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Constructing Corruption Identifying the Enablers Helping Build Violent Kleptocracies



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Constructing Corruption
Identifying the Enablers Helping Build Violent Kleptocracies By Oliver Windridge
For many years, the focus of anti-corruption efforts has been on kleptocratic leaders, their inner circles, and the finely honed craft of state theft. While these targets must continue to be investigated, it is clear that no kleptocratic regime works alone. In order to identify, secure, and move stolen assets and funds into the international financial system, klep- tocratic leaders and their inner circles require a cast of enablers willing to lend their expertise to state theft.
The release of damaging data through projects such as the Pandora Papers and the Credit Suisse leak lays bare just how immersed in the movement of corrupt funds enablers and the structures they maintain are. Such leaks illuminate the need to focus much more intentionally on these enablers. This realization has occurred at multiple levels, with the Biden administration recognizing the need to address deficiencies in this area in the first-ever United States Strategy on Countering Corruption; the introduction in Congress of the ENABLERS Act,1 which is aimed at making it harder for illicit finance to be housed in the US by requiring certain professional gatekeepers to the US financial system to put in place anti-money laundering (AML) procedures; and the issuance by the US Department of the Treasury of an advanced notice of proposed rulemaking to enhance the AML reporting requirements related to real estate transactions.2 In addition, the European Parliament has called for focus on the role played by Europe-based enablers in corruption,3 and civil society has published several recent reports and books looking at the role of enablers.4, 5
The Sentry’s investigations have exposed numerous enablers operating in East and Central Africa, and, in the process, commonalities and characteristics have emerged that are likely applicable to other kleptocratic regimes. These traits include the ability to target countries with vast unexploited wealth, weak government structures, underlying corrupt prac- tices, and conflict. Enablers often bring unscrupulous practices aimed at the enrichment of leadership and themselves, with little to no regard for the people.
This report looks beyond borders and reviews how enablers—including banks, financial institutions, and professionals, as well as less recognized international operators and insiders—help operate a “successful” kleptocratic regime. It highlights the importance of these enablers and their links to illicit financial flows and associated conflict and human rights abuses, and it provides a checklist for governments and financial institutions to apply when using financial tools of pressure.6
The Bank
Kleptocracies need to move funds, so it is essential to have enablers within—or with access to—those institutions that hold, transfer, and invest money. The most obvious ways of moving the proceeds of a violent kleptocracy are for a finan- cial institution to knowingly accept stolen funds, willingly turn a blind eye, or have insufficient protocols to identify them. While the first two categories require a level of criminal intent, often the lack of sufficient protocols in the third category is enough for enablers to prey on.
Insufficient protocols can include the failure to properly conduct know your customer (KYC) checks, which can lead to an absence of information on who is operating accounts and where their funds are sourced. They can also include the ab- sence of proper training in how to identify potential suspicious customers or transactions, as well as the failure to provide ongoing resources dedicated to maintaining the highest banking standards. These weaknesses can be exacerbated by working environments that fail to encourage staff to take a risk-based approach to corruption and associated illicit finan- cial flows—for instance by flagging or declining suspicious transactions—or that deliberately block staff from effectively reporting suspicious business or transactions.
The lack of adequate procedures is particularly advantageous when the financial institution in question is part of a cor- respondent banking relationship with other international financial institutions. In these instances, there is often no need for an illicit actor or their enablers to engage directly with larger banks in order to obtain US dollar accounts. Instead, banks and financial institutions with correspondent banking relationships may allow access to US dollar accounts and the international market without requiring customers to engage directly with US-based banks and their potentially height- ened security checks or enhanced due diligence. Such relationships allow funds to flow more easily into the international financial system, where it can be very difficult—if not impossible—to identify onward money flows.
The fight against global kleptocracy is only ever as strong as its weakest link, particularly with regard to financial institu- tions, as global markets connect banks and institutions across the world. Red flags for susceptible financial institutions include:
─ Insufficient or non-existent procedures for identifying customers or the sources of funds
─ Operations in countries where banking sector regulators have little or insufficient oversight, either through lack of capacity or willful obstruction
─ Close, opaque relationships between senior banking officials and leaders and their inner circles, including ownership or control of banks or other financial institutions by politically exposed persons (PEPs)

Case 1: Afriland First Bank7, 8
Countries: Democratic Republic of Congo, North Korea
In 2018, two North Korean businessmen formed a construction company in the Democratic Republic of Congo (DRC). The company erected statues and undertook construction projects in apparent violation of sanctions adopted by the Eu- ropean Union, the United Nations, and the US. Despite strict international prohibitions, these individuals obtained a US dollar-denominated account at the DRC affiliate of Afriland First Bank, an institution headquartered in Cameroon, likely due to weak internal procedures and a lack of robust checks.9 This account enabled the North Korea-controlled company to move funds globally via the London-headquartered BMCE Bank International’s Paris branch, which was the banking partner designated to process US dollar and euro transactions for Congo Aconde’s account in the DRC.10
Case 2: Kwanza Capital and the Congolese Banking Sector11
Countries: Democratic Republic of Congo

Between 2016 and 2018, specialized financial institution Kwanza Capital, a vehicle that records indicate former DRC President Joseph Kabila’s inner circle used to hold embezzled funds and the proceeds of corruption, made significant attempts to control around 28% of the country’s roughly $5 billion banking sector.12 Part of the prize was seemingly the established correspondent banking relationships Congolese banks enjoyed with US and European banks, which would provide Kabila and his network with direct access to the international financial market through which they could launder corrupt wealth.13 While Kwanza Capital was ultimately unsuccessful, its attempt demonstrates the crucial role of financial institutions, even when they seem geographically removed from the financial centers of power.14, 15
Case 3: BGFIBank DRC16, 17
Countries: Democratic Republic of Congo, China
BGFIBank Group has been accused of involvement in serious corruption across various sectors in the DRC through its subsidiary BGFIBank DRC, which sat at the center of a complex web of transactions and was used to redistribute funds originally designated for projects to benefit the Congolese people.18 Managed by Kabila’s brother Francis Selemani,19 BGFIBank DRC was the main financial institution used by Chinese businessman “David” Du Wei, a key international enabler discussed in this report.20 Du moved $65 million through accounts for his shell company Congo Construction Company (CCC) at BGFIBank DRC, transferring $31 million to Kabila-linked entities and $8 million to commercial part- ners of the Kabila family.21 Transfers to CCC were flagged by compliance officers at BGFIBank DRC’s correspondent banks, and in response, BGFIBank DRC provided documents that bore clear indications of fraud and falsification.22 In 2018, the chief internal auditor at BGFIBank DRC conducted an investigation into Selemani and other board members, uncovering evidence of fraud and giving the bank an “unacceptable” overall grade. It is unclear whether any actions were taken by BGFIBank Group in response to the audit.23

Case 4: Kenya Commercial Bank24

Countries: Kenya, South Sudan
Between 2012 and 2016, $3.03 million moved through the personal account at Kenya Commercial Bank (KCB) of UN-sanctioned South Sudanese General Reuben Riak.25, 26 Recorded transactions include cash deposits and payments from international construction companies operating in South Sudan totaling more than $700,000. Additionally, $1.16 million in cash was withdrawn over the same period.27 Between February and December 2014, South Sudanese General Gabriel Jok Riak, also sanctioned by the UN,28 received large financial transfers to his personal bank account at KCB totaling at least $367,000—more than 10 times his estimated annual government salary.29 Following these allegations, KCB has reportedly made efforts to eliminate the flow and receipt of conflict-related funds.30

The International
Outside international assistance is often necessary to keep a successful kleptocracy running and may be provided by individuals, not necessarily from established professions, who work on deals in multiple unconnected countries. These individuals may be drawn in by a potent mix of underexploited natural resources and the weak—or, in some cases, absent—application of the rule of law. Whether by sourcing gold in the DRC, exploiting natural resources in the Central African Republic (CAR), or making suspect deals in South Sudan, international businesspeople working closely with political elites can be a necessary part of building a violent kleptocracy, bringing international networks and connections and the promise of access to international financial markets. Red flags for these individuals include:
─ A close personal relationship with key leadership
─ A track record of deals in seemingly unconnected countries where the only commonality is weak government and a lack of rule of law
─ An ability to access international financial systems through multiple foreign companies, trusts, or corporate vehicles, often in high-risk jurisdictions
Case 1: “David” Du Wei
Countries: Democratic Republic of Congo, China
“David” Du Wei, a Chinese businessman and intermediary to several large Chinese corporations, positioned himself as an expert in safeguarding the African assets of Beijing’s state-owned enterprises, particularly by warding off political risk through “countermeasures.”31 Exceptionally well connected and with a direct line to Kabila’s family, Du’s business often favored less-than-legitimate means to broker large-scale natural resource-linked infrastructure deals. Records contained in the Congo Hold-up leak, described as “the biggest leak of sensitive data in African history,”32 show that Du moved millions of dollars through the shell company CCC using false justifications and sometimes even apparently forged documents.33 The Sentry reported that, at particularly vital moments, “Du drove tens of millions of dollars through the international banking system into the hands of former DRC President Joseph Kabila associates—behavior that bore the hallmarks of bank fraud, money laundering, and bribery.”34
Case 2: Dan Gertler
Countries: Democratic Republic of Congo
Israeli businessman Dan Gertler “amassed his fortune through hundreds of millions of dollars’ worth of opaque and cor- rupt mining and oil deals in the Democratic Republic of the Congo.”35 Using his close friendship with Kabila, Gertler “act- ed as a middleman for mining asset sales in the DRC,” with some multinational companies even having “to go through

Gertler to do business with the Congolese state.”36 According to the US Treasury Department, “between 2010 and 2012 alone, the DRC reportedly lost over $1.36 billion in revenues from the underpricing of mining assets that were sold to off- shore companies linked to Gertler.”37 In 2017, Gertler and several entities linked to him were sanctioned by the US, with further sanctions applied on Gertler’s network in 2018 and 2021.38, 39 In January 2021, a license was granted that allowed Gertler to resume transactions with US persons and unblocked his frozen property.40 The license was subsequently revoked by the Biden administration in March 2021, citing its issuance as “inconsistent with America’s strong foreign policy interests in combatting corruption around the world,”41 and Gertler remains under US sanctions. In February 2022, reports emerged that the Congolese government had entered into an agreement with Gertler for the recovery of oil and mining assets; however, the details of this agreement remain confidential.42
Case 3: Alain Goetz
Countries: Democratic Republic of Congo, Rwanda, Uganda
The corporate network controlled by US-sanctioned Belgian tycoon Alain Goetz has been involved in refining conflict gold sourced from mines controlled by armed groups in eastern DRC at the African Gold Refinery in Uganda and then exporting it through a series of companies to the US and Europe, ticking all the boxes of legitimacy, access to financial markets, and international connections that the international enabler can bring.43, 44 Gold is a key driver of conflict in east- ern DRC, and the Goetz network was implicated in the “illicit movement of gold valued at hundreds of millions of dollars per year” from the country.45 In 2020, Goetz and his brother Sylvain were convicted in Antwerp, Belgium, of corruption-re- lated offenses, and investigators are looking into allegations linked to Uganda.46
Case 4: Ali Khalil Merhi
Countries: South Sudan
Lebanese businessman Ali Khalil Merhi transitioned from wanted fugitive in Paraguay to Ali Khalil Myree, a well-connect- ed businessman in South Sudan, operating numerous companies and rubbing shoulders with the political elite.47 With a business empire spanning multiple countries, Myree incorporated several companies in South Sudan, sometimes with the relatives of senior political and government leaders, including the daughter of current President Salva Kiir.48 Myree’s companies secured lucrative government contracts and licenses for natural resources.49 These companies were also used to send cash transactions to senior officials, including General Malek Reuben Riak, a since-sanctioned general in the South Sudanese army.50, 51, 52, 53 In July 2020, Myree formally became South Sudan’s honorary consul to Lebanon.54
Case 5: Aziz Nassour
Country: Central African Republic
Aziz Nassour, a Lebanese businessman with alleged links to terror financing and diamond trafficking in conflict zones, has become a power broker in CAR under current leader Faustin-Archange Touadéra.55, 56, 57, 58, 59, 60, 61, 62 Nassour has previously been linked to counterfeiting, money laundering, and major diamond trafficking in conflict zones in the DRC, Liberia, and Sierra Leone.63, 64, 65, 66, 67, 68 In CAR, Nassour has purportedly used this experience to assist Touadéra in concealing diamond, drug, and weapons trafficking, benefiting in turn by receiving public contracts to digitize govern- ment-issued documents.69

The Insider
The insider is an individual linked closely to the inner circle of a kleptocratic regime, often coming from the same coun- try or region as senior leaders. Insiders occupy different roles than international enablers. While they are sometimes described as advisors to leadership, they are often found at the very center of a regime, operating with complete trust and working not only on deals to enrich leaders but also often in direct partnership with them. Red flags for this type of enabler include:
─ A close personal relationship with key leadership
─ A vague role without an official title, neither within the civil service nor as an elected official
─ Receipt of government contracts or apparent profit sharing with government officials
Case 1: Kudakwashe Tagwirei
Country: Zimbabwe
Trusted insider Kudakwashe Tagwirei, a Zimbabwean businessman and presidential advisor, has accumulated both wealth and power.70, 71 The US Treasury Department imposed sanctions on Tagwirei and his company Sakunda Holdings in 2020, stating, “Tagwirei used a combination of opaque business dealings and his ongoing relationship with Presi- dent [Emmerson] Mnangagwa to grow his business empire dramatically and rake in millions of U.S. dollars.”72 Multiple times, large-scale government procurement decisions made under questionable circumstances have greatly benefited Tagwirei. For example, in 2016, Sakunda Holdings won a $630 million contract to build an emergency diesel generating plant. The Sentry reported that “a forensic audit report commissioned by the Auditor General found that the Office of the President had interfered with the procurement process in favor of Sakunda, a company that didn’t build diesel plants and hadn’t bid the first time around.”73, 74
Case 2: Al-Cardinal
Country: South Sudan
UK- and US-sanctioned Sudanese businessman Ashraf Seed Ahmed Hussein Ali,75, 76 commonly known as “Al-Cardinal,” was shown to be the trusted confidant of the South Sudanese political elite.77, 78 Neither an elected official nor a civil servant, Al-Cardinal was “used by a senior South Sudanese government official as an intermediary to deposit and hold a large amount of funds in a country outside of South Sudan.”79 At the same time, he acquired personal wealth in a series of questionable deals over at least a decade, including arranging government vehicle purchases at inflated costs and engaging in business ventures with high-ranking military officials, including the then-chief of staff of the South Sudanese army, General Paul Malong Awan.80

Case 3: Benjamin Bol Mel
Country: South Sudan
In South Sudan, businessman Benjamin Bol Mel occupied three roles that should have raised significant concerns about conflicts of interest: president of a construction company; chairman of South Sudan’s Chamber of Commerce, Industry, and Agriculture; and principal financial advisor and secretary to South Sudan’s president. Bol Mel’s company was awarded tens of millions of dollars in government road construction contracts, for which the government did not hold competitive tender processes.81, 82 These contracts not only enriched Bol Mel but also appear to be oil-backed, no-bid contracts, thereby violating South Sudan’s 2018 Public Procurement Act.83, 84 Bol Mel was designated for sanctions by the US in 2017, along with two of his companies.85
Case 4: Francis Selemani
Country: Democratic Republic of Congo
Francis Selemani is the brother of former DRC President Kabila and served as managing director of BGFIBank DRC.86, 87 Selemani and the Kabila family used a network of companies and the bank they controlled to misappropriate public funds, transferring millions abroad and purchasing millions of dollars in foreign real estate. Selemani personally man- aged the banking relationship with “David” Du Wei’s company CCC, a conduit for tens of millions of dollars from major Chinese construction contractors that wound up in accounts used by Kabila and his inner circle, including Selemani him- self.88 Between 2015 and 2018, more than $12 million was sent to Selemani’s own accounts and to companies he owned or controlled, according to BGFIBank DRC records reviewed by The Sentry.89 The Sentry reported that, at the same time that money was transiting accounts “held by Selemani and companies linked to him and his wife, Selemani purchased 17 properties for a total of $6.6 million in the affluent suburbs of Washington, DC, and Johannesburg, South Africa.”90

The Professional
Running a successful kleptocracy is complex, and expertise is often required. Professional service providers—for exam- ple, lawyers or accountants—can therefore play a key role in drafting contracts, complying with (or avoiding) regulations, and providing advice on jurisdictions, litigation, and other legal niceties. In addition to this practical work, professional service providers can also offer a veil of legitimacy on an otherwise questionable deal. For instance, mentioning that a certain law firm or accountant is engaged on a particular project can help assert the image of acceptability while also providing protection should the project take a turn.
Given the trusted role that professional industries such as law and accountancy play in the proper running of business and finance, influential authorities—whether national or state bar associations or accountancy authorities—often over- see their practice. These regulators often possess the ability to investigate conduct and levy fines or disciplinary action where appropriate. Here, the question is often whether a firm is willing to either turn a blind eye or simply not conduct due diligence beyond the absolute minimum required in order to engage in lucrative work. Red flags for this type of enabler include:
─ A track record of acting in countries and regions considered “difficult” or “challenging”
─ A record of regulatory investigations, fines, or convictions
─ High-profile relationships with leaders that may be publicly mentioned to augment credibility
Case 1: Law firm partner
Country: Democratic Republic of Congo
A partner at the French affiliate of a US-headquartered global law firm represented Kwanza Capital in its attempt to buy shares in a Congolese bank with valuable correspondent banking relations in the US and Europe.91, 92 The partner also reportedly acted as an advisor for the financing of a major hydroelectric project in the DRC and has advised the state-controlled mining company Gécamines on a number of high-profile deals.93
Case 2: Advisors to Kudakwashe Tagwirei (corporate structures)
Countries: Zimbabwe
The complex corporate web of Kudakwashe Tagwirei, a Zimbabwean businessman and presidential advisor, includes companies and corporate structures not only in Zimbabwe but also in Mauritius, South Africa, Switzerland, and the Cay- man Islands.94 Such a complex structure requires a team of advisors and lawyers to operate and finesse the system in


order to gain maximum financial benefit while staying entirely behind the scenes.95 Tagwirei’s team included corporate service providers in Mauritius,96, 97 South African law firms,98 and banks in Switzerland.99
Case 3: Real estate brokers
Countries: United States, South Africa, Democratic Republic of Congo, Zimbabwe
The role of professional enablers also extends to the acquisition of real estate.100 Real estate professionals can provide valuable financial intelligence on possible money laundering schemes, but, in the US for example, they’re subject to far fewer AML reporting requirements than financial institutions and, unlike banks, can choose whether to identify benefi- cial owners or report suspicious activity.101 The Financial Action Task Force and the Egmont Group have warned that loopholes in the real estate sector can provide an “unregulated backdoor” to the global financial system.102 Suspected stolen funds may be channeled via complex webs of companies and banks and ultimately used to buy property abroad, including in the US. For example, Selemani, described in this report, was able to purchase 17 homes across the US and South Africa using these methods, with seemingly no flags raised by real estate professionals working on the deals.103 Tagwirei also used corporate vehicles to finance the purchase of a home in the upscale neighborhood of Borrowdale, Harare, in Zimbabwe.104

Enablers are of critical importance to violent kleptocracies, whether by moving money, housing money, or creating struc- tures into which funds can be transferred. While the categories of enablers discussed should not be considered exhaus- tive, they do provide a starting point for the public and private sectors to play their part by identifying vulnerable countries or regions, flagging the presence of enablers, and increasing due diligence to ultimately change the cost-benefit analysis for enablers and the kleptocratic leaders they serve.
Significantly, kleptocratic leaders’ heavy reliance on enablers and their expertise creates vulnerability and opportunity to gain leverage in countries where leverage is often considered scarce. By targeting enablers through financial tools of pressure and other policy actions, there is an opportunity to effect real change on the ground by disincentivizing the benefits to possible enablers, thereby removing the crucial layer of assistance that kleptocracies rely on.
Success when targeting enablers can be profound. In the case of Gertler, the network approach of sanctioning him, his business associates, and related entities is often cited as a significant reason for then-President Kabila’s decision not to run for reelection in the DRC in 2018.105 With a greater focus on the enablers, violent kleptocracies lose an essential ally in the finely crafted state theft that has besieged many states for too long.
Private sector
─ Banks and other financial institutions should use the categories of enablers discussed to identify red flags and share typologies for the onboarding of new clients and the review of existing clients and their accounts, with a view toward enhancing due diligence checks.
─ Banks and other financial institutions should increase their engagement with government, regional, and other public institutions to best identify the categories of enablers mentioned in this report with a view toward sharing intelligence, thereby ensuring that enablers are not able to move looted funds and profits.
─ Banks and other financial institutions should adopt policies and processes that allow for clear lines of communication with civil society and journalists in order to act upon information relating to enablers.
─ Professionals working in the legal, accountancy, and real estate sectors should similarly use the catego- ries discussed to identify red flags both in client onboarding and in ongoing relationships. They should report suspicious activities to local financial intelligence units.
Public sector
─ Government and regional bodies should prioritize and, when possible, fast-track the passage and adop- tion of legislation and regulatory action that targets the role of enablers.
─ Government and regional bodies should use the categories of enablers mentioned in this report as a framework to identify countries that may be particularly susceptible to enablers, with a view toward the im- plementation of further pressure. For example, when one or more of the categories of enablers is known to operate in a country, this should trigger the deployment of financial tools of pressure.
─ Governments and regional bodies should issue alerts or advisories focused on enablers that include real-world examples of the dangers of working and engaging with enablers in high-risk jurisdictions.

─ The US, UK, EU, Canada, Australia, and other jurisdictions should prioritize applying targeted network sanctions via Global Magnitsky-style or other appropriate sanctions regimes against enablers, including those cited in the case studies above, who continue to assist kleptocratic leaders. Sanctions against en- ablers tend to be particularly effective given their access to the global financial system.
─ The US, UK, EU, and other jurisdictions should increase the issuance of advisories and alerts focused on violent kleptocratic regimes and the enablers that benefit from them. Consideration should be given to enabler-specific advisories and alerts.
─ Law enforcement agencies in the US, UK, EU, and other jurisdictions should prioritize the rising influence of enablers and their links to increased illicit financial flows and kleptocracy. Focused initiatives should be launched to investigate enablers’ modes of operations, and suitable law enforcement tools should be engaged to disrupt, investigate, and prosecute, when possible.
─ Regulated professions—for example, lawyers and accountants—should, through appropriate bar and accountancy associations, launch kleptocracy-focused initiatives to work with and train members on the dangers posed by kleptocracies, the commonalities across countries, and the links between corruption, conflict, and human rights violations.
─ Countries susceptible to the presence and influence of enablers should conduct transparent and open reviews of consultants, businesspersons, and advisors working at high positions within government to best determine and remove unwanted influences.

1 Establishing New Authorities for Businesses Laundering and Enabling Risks to Security (ENABLERS) Act, [H.R. 5525, 117th Congress, 2021, available at:
2 Financial Crimes Enforcement Network, “Anti-Money Laundering Regulations for Real Estate Transactions,” December 8, 2021, available at:
3 European Parliament, “Corruption and Human Rights: European Parliament recommendation of 17 February 2022 to the Council and the Vice President of the Commission / High Representative of the Union for Foreign Affairs and Security Policy concerning corruption and human rights, (2021/2066(INI)),” February 17, 2022, available at: 0042_EN.pdf
4 Frank Vogl, The Enablers: How the West Supports Kleptocrats and Corruption—Endangering Our Democracy, London: Rowman & Littlefield Publishing Group, 2021.
5 Transparency International UK, “At Your Service: Investigating How UK Businesses and Institutions Help Corrupt Individuals and Regimes Launder Their Money and Reputations,” October 2019, available at: service
6 The red flags should serve as guidance to potential questionable action, particularly when there are multiple flagged activities. The existence of activity that fits within a red flag category does not in and of itself indicate wrongdoing.
7 The Sentry, “Overt Affairs: How North Korean Businessmen Busted Sanctions in the Democratic Republic of Congo,” August 2020, available at:
8 The Sentry, “Artful Dodgers: New Findings on North Korean Sanctions-Busting in the Democratic Republic of Congo,” January 2021, available at:
9 See note 7, pp. 1, 6, 8, 10.
10 See note 7, pp. 1, 6, 8, 10.
11 The Sentry, “Covert Capital: The Kabila Family’s Secret Investment Bank,” May 2019, p. 7, available at: covert-capital
12 Ibid., pp. 2, 7.
13 Ibid., pp. 2, 7, 10.
14 Ibid., p. 10.
15 The Sentry, “The Backchannel: State Capture and Bribery in Congo’s Deal of the Century,” November 2021, p. 11, available at: https://
16 The Sentry, “Embezzled Empire: How Kabila’s Brother Stashed Millions in Overseas Properties,” November 2021, available at: https://
17 See note 15, p. 11.
18 See note 15, pp. 15-16.
19 See note 16.
20 See note 15, p. 11.
21 See note 15, pp. 11, 17-18.
22 See note 15, pp. 20-21.
23 See note 15, p. 32.

24 The Sentry, “War Crimes Shouldn’t Pay: Stopping the Looting and Destruction in South Sudan,” September 2016, available at: https://
25 United Nations Security Council, “Malek Reuben Riak Rengu,” July 13, 2018, available at: malek-reuben-riak-rengu
26 See note 24, p. 44.
27 See note 24, p. 44.
28 United Nations Security Council, “Gabriel Jok Riak,” July 1, 2015, available at: materials/summaries/individual/gabriel-jok-riak
29 See note 24, p. 41.
30 Private communication with The Sentry.
31 Du Wei, “洲面临的政治风险及应对策略” (Political Risks Faced by Chinese Enterprises Investing in Africa and Countermeasures), 中国企业投资非, 现代经济探讨 (Modern Economic Research), Issue 3, 2016.
32 William Clowes and Michael Kavanagh, “Document Leak Shows Kabila Family, Associates Looted DRC Funds,” Aljazeera, November 19, 2021, available at:
33 See note 15.
34 See note 15.
35 United States Department of the Treasury, “United States Sanctions Human Rights Abusers and Corrupt Actors Across the Globe,” Press Release, December 21, 2017, available at:
36 Ibid.
37 Ibid.
38 United States Department of the Treasury, “Treasury Sanctions Fourteen Entities Affiliated With Corrupt Businessman Dan Gertler Under Global Magnitsky,” Press Release, June 15, 2018, available at:
39 United States Department of the Treasury, “Treasury Targets Corruption Linked to Dan Gertler in the Democratic Republic of Congo,” Press Release, December 6, 2021, available at:
40 Eric Lipton, “Trump Administration Quietly Eased Sanctions on Israeli Billionaire,” New York Times, January 24, 2021, available at:

41 United States Department of State, “Revocation of License Granted for Dan Gertler,” Press Release, March 8, 2021, available at: https://
42 William Clowes and Michael Kavanagh, “Congo Seals Deal With Israeli Billionaire to Recover Assets,” Bloomberg, February 26, 2022, available at:
43 United States Department of the Treasury, “Treasury Sanctions Alain Goetz and a Network of Companies Involved in the Illicit Gold Trade,” Press Release, March 17, 2022, available at:
44 The Sentry, “The Golden Laundromat: The Conflict Gold Trade From Eastern Congo to the United States and Europe,” October 2018, available at:
45 See note 43.
46 Reuters, “Court Convicts Belgian Gold Refinery Tony Goetz of Money Laundering,” February 5, 2020, available at: https://www.reuters.
47 The Sentry, “The Metamorphosis of Ali Khalil Merhi: How a One-Time Fugitive Found Fortune in South Sudan,” April 2021, available at:

The Metamorphosis of Ali Khalil Merhi

48 South Sudan Ministry of Justice, “Memorandum & Articles of Association of Rocky Mining Industries Limited,” September 10, 2009.
49 See note 47, p. 10.
50 Banks records on file with The Sentry
51 United States Department of the Treasury, “Treasury Targets South Sudanese Government Officials and Related Companies for Continued Destabilization,” Press Release, September 6, 2017, available at: Pages/sm0152.aspx
52 See note 25.
53 Council of the European Union, “Council Implementing Regulation (EU) 2018/1115,” Official Journal of the European Union, August 10,
2018, available at:
54 See note 47.
55 Douglas Farah, “Al-Qaeda and the Gemstone Trade,” in Countering the Financing of Terrorism, ed. by Thomas J. Biersteker, Sue E. Eckert, New York: Routledge, 2008, pp. 193-206.
56 Dan Levy, “Hezbollah’s Fundraising Activity in Africa: Focus on the Democratic Republic of Congo,” International Institute for Counter- Terrorism, March 2013, available at:
57 Douglas Farah, “Hezbollah’s External Support Network in West Africa and Latin America,” International Assessment and Strategy Center, August 4, 2006.
58 Carl A. Wege, “Hizballah in Africa,” Perspectives on Terrorism 6.3, 2012, pp. 45-56, available at: Hizballah_In_Africa
59 Bartlett v. Société Générale de Banque au Liban SAL, 1:19-cv-00007, US District Court Eastern District of New York, “Amended Complaint: Jury Trial Demanded,” August 2, 2019, pp. 182-186.
60 United Nations Security Council, “Final Report of the Panel of Experts on the Illegal Exploitation of Natural Resources and Other Forms of Wealth of the Democratic Republic of the Congo,” S/2002/1146, October 16, 2002, p. 9, available at: en/S/2002/1146
61 Global Witness, “For a Few Dollars More: War and Peace in Sierra Leone,” April 17, 2003, p. 74, available at: docs/200710111245014847.pdf
62 Nathalia Dukhan, “State of Prey: Proxies, Predators, and Profiteers in the Central African Republic,” The Sentry, October 2020, p. 5, available at:
63 See note 56.
64 See note 57.
65 Carl A. Wege, “Hizballah in Africa,” Perspectives on Terrorism, 6.3, 2012, pp. 45-56, available at: Hizballah_In_Africa
66 See note 59.
67 See note 60.
68 See note 61.
69 See note 62.
70 The Sentry, “Shadows and Shell Games: Uncovering an Offshore Business Empire in Zimbabwe,” July 2021, available at: https://

71 The Sentry, “Legal Tender?: The Role of Sakunda and the Reserve Bank of Zimbabwe in Command Agriculture,” March 2022, available at:
72 United States Department of the Treasury, “Treasury Sanctions Corrupt Zimbabwean Businessman,” Press Release, August 5, 2020, available at:
73 See note 70.
74 PricewaterhouseCoopers, “ZESA Holdings: Final Forensic Investigation Report,” January 2019, on file with The Sentry.
75 United States Department of the Treasury, “Treasury Sanctions Businessmen in South Sudan for Corrupt Dealings With Government Officials and Sanctions Evasion,” Press Release, October 19, 2019, available at:
76 United Kingdom Foreign, Commonwealth, and Development Office, “UK Sanctions 22 Individuals Involved in Serious International Corruption,” Press Release, April 26, 2021, available at: serious-international-corruption
77 The Sentry, “The Taking of South Sudan: The Tycoons, Brokers, and Multinational Corporations Complicit in Hijacking the World’s Newest State,” September 2019, available at:
78 The Sentry, “Al Cardinal: South Sudan’s Original Oligarch,” October 2019, available at: sudan-oligarch/
79 See note 75.
80 See note 78, pp. 6, 10, 11.
81 See note 24.
82 The Sentry, “Alert: Sanctioned South Sudanese Businessmen Are Skirting US Sanctions,” October 2021, available at: https://thesentry. org/reports/south-sudanese-skirting-sanctions/
83 Hot in Juba, “Juba-Bor Highway: South Sudan’s Newest Road to Prosperity,” March 18, 2021, available at: bor-highway-south-sudans-newest-road-to-prosperity/
84 South Sudan, Public Procurement and Disposal Act, 2018.
85 See note 35.
86 See note 16.
87 See note 15, p. 11.
88 See note 15.
89 See note 16.
90 Ibid.
91 See note 11, pp. 12-13.
92 During the relevant period, Pascal Agboyibor was a partner at the Paris-based affiliate of US-headquartered Orrick, Herrington & Sutcliffe. Orrick fired Agboyibor in March 2019 following an investigation into allegations of inappropriate conduct and lapses in judgment. See:
Meghan Tribe, “Orrick Ousts Practice Leader to ‘Uphold Our Values and Culture’,” The American Lawyer, March 11, 2019, available at:
93 See note 11, p. 12.
94 See note 70, p. 3.

95 Tagwirei’s operations appear to employ a complex web of corporate structures. See note 70, p. 4.
96 Mauritius Company Register, Sotic International, C135746, record accurate as of June 4, 2021, available at: https://companies.govmu.
97 Mauritius Company Register, Quorus Management Services, C134978, available at:
98 Email sent on July 9, 2019, on file with The Sentry.
99 See note 70, p. 2.
100 The Sentry, “Looted Funds Used to Buy African Real Estate,” July 2020, available at:
101 See note 16, p. 16.
102 Financial Action Task Force and the Egmont Group, “Concealment of Beneficial Ownership,” July 2018, available at: https://www.fatf-
103 See note 16.
104 See note 70, p. 26.
105 Brad Brooks-Rubin, “Statement of Brad Brooks-Rubin, General Counsel, The Sentry, for the House Foreign Affairs Committee Tom Lantos Human Rights Commission Hearing on The Global Magnitsky Human Rights Accountability Act: Taking Stock,” March 24, 2021, available at: BBrooksRubin_final.pdf

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MoH deploys Ebola response team at southern borders



Team of health workers deployed at the border towns of Nimule. (Photo: Mabior Kiir).
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The national Ministry of Health has deployed a technical team of 15 health workers to areas bordering Uganda and Democratic Republic of Congo to monitor and screen travelers amid the new Ebola outbreak in Uganda.

Dr. Victoria Anib Majur, the ministry’s undersecretary said a five-member team is heading to Yambio of Western Equatoria State.

The health personnel include public health officers, lab technicians, case management surveillance officers and infection and preventing control officers.

“The ministry of health is very determined to make sure that there are precautionary measures in place to make sure Ebola doesn’t enter to the country,” said Anib.

“On top of it, we want to send a message to people to adhere with measure by washing hand If any person develops symptoms of fever or suspects any symptoms, he should report it to the nearest health facility.”

Dr. Victoria who spoke to reporters upon the departure of the doctors from Juba Airport, revealed that the ministry has also dispatched similar five-member team to Yei and another to Nimule.

Team of specialists deployed in Yei to conduct surveillance on Ebola Virus Disease. (Mabior Kiir).
She said the health professionals will launch precautionary measures center to monitor suspect Ebola cases.

On Tuesday, health authorities in Uganda declared an outbreak of Ebola after a case of the rare Sudan strain was confirmed in Mubende district in the central part of the country.

So far, 31 confirmed and suspected cases, and 19 deaths have been reported by Uganda’s health ministryOn Friday, President Kiir’s cabinet meeting allocated 500,000 US dollars as funds for mitigation and prevention of Ebola following reported outbreak of the virus in Uganda early this week.

Via Eyeradio



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S. Sudan, Ethiopia agree on joint project to link with Djibouti port



South Sudan Vice-President Taban Geng Gai talks with Ethiopian Defence Minister, Abraham Belay after his arrival in Addis Ababa on September 21, 2022
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By Tesfa-Alem Tekle

September 23, 2022 (NAIROBI) – Ethiopia and South Sudan have agreed to carry out a series of joint infrastructure projects that would eventually enable the latter to link with the port of Djibouti.

The agreement was reached on Tuesday after a high-level South Sudan delegation led by Vice-President, Taban Geng Gai, met with a group of Ethiopian Ministers led by Finance Minister, Ahmed Shide.
Earlier, the two sides discussed ways how to enhance joint infrastructure connectivity projects.

In this regard, both sides agreed on ways to enhance their previously designed plans in the areas of road infrastructure, energy, telecommunications, water transportation, and other vital economic sectors with a view to creating integration for mutual benefits.

Per the newly reached agreement, one of the key projects being prioritized was to undertake road projects with a view to boosting connectivity between the two landlocked countries.

After the discussions, Ethiopia’s Finance Minister, Ahmed Shide, confirmed that the two sides have concluded a very important agreement in terms of advancing two road projects.

“We comprehensively agreed to work on joint infrastructural connectivity that will overcome geographical barriers in terms of trade and logistics flows between our two countries and people-to-people relations.”

Cut reliance on Kenya’s port

The fresh agreement with Ethiopia comes only a few days after South Sudan announced buying three acres of land at the port of Djibouti for the construction of a facility to handle its import and export of goods as the landlocked country eyes an alternative route to cut high dependency on Kenya’s Mombasa port.

“We have only been using Port Sudan and Mombasa but recently, we have decided to go to Djibouti and as I am speaking to you, we have landed in Djibouti,” South Sudan Minister for Petroleum Puot Kang Chol is quoted as saying by local media.
The minister said the land was procured by the Ministry of Petroleum for the purpose of exporting the country’s crude oil as well as using it on imported goods.

If effected, the move will hit the port of Mombasa given that Juba is one of Kenya’s largest clients importing nearly all of its cargo through the Kenyan port.
Rising costs Khartoum charges Juba for pipelines have also pushed South Sudan to eye alternative routes to export its crude oil to the international market.

Port of Djibouti

The road projects will be given top priority to open up transportation so that connectivity of South Sudan will be enhanced via Ethiopia through the Djibouti corridor, the Ethiopian minister added.
“These projects will be financed jointly and we have agreed to finalize the feasibility and preparations in terms of selecting a contractor so that the joint financing mechanism will be worked upon,” Shide said.
The South Sudanese delegation, on its part, vowed to cooperate and work for the immediate implementation of the joint projects.
“The agreed projects will be operationalized and put into consideration as soon as all the technical aspects are addressed,” said Michael Makuei Lueth, South Sudan’s Information minister said on behalf of the delegation.
Lueth said that it is worth mentioning that South Sudan, as a landlocked country, will benefit from the port of Djibouti using Ethiopia as a transport hub.
“Trade can be facilitated by Ethiopia through the Djibouti corridor,” he said adding “We expect Ethiopia to support us so that we can grow and be as strong as Ethiopia is today.” the South Sudanese minister added.
In transport connectivity, river, fibre optics and transmission line connectivity has been agreed upon and the preparation to realize the agreement will commence right after this meeting, Ethiopian officials said.
“As soon as the preparations are completed we will work together for resource mobilization and reaching out to development financial institutions as part of the Horn of Africa initiative” Shide added.
Aviation Sector
The two sides have also agreed to work on the aviation sector.
“Ethiopia has massive experience in airport construction. With this capacity, we have also agreed to share our experience and work on a joint mechanism on aviation connectivity and development with the republic of South Sudan.” the Ethiopian Finance Minister told journalists.
Peace Process
Ethiopia will continue to work and support the peace process in South Sudan, the minister said.
He noted that ensuring regional peace and stability are crucial for the two countries’ joint infrastructural development.
“We have a very comprehensive political commitment and will to advance the cooperation between the two countries,” Shide added.

The South Sudanese high-level delegation arrived in Addis Ababa on Wednesday for a three-day official working visit.
Upon arrival at Addis Ababa Bole International Airport, the South Sudanese delegation was warmly received by Ethiopian Defense Minister Abraham Belay and Director General of African Affairs of the Ministry of Foreign Affairs, Fisseha Shawul, among other senior government officials.

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Russian men flee abroad, fearing call-up to fight in Ukraine



Cars queue to cross the border from Russia to Finland at the Vaalimaa border check point in Virolahti, Finland, Friday Sept. 23, 2022. (Sasu Makinen/Lehtikuva via AP)
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Military-aged men fled Russia on Friday, filling planes and causing traffic jams at border crossings to avoid being rounded up to fight in Ukraine following the Kremlin’s partial military mobilization.

Queues stretching for 10 kilometers (6 miles) formed on a road leading to the southern border with Georgia, according to Yandex Maps, a Russian online map service.

The lines of cars were so long at the border with Kazakhstan that some people abandoned their vehicles and proceeded on foot — just as some Ukrainians did after Russia invaded their country on Feb. 24.

Meanwhile, dozens of flights out of Russia — with tickets sold at sky-high prices — carried men to international destinations such as Turkey, Armenia, Azerbaijan and Serbia, where Russians don’t need visas.

Among those who reached Turkey was a 41-year-old who landed in Istanbul with a suitcase and a backpack and plans to start a new life in Israel.

“I’m against this war, and I’m not going to be a part of it. I’m not going to be a murderer. I’m not going to kill people,” said the man, who identified himself only as Yevgeny to avoid potential retribution against his family left behind in Russia.

He referred to Russian President Vladimir Putin as a “war criminal.”

Yevgeny decided to flee after Putin announced a partial military call-up on Wednesday. The total number of reservists involved could be as high as 300,000.

Some Russian men also fled to neighboring Belarus, Russia’s close ally. But that carried risk.

The Nasha Niva newspaper, one of the oldest independent newspapers in Belarus, reported that Belarusian security services were ordered to track down Russians fleeing from the draft, find them in hotels and rented apartments and report them to Russian authorities.

Russian authorities tried to calm an anxious public about the draft.

Legislators introduced a bill Friday that would suspend or reduce loan payments for Russians called up for duty. News outlets emphasized that draftees would have the same status as professional soldiers and be paid the same, and that their civilian jobs would be held for them.

The Defense Ministry said that many people who work in high tech, communications or finance will be exempt from the call-up “to ensure the operations” of those fields, the Tass news agency reported.

White House press secretary Karine Jean-Pierre said the fact that Russians were leaving their country to avoid conscription shows that the war in Ukraine is “unpopular.”

“What Putin is doing — he is not coming from a place of strength,” Jean-Pierre told reporters. “He is coming from a place of weakness.”

The exodus unfolded as a Kremlin-orchestrated referendum got underway seeking to make occupied regions of Ukraine part of Russia. Kyiv and the West condemned it as a rigged election whose result was preordained by Moscow.

German government officials voiced a desire to help Russian men deserting military service, and they called for a European solution.

“Those who bravely stand up to Putin’s regime and thereby put themselves in great danger can apply for asylum in Germany on the grounds of political persecution,” the spokesman for German Interior Minister Nancy Faeser said.

The spokesman, Maximilian Kall, said deserters and those refusing to be drafted would receive refugee status in Germany if they are at risk of serious repression, though every case is examined individually.

But they would first have to make it to Germany, which has no land border with Russia, and like other European Union countries has become far more difficult for Russians to travel to.

The EU banned direct flights between its 27 member states and Russia after the attack on Ukraine, and recently agreed to limit issuing Schengen visas, which allow free movement across much of Europe.

Four out of five EU countries that border Russia — Latvia, Lithuania, Estonia and Poland — also recently decided to turn away Russian tourists.

Some European officials view fleeing Russians as potential security risks. They hope that by not opening their borders, it will increase pressure against Putin at home.

Latvian Foreign Minister Edgars Rinkevics said Thursday that many of those fleeing “were fine with killing Ukrainians. They did not protest then. It is not right to consider them as conscientious objectors.”

The one EU country that is still accepting Russians with Schengen visas is Finland, which has a 1,340-kilometer (830-mile) border with Russia.

Finland border guards said Friday that the number of people entering from Russia has climbed sharply, with media reporting a 107% increase compared with last week.

At Vaalimaa, one of the busiest crossings on the border, the line of waiting cars stretched for half a kilometer (a third of a mile), the Finnish Border Guard said.

Finnish broadcaster MTV carried interviews with Russian men who had just crossed into Finland at the Virolahti border crossing, including with a man named Yuri from Moscow who said that no “sane person” wants to go to war.

A Russian man from St. Petersburg, Andrei Balakirov, said he had been mentally prepared to leave Russia for half a year but put it off until the mobilization.

“I think it’s a really bad thing,” he said.

Valery, a man from Samara who was heading to Spain, agreed, calling the mobilization “a great tragedy.”

“It’s hard to describe what’s happening. I feel sorry for those who are forced to fight against their will. I’ve heard stories that people have been given these orders right in the streets — scary.”

Associated Press writers Frank Jordans in Berlin; Vanessa Gera in Warsaw, Poland; Jan M. Olsen in Copenhagen, Denmark; and Zeynep Bilginsoy in Istanbul contributed

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