Uncovered Investigation: Recovery of $185 Million through Forensic Audit by Simbi Wabote, Focusing on Missing Oil Revenue in Nigeria
During his tenure as Executive Secretary of the Nigerian Content Development and Monitoring Board (NCDMB) from 2016 to December 2023, Simbi Wabote authorised a comprehensive forensic audit that uncovered systemic non-compliance with a legal requirement in the oil and gas sector.
The investigation, which covered years 2010 through 2017, found that many companies were unaware of their obligations, others had failed to implement proper systems, and some deliberately ignored the requirement set out in Section 104 of the Nigerian Oil and Gas Industry Content Development Act. The law mandates that one percent of every contract value in the upstream oil and gas sector be deducted and remitted to the Nigerian Content Development Fund.
Wabote engaged 20 external forensic audit firms with specialized expertise in financial investigations to carry out the audit. The audit process demonstrated NCDMB's ability to manage large-scale, multi-year investigations while maintaining normal operations.
The first phase of the investigation revealed non-compliance happening in the shadows, particularly in sub-contracts and ancillary transactions that rarely attracted regulatory attention. As a result, companies began incorporating clearer compliance procedures in contract structuring.
Sub-contracting arrangements started including explicit remittance responsibilities, and the problem was no longer limited to the initial contracts. The forensic audit created a powerful deterrent effect across Nigeria's oil sector.
Early results from phase two, covering 2018 to 2023, added approximately $15 million to the total recovery, bringing the combined figure to over $185 million. As of the first quarter of 2023, the board had recovered over $170 million from defaulting companies.
The audit established clear precedents for enforcement of Section 104 requirements, and the enforcement success strengthened legal precedent for future compliance efforts. The scope of potential non-compliance was staggering, involving thousands of contracts annually.
The successful forensic audit reflected broader institutional development at NCDMB under Wabote's leadership. Phase two of the forensic audit, launched in December 2022, will continue to uncover and address non-compliance in the oil and gas sector.
