 Trillion) and also
had a negative total equity ofN2,345,620,364,000 (over N 2.3
Trillion) at the end of 2011. The FRCN alleges that I should have brought it to
the attention of His Excellency, Mr President, that a large portion of the
AMCON bonds would be due for redemption by 31 December 2013 and that the
inability of the Federal Government to fulfil the guarantee may affect the
credit rating of Nigeria negatively. In other words, the CBN breached its
statutory objects under Section 2(e) of the CBN Act by not drawing His
Excellency’s attention to the matter.
Response:
i. A major achievement of the Central
Bank was that the AMCON bonds in question that matured at the end of 2013 were
successfully redeemed without any budgetary appropriation or call on the
Federal Government to guarantee the repayment as referenced above.
ii. It must be emphasized that AMCON
bonds are not instruments issued by the CBN. On that score, it would be most
inappropriate and against every known principle of standard accounting
convention for the CBN to incorporate full disclosures on the maturity profile
of AMCON’s bonds in its audited financial statements (balance sheet and
notes).
iii. Rather, in accordance with
international best practice, the CBN is only required to disclose in its
accounts, the portion of the bonds held by it (the CBN). To this extent, the
CBN made appropriate disclosures in the financial statements on the bonds it
held as at 31 December 2012. See Annexure T – which is note 6 to the
CBN’s 2012 financial statements showing the amount CBN has invested in AMCON
bonds.
32. Non-approval
of 2012 financial statement by CBN Board
Briefing Note Allegation 32:that the date of the Board’s
approval of the financial statements was not indicated or disclosed and
accordingly, the response provided to the President’s request for
clarifications indicated that the management letter on the financial statements
was yet to be discussed by the Board Audit and Risk Management Committee.
Response:
i. The financial statements were presented to the board
and approved on 26 February 2013. The date of approval was stated clearly on
the balance sheet page behind the signature of each of the directors. (See Annexure
Ufor a board approval dated 26 February 2013 approving financial
statements).Issues of a material nature requiring adjustments had been
fully incorporated into the Financial Statement prior to presentation to the
Board.
ii. The items in the Management Letter were suggestions for
improvement made by external auditors and these were subsequently considered by
the Board Audit and Risk Management Committee and are being implemented by
Management on an on-going basis.
33. Compliance
with the PPA
Briefing Note Allegation 33:non-compliance with the provisions
of the Public Procurement Act (PPA).
Response:
i. The only issue that has been raised to the knowledge of
the CBN, is that the CBN,over a period in the past,did not obtain ‘Certificate
of No Objection’ from the BPP before awarding contracts.
ii. On 11 August 2008 (before my
tenure), the CBN wrote to His Excellency, President Yar’adua, requesting for certain
exemptions in CBN’s procurement process.See Annexure V.On 20
August 2008, the President gave his approval to the CBN’s application. See Annexure
W.
iii. In line with this approval, the CBN continued to
approve its contracts in full compliance with the Public Procurement
Guidelines, with the only exception that it did not apply for a ‘Certificate of
No Objection’ based on the Presidential waiver.
iv. It should be noted that the CBN’s own procurement process
is more or less identical to the procurement process under the Public
Procurement Act(PPA). Indeed, the BPP has had occasion to write in the past
commending the CBN’s commitment to transparency and making recommendations for
further improving the process. See Annexure X.
v. In the course of the CBN interaction with the BPP on
this subject, we provided an explanation by way by a letter of 11 August 2013,
informing the BPP of the Presidential waiver. After an exchange of correspondences
between the CBN and the BPP on this issue, the BPP disagreed that the
Presidential waiver constituted an exemption from the requirement to obtain a
Certificate of No Objection and insisted that the CBN should start doing so.
vi. The CBN, out of an abundance of caution, immediately
began to obtain Certificates of No Objection in respect of subsequent
procurements within the stipulated threshold. In this regard, the CBN did
obtain Certificates of No Objection dated 17 December 2013, 31 December 2013
and 14 February 2014. See Annexure Y [A-D] for these.It is
important to note that the contracts for which these Certificate of No
Objections were issued were approved based on the same process that apply to
all the other contracts approved by the Bank. This, in itself, is testimony
that the Bank has always complied with the provisions of the Act.
vii. It is also important to note that in October 2013, the
BPP-appointed consultant (Messrs SadaIdris& Co) also gave the CBN a good
bill of health after reviewing the bank’s procurement processesfor 2010and2011.See
Annexure Z. In its final report, the consultant in fact mentioned
that the CBN satisfactorily complied with the provisions of the PPA.
viii. Furthermore, the CBN has facilitated compliance with
the provisions of the PPA by making it a requirement for entities seeking to
access the CBN Intervention Projects Fund, to comply with the PPA and to obtain
a Certificate of No Objection to Contract Award, where required. See Annexure
AA for the BPP Letter of No Objection of 12 October 2010in relation to
procurements by the Nigeria Police Force.
34. Unlawful
Expenditure on CBN Intervention Projects
Briefing Note Allegation 34: that CBN Interventions in areas
like Education,Community, etc. are unlawful.
Response:
i. A principal focus of the CBN Corporate Social
Responsibility (CSR) policy in the last decade (even before my tenure) has been
the Educational sector in Nigeria. The CBN Act lists its objects,
functions and prohibited activities, and the Board is empowered to approve the
budget and formulate policies of the CBN. The Intervention Projects mentioned
are CSR interventions that fully comply with the CBN Act and were duly
approved by the Board.
ii. It is worth noting that the CSR policy of the CBN is
consistent with the activities of many other central banks of developing
countries including, Bank Negara Malaysia, the Bank of Namibia, the Bank of Botswana
and the Bank of Indonesia.
iii. The Federal Governmentof Nigeria has been aware,
supported and encouraged the CBN intervention projects, in recognition of their
positive contribution to development.
iv. During the recent strike by the Academic Staff Union of
Universities(ASUU), the CBN intervention projects in universities were an
important fulcrum in the settlement negotiations between the FG and ASUU as
borne out in the Memorandum of Understanding between the FG and ASUU, where the
Intervention Projects were recognised as part of the contributions of the FG to
Education in tertiary institutions.
v. Furthermore, the FG standing committee on the
Implementation of Needs Assessment of Nigerian Public Universities requested
that the CBN channel a portion of its annual budget to the identified projects.
See Annexure BB- TheInterim Report of the Technical Sub-committee of
the Committee on the Implementation on Needs Assessment of Nigerian Public Universities.
vi. A major aspect of the CBN intervention projects is the
Centre for Excellence, which are not merely physical structures. The CBN
entered into Memoranda of Understanding with partner Universities to develop a
holistic and multi-faceted scheme which includes the establishment of Centres
for Excellence under which the CBN would, in the principal areas of Economics
andFinance, fund the endowment of Professorial Chairs, create access
for Nigerian students to participate in virtual and remote learning with
foreign tertiary institutions like Harvard, Princeton, Oxford Universities, and
special programs for students of Business and Economics. In this regard, the
CBN is in the process of establishing Centres for Excellence across the
geo-political zones of the country including:
· Nigeria Defense Academy, Kaduna
·
University of Lagos,
Lagos
·
University of
Maiduguri, Borno
·
University of Port
Harcourt, Rivers
·
University of Jos, Plateau
·
Bayero University,
Kano
vii. Consistent with our policy of development, upon the
instruction of His Excellency, the President, the CBN intervened by paying N19.7
Billion to the Ministry of Police Affairs for the purchase of armoured
helicopters and other security equipment.
viii. Also, upon the application of the Secretary
to the Government of the Federation, the CBN paid N2.1 Billion for
the automation and renovation of the Federal Executive Council Chamber. See
Annexure CC.
ix. The CBN also initiated, with His Excellency, the
President’s approval, the construction of the International Conference Centre
for Nigeria. See Annexure DD.
x. His Excellency, the President, also requested that the
CBN pay N3.2 Billion for the construction of a new counter terrorism
centre for the office of the National Security Adviser.See Annexure
EE.
xi. The FRCN itself is a beneficiary of
the CBN’s intervention policy as
the CBN paid the sum of N220 Million to the FRCN and also organised the
banking sector, through the Banker’s Committee, to payN280 Million,
totalling a sum of N500 Million, for the construction of the IFRS
Academy. See Annexure FF.
xii. All of these requests were duly submitted to the CBN
Board of Directors and were duly approved.
xiii. It is also important to emphasise that the grants under
the Intervention Program were duly budgeted for, and made on a limited and
selected basis.
xiv. Intervention in National Security: At the height of security
uncertainties in Nigeria, the Ministry of Police Affairs petitioned His
Excellency, the President, for access to the CBN Intervention Fund. His
Excellency approved that this be done in his letter of 6 October 2010
referenced MPA/PSD/S/0243. See Annexure GG. The CBN Board of
Directors then reviewed and approved this request. See Annexure HHfor
the issuance of a grant by the CBN from the Intervention Fund to the Nigerian
Police Force, for the procurement of:
o
Armoured Helicopters,
o
Armoured Patrol Vans,
o
Anti-Riot Equipment;
o
Hand held Communication
Equipment.
35. Akingbola
Petition &the N40 Billion Loan Waiver
Allegation 35: attached to the my letter of
suspension was a petition written by the former Managing Director of the
defunct Intercontinental Bank Plc (ICB now Access Bank Plc)- Erastus Akingbola
(MrAkingbola), on an alleged waiver of a N40 Billion loan to a Nigerian
bank.
Response:
Before responding to the allegation, it should be
stated that the said MrAkingbola is a man found by a final judgment of the Courts
in England to have been liable for financial improprieties in the management of
the affairs of ICB.
i. In his self-serving petition, MrAkingbola alleged that
the CBN, on my watch, wrote-off a loan in favour of Dr. BukolaSaraki. This
is untrue.
ii. The CBN was at no time involved in the decision of ICB
(or any other bank for that matter) to write-off its loans. The CBN never gave
prior approval to the Management and Board of ICB to write-off any particular
loan. It is important to state up-front that all the non executive
directors on the Board of ICB were appointed by its shareholders while
Akingbola was CEO and they were the majority on the Board that approved the
write-offs.
iii. From the submissions of ICB to the CBN, the said loan
write-off, involved over 1000 customers accounts, totalling N49.07 billion –
including accounts held by companies related to Dr. BukolaSaraki.
iv. It
is well known that decisions on loan write-offs in the process of recovering
non-performing loans are taken by the management and board of banks in line
with their internal credit policies. The outstanding amounts are then written
off the books of banks after receiving approval of the CBN. ICB therefore only
approached the CBN, after it has completed all its negotiations and agreements
with its customers, to seek CBN ‘ No Objection’ approval to write-off the
loans. Indeed, after a careful review of the submission by ICB, the CBN
initially raised objections to the justifications provided for the write-off of
the debts on the accounts related to Dr. BukolaSaraki.See Annexure II.
v. In response to these objections, the Management of ICB
wrote explaining the rationale for the Board decision. (This is also contained
in Annexure II). It is important to note that decisions on loan write-offs
involve significant exercise of judgement by those involved. Usually a
number of factors come into play including whether or not the loan is secured,
the value of collateral and if the bank is in a legal position to realise same,
the general liquidity in the secondary market and the liquidity position of the
bank itself which determines if it is negotiating from a position of strength
or weakness. Ultimately, while we may debate these issues, the judgement has to
be exercised by those actually managing the bank in the best interest of
shareholders and the responsibility lies with them.
vi. In the case of ICB it is well known that the bank was
in a grave situation as a result of years of mismanagement by Akingbola. The
loans in question were largely loans secured by shares in the capital market
and therefore were vulnerable to what is called Market risk. The collapse of
the Nigerian capital market following the Global Financial Crisis in 2008 meant
that the collateral for these loans had been totally wiped out. The losses
suffered by the bank were therefore a result of very bad credit decisions taken
by Mr. Akingbolahimself which led to the bank taking on huge amounts of risk
that crystallised. In this situation all that was left for Management was to
minimise its losses and recover as much as it could before the situation got
worse.
vii. With specific reference to the ICB loans to companies
related to Dr Saraki, the bank’s Management explained that there were four
loans totalling N9.489 billion, of which three were margin loans secured by
shares and the fourth was secured by real estate. The value of the collateral
underlying the Margin loans had been eroded and the bank was compelled to give
waivers to make some recovery while still retaining the shares for sale at a
future date. It should also be added that the real estate used to secure
the non-margin loan were not perfected by the management under Mr. Akingbola –
which is another indication of bad credit policies under Mr. Akingbola.
viii. There was no waiver granted to Dr Saraki on the fourth
loan as it was paid in full (plus accumulated interest). Of the N9.4 billion, a
total of N4.04 billion was repaid, representing a waiver of 57.42 %. Losses on
Margin loans were common at this time in the entire industry. To illustrate
this, when AMCON purchased margin loans from Intervened banks on December 30,
2010 it offered a premium of 60% above the average price of the shares in the
preceding 60 days. In spiteof these generous terms AMCON paid an average of
only 24.27% of the value of margin loans purchased. Without the premium AMCON
would have purchased the loans at 15.17% of their book value. This actually
would suggest that the Management of ICB did get a reasonably fair deal for the
bank in these circumstances. The best construction we can place on Mr
Akingbola’s petition is that he is complaining that the Management that
succeeded him could have done a better job of cleaning up the mess he created
and left behind.
ix. As for Akingbola’s allegation of fraud, conspiracy,
forgery and stealing against Dr. Saraki in connection with Joy Petroleum Ltd,
the Central Bank was in the process of collaborating with law enforcement
agents involved in the investigations when we received a copy of a letter
written by the Honourable Attorney-General and Minister of Justice declaring
that these allegations were unfounded and there was no basis in law for any
criminal investigation in respect thereof. See Annexure HH. The
Central Bank therefore cannot be held in any manner responsible for this
decision as this was a position taken by the nation’s chief law officer.
36. Conclusion
i. It is now clear that each of the allegations made by
the FRCN in the Briefing Note could easily have been resolved upon a simple
request to the CBN for clarification or a little more careful review. There is
no doubt that if the CBN had received the Briefing Note, which was prepared in
June 2013, all the misconceptions, misrepresentations and erroneous
inferencescontained therein would have been cleared, and the misleading of His Excellency
would have been avoided.
ii. It is now my sincere hope that, having painstakingly
provided detailed explanations, backed by verifiable documents, His Excellency,
Mr President will find the response satisfactory, and in line with his
adherence to fairness and justice, revisit and redress the issue of my
suspension.
iii. Furthermore, it is my wish that His Excellency, Mr
President, will apply the same rationale and rigour to other agencies of the
Federal Government that have had serious allegations and queries levied against
them, and presume upon them to provide responses and explanations with the same
level of clarity and transparency.
iv. In closing, I would like to place on record the dogged
professionalism and patriotism of the staff of the CBN. They have, over the
years, served this country creditably, loyally and diligently.
I hereby restate my enduring passion for,
and commitment to, our great country Nigeria.
Signed:
Sanusi
lamido sanusi, CON
Governor,
Central Bank of Nigeria
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