The Nigerian business environment is highly segmented into oil-related industries, public sector and parastatals (highly oil-dependent), organised private sector, and a thriving informal sector. According to CMI 2009, the oil and gas sector alone contributes almost 99% of the country's export revenue and 85% of government revenues. In 2004, Nigeria established the Nigeria Extractive Industries Transparency Initiative (NEITI), aimed at improving transparency in payments by extractive industrial companies to government and government-linked entities. A NEITI Bill was signed into law in May 2007, giving the NEITI's activities legal backing and providing legal instruments to fight for increased transparency in the oil, gas and mining sectors in Nigeria. Furthermore, former President Yar'Adua has initiated a complete unpacking and restructuring of the oil sector, including the Nigerian National Petroleum Corporation (NNPC), in order to increase the competitiveness of the sector and to root out corruption. One of the largest FCPA cases occurred in Nigeria where over USD 1 billion was paid out in fines by Haliburton, Eni, Technip and Gasoline Corp. The companies bribed Nigerian officials in order to win a USD 6 billion contract to build a liquefied gas plant - more information can be found in the Extractive Industry section.

Companies operating in Nigeria are reportedly frequent targets of corrupt practices. This is especially the case for SMEs operating in the formal private sector. The manufacturing sector has declined during the last 20 years and the informal sector remains the main source of income and employment for most Nigerians. According to the World Bank & IFC Enterprise Surveys 2007, 60% of services companies report that they compete against unregistered or informal companies. Several business surveys indicate that corruption is widespread and constitutes a major obstacle for companies operating in Nigeria. For instance, the companies surveyed in the World Economic Forum Global Competitiveness Report 2011-2012 consider corruption to be among the most problematic factors for doing business in Nigeria. Public funds are sometimes diverted to companies, individuals or groups due to corruption. Government officials fairly commonly favour well-connected companies and individuals when deciding on policies and contracts. Both citizens and the business community perceive corruption to stem from the public sector. The World Bank & IFC Enterprise Surveys 2007 report that 25% of companies surveyed in Nigeria consider corruption to be a major constraint, and 41% of companies report that they expect to pay facilitation payments to public officials to 'get things done'. The US Department of State 2011 states that Nigeria’s procurement system has become slightly more transparent, exemplified by contracts now being rewarded under an open-tender system. However, corrupt practices, such as improper payments or kickbacks, still persist in procurement for capital projects. Forty-five percent of companies surveyed in the World Bank & IFC Enterprise Surveys 2007 stated that they expect to give gifts in order to secure a government contract.  In order to best reduce the risk of extortion and demands for bribes in the procurement process, companies considering bidding on public tenders in Nigeria are advised to use a specialised due diligence tool on public procurement. In general, the state level of governance is reported to be more corrupt than the federal level and has direct control of many areas important to business activity. State agencies tend to impose a wide range of fees, licences, fines and taxes arbitrarily. Some companies even report that they avoid posting signs identifying their factories, claiming that to do so would be an invitation to corrupt officials to stop by and solicit bribes.

The World Economic Forum Global Competitiveness Report 2011-2012 also reveals that the ethical behaviour of companies in Nigeria is fairly poor and constitutes a competitive disadvantage for doing business. Furthermore, business in Nigeria has a bad reputation, due largely to the widely known e-mail based 'advance fee frauds' committed by Nigerians. As a consequence, some Nigerian companies register in neighbouring countries or in the UK. Companies report that they are often forced to rely on lawyers to complete routine interactions with government officials that would normally be handled directly. In order to limit the possibility of corruption, it has been made a criminal offence for individuals to make or accept cash payments in excess of NGN 500,000 and for corporate bodies to make or accept cash payments in excess of NGN 2 million without going through a financial institution. Furthermore, a new policy aims at reducing money laundering and other financial crimes, is expected to take effect on 1 June 2012. According to a May 2011 news article by This Day Live, a new daily cash withdrawal allowance for individuals and corporate customers will be NGN 150,000 and NGN 1 million, respectively. Foreign investors considering establishing themselves in Nigeria are generally advised to consult with experienced attorneys, to develop, implement and strengthen integrity systems, and to carry out extensive due diligence before committing funds and when already doing business in the country.

A lack of clear policy formulation by the central government has created complex and varying regulatory interpretations and applications at all levels of the state structure. Consequentially, Nigeria's administrative systems are unnecessarily complex and opaque, with overlapping authorities in many areas, such as taxation and licensing. The federal states have considerable independence, and the central government's capacity to govern has been systematically undermined by corrupt public officials, the military and patronage networks. Nigeria's legal and regulatory systems are generally consistent with international standards, but enforcement of rules and legislation are often cited as inadequate and inconsistent, as reported by the US Department of State 2011. State and local officials are known to impose arbitrary taxes and licensing requirements in order to raise extra revenue. Administrative barriers, red tape and delays are major constraints on foreign as well as domestic companies, especially for SMEs with less financial resources. On the contrary, the recent Global Competitiveness Report 2011-2012 conducted by the World Economic Forum illustrates that the level of difficulty in complying with governmental administrative requirements is somewhat neutral, constituting a competitive advantage compared to other countries. Official business registration fees are generally low, but associated costs and facilitation payments reportedly make the total price relatively high and unpredictable. For example, according to Transparency International's National Integrity System 2004, a simple business registration that officially costs NGN 5.50 can easily end up costing more than NGN 1,000. According to the World Bank & IFC Enterprise Surveys 2007, senior management can expect to spend approximately 6% of its time dealing with the requirement of government regulations in Nigeria. According to the World Bank & IFC Doing Business 2012, the requirements to start a business have eased in recent years to an average of 34 days and 8 procedures at a cost of 70.6% of GNI per capita, which is below regional averages. According to the US Department of State 2011, dealing with the tax system is another area of concern for companies, as the tax administration is highly uneven and lacks transparency. This has led to high levels of tax evasion and tax officials demanding bribes and facilitation payments in return for lower tax rates.

Despite difficulties and barriers to entry, Nigeria has a large and dynamic private sector, although many smaller companies remain within the informal sector. A significant challenge is that there is generally little consistent and systematic interaction between the formal business sector and the different levels of government. Some recent initiatives have been undertaken, especially in the extractive industries, such as the Niger Delta Development Commission (NDDC), a leader in the development of Nigerian natural resources, and the Nigeria Extractive Industries Transparency Initiative (NEITI). The Nigeria Economic Summit Group (NESG) is the prime forum for business-government interaction at the federal level and has launched a SME Working Group. The Nigerian government has also launched the Nigerian Investment Promotion Commission (NIPC), an open to public one-stop shop providing information on investment requirements in Nigeria. The NIPC provides information on business registration procedures and links to relevant authorities.

Companies should note that, according to the US Department of State 2011, although property rights, intellectual property rights and trademark laws exist, enforcement of the rules is weak and subject to corruption. Transferring property is complex and usually involves state governor's offices, while acquiring and maintaining rights to real property are major challenges. The legal system is based on English common law, but civil codes exist for certain issues. For example, some legal codes are based on Shari'a (Islamic law) in the north and others on customary law, known as 'traditional law', in the south. The multiple and sometimes overlapping jurisdictions of federal, state and local governments in various aspects of commercial activity make the bureaucratic process complex. Due to this inefficient legal system, it is common to settle disputes out of court using various forms of arbitration and negotiation. The Arbitration and Conciliation Act of 1988 provides for a unified and straightforward legal framework for the settlement of commercial disputes through the Nigerian Arbitration Institute, and the Lagos Chamber of Commerce & Industry also handles arbitration. The act furthermore provides for the application of arbitration rules under the United Nations Commission on International Trade Law (UNCITRAL) and has made the Convention on the Recognition and Enforcement of Arbitral Awards (New York Convention 1958) applicable to enforcement of contracts. Nigeria is also a member of the International Centre for the Settlement of Investment Disputes. Larger companies typically use arbitration under the London Court or the International Chamber of Commerce (ICC). Access the Lexadin World Law Guide for a collection of laws in Nigeria.

Individual Corruption

According to Transparency International's Global Corruption Barometer 2010, the judiciary is perceived to be among the most corrupt institutions in Nigeria. In a similar vein, the US Department of State 2010 points out that citizens encounter long delays and frequent requests from judicial officials for bribes to expedite cases or obtain a favourable ruling.

Global Integrity 2010 further reports that legal costs are extremely high, which makes it difficult for average citizens to afford a legal suit, preventing access to justice. Very few lawyers are assigned to legal aid, which creates massive delays in trials. The high costs of litigation have spurred several civil society initiatives to provide legal aid to individuals. Amongst these organisations is the Nigerian Bar Association. These projects are located in the larger cities.

Business Corruption

According to the Bertelsmann Foundation 2010, the judiciary in Nigeria lacks resources and qualified personnel and it is hampered by corruption. Global Integrity 2010 reports that due to prohibitive legal costs and the time consuming process, many small companies are discouraged from filing law suits and so prefer to settle cases outside the courts.

Corruption often involves tampering with evidence by prosecutors for financial and material gain, and in such cases the prosecutors usually collaborate with the police. According to Transparency International's Global Corruption Report 2007, the main reason to pay bribes to courts is to expedite court processes or to be granted bail. It is further reported that lawyers and businesspeople are more likely than judges and other court users to experience corruption within the judiciary. Nevertheless, more than half of the responding companies from the World Bank & IFC Enterprise Surveys 2007 believed that the court system in Nigeria is fair, impartial and uncorrupted.

Political Corruption

The constitution provides for an independent judiciary. However, according to Freedom House 2011, the judiciary still suffers from political interference, with corruption and inefficiency remaining a problem. For instance, according to the US Department of State 2010, there is a widespread perception that judges are easily bribed and that litigants cannot rely on the courts to render impartial judgements. The report further states that executive influence on the judiciary continues to represent a significant problem. Nevertheless, as emphasised by the Bertelsmann Foundation 2010, during the democratic dispensation, the judiciary has partly won back its former independence and continues to strengthen it.

The Independent Corrupt Practices and Other Related Offences Commission (ICPC) has only prosecuted a few judges, and the judicial system has generally not been very proactive in investigating and prosecuting cases of corruption. An exception to this is the Lagos State, which has been active in enforcing anti-corruption legislation and has made significant efforts to tackle corruption in the judiciary. Similarly, Human Rights Watch 2011 also reports that except for the court system in Lagos State, most Nigerian courts are burdened with old-fashioned physical and legal infrastructure that makes them extremely slow and inefficient.

Frequency

The World Bank & IFC: Doing Business 2012:
- On average, it takes a company 40 procedures, 457 days at a cost of 32% of the claim to enforce a commercial contract.

World Economic Forum: The Global Competitiveness Report 2011-2012:
- Business executives give the independence of the judiciary from influences of members of government, citizens, or companies a score of 3.7 on a 7-point scale (1 being 'heavily influenced' and 7 'entirely independent').

- Business executives give the efficiency of the legal framework for private companies to settle disputes and to challenge the legality of government actions and/or regulations a score of 3.9 and 3.8 respectively on a 7-point scale (1 being 'extremely inefficient' and 7 'highly efficient').

Transparency International: Global Corruption Barometer 2010:
- Citizens give the judiciary a score of 3.7 on a 5-point scale (1 'not at all corrupt' and 5 'extremely corrupt').

- 33.7% of households surveyed consider the judiciary to be 'extremely corrupt'.

- 37% of households who had contact with the judiciary in 2009 report to have paid a bribe.

Transparency International: Bribe Payers Index 2008:
- Business executives give the judiciary a score of 3.2 on a 5-point scale (1 'not at all corrupt' and 5 'extremely corrupt').

Afrobarometer: Summary of Results Nigeria 2008:
- 27% of respondents in this public opinion survey believe that most judges and magistrates are involved in corruption.

- 30% of the surveyed citizens believe that people are always treated unequally under the law.

The World Bank & IFC: Enterprise Surveys 2007:
- Over 53% of companies surveyed believe that the court system is fair, impartial and uncorrupted.

Transparency International: Global Corruption Report 2007:
- Half the Nigerian judges agree that the judiciary is controlled by the government, and more than half of Nigerian lawyers regard court decisions to be influenced by politics.

- Between 30 to 50% of court users indicate that they will not use the courts again based on previous experiences.

- Resolving a case in Nigeria takes between 16 to 36 months on average.

Individual Corruption

Citizens perceive the police to be the most corrupt institution in Transparency International's Corruption Barometer 2010. According to the survey, of those who had contact with the police in 2009, nearly four out of five reported to have paid a bribe.

Harassment, extortion and violence by the police force are widespread, as is corruption. This is supported by the US Department of State 2010, according to which, corruption in the police was rampant, particularly, involving the traffic police at highway checkpoints. According to the report, police routinely stopped drivers who had committed no traffic infractions, refusing to allow a car to continue until the driver paid a bribe.

This problem is further emphasised in a July 2009 article by AllAfrica, according to which, it appears to be common for Vehicle Inspection Officers (VIO) from the Lagos State Ministry of Transport to arbitrarily stop motorists, contravene on account of the possession of 'inauthentic' Ministry of Transport (MOT) Test Certificate and impound their vehicles, in this way forcing them to settle the matter by paying a bribe. To counter the problem of corruption, the Lagos state has given a directive that motorists should not be harassed over alleged possession of fake MOT certificates.

Business Corruption

Companies should note that the police force in Nigeria is notoriously slow to act on complaints and reported criminal activity. According to the World Economic Forum Global Competitiveness Report 2011-2012, business executives report that the police in Nigeria cannot be relied upon to enforce law and order and thereby protect companies from the costs of crime. Moreover, business executives in the Transparency International's Bribe Payers Index 2008 perceive the police to be the most corruption-prone institution in the country.

One example, where the US Department of State 2010 cites a 2009 news article, police officers often stop commercial drivers to solicit bribes, and the amount of a bribe is determined by the weight of the vehicle. Police shot drivers who refused to pay, who disagreed over the price of a bribe, or when it was unclear whether a bribe had been paid.

Political Corruption

Human Rights Watch 2010 reports that although the 2008 Presidential Committee produced a report on Police Reform, its implementation has been very limited to date. The report goes on to say that police reform should be seen in context of the bigger picture, a situation where the use of violence as a tool for political manipulation is increasing and the culture of impunity that characterises the political elite remains. According to the same report, service conditions in the police force are very bad and its funding and equipment are insufficient. Part of the blame is placed at the feet of high ranking officials who have embezzled or misappropriated large sums of money that were meant to be spent on basic police operations or equipment. A notable recent case concerned the Presidential Committee on Police Equipment Fund, set up in 1992. The fund raised some USD 387.5 million through a combination of government funds and private donations. The then president brother-in-law headed the fund and was accused, along with the other fund administrators, of siphoning off at least USD 17 million.

Corruption in the police force is systemic, and the requirement for low-ranking officers to pay part of the bribes they collect to their superiors forms part of this system. Police appointments at all levels are officially regulated by the Police Service Commission and, according to Global Integrity 2010, appointments are generally made based on merit but not wholly devoid of other considerations such as loyalties and ethnicity.

The X Squad is the disciplinary body responsible for investigating corruption inside the police. However, according to Human Rights Watch 2010, the X-Square frequently extort money from junior police officers whom they accuse of corruption. In fact, a former senior police official, as cited in the report, describes the X-Square as ‘one of the most corrupt units’ in the police force.

Frequency

World Economic Forum: The Global Competitiveness Report 2011-2012:
- Business executives give the reliability of Nigeria's police services to enforce law and order a score of 3 on a 7-point scale (1 'cannot be relied upon at all' and 7 'can always be relied upon').

Transparency International: Global Corruption Barometer 2010:
- 78% of households who had contact with the police in 2009 report to have paid a bribe, up from 40% in the previous year.

- Citizens give the police a score of 4.7 on a 5- point scale (1 'not at all corrupt' and 5 'extremely corrupt').

Afrobarometer: Summary of Results Nigeria 2008:
- 37% of the surveyed citizens believe that most police officers are involved in corruption.

- 43% of the surveyed citizens report no trust in the police at all..

Transparency International: Bribe Payers Index 2008:
- Business executives give police a score of 4.7 on a 5-point scale (1 'not at all corrupt' and 5 'extremely corrupt').

The World Bank & IFC: Enterprise Surveys 2007:
- 23% of the companies surveyed identify crime, theft and disorder as major constraints to doing business.

Individual Corruption

According to Transparency International’s Global Corruption Barometer 2010, a large percentage of the surveyed households reported to have paid a bribe to get utility services within the precedent year. This is a sharp contrast compared to a 2008 household survey conducted by Afrobaromter, in which only a very small percentage of responding households stated they have often paid a bribe, given a gift or done a favour to government officials in order to get water and sanitation services in 2007.

Business Corruption

According to the US Department of State 2011, infrastructure in general and electricity provisions in particular are inadequate in Nigeria, with the result being that many companies are forced to provide their own water and power. Moreover, according to the World Bank & IFC Enterprise Surveys 2007, companies report that public utilities services in Nigeria are rife with corruption.

Global Integrity 2010 reports that officers at the Corporate Affairs Commission (CAC, which deals with company registration and administration) demand bribes, and if a bribe is not paid, the registration process may be delayed, sometimes beyond a month. Furthermore, according to the report, the unofficial cost, for obtaining a business licence can be inflated to about USD 400, which is a lot higher than the official fees. The unofficial cost includes the mandatory ‘tipping’ to officers to facilitate the process.

Frequency

The World Bank & IFC: Doing Business 2012:
- Starting a company in Nigeria requires the entrepreneur to go through 8 procedures, taking 34 days and costing 70.6% of income per capita. All three measures are lower than their respective regional averages.

- In order to obtain a construction permit, a company must go through 15 procedures and spend 85 days at a cost of approximately 504.8% of income per capita.

World Economic Forum: The Global Competitiveness Report 2011-2012:
- Business executives give government administrative requirements (permits, regulations, reporting) a score of 3.6 on a 7-point scale (1 'extremely burdensome' and 7 'not burdensome at all').

Transparency International: Global Corruption Barometer 2010:
- 22% of households who had contact with registry and permit services in 2009 report to have paid a bribe.

- 43% of households who had to obtain public utilities in 2009 report to have paid a bribe.

- 17% of households who had contact with medical services in 2009 report to have paid a bribe.

Afrobarometer: Summary of Results Nigeria 2008:
- 3% of the surveyed citizens reported to have often paid a bribe, given a gift or done a favour to government officials in order to get water and sanitation services.

- 64% of the surveyed citizens stated that they have never paid a bribe, given a gift or done a favour in order to obtain the same services

Transparency International: Bribe Payers Index 2008:
- Business executives give the registry and permit services a score of 3.9 on a 5-point scale (1 'not at all corrupt' and 5 'extremely corrupt').

The World Bank & IFC: Enterprise Surveys 2007:
- 40% of companies expect to give gifts to get an operating licence.

- 53% of companies expect to give gifts to get a construction permit.

- 39%, 33% and 24% of companies expect to give gifts to get an electrical connection, a water connection and a phone connection respectively.

Individual Corruption

According to the Transparency International Global Corruption Barometer 2010, nearly one-third of Nigerians report to have paid a bribe to the land services in 2009 in order to obtain services such as buying and renting land. Moreover, nearly half of the surveyed households perceive land matters to be distorted by grand and political corruption, according to the Transparency International Global Corruption Barometer 2009.

Business Corruption

According to the US Department of State 2011, enforcement of the property rights laws in Nigeria is weak and subject to corruption. Transferring property is complex as the majority of land transfers are carried out at the state level and governors have to approve transactions. Acquiring and maintaining rights to real property are reported to be major challenges. For example, the Federal Capital Territory government in Abuja cancelled all property allotments and subjected them to reregistration, but denied renewing those it deemed conflicting with city plans. It is further reported that, even despite court injunctions, buildings on these conflicting properties have frequently been demolished.

According to the World Bank & IFC Doing Business 2012, Nigeria performs poorly in relation to registering property. Most land in Nigeria is publicly held and granted only in hereditary leases. A customary land allocation system exists parallel to the state system. The record keeping is poor and the process very slow. Time requirements of 6 months to 2 years are not uncommon. Legitimate fees alone can be as high as 15% of land value. It is a standard practice to hold land in corporations in order to avoid high fees, cumbersome bureaucratic procedures and corruption when the land is sold. Changes in ownership of hereditary leases can be difficult due to the weak judicial system. It is also reported that land with unsecured status is at times sold.

Frequency

The World Bank & IFC: Doing Business 2012:
- Registering property requires a company to go through an average of 13 administrative procedures, which take an average of 82 days and cost 21% of the property value.

World Economic Forum: The Global Competitiveness Report 2011-2012:
- Business executives give property rights, including financial assets, a score of 3.2 on a 7-point scale (1 'very weak' and 7 'very strong').

Transparency International: Global Corruption Barometer 2010:
- 31% of the households surveyed reported to have paid a bribe to land services in 2009. An increase from 20% in the previous year.

Transparency International: Global Corruption Barometer 2009:
- 46% of households consider grand or political corruption in land matters to be a 'very serious problem'.

- 48% of household respondents consider bribes to land authorities to obtain favourable decisions a 'very serious problem' in Nigeria.

Individual Corruption

According to the Transparency International Global Corruption Barometer 2010, approximately two out of five surveyed households who had contact with tax authorities in 2009 report to have paid a bribe. The US Department of State 2011 reports that many individuals avoid paying taxes or are able to underpay through the use of bribes.

Business Corruption

According to the World Bank & IFC Doing Business 2012, the Nigerian tax regime is very cumbersome and time-consuming, although corporate tax levels are fairly standard (30%). The average number of hours a company spends annually paying taxes is nearly three times higher than the regional average.

Both Global Integrity 2010 and the US Department of State 2011 agree that the reason why tax laws are not always enforced uniformly or without discrimination is because of the subversion by corrupt officials and their agents. Many companies state that they have 'negotiated' their own taxation levels with or without bribery, even at federal and state levels. With the exception of banks and listed companies, many companies simply pay no official taxes on corporate profits. Many taxes seem to be arbitrarily levied, and corruption often plays a role in the assessment of tax levels. The system sometimes encourages companies to operate in the informal sector, where they are less visible to regulatory oversight and thus less subject to demands for bribes.

Political Corruption

There are numerous taxes at federal, state and local levels, and the system is very complex. Some observers suggest that the complexity of regulations and insufficient training result in mismanagement, misinterpretation and corruption by agency staff.

According to Global Integrity 2010, tax collection is an area for corruption that funds several leading politicians.

Frequency

The World Bank & IFC: Doing Business 2012:
- A company spends an average of 938 hours per year paying taxes in Nigeria, making an average of 35 payments at a total tax rate of a little more than 32% of profits.

Transparency International: Global Corruption Barometer 2010:
- 38% of households who had contact with tax revenue services throughout 2009 report to have paid a bribe. An increase from 20% in the previous year.

Afrobarometer: Summary of Results Nigeria 2008:
- 37% of the surveyed citizens believe that most or all of the tax officials are involved in corruption.

Transparency International: Bribe Payers Index 2008:
- Business executives give tax revenue authorities 3.7 on a 5-point scale (1 'not at all corrupt' and 5 'extremely corrupt').

The World Bank & IFC: Enterprise Surveys 2007:
- 23% of companies expect to give gifts in meetings with tax officials.

- 68% of companies report that a typical company declares less than 100% of its sales for tax purposes.

Individual Corruption

The Nigeria Customs Service (NCS) is a notoriously corrupt public institution, according to the Transparency International Global Corruption Barometer 2005. This is corroborated by the Transparency International Global Corruption Barometer 2010, in which more than half of surveyed households who had contact with the customs administration throughout 2009 report to have paid a bribe.

Business Corruption

According to Global Integrity 2010, due to corruption, customs and excise laws are not always enforced uniformly or without discrimination. The process of clearing goods through Nigerian ports is very bureaucratic and prone to corruption, and this is supported by the World Economic Forum Global Enabling Trade Report 2010, which illustrates that trade in Nigeria is impeded by customs procedures and irregular payments, such as bribes taking place during import and export processes.

According to the US Department of State 2011, companies are known to attempt to undervalue their goods to evade duties. Furthermore, due to the high number of companies operating in the informal sector that are not formally taxed, many companies resort to smuggling instead of legal trade. Bribery of customs and port officials remains common. As a response to the high levels of duty evasion, the government has instituted a 100% inspection requirement in the Port of Lagos, which has resulted in massive congestion and delays. However, according to the US Department of State 2011, shippers now report that the efforts to modernise and professionalise the process have reduced the resulting clearance times caused by the congestion and delays.

Political Corruption

The borders of Nigeria are porous, and smuggling through Nigeria's seaports and land borders is common. In particular, the smuggling of subsidised Nigerian petrol is widespread and lucrative. Due to the high levels of smuggling, the Nigeria Customs Service (NCS), a parliamentary organisation, has an armed paramilitary unit. According to the US Department of State 2011, the smuggling is facilitated by the high frequency of corruption amongst customs and port officials.

There have been a number of corruption and fraud scandals involving foreign companies paying a large sum of bribes into the pockets of Nigerian customs officials, in exchange for services such as circumventing customs regulations or to obtain false documentation. One example took place between 2002 and 2005; when according to a 2007 press release by the US Department of Justice, in 2007, three subsidiaries of the oil service company Vetco pleaded guilty to US authorities for authorising a Swiss based freight company, Panalpina, to make a series of illegal payments amounting in total to USD 2.1 million to the Nigerian Customs Service officials in exchange for preferential treatment. Another bribery case involves Transocean Inc., a Swiss based offshore drilling contractor, paying USD 90,000 in bribes in Nigeria in order to get around customs regulations, as reported in a November 2010 news release by the US Department of Justice.

Frequency

The World Bank & IFC: Doing Business 2012:
- It takes an average of 24 days and 10 documents to export a standard container from Nigeria, at a cost of USD 1,263.

- It takes an average of 39 days and 9 documents to import a standard container to Nigeria, at a cost of USD 1,440.

World Economic Forum: The Global Competitiveness Report 2011-2012:
- Business executives give the efficiency of customs procedures (formalities regulating the entry and exit of merchandise) in Nigeria a score of 3.5 on a 7-point scale (1 being 'extremely inefficient' and 7 'extremely efficient').

World Economic Forum: The Global Enabling Trade Report 2010:
- Business executives give the transparency of border administration (irregular payments in exports and imports) a score of 2.8 on a 7-point scale (1 'not transparent' and 7 'transparent').

Transparency International: Global Corruption Barometer 2010:
- 51% of households who had contact with customs services in 2009 report to have paid a bribe.

Transparency International: Bribe Payers Index 2008:
- Business executives give customs a score of 4.3 on a 5-point scale (1 'not at all corrupt' and 5 'extremely corrupt').

The World Bank & IFC: Enterprise Surveys 2007:
- More than 33% of companies expect to give gifts in order to obtain an import licence.

Business Corruption

Nigeria's public procurement system is reportedly prone to corrupt practices, with more than two out of five companies surveyed in the World Bank & IFC Enterprise Surveys 2007 reporting that they expect to give gifts to public officials in order to secure a government contract. Business executives surveyed by the World Economic Forum Global Competitiveness Report 2011-2012 report that government officials in Nigeria frequently favour well-connected companies and individuals when deciding upon policies and contracts. According to the US Department of State 2011, whilst procurement has become slightly more transparent, US companies still report that they are at a disadvantage when seeking government contracts. US companies bidding on government contracts further report that collusion occurs between foreign competitors and key government officials. Bureaucratic corruption is rampant, the conflict of interest legislation is not enforced, and procurement for capital projects is often subject to over-invoicing, which leaves room for improper payments to brokers, contractors and public sector officials. The government enacted the Public Procurement Act in 2007, creating a more transparent and competitive procedure for awarding public contracts and introducing a debarment procedure for corrupt companies, allowing the Bureau of Public Procurement (BPP) to debar companies for no less than five years and impose fines. However, Global Integrity 2010 reports that public procurement regulations are not effectively enforced in practice, as companies guilty of major violations of procurement regulations are not always blacklisted.

Corruption in contracting is typically carried out through brokers or agents who obtain contracts through bribes and patronage. SMEs face problems competing for government contracts against well-connected large companies with more resources and experience in bribing public officials. In late 2007, two multinational companies, Wilbros and Siemens, were convicted both in the US and Europe for bribing public officials in Nigeria in order to obtain lucrative contracts in the country.

In February 2009, the US government charged engineering company KBR Inc in a USD 180 million scheme to bribe Nigerian officials to secure USD 6 billion in contracts, according to a February 2009 article by Reuters. Allegedly, the bribes were paid between 1994 and 2004 to secure four contracts for a KBR joint venture to build and expand Nigeria's Bonny Island liquefied natural gas terminal. Subsequently, KBR agreed to pay a USD 402 million fine to end the investigation. Nigerian government has announced that it will prosecute those Nigerian officials involved in the scandal. Companies are advised to use a specialised public procurement due diligence tool in order to mitigate the corruption risks associated with public procurement in Nigeria.

Read more on public procurement under 'Public Anti-Corruption Initiatives' in the Initiatives section.

Political Corruption

Despite official legislation, Global Integrity 2010 claims that there is no effective law to monitor public officials' spending, assets and income unless one is suspected of money laundering. This means that corrupt officials in public procurement can be difficult to trace due to a lack of effective monitoring of assets declarations. The Code of Conduct Bureau (CCB) collects declarations of assets, but the effectiveness of these declarations is disputed.

In October 2009, the Former Chairman of the Board of the Nigerian Ports Authority, Bode George, and five other commissioners were convicted by the courts of abuse of public office in the improper awarding of contracts. George was sentenced to 30 months in jail, without the option of paying a fine, according to the US Department of State Human Rights Report 2010.

Read more on public procurement under 'Public Anti-Corruption Initiatives' in the Initiatives section.

Frequency

World Economic Forum: The Global Competitiveness Report 2011-2012:
- Business executives give the favouritism of government officials when deciding upon policies and contracts a score of 2.6 on a 7-point scale (1 being 'always show favouritism' and 7 'never show favouritism').

- Business executives give the diversion of public funds to companies, individuals, or groups due to corruption a score of 2.2 on a 7-point scale (1 being 'very common' and 7 'never occurs').

The World Bank & IFC: Enterprise Surveys 2007:
- 44.5% of companies polled expect to give gifts to secure a government contract.

- The value of a gift expected to secure government contracts amounts to 4.6% of the contract value.

Business Corruption

An environmental impact assessment is required for a wide range of business activities. The assessment is administered by the Federal Environmental Protection Agency (FEPA), but the agency has proven to be unable to assist companies in meeting the requirements. Global Integrity 2010 reports that environmental regulations are not always enforced uniformly or in an even-handed manner.

Large scale bribery is common in the extractive industry in Nigeria, as exemplified by the following case. In December 2010, the US company Halliburton paid a USD 35 million fine to settle a case with Nigerian authorities. The case relates to a joint venture between: KBR - a subsidiary of Halliburton until 2007, Snamprogetti Netherlands - a unit of Saipem SpA and subsidiary of Eni SpA of Italy, Technip of France, and Japan's JGC. They bribed officials USD 180 million over a 10 year period from 1994 to 2004 to win a 6 USD billion contract to build a liquefied gas plant. All were found guilty in US courts of bribery. KBR and Halliburton were fined USD 579 million in 2009. Saipem and Eni paid a settlement totalling of USD 365 million. Technip made a USD 342 million settlement. This case was covered by many news sources, including a 2010 Bloomberg article. JGC was the last to settle their case, paying a USD 218.8 million fine in April 2011, according to a 2011 news release by the US Department of Justice.

In January 2010, Nigeria's Minister of Petroleum Resources reported that the Economic and Financial Crimes Commission (EFCC) will look into the alleged missing 90 million litres of petrol belonging to the Pipelines and Products Marketing Company (PPMC), a subsidiary of the Nigerian National Petroleum Corporation. Prior to this, in December 2009, the government promised to set up a committee that would look into the missing fuel, which has allegedly been misappropriated by the PPMC in collaboration with some depot owners, according to a 2010 article by The Nation.

Political Corruption

CMI 2009 reports that misallocation of funds and contracts is common in the oil industry in Nigeria. Another problem is the theft of crude oil from pipelines, which is estimated to be around 100,000 barrels per day. According to CMI 2009, government and oil companies' representatives are generally perceived to be complicit in those theft activities.

It is claimed that there has been massive corruption and misappropriation of funds from the oil industry by top politicians and officials within the Nigerian National Petroleum Corporation (NNPC). For instance, according to a March 2009 article by Reuters, the NNPC has been plagued by corruption for decades with USD billions of oil money going to a few well-connected figures.

CMI 2009 also listed a corruption case involving a US oil service company paying approximately USD 180 million in bribes to the NNPC, the Petroleum Ministry and other government officials in exchange for securing several contracts to build liquefied natural gas facilities in Nigeria from 1995 to 2004. The company pleaded guilty.

See a US Energy Information Administration analysis of the Nigerian energy sector.

• Legislation: Nigeria ratified the United Nations Convention against Corruption in December 2004 and the African Union Convention on Preventing and Combating Corruption in September 2006. The Corrupt Practices and Other Related Offences Act 2000 applies to all public officials and criminalises active and passive bribery, as well as attempted corruption, abuse of office, fraud, extortion, and money laundering. The Money Laundering (Prohibition) Act 2004 repealed the previous act from 2003 and criminalises individuals making or accepting cash payments in excess of NGN 500,000 and corporate bodies making or accepting cash payments in excess of NGN 2 million without going through a financial institution. The National Assembly also passed the Advance Fee Fraud and other Fraud Related Offences Act 2006 in order to combat the persistently large body of fraudulent activities in Nigeria that have negatively affected Nigeria's business reputation. On the other hand, the Fiscal Responsibility Act 2007 is aimed at improving budgeting and, in turn, reducing opportunities for corruption, according to Transparency International's Global Corruption Report 2009. The Nigerian Constitution 1999 specifies requirements for asset disclosure, regulations governing the offering and receiving of gifts for members of the executive, Parliament and legislature. These issues are detailed in various codes of conduct for public officials, including the Code of Conduct for Ministers and Special Advisers and backed by the Code of Conduct Bureau and Tribunal Act 1999. According to Global Integrity 2010, the Nigerian legal framework for addressing corruption is 'very strong'. However, rule of law and law enforcement is described as moderate for reasons such as government interference with public law enforcement agencies, vague and ineffective regulations governing the acceptance of gifts for public officials, and ineffective conflict of interest regulations, among others. Furthermore, as emphasised by the US Department of State 2010, penalties for corruption, if found guilty, remain insufficient to serve as a deterrent. Access the Lexadin World Law Guide for a collection of legislation in Nigeria.

• Government Strategies: Corruption continues to be a major problem in Nigeria, and several public strategies and campaigns to curb corruption have been launched during the last three decades. Among these can be mentioned the Ethical Revolution (1981-83), the War Against Indiscipline (1984), the National Orientation Movement (1986), the Mass Mobilisation for Social Justice (1987) and the new War Against Indiscipline (1996). However, it was only with the signing of the Corrupt Practices and Other Related Offences Act in 2000, during the Obasajo presidency, that Nigeria first imposed a legal framework and severe sanctions to fight corruption. In the wake of this act, three main agencies were created with different mandates regarding corruption: the Independent Corrupt Practices and Other Related Offences Commission (ICPC), the Economic and Financial Crimes Commission (EFCC) and the Code of Conduct Bureau (CCB) (see below). Former President Yar'Adua has proposed a merger of these three anti-corruption agencies in order to coordinate their work. Some observers interpret this measure as a tactic to accommodate the critique of these agencies that they have been biased in their investigations by primarily targeting political opponents of former President Obasanjo. However, other observers fear that the merger of the agencies indicates a desire by the executive to exercise political control over anti-corruption cases. On a positive note, in May 2011, President Jonathan signed the Freedom of Information Bill into law, which allows citizens access to public records and information. According to a 2011 news article by IFEX, the new law is believed to serve as an important tool to uncover facts, fight corruption and hold officials and institutions accountable. Furthermore, a new policy aimed at reducing money laundering and other financial crimes, is expected to take effect on 1 June 2012. According to a May 2011 news article by This Day Live, a new daily cash withdrawal allowance for individuals and corporate customers will be NGN 150,000 and NGN 1 million, respectively.

• Anti-Corruption Agency: There are a number of anti-corruption agencies in Nigeria, one of them is the Independent Corrupt Practices and Other Related Offences Commission (ICPC), which was established in 2000 with a mandate to investigate reports of corruption, review government systems prone to corruption and educate the public about corruption. The ICPC is legally protected from political interference. However, according to Global Integrity 2010, the ICPC is sometimes influenced by political incentives. Today, the ICPC is accredited as a cornerstone in the fight against corruption in Nigeria. The ICPC can initiate investigations and does so often. However, only a few high-level prosecutions have taken place, with few or no consequences. Due to underfunding, the commission has a backlog of cases. Its reports are not regularly published and are not available to the public. Click here for the recent publications by the ICFC. The ICFC also has a section named ‘Interactivity’ where discussion forum, chatroom and guest book can be found.

• Economic and Financial Crimes Commission (EFCC): The EFCC is another main anti-corruption agency that was set up in 2004 and includes a Financial Intelligence Unit to fight economic crime, including the infamous 'advance fee fraud' e-mail scams that emanate from Nigeria. The legal instrument backing the EFCC is the EFCC Establishment Act from 2004, which mandates the EFCC to prevent, investigate, prosecute and penalise financial and economic crimes. Under the leadership of former Chairman Nuhu Ribadu, the EFCC was active in investigating and prosecuting several high-profile individuals involved in financial corruption. In January 2008, Chairman Ribadu was ordered on a year-long training course and a new chairman, Farida Waziri, was appointed by former President Yar'Adua. Transparency International in its May 2008 press release has expressed concerns that due process might not have been followed in the appointment of the new chairman. Individuals and organisations can file complaints through a written petition to the EFCC, which will then initiate investigations if the case falls within the scope of the EFCC's mandate. The EFCC arrested and detained several state, local, and federal government officials on corruption charges during 2008, although critics charged that some arrests were politically motivated, according to the US Department of State Human Rights Report 2010. In a similar vein, a 2011 report published by Human Rights Watch points out that despite that there were many high-profile corruption cases against the political figures since the commencement of the EFCC, only few convictions have been made, and those who were convicted faced relatively little or no prison sentences. The report also lists some external obstacles such as political interference as well as the EFCC’s own shortcomings that have undermined the EFCC’s anti-corruption work.

• Code of Conduct Bureau (CCB): The mission of the CCB is to establish higher standards of morality in the conduct of government activities through the enforcement of a 1999 Code of Conduct for Ministers and Special Advisers. The CCB was established in 1999 in accordance with the Code of Conduct Bureau and Tribunal Act. The CCB monitors public officials through the collection and verification of annual asset declarations. All public servants are required to file an asset disclosure form, but the CCB focuses primarily on fixed tenure, career civil servants. Although these declarations are not made public, the CCB can take officials to court.

• Ombudsman: The Public Complaints Commission (PCC) is the Nigerian equivalent to an Ombudsman. The PCC has offices in all Nigerian states and is empowered to investigate citizens' complaints against any governmental or private body. The agency is formally independent and, according to Global Integrity 2010, there has been no case of political inference with the office. Appointments to the agency are based on criteria of personal integrity and other relevant qualifications. The PCC receives regular funding and has a full-time staff; however, according to Global Integrity 2008, the agency has a significant backlog of cases, largely due to a lack of human resources and funding. The agency publishes publicly available reports and the government usually acts on its findings. However many complaints are never investigated due to the lack of resources.

• Auditor General: Established under Section 85 of the Constitution 1999, the Auditor General of the Federation (AG) heads the Supreme Audit Institution (SAI) and is responsible to the National Assembly, but also takes directives from and cooperates with the executive in matters relating to the audit of government accounts and agencies. The agency is legally independent and the same seems to be true in practice according to Global Integrity 2010. The AG receives regular funding and has a full time staff. Although it publishes reports, Global Integrity 2008 reports that those are neither issued regularly nor available to the public. Furthermore, the government rarely acts on these reports even though the AG has indicted several government bodies and revealed instances of corruption and irregular procedures.

• Nigerian Extractive Industries Transparency Initiative (NEITI): The NEITI is the Nigerian subset of a global initiative, the Extractive Industries Transparency Initiative (EITI), aimed at following due processes and achieving transparency in payments by extractive industries companies to governments and government-linked entities. The NEITI was launched by President Obasanjo in 2004 and is implemented through a National Stakeholders Working Group (NSWG). Nigeria signed the NEITI Act into law in May 2007 and was accepted as an EITI candidate country in September 2007. The act mandates the NEITI to promote due process, independent auditing, and transparency in extractive revenues, particularly oil and gas revenues, paid to and received by government as well as to ensure transparency and accountability in the application of extractive revenues. Hence, according to Transparency International's Global Corruption Report 2009, the oil, gas and mining sector will now be audited annually according to international standards, and violations will be punished with fines, loss of licences and, when individuals are found guilty, criminal sanctions. In February 2011, the NEITI released the 2006-2008 EITI Reconciliation Report, which includes useful observations and recommendations on improving the management of revenues from the extractive sector. Since 2007, the Nigeria government has reported USD 1 billion in additional revenues from the extractive industry, illustrating a benefit from implementing the NEITI, as reported in a 2011 news article by Natural Resources Canada.  

• Budget Monitoring and Price Intelligence Unit (BMPIU): The BMPIU was established under the Office of the Principal Secretary to the President in 2003 as an operationally independent body designed to harmonise regulations and standards in public tender procedures and monitor all government contracts and procurement of goods and services. The BMPIU has instituted a process of contract award review in public contracting in order to ensure transparent and competitive bidding.

• E-Governance: The Nigerian government has taken steps in relation to e-governance to improve its dealings with the business sector. The Nigerian Investment Promotion Commission (NIPC) is a public one-stop shop for information on investment in Nigeria. The NIPC provides information on business registration procedures and links to relevant authorities. State websites also provide and are further developing online business services. For example, the Federal Inland Revenue Service (FIRS) provides relevant information on how and where to pay corporate and individual taxes. Furthermore, to increase transparency in Nigeria's customs administration, the Automated System for Customs Data (ASYCUDA), a computerised customs management system, was launched in 1999 by government and became operational in 15 customs offices. This system facilitates the electronic processing of declarations, risk management, transit operations and expedited clearance of goods, in turn reducing corruption risks, as meetings between customs officials and the public decrease.

• Public Procurement: Nigeria enacted the Public Procurement Act (PPA) in 2007, creating the Bureau of Public Procurement (BPP) and laying down the procedure by which the BPP can debar companies guilty of major violations in procurement processes from participating in future government contracts. Transparency International's Global Corruption Report 2009 emphasises that the Bureau can also refer cases to the law enforcement agencies if offences are uncovered. However, according to Global Integrity 2010, public procurement regulations are not effectively enforced in practice, as companies guilty of major violations of procurement regulations are not always blacklisted. The PPA addresses conflict of interest for procurement officials and empowers the BPP to undertake professional training of these officials. The PPA also establishes requirements for open competitive bidding, defines bid security, ensures clarified tendering procedures and mobilisation fees, and provides for an audit process. Government tenders are advertised in newspapers and on websites, including the BBP section on Federal Government Procurement Notices. Unsuccessful parties to the bidding process can make administrative appeals using the BBP complaint mechanism and challenge procurement decisions in the courts.

• Whistle-Blowing: According to Global Integrity 2010, civil servants and private sector employees reporting cases of corruption have no legal protection from recrimination or other negative consequences. Complaints cannot be submitted anonymously, although some anti-corruption agencies, such as the Independent Corrupt Practices and Other Related Offences Commission (ICPC) and the Economic and Financial Crimes Commission, have their own internal mechanisms to protect informants' identities. The ICPC has a reporting mechanism on its website to which any person (private and public) can submit complaints if they suspect that an offence has been committed under the Corrupt Practices and Other Related Offenses Act. According to an October 2011 news article by AllAfrica, the whistle-blower bill was sent to the House of Representatives in September 2011 for the first reading and is expected to be listed for the second reading.

• General Comments on the Public Anti-Corruption Initiatives: The legal and administrative framework for combating corruption is generally in place. However, as with legislation and regulations in general in Nigeria, implementation and enforcement is weak. Despite several anti-corruption agencies in Nigeria, their ability to tackling corruption and bringing corrupt individuals to justice have been questioned. For example, since the inception of the Economic and Financial Crimes Commission (EFCC), only a few corrupt high-ranking politicians have been charged, and with only very little or no prison terms handed down. Impediments such as political interference and an inefficient judiciary are blamed for undermining the work of these agencies. Nevertheless, there have also been several positive developments by the government in addressing corruption and promoting good governance such as the signing of the Nigerian Extractive Industries Transparency Initiative Act in 2007 and the passage of the Freedom of Information Bill into law in 2011. Nigeria remains one of the most corrupt countries in the world according to various corruption-related indices, fighting endemic corruption is definitely not an easy task, and it requires a full support from all levels of society.

• Media: The Nigerian Constitution provides for freedom of speech and press, however the government sometimes restricts their rights, according to both Freedom House 2011 and the US State Department 2010. The Nigerian press is independent and often criticises the government and exposes corruption cases; however, journalists are at times subjected to harassment, arrest and other forms of repression, especially when reporting on sensitive issues, such as corruption. A culture of impunity persists for crimes against journalists. There has been a worrying increase in violence against journalists both by the authorities and by civilians whose anger at journalists is based upon religious beliefs. The media have been also impaired by restrictions on access to information. A Freedom of Information Bill was introduced in 1999, but was only signed into law in May 2011. A number of laws prevented civil servants from imparting official facts and figures, especially the Official Secrets Act, which made an offence for civil servants to disseminate government information and for anyone to receive or produce such information. It is too early to assess whether the new Access to Information Law will have any positive effect. The private print press has actively reported corruption. However, according to the Bertelsmann Foundation 2010, this is changing as the private media becomes more biased and more of a public relations agency for different groups. Furthermore, Global Integrity 2010 reports that cases of cash-for-stories, where journalists are paid to write, abstain from writing or alter stories, are not unusual in Nigeria. Freedom House 2011 ranks Nigeria 110th out of 196 countries and describes the country's press environment as 'partly free', while the Reporters Without Borders 2010 ranks Nigeria 145th out of 178 countries.

• Civil Society: The constitution guarantees freedom of assembly, association and religious freedom. However, according to Freedom House 2011 and several human rights organisations, these basic rights are not effectively upheld and protected in reality, and there have been several reports of abuses by authorities, especially during demonstrations organised by youth groups or in the Niger Delta. The Bertelsmann Foundation 2010 reports that civil society in Nigeria is weak and usually ignored by the political leadership. However, a generally positive trend is reported in the development of civil interest groups as well as civic support for democracy.

• Zero Corruption Coalition (ZCC): The ZCC is a network of over 50 CSOs campaigning against corruption in Nigeria. The ZCC is a partner in the 'Accountability Nigeria' coalition of public and private organisations working with transparency and accountability in Nigeria. The ZCC does advocacy work with legislators and government anti-corruption agencies on the need to domesticate and implement both the UNCAC and the AU Convention on Preventing and Combating Corruption.

• Integrity: Integrity is a Nigerian non-profit anti-corruption NGO founded in 1995. It is working to empower and inform civil society in order to tackle corruption in Nigeria, and to coordinate efforts between public and private institutions in a national fight against corruption. Integrity has published several reports on good governance and is running programmes and projects aimed at promoting transparency and integrity. For example, it has been awarded a European Community grant to run a budget monitoring project in Nigeria aimed at promoting good governance, transparency and respect for the rule of law in budgetary matters.

• Convention on Business Integrity (CBi): The CBi consists of Nigerian and foreign companies operating in Nigeria who have signed a Code of Business Integrity originally adopted in 1998. Members have to go through an accreditation process and adhere to values of corporate integrity and transparency. The CBi has an online toolkit that provides ‘how-to’ guide for businesses to achieve the CBi Standard and fully integrate a commitment against bribery and corruption within their business activities. Read more about the Nigerian CBi presented by a Business Fighting Corruption case study.

• Transparency in Nigeria (TIN): TIN is a local chapter of the international anti-corruption NGO Transparency International. It was founded in 1994 to provide a forum for individuals and the public, as well as for private institutions to exchange ideas and share experiences and to take appropriate action towards reducing corruption.

• Independent Advocacy Project (IAP): The IAP is an NGO working to promote transparency, accountability and good governance in Nigeria by building partnerships between individuals and organisations through information sharing. The IAP issues a monthly electronic newsletter, an in-depth quarterly report and specialised reports. It also produces the Nigerian Corruption Index (NCI) in order to empirically determine the degree of corruption in Nigeria.

• African Parliamentarians Network Against Corruption (APNAC): APNAC is a leading all-party parliamentary anti-corruption network in Africa. Its main work is to promote good governance and to strengthen parliamentary capacity to fight corruption. It has a local office in Abuja, Nigeria.
  
  
• Nigerian Economic Submit Group (NESG): NESG is a non-profit partisan private sector organisation established in 1996. The NESG serves as a platform for public-private sectors for dialogue and discussion of the Nigerian economy. The NESG sponsors workshops, researches and information services and educational activities. The flagship of the NESG’s advocacy efforts is the annual Nigerian Economic Summit, which has been held annually since 1993. The most recent summit was held on 10-12 November 2011. Click here to view some achievements from the previous summits.
  
  
• Nigerian Bar Association (NBA): NBA is a non-profit, umbrella organisation of all lawyers certified to practice law in Nigeria. Today, the NBA has 88 branches across the country. The NBA engages in the promotion and protection of human rights, the rule of law and good governance. The NBA is involved in various thematic programme areas that include anti-corruption and judicial sector reform. The NBA has been actively voicing corruption-related problems within the Nigerian judicial system. In February 2011, the NBA set up a high-powered committee to work with other stakeholders to probe corruption and similar issues in the judiciary, according to a February 2011 news release on its website.
  

The websites listed below provide useful facts on Nigeria as well as contacts and tools for companies operating in Nigeria:

• International Finance Corporation: Nigeria SME Toolkit and West Africa SME Toolkit (in French)
  Guide to sustainable business management practices for SMEs.
• Business Fighting Corruption
  An online resource centre for business on collective action to avoid corruption which contains a guide and resources for partnerships with companies and other stakeholders to fight against corruption.
• CIA World Fact Book: Nigeria Country Profile
• World Bank: Nigeria Data Profile

Sources for further reading:

• Human Rights Watch: World Economic Forum: Corruption on Trial? The Record of Nigeria’s Economic and Financial Crimes Commission, August 2011.
• Freedom House: Freedom in the World - Nigeria 2011.
• US Department of State: Investment Climate Statement - Nigeria 2011.
• US Department of State: Human Rights Report - Nigeria 2010.
• The Bertelsmann Foundation: Transformation Index - Nigeria 2010.
• Global Integrity: Nigeria Country Report 2010.
• Transparency International: Global Corruption Report 2009.

UNCAC Status: Signed 9 December 2003. Ratified 14 December 2004.

Status on UNCAC Implementation
This field describes the country's status on the United Nations Convention against Corruption. Please note any declarations and reservations made upon ratification. The list of signatories can be found on the UNODC website. Read more about the UNCAC.

Other Relevant Conventions or Treaties:

• African Union Convention on Preventing and Combating Corruption: Signed 16 December 2003. Ratified 26 September 2006.
  Read Transparency International's summary and assessment of the convention.
• United Nations Convention against Transnational Organized Crime: Signed 13 December 2000. Ratified 28 June 2001.
  Read Transparency International's summary and assessment of the convention.  

Transparency CPI: 2011: 134/178 (Score: 2.4)

Transparency CPI
This field consists of the score for the country in question on the Corruption Perceptions Index from Transparency International as well as its ranking.

World Bank CORR Index (-2.5 - +2.5): 2010: -0.99

World Bank Corruption Index
This field consists of the score for the country in question on the 'Control of Corruption'-indicator in the World Bank Governance Research Indicator Country Snapshot (GRICS): 1996-2010.

OECD Country Risk Classification (0-7): 2011: 5

Country Risk Classification
The classification of countries by risk category has the aim of providing OECD countries with a basis for calculating the premium interest rate to be charged to cover the risk of non-repayment of export credits. Countries are placed in risk categories 0 - 7, with 0 being the lowest risk category and thus the least expensive. Conversely, premium group 7 is the highest risk category. Each classification is comprised of 2 components: 1) an assessment of the country's economic/financial situation, and 2) its overall political stability. Access the complete list of OECD Country Risk Classification figures.

Data Verification:

Latest update: November 2011

Data verified by: Global Advice Network

General Information Sources

• The World Bank & IFC: Doing Business 2012.
• World Economic Forum: The Global Competitiveness Report 2011-2012.
• Freedom House: Freedom in the World - Nigeria 2011.
• US Department of State: Investment Climate Statement - Nigeria 2011.
• All Africa: 'Nigeria: Freedom of Information Act and the States', 21 June 2011.
• Nigerian Tribune: 'NHRC, Atiku commends on FOI Bill', 02 June 2011.
• This Day Live: 'CBN cash limits to check money laundering - report', 11 May 2011.
• BBC News: 'Nigeria election: Muhammadu Buhari's CPC goes to court', 9 May 2011.
• Global Financial Integrity: Illicit Financial Flows from Developing Countries: 2000-2009, January 2011.
• US Department of State: Human Rights Report - Nigeria 2010.
• Transparency International: Global Corruption Barometer 2010.
• Global Integrity: Nigeria Country Report 2010.
• The Bertelsmann Foundation: Transformation Index - Nigeria 2010.
• Global Financial Integrity: Illicit financial flows from Africa: hidden resources for development, March 2010.
• 234Next: 'Alamieyeseigha seeks reinstatement as governor', 26 January 2010.
• Transparency International: Global Corruption Report 2009.
• CMI: Reforming Corruption Out of Nigerian Oil? 2009.
• SomaliPress: 'Court Frees Nigerian Former Delta State Governor James Ibori', 18 December 2009.
• Reuters: 'Nigeria arrests ex-governor over corruption', 4 March 2009.
• Afrobarometer: Summary of Results Nigeria 2008.
• Lexadin: The World Law Guide - Legislation Nigeria 2008.
• Reuters: 'Convicted Nigeria ex-governor to pay fine', 19 December 2008.
• Human Rights Watch: Criminal Politics - Violence, 'Godfathers' and Corruption in Nigeria 2007.
• The World Bank & IFC: Enterprise Surveys 2007.
• Transparency International: Global Corruption Report 2007.
• The World Bank: Nigeria - Country Brief 2007.
• Global Insight: 'Powers of Anti-Corruption Watchdog in Nigeria to be Curbed', 7 August 2007.
• Global Insight: 'Nigerian President Scraps National Oil Corp; Unbundling and Restructuring Ahead', 30 August 2007.
• Rotimi T. Suberu: 'Nigerian Federalism - Genie in a Bottle? in Democracy at Large', Vol. 2, No. 2 2006.
• Transparency International: National Integrity System Country Study Report Nigeria 2004.
• Transparency International, Osita Agbu: New Anti-Corruption Governments: The Challenge Of Delivery. Nigeria - a Case Study 2004.
• US Energy Information Administration: Nigeria Country Analysis Brief.
• Nigeria Extractive Industries Transparency International.

Corruption Levels Sources

Judicial System

• The World Bank & IFC: Doing Business 2012.
• World Economic Forum: The Global Competitiveness Report 2011-2012.
• US Department of State: Investment Climate Statement - Nigeria 2011.
• Freedom House: Freedom in the World - Nigeria 2011.
• Human Rights Watch: World Economic Forum: Corruption on Trial? The Record of Nigeria’s Economic and Financial Crimes Commission, August 2011.
• US Department of State: Human Rights Report - Nigeria 2010.
• Transparency International: Global Corruption Barometer 2010.
• The Bertelsmann Foundation: Transformation Index - Nigeria 2010.
• Global Integrity: Nigeria Country Report 2010.
• Afrobarometer: Summary of Results Nigeria 2008.
• Transparency International: Global Corruption Report 2007.
• The World Bank & IFC: Enterprise Surveys 2007.
• Transparency International: National Integrity System Country Study Report Nigeria 2004.

Police

• The World Bank & IFC: Doing Business 2012.
• World Economic Forum: The Global Competitiveness Report 2011-2012.
• US Department of State: Investment Climate Statement - Nigeria 2011.
• Freedom House: Freedom in the World - Nigeria 2011.
• US Department of State: Human Rights Report - Nigeria 2010.
• Transparency International: Global Corruption Barometer 2010.
• Human Rights Watch: "Everyone's in on the game" - Corruption and Human Rights Abuses by the Nigeria Police Force 2010.
• The Bertelsmann Foundation: Transformation Index - Nigeria 2010.
• Global Integrity: Nigeria Country Report 2010.
• Nigeria Guardian: 'DPA lauds Lagos ban on MOT inspection', 20 August 2009.
• Lagos State Government: 'Fashola Directs Stoppage of Arrests for MOT Offences', 18 August 2009.
• AllAfrica: 'Nigeria: Fashola, Your Lastma & Vio are Bleeding Us Dry!', 20 July 2009.
• Global Integrity: Nigeria Country Report 2008.
• Afrobarometer: Summary of Results Nigeria 2008.
• Transparency International: Bribe Payers Index 2008.
• Human Right Watch: Criminal Politics. Violence, 'Godfathers' and Corruption in Nigeria 2007.
• Transparency International: National Integrity System Country Study Report Nigeria 2004.
• Transparency International, Osita Agby: New Anti-Corruption Governments: The Challenge of Delivery. Nigeria - a Case Study 2004.

Licences, Infrastructure and Public Utilities

• The World Bank & IFC: Doing Business 2012.
• World Economic Forum: The Global Competitiveness Report 2011-2012.
• US Department of State: Investment Climate Statement - Nigeria 2011.
• Freedom House: Freedom in the World - Nigeria 2011.
• US Department of State: Human Rights Report - Nigeria 2010.
• Transparency International: Global Corruption Barometer 2010.
• The Bertelsmann Foundation: Transformation Index - Nigeria 2010.
• Global Integrity: Nigeria Country Report 2010.
• Transparency International: Global Corruption Report 2009.
• Reuters: 'More charges against ex-boss of Nigerian Bank PHB', 15 December 2009.
• AllAfrica: 'Nigeria: Fashola, Your Lastma & Vio are Bleeding Us Dry!', 20 July 2009.
• AFP: 'KBR pleads guilty in Nigeria bribery probe', 11 February 2009.
• Reuters: 'US govt formally charges KBR in Nigeria bribe case', 7 February 2009.
• Afrobarometer: Summary of Results Nigeria 2008.
• Transparency International: Bribe Payers Index 2008.
• The World Bank & IFC: Enterprise Surveys 2007.

Land Administration

• The World Bank & IFC: Doing Business 2012.
• World Economic Forum: The Global Competitiveness Report 2011-2012.
• US Department of State: Investment Climate Statement - Nigeria 2011.
• Freedom House: Freedom in the World - Nigeria 2011.
• Transparency International: Global Corruption Barometer 2010.
• US Department of State: Human Rights Report - Nigeria 2010.
• The Bertelsmann Foundation: Transformation Index - Nigeria 2010.
• Transparency International: Global Corruption Barometer 2009.

Tax Administration

• The World Bank & IFC: Doing Business 2012.
• World Economic Forum: The Global Competitiveness Report 2011-2012.
• US Department of State: Investment Climate Statement - Nigeria 2011.
• Freedom House: Freedom in the World - Nigeria 2011.
• US Department of State: Human Rights Report - Nigeria 2010.
• Transparency International: Global Corruption Barometer 2010.
• The Bertelsmann Foundation: Transformation Index - Nigeria 2010.
• Global Integrity: Nigeria Country Report 2010.
• Afrobarometer: Summary of Results Nigeria 2008.
• Transparency International: Bribe Payers Index 2008.
• The World Bank & IFC: Enterprise Surveys 2007.

Customs Administration

• The World Bank & IFC: Doing Business 2012.
• World Economic Forum: The Global Competitiveness Report 2011-2012.
• US Department of State: Investment Climate Statement - Nigeria 2011.
• Freedom House: Freedom in the World - Nigeria 2011.
• World Economic Forum: Global Enabling Trade Report 2010.
• US Department of State: Human Rights Report - Nigeria 2010.
• Transparency International: Global Corruption Barometer 2010.
• The Bertelsmann Foundation: Transformation Index - Nigeria 2010.
• Global Integrity: Nigeria Country Report 2010.
• US Department of Justice: 'Oil services companies and a freight forwarding company agree to resolve foreign bribery investigations and to pay more than $156 million in criminal penalties', 4 November 2010.
• The Washington Times: 'U.S. announces settlement in global bribery scandal', 4 November 2010.
• The World Bank & IFC: Enterprise Surveys 2007.
• US Department of Justice: 'Three Vetco International Ltd. Subsidiaries Plead Guilty
  to Foreign Bribery and Agree to Pay $26 Million in Criminal Fines' - Press Release 6 February 2007.

Public Procurement and Contracting

• World Economic Forum: The Global Competitiveness Report 2011-2012.
• US Department of State: Investment Climate Statement - Nigeria 2011.
• Freedom House: Freedom in the World - Nigeria 2011.
• US Department of State: Human Rights Report - Nigeria 2010.
• Transparency International: Global Corruption Barometer 2010.
• The Bertelsmann Foundation: Transformation Index - Nigeria 2010.
• Global Integrity: Nigeria Country Report 2010.
• Market Watch: 'Nigeria to prosecute citizens involved in Halliburton scandal', 7 April 2009.
• AFP: 'KBR pleads guilty in Nigeria bribery probe', 11 February 2009.
• Reuters: 'US govt formally charges KBR in Nigeria bribe case', 7 February 2009.
• The World Bank & IFC: Enterprise Surveys 2007.
• Transparency International: National Integrity System Country Study Report Nigeria 2004.

Environment, Natural Resources and Extractive Industry

• The New York Times: 'Nigerian National Petroleum Corporation', 11 March 2011.
• Bloomberg: 'Nigeria in Talks With Technip, Eni and JGC Over Bribe Case' 7 December 2010.
• Global Integrity: Nigeria Country Report 2010.
• The Nation: 'EFCC to probe missing 90m litres of petrol', 15 January 2010.
• CMI: Reforming Corruption Out of Nigerian Oil? 2009.
• Reuters: 'Years of distrust hurt chances of Nigeria oil reforms', 9 March 2009.
• Transparency International: National Integrity System Country Study Report Nigeria 2004.
• Nigeria Extractive Industries Transparency Initiative.

Public Anti-Corruption Initiatives Sources

• Human Rights Watch: World Economic Forum: Corruption on Trial? The Record of Nigeria’s Economic and Financial Crimes Commission, August 2011.
• All Africa: 'Nigeria: National Aseembly to Legalise Whistle Blowing', 11 October 2011.
• IFEX: 'Freedom of information law is a victory for democracy', 1 June 2011.
• This Day Live: 'CBN cash limits to check money laundering - report', 11 May 2011.
• Natural Resources Canada: 'Progress in Countries Implementing the EITI - Case Studies: Liberia and Nigeria', 24 February 2011.
• The Bertelsmann Foundation: Transformation Index - Nigeria 2010.
• Freedom House: Countries at the Crossroads - Nigeria 2010.
• Global Integrity: Nigeria Country Report 2010.
• US Department of State: Human Rights Report - Nigeria 2010.
• Transparency International: Global Corruption Report 2009.
• AllAfrica: 'Modified Asycuda System to Make Nigerian Ports More Efficient - NPA Boss', 25 November 2009.
• Global Integrity: Nigeria Country Report 2008.
• UNCTAD Trust Fund for Trade Facilitation Negotiations Technical Note No. 21: Automated System for Customs Data ASYCUDA 2008.
• Transparency International: 'Nigeria's Anti-Graft Agency must set Standard for Transparency and Accountability' (Press Release), 30 May 2008.
• AllAfrica: 'Nigeria: House moves to merge ICPC, EFCC', 14 January 2008.
• AllAfrica: 'Nigeria: EFCC/ICPC/CCB - One merger, many questions', 22 December 2007.
• Global Integrity: Nigeria Country Report 2007.
• BBC News: 'Nigeria governors in graft probe', 28 September 2006.
• Transparency International: National Integrity System Country Study Report Nigeria 2004.
• Transparency International, Osita Agbu: New Anti-Corruption Governments: The Challenge of Delivery. Nigeria - a Case Study 2004.

Private Anti-Corruption Initiatives Sources

• US Department of State: Investment Climate Statement - Nigeria 2011.
• Freedom House: Freedom in the World - Nigeria 2011.
• Freedom House: Freedom of the Press - Nigeria 2011.
• Freedom House: Freedom of the Press Index 2011.
• Reporters Without Borders: Nigeria Country Report 2011.
• Nigerian Bar Association: 'NBA Constitutes High Powered Committee', 23 February 2011.
• Reporters Without Borders: Press Freedom Index 2010.
• US Department of State: Human Rights Report - Nigeria 2010.
• Transparency International: Global Corruption Barometer 2010.
• The Bertelsmann Foundation: Transformation Index - Nigeria 2010.
• Global Integrity: Nigeria Country Report 2010.
• Transparency International: National Integrity System Country Study Report Nigeria 2004.
• Transparency International, Osita Agbu: New Anti-Corruption Governments: The Challenge of Delivery. Nigeria - a Case Study 2004.
• Independent Advocacy Project Homepage.