02/13/2023
Mr. Atiku Abubakar
Using Offshore Corporations to bring Suspect Funds Into the United States.
From 2000 to 2008, Mr. Abubakar and Ms. Douglas used a network of accounts at U.S. financial institutions to bring over $40 million in suspect funds into the United States through multiple wire transfers supplied by offshore corporations located in Germany, Nigeria, Panama, the British Virgin Islands, and Switzerland. Nearly $25 million of those funds were wire transferred to more than 30 U.S. bank accounts opened by Ms. Douglas in her own name or in the name of the Jennifer Douglas Abubakar Family Trust, the Gede Foundation, or American University of Nigeria (AUN). She opened 18 of those accounts at Citibank, four at Chevy Chase Bank, six at Wachovia Bank, and three at Eagle Bank in Maryland, among other financial institutions. These four banks opened accounts for Ms. Douglas in most cases without being aware of her PEP status, at times relying on third party vendors using incomplete PEP databases or inadequate due diligence procedures. Over time, as each financial institution began to ask questions about the offshore corporations sending her funds and decided to close her accounts, She opened new accounts at other financial institutions, at times with the assistance of her U.S. lawyer, Edward Weidenfeld. Mr. Weidenfeld also accepted $3.4 million from offshore entities to pay the Abubakars’ legal bills and to fund an AUN account he opened at Suntrust Bank.
To analyze these accounts and transactions, the Subcommittee subpoenaed documents from a number of U.S. financial institutions. In most cases, the Subcommittee obtained bank documents covering a five-year period, from 2003 to 2008, although it obtained records for some earlier transactions as well. The Subcommittee did not attempt to trace all of the funds that went into or out of the accounts discussed below, nor did the Subcommittee examine every U.S. bank account opened by Ms. Douglas.1050 Instead, the Subcommittee focused its analysis on more than 30 accounts at five U.S. banks, as detailed below. The resulting analysis, while limited, shows how Mr. Abubakar and Ms. Douglas used offshore corporations to bring suspect funds into the United States and provides a conservative estimate of the amount of funds they actually introduced into the U.S. financial system to advance their interests.
(1) Citibank
From 2000 to 2007, Mr. Abubakar and Ms. Douglas opened 18 different accounts at Citibank in Potomac, Maryland, and brought nearly $20 million in suspect funds into the United States through the bank. These accounts consisted of five personal checking accounts, five savings accounts, two brokerage accounts, a home equity account, three accounts in the name of the Gede Foundation, and two additional personal checking accounts that were later expanded to reference both Ms. Douglas and AUN1051 Ms. Douglas also maintained four Citibank credit card accounts, three of which were for herself or her husband, and one of which was for the Gede Foundation. Over the nearly seven years these accounts were open, Ms. Douglas received multiple wire transfers totaling nearly $20 million from Siemens AG, LetsGo, Guernsey Trust Company, Sima Holding, China Castle Investments, and a few unidentified “clients.” For most of the seven years, Citibank was unaware of Ms. Douglas’ PEP status. In 2007, Citibank learned of Ms. Douglas’ PEP status, and began closing her accounts. By August 2007, all of her accounts were closed.1052 Initial Personal Accounts. Ms. Douglas opened her first two accounts with Citigroup on June 28, 2000, Checking Account No. 52096374 and Savings Account No. 52096382.1053 In the account opening documentation, Ms. Douglas identified herself as a U.S. citizen residing in Maryland, and supplied a Social Security number.1054 Citibank told the Subcommittee: “Nothing in Ms. Douglas’s initial application referenced or suggested that she had any connection to a foreign country or had a relationship with any foreign official. As a result, consistent with applicable law, Ms. Douglas was not considered to be a ‘politically exposed person’ or ‘PEP.’”1055 During her seven years with Citibank, this initial personal checking account was the one that received the bulk of the wire transfers from offshore corporations. Credit Card Accounts. Also in 2000, Ms. Douglas opened two personal CitiCard credit card accounts.1056 One credit card account, opened in June 2000, listed both her and Mr. Abubakar as authorized signatories and identified Mr. Abubakar as her husband, but did not identify him as a foreign official.1057 A second credit card account, opened in July 2000, also listed both her and Mr. Abubakar as authorized users, and was linked to a third credit card account held solely in Ms. Douglas’s name and for which Ms. Douglas was financially responsible.1058 The first credit card account was closed in March 2005. The second remained open until all the Douglas-related accounts were closed in 2007. Citibank told the Subcommittee that these credit card accounts were “the only Citigroup accounts identified to which Ms. Douglas’s husband had a direct connection.” 1059 Smith Barney Account. In June 2000 and January 2001, Ms. Douglas opened two brokerage accounts at Citibank’s affiliated broker-dealer, Smith Barney, Account No. 62H-07385 and Account No. 168-24253 (later renumbered 232-75087). 1060 The 2000 account was apparently never funded; the 2001 account was initially funded with a $500,000 cashiers check and engaged in a number of investments, but did not grow substantially larger and essentially went dormant in September 2006.1061Household Account. On August 8, 2001, Ms. Douglas opened a second personal checking account at Citibank, Checking Account No. 1209003581, which she deemed her “household account.”1062 At first, this checking account was linked to a high-yield savings account, IMMA No. 1208951651, which was initially funded with about $50,000, and a Certificate of Deposit No. 1679323897, which was initially funded with about$100,000.1063 By late 2001, however, all the funds in the savings account and certificate of deposit, which then totaled about $300,000, were withdrawn, and the household checking account continued on its own.1064 Over the six years this account was open, Ms. Douglas wrote numerous checks each month to pay a variety of household expenses, relying primarily on deposits from her other accounts for funds and, beginning in 2004, on loans from a home equity account described below. Altogether in a month, Ms. Douglas wrote checks that totaled anywhere from $10,000 to $90,000.1065 This account remained open until all the Douglas-related accounts were closed in 2007.1066 Home Equity Account. In April 2004, Ms. Douglas opened a home equity account at Citibank, Equity Source Account No. 7707591587.1067 She used this account to obtain a line of credit from Citibank, secured by her Maryland residence.1068 Her borrowings rose from about $159,000 in April 2004, to more than $350,000 during 2006 and 2007. Ms. Douglas told the Subcommittee she used these funds to support her “household and charitable activities.”1069 Ms. Douglas made regular payments on the home equity loan from April 2004 until the account was closed in August 2007,1070 paying a total of about $975,000.1071 Ms. Douglas told the Subcommittee: “All monies used to make the repayments on the line of credit, as well as all monies used to pay her expenses, and to fund her contributions to AUN, GEDE Foundation, and American politicians and political groups, came from her husband.” 1072Gede Foundation Accounts. In February and March 2002, Ms. Douglas opened three bank accounts in the name of the Gede Foundation Inc., Checking Account No. 17581251, Checking Account No. 17581366, and Savings Account No. 17581278.1073 Six months later, in September 2002, the Foundation also received a Citi Card credit card.1074 The account opening documentation shows that Gede Foundation provided a copy of its certificate of incorporation, a W-8 BEN form, and a copy of Ms. Douglas’ Maryland driver’s license.1075 Ms. Douglas provided “Abubakar” as her married name.1076 Citibank told the Subcommittee that it later revised its policy towards nonprofit organizations to require more enhanced due diligence for organizations providing services outside of the United States.1077 AUN Accounts. On April 4, 2005, Ms. Douglas opened Checking Account No. 1209739556, initially under her own name, but later, on an unspecified date, changed the account name to “Jennifer Douglas/ABTI American University.”1078 “ABTI American University” refers to AUN by an earlier name. Citibank told the Subcommittee that when Ms. Douglas added the university to the account, it should have been re-categorized as a business account, and that its continuing to operate as a personal account was “inconsistent with [Citibank] practice.”1079Seven months later, on January 13, 2006, Ms. Douglas opened another personal checking account that was also used by AUN, Checking Account No. 1208993341.1080 This account initially referred solely to Ms. Douglas who was the only signatory.1081 Later, on an unspecified
date, she changed the account name to: “Jennifer Douglas/ABTI-American University,” which again refers to AUN by an earlier name.1082 On February 27, 2006, Buford George Peterson, AUN’s Vice President of Finance and Administration,1083 was added as a co-signatory on the account.1084 In March 2006, the account name was changed a third time, to “Buford George Peterson/ABTI-American University.” 1085 Citibank told the Subcommittee that, like the first AUN account, “this account remained incorrectly categorized as a personal checking account following the title change.”1086 Additional Personal Accounts. In 2005, Ms. Douglas opened five more personal accounts, three of which were opened for only a short period. The short - term accounts were Checking Account No. 1209739572, which Ms. Douglas opened on April 5 and closed six months later on October 31, 2005; and a Checking Account No. 1209763257 and savings account bearing the same identifying number, both of which were opened on May 12 and closed four months later in September 2005. 1087 These accounts held minimal funds. The two longer term accounts were Checking Account No.1208896250 and Savings Account No. 1208896269, both of which were opened on September 22, 2005, and closed in 2007.1088 The checking account held limited funds which were transferred over the course of six months to the Gede Foundation; the account then went dormant until it was closed. The savings account was opened in the name of Ms. Douglas and one of her sons. At times it had minimal funds, but from mid-2006 to mid-2007, a few large transfers went into and out of the account each month, involving $100,000 to $200,000 at a time.1089 Safe Deposit Boxes. In addition to her financial accounts at Citibank, in December 2001 and January 2004, Ms. Douglas opened two safe deposit boxes at the bank. 1090Citibank Account Activity. From 2000 to 2007, Ms. Douglas accepted multiple large wire transfers into her accounts, totaling nearly $20 million, from offshore corporations, including Siemens AG, LetsGo Ltd. Inc., Guernsey Trust Company Nigeria Ltd., Sima Holding Ltd., and China Castle Investments Ltd. Most of the incoming funds were wire transferred into her initial personal checking account. In 2001 and 2002, for example, Ms. Douglas accepted wire transfers totaling nearly $2 million in suspect payments from Siemens AG. On January 30, 2003, she received a single wire transfer for $500,000 from China Castle Investments. Citibank told the Subcommittee that it had no further information about this company and deemed the transfer “questionable.”1091 From 2003 to 2007, another $17 million was wire transferred into her account by LetsGo Ltd., the Guernsey Trust Company, and Sima Holdings Ltd. Banking and credit card records show that, over the years, Ms. Douglas spent much of the money she received to support a lavish lifestyle as well as supporting the Gede Foundation and AUN. Siemens Payments. As explained earlier, in December 2008, the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC) filed criminal and civil pleadings alleging that Siemens AG had violated the U.S. Foreign Corrupt Practices Act (FCPA) and engaged in a wide-ranging pattern of paying bribes to foreign officials to advance its interests in several countries.1092 Siemens pled guilty to violating the books and recordkeeping requirements of the FCPA.1093 One provision in the SEC complaint alleged as follows: “[A]pproximately $2.8 million of the bribe payments was routed through a bank account in Potomac, Maryland, in the name of the wife of a former Nigerian Vice President. The Vice President’s wife, a dual U.S.-Nigerian citizen living in the United States, served as the representative of a business consultant that entered into fictitious business consultant agreements … but did no actual work for Siemens. The purpose of these payments was to bribe government officials. Other corrupt payments included the purchase of approximately $172,000 in watches for Nigerian officials designated in internal Siemens records as ‘P.’ and ‘V.P.,’ likely referring to the President and Vice President of Nigeria.”1094
The Subcommittee contacted Siemens about this allegation and also reviewed the Citibank account records. The Subcommittee identified Citibank records showing three wire transfers from Siemens AG, in 2001 and 2002, that together provided over $1.7 million to Ms. Douglas’ personal checking account at Citibank. This chart identifies those wire transfers.
Siemens Wire Transfers to Douglas Account at Citibank: 52096374
Using Citibank Wire Transfer Records
Wire Transfer
Directed To Date Amount Bates
J.E. Douglas 4/12/01 $450,703.79 B00007975, B00007962‐63,
B00007972
J.E. Douglas 10/01/01 $461,440.92 B00007979, B00007965‐66
J.E Douglas Steradian Co. UK 1/28/02 $860,500.00 B00007989, B00007968‐69,
B00007984
SOURCE: Citibank $1,772,644.71 ‐ TOTAL
Chart prepared by Subcommittee
When contacted by the Subcommittee, Siemens confirmed the information in the SEC complaint and said that the allegations in the complaint referred to payments made by the company to Ms. Douglas and to wire transfers sent to her checking account at Citibank in Potomac, Maryland.1095 Siemens told the Subcommittee that it had asked an outside law firm, Debevoise & Plimpton, to conduct an independent investigation into corruption allegations, which included a review of the payments made by Siemens related to Ms. Douglas. Siemens told the Subcommittee that the law firm confirmed not only that Siemens AG had sent wire transfers to Ms. Douglas’ account at Citibank, but also that it had sent a wire transfer to her at another bank and made nearly $2 million in additional cash payments to her over a three-year period, from 2000 to 2003. Siemens told the Subcommittee that those wire and cash payments had been made to “J.E. Douglas” or two companies she beneficially owned, “J.E Douglas Steradian Co. UK L,” or “Peniel Inc. UK Ltd.” The Subcommittee contacted the SEC for additional information related to its complaint, but the SEC declined to elaborate due to an ongoing investigation into individuals involved in the Siemens misconduct.1096 The Subcommittee also showed the Citibank wire transfers to Ms. Douglas’ legal counsel and requested an explanation of the $1.7 million in wire transfers from Siemens to her account. Her legal counsel did not provide an explanation.
1094 SEC v. Siemens Aktiengesellschaft, (USDC DC), Case No. 1:08-cv-02167-RJL (Dec. 12, 2
Siemens Payment and Gede Foundation. According to Citibank records, one of the Siemens wire transfers for $860,500 was deposited into Ms. Douglas’ personal checking account on January 28, 2002. Three days earlier, on January 25, 2002, Ms. Douglas had formed the Gede Foundation Inc. as a nonprofit corporation under the laws of the District of Columbia.1097 The Foundation articles of incorporation provide it with wide authority to pursue charitable causes.1098 The Gede Foundation website states:
“Gede Foundation is a 501c (3) non-profit, non-governmental organization that works for the benefit of the people of Africa to restore to them the right to a sense of self worth, and a life of hope, health and happiness through programs that educate, promote healthy communities and help eliminate the stigma of illness.”1099Cynthia J. Ticao, a Phillipines national, is the Foundation’s executive director and has been listed as an account signatory on the Gede Foundation accounts at Citibank.1100 On February 1, 2002, four days after receiving the $860,500 from Siemens, Ms. Douglas transferred $250,000 to a newly opened Gede Foundation account at Chevy Chase Bank, as described below. She also opened a Gede Foundation account at Citibank.LetsGo, Guernsey Trust Company, and Sima Holding Payments. Over a four-year period from 2003 to 2007, Ms. Douglas also accepted nearly $17 million in wire transfers from LetsGo, Guernsey Trust Company, and Sima Holdings into her Citibank accounts. As explained earlier, the Guernsey Trust Company is a Nigerian shell corporation that manages the Abubakar Blind Trust, while LetsGo and Sima Holdings are offshore corporations beneficially owned by Mr. Volpi and his relatives.
