The Ex-boss of the Nigerian Police Force and the court

The EFCC Charges Against Balogun (1 )

04.05.2005 CORDS

COUNT 1

That you Tafa Adebayo Balogun being the former Inspector-General of
Police on or about 20th July 2004 at Abuja in the Abuja Judicial
Division of the Federal High Court did transfer the sum of N87,
720,000.00 (eighty-seven million, seven hundred and twenty thousand
Naira) which sum you knew represent the proceed of an illegal act to
wit: theft, property of the Nigeria Police Force which aim is to
conceal the nature of the proceeds of the said illegal act by buying
1,500,000 shares in Nigerian Breweries Plc and thereby committed an
offence contrary to section 14(l)(a) and punishable under section 14
(1) of Money Laundering Act 2004.

COUNT 2

That you Tafa Adebayo Balogun being the former Inspector-General of
Police on or about 20th July 2004 at Abuja in the Abuja Judicial
Division of the Federal High Court did transfer the sum of N42,
000,000.00 (forty-two million Naira) which sum you knew represent the
proceed of an illegal act to wit: theft, property of the Nigeria
Police Force which aim is to conceal the nature of the proceeds of
the said illegal act by buying 1,500,000 shares in First Bank of
Nigeria Plc and thereby committed an offence contrary to section 14(l)
(a) and punishable under section 14(1) of Money Laundering Act 2004.

COUNT 3

That you Tafa Adebayo Balogun being the former Inspector General of
Police on or about 20th July 2004 at Abuja in the Abuja Judicial
Division of the Federal High Court did transfer the sum of N50,
050,000.00 (fifty million and fifty thousand Naira) which sum you
knew represent the proceed of an illegal act to wit: theft, property
of the Nigeria Police Force which aim is to conceal the nature of the
proceeds of the said illegal act by buying 1,500,000 shares in Union
Bank Plc and thereby committed an offence contrary to section 14(1)
(a) and punishable under section 14(1) of Money Laundering Act 2004.

COUNT 4

That you Tafa Adcbayo Balogun being the former Inspector-General of
Police on or about 20th July 2004 at Abuja in the Abuja Judicial
Division of the Federal High Court did transfer the sum of N148,
000,000.00 (one hundred and forty-eight million Naira) which sum you
knew represent the proceed of an illegal act to wit: theft, property
of the Nigeria Police Force which aim is to conceal the nature of the
proceeds of the said illegal act by buying 1,500,000 shares in
Guinness Nigeria Plc and thereby committed an offence contrary to
section 14(1)(a) and punishable under section 14(1) of Money
Laundering Act 2004.

COUNT 5

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Caledonian Telecommunications Ltd and Gbenga Ajala,
Relationship Manager, Abuja Branch of Fountain Trust Bank Plc (now at
large) on or about May 2003 at Abuja in the Abuja Judicial Division
of the Federal High Court did use the sum of N500 million (five
hundred million Naira) which sum you knew represent the proceed of an
illegal act to wit: theft, property of the Nigeria Police Force which
aim is to conceal the nature of the proceeds of the said illegal act
to buy Treasury bills for Caledonian Telecommunication Ltd and
thereby committed an offence contrary to section 14 (l)(a) and
punishable under section 14(1) of Money Laundering Act 2003.

COUNT 6

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Ceejay Nigeria Ltd and Gbenga Ajala, Relationship Manager,
Abuja Branch of Fountain Trust Bank Plc (now a( large) sometime in
May 2004 at Abuja in the Abuja Judicial Division of the Federal High
Court did use the sum of N350 million (three hundred and fifty
million Naira) which sum you knew represent the proceed of an illegal
act to wit: (theft, property of the Nigeria Police Force which aim is
to conceal the nature of the proceeds of the said illegal act to buy
a block of 6 numbers of 3 bed room fat at Olusegun Aina Street, Park
View Estate, Ikoyi, Lagos in the name of Ceejay Properties Nigeria
Ltd and thereby committed an offence contrary to section 14(1)(a) and
punishable under section 14(1) of Money Laundering Act 2004.

COUNT 7

That you Tafa Adebayo Balogun  being the former Inspector-General of
Police and Gbenga Ajala, Relationship Manager, Abuja Branch of
Fountain Trust Bank Plc (now at large) between January 2004 and
December 2004 at Abuja in the Abuja Judicial Division of the Federal
High Court did use the sum of N35,000,000.00 (thirty-five million)
which sum you knew represent the proceed of an illegal act to wit:
theft, property of the Nigeria Police Force which aim is to conceal
the nature of the proceeds of the said illegal act to buy 5 bed room
detached house at Victoria Garden City situate at Road 3, Plot J in
the name of Gbenga Ajala and thereby committed an offence contrary to
section 14(l)(a) and punishable under section 14(1) of Money
Laundering Act 2004.

COUNT 8

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Yeboa Investment Ltd,  Caledonian Investment, Renovations
Constructions Ltd, Aworo Investment Nigeria Ltd, Olatrade Nigeria
Ltd, Yaboa Nigeria Ltd and Gbenga Ajaia, Relationship Manager, Abuja
Branch of Fountain Trust Bank Plc (now at large) between January 2004
and December 2004 at Abuja in the Abuja Judicial Division of the
Federal High Court did use the sum of N130 million (one hundred and
thirty million Naira) which sum you knew represent the proceed of an
illegal act to wit: theft, property of the Nigeria Police Force which
aim is to conceal the nature of the proceeds of the said illegal act
to buy 5 bed room detached house at Park View Estate with 2 bed room
boys quarters Ikoyi, Lagos and thereby committed an offence contrary
to section 14(l)(a) and punishable under section 14(1) of Money
Laundering Act 2004.

COUNT 9

That you Tafa Adebayo Balogun (a.k.a. Adebayo Mustapha) being the
former Inspector-General or Police, Yeboa Investment Ltd, Caledonian
Investment, Renovations Constructions Ltd, Aworo Investment Nigeria
Ltd, Olalrade Nigeria ltd, Yaboa Nigeria Ltd and Gbenga Ajala,
Relationship Manager, Abuja Branch of Fountain Trust Bank Plc (now at
large) between January 2004 and December 2004 at Abuja in the Abuja
Judicial Division of the Federal High Court did use the sum of N485
million ((four hundred and eighty-five million Naira) which sum you
knew represent the proceed of an illegal act to wit: theft, property
of the Nigeria Police Force which aim is to conceal the nature of the
proceeds of the said illegal act to buy Shakir Plaza located at Plot
1020 Cadastral Zone A3 Garki II, Abuja and thereby committed an
offence contrary to section 14(l)(a) and punishable under section 14
(1) of Money Laundering Act 2004.

COUNT 10

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Yeboa Investment Ltd, Caledonian Investment, Renovations
Constructions Ltd, Aworo Investment Nigeria Ltd, Olatrade Nigeria
ltd, Yaboa Nigeria Ltd and Gbenga Ajala, Relationship Manager, Abuja
Branch of Fountain Trust Bank Plc (now at large) sometime in 2002 at
Abuja in the Abuja Judicial Division of the Federal High Court did
use the sum of N285 million (two hundred and eighty-five million
Naira) which sum you knew represent the proceed of an illegal act to
wit: theft, property of the Nigeria Police Force which aim is to
conceal the nature of the proceeds of the said illegal act to buy
Yasuha Plaza located at Plot 1046 Ademola Adetokunbo Street, Wuse II,
Abuja in the name of Olatrade Nigeria Ltd and thereby committed an
offence contrary to section 14(l)(a) and punishable under section 14
(1) of Money Laundering Act 2004.

COUNT 11

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Olatrade Nigeria Ltd and Gbenga Ajala, Relationship Manager,
Abuja Branch of Fountain Trust Bank Plc (now at large) between
January 2004 and December 2004 at Abuja in the Abuja Judicial
Division of the Federal High Court did use the sum of N280 million
(two hundred and eighty million Naira) which sum you knew represent
the proceed of an illegal act to wit: theft, property of the Nigeria
Police Force which aim is to conceal the nature of the proceeds of
the said illegal act to buy two double duplex apartments located at
Plot 110 Tunis Street, Wuse Zone 6, Garki, Abuja in the name of Ola
Trade Nigeria ltd and thereby committed an offence contrary to
section 14(a)(l) and punishable under section 14(1) of Money
Laundering Act 2004.

COUNT 12

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Caledonian Telecommunications Ltd and Gbenga Ajala,
Relationship Manager, Abuja Branch of Fountain Trust Bank Plc (now at
large) between 21st December 2004 and 3rd February 2005 at Abuja in
the Abuja Judicial Division of the Federal High Court  did invest the
sum of N345,720,320.14 (three hundred and forty-five million, seven
(hundred and twenty thousand, three hundred and twenty Naira and
Fourteen kobo) in commercial papers in the name of Caledonia
Telecommunications Ltd which sum you knew represent the proceed of an
illegal act to wit: theft, property of the Nigeria Police Force which
aim is to conceal the nature of the proceeds of the said illegal act
and thereby committed an offence contrary to section 14(1 )(a) and
punishable under section 14(1) of Money Laundering Act 2004.

COUNT 13

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Yeboa Investment Ltd and and Gbenga Ajala, Relationship
Manager, Abuja Branch of Fountain Trust Bank Plc (now at large)
between 21st December 2004 and 3rd February 2005, at Abuja in the
Abuja Judicial Division of the Federal High Court did invest the sum
of N468,959,667.36 (four hundred and sixty-eight million, nine
hundred and fifty- nine thousand, six hundred and sixty-seven Naira
and thirty-six kobo) in commercial papers in the name of Yeboa
Investment Ltd which sum you knew represent the proceed of an illegal
act to wit: theft, property of the Nigeria Police Force which aim is
to conceal the nature of the proceeds of the said illegal act and
thereby committed an offence contrary to section 14(l)(a) and
punishable under section 14(1) of Money Laundering Act 2004.

COUNT 14

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Yeboa Nigeria ltd and Gbenga Ajala, Relationship Manager,
Abuja Branch of Fountain Trust Bank Plc (now at large) between 21st
December 2004 and 3rd February 2005 at Abuja in the Abuja Judicial
Division of the Federal High Court did invest the sum of
N91,440,640.28 (ninety-one million, four hundred and forty thousand,
six hundred and Forty Naira and twenty-eight kobo) in commercial
papers in the name of Yeboa Investment Ltd which sum you knew
represent the proceed of an illegal act to wit: theft, property of
the Nigeria Police Force which aim is to conceal the nature of the
proceeds of' the said illegal act and thereby committed an offence
contrary to section 14(1 )(a) and punishable under section 14(1) of
Money Laundering Act 2004.

COUNT 15

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Yeboa Investmenl ltd and Gbenga Ajala, Relationship Manager,
Abuja Branch of the Fountain Trust Bank Plc (now at large) between
December 2004 and 3"' February 2005 at Abuja in the Abuja Judicial
Division of the Federal High Court did invest the sum of N4,985,549.
13 (four million, nine hundred and eighty-five thousand, five hundred
and forty-nine Naira and thirteen kobo) in commercial papers in the
name of Yeboa Investment Ltd which sum you knew represent the proceed
of an illegal act to wit: theft, property of the Nigeria Police
Force, which aim is to conceal the nature of (lie proceeds of the
said illegal act and thereby committed an offence contrary to section
14(l)(a) and punishable under section 14(1) of Money Laundering Act
2004.

COUNT 16

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Renovations Constructions Ltd and Gbenga Ajala, Relationship
Manager, Abuja Branch of Fountain Trust Bank Plc (now at large)
between December 2004 and 3rd February 2005 at Abuja in the Abuja
Judicial Division of (the Federal High Court did invest the sum of N
140,233,88 1.73 (one hundred and forty-six million, two hundred and
thirty-three thousand, eight hundred and eighty-one Naira and seventy-
three kobo) in commercial papers in the name of Renovations
Constructions ltd which sum you knew represent the proceed of an
illegal act to wit: theft, property of the Nigeria Police Force which
aim is to conceal the nature of the proceeds of the said illegal act
and thereby committed an offence contrary to section 14(l)(a) and
punishable under section 14(1) of Money Laundering Act 2004.

COUNT 17

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Renovations Constructions l.td and Gbenga Ajala, Relationship
Manager, Abuja Branch of the Fountain Trust Bank Plc (now at large)
between December 2004 and 3rd February 2005 at Abuja in the Abuja
Judicial Division of the Federal High Court did invest the sum of
N44,008,448.21 (forty-four hundred million, eight thousand and four
hundred and forty-eight Naira and twenty-one kobo) in commercial
papers in the name of Renovations Constructions Ltd which sum you
knew represent the proceed of an illegal act to wit: theft, property
of the Nigeria Police Force which aim is to conceal the nature of
the, proceeds of the said illegal act and thereby committed an
offence contrary lo section 14(a)(l) and punishable under section 14
(1) of Money Laundering Act 2004.

COUNT 18

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Caledonian Telecommunications Ltd and Gbenga Ajala,
Relationship Manager, Abuja Branch of Fountain Trust Bank Plc (now at
large) between January 2004 and January 2005 al Abuja in the Abuja
Judicial Division of the Federal High Court did lodge the sum of
N1,152,143,1 84.25) (one billion, one hundred and fifty-two million,
one hundred and forty-three ( thousand, one hundred and eighty-four
Naira and twenty-five kobo) into Current Account No. 01C31201472 with
Fountain Trust Bank Plc, Abuja Branch, operated by Caledonia
Telecommunications I Ad, which sum you knew represent the proceed of
an illegal act to wit: theft, property of the Nigeria Police Force 
which aim is to conceal the nature of the proceeds of the said
illegal act and thereby committed an offence contrary to section 14(l)
(a) and punishable under a section 14( 1) of Money Laundering Act
2004.
                              
COUNT 19

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Renovations Constructions Ltd and Gbenga Ajala, Relationship
Manager, Abuja Branch of Fountain Trust Bank Plc (now at large)
between 28th December 2004 and January 2005 at Abuja in the Abuja
Judicial Division of the Federal High Court did lodge the sum of N
10,949,434.68 (ten : million, nine hundred and forty-nine thousand,
four hundred and thirty-four Naira and sixty-eight kobo) into Call
Deposit Account No. 01D3 120147305 with Fountain Trust Bank Plc,
Abuja Branch operated by Renovations Constructions-; Ltd, which sum
you knew represent the proceed of an illegal act to theft, property
of the Nigeria Police Force which aim is to conceal the nature of the
proceeds of the said illegal act and thereby committed an offence
contrary to section 14(1)(a) and punishable under section 14(1) of
Money Laundering Act 2004.

COUNT 20

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Renovations Constructions Ltd and Gbenga Ajala, Relationship
Manager, Abuja Branch of Fountain Trust Bank Plc (now at large)
between June, 2004 and January 2005 at Abuja in the Abuja Judicial
Division of the Federal High Court did lodge the sum of N91,05,376.13
(ninety-one million, eighty-five thousand, three hundred and seventy-
six Naira and thirteen kobo) into Call Deposit Account No. 01 D3 I 20
1/17304 with Fountain Trust Bank 1td, Abuja Branch operated by
Renovations Constructions ltd, which sum you knew represent the
proceed of an illegal act to wit; theft, property of the Nigeria
Police Force which aim is to conceal the nature of the proceeds of
the said illegal act and thereby committed an offence contrary to
section 14(a)( 1) and punishable under section 14(1) of Money
Foundering Act 2004.

COUNT 21

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Renovations Constructions Ltd and Gbenga Ajala, Relationship
Manager, Abuja Branch of Fountain Trust Bank Plc (now at large)
between January 2000 and January 2005 at Abuja in the Abuja Judicial
Division of the Federal High Court did lodge the sum of N
138,586,536.77 (one hundred and thirty-eight million, five hundred
and eighty-six thousand, five hundred and thirty-six Naira and
seventy-seven kobo) into Call Deposit Account. No. 01D3120147303 wit:
Fountain Trust Bank Plc, Abuja Branch operated by Renovations
Constructions Ltd, which sum you knew represent the proceed of an
illegal act to wit: theft, properly of the Nigeria Police Force which
aim is to conceal the nature of the proceeds of the said illegal act
and thereby committed an offence contrary to section 14(l)(a) and
punishable under section 14(1) of Money Laundering Act 2004.

COUNT 22

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Yeboa Nigeria Ltd and Gbenga Ajala, Relationship Manager,
Abuja Branch of Fountain trust Bank Plc (now at large) between
January 2000 and January 2005 at Abuja in the Abuja Judicial Division
of the Federal High Court did lodge the sum of N1, 383,21 1,340.45
(one billion, three hundred and eighty-three million, two hundred and
eleven thousand, three hundred and forty Naira and forty-five kobo)
into Current Account No. 01C3 1201474 with Fountain Trust Bank Plc,
Abuja Branch operated by Yeboa Nigeria Ltd, which sum you knew
represent the proceed of an illegal act to wit: theft, property of
the Nigeria Police Force which aim is to conceal the nature of the
proceeds of the said illegal act and thereby committed an offence
contrary to section 14(l)(a) and punishable under section 14(1) of
Money Laundering Act 2004.

COUNT 23

That you Tafa Adebayo Balogun being the former Inspector-General
Police, Yeboa Nigeria ltd and Gbenga Ajala, Relationship Manager,
Abuja Branch Fountain Trust Bank Plc (now at large) between January
2002 and January 2005 at Abuja in the Abuja Judicial Division of the
Federal High Court did lodge the sum of N254,279,679.86 (two hundred
and fifty-four million, two hundred and seventy-nine thousand, six
hundred and seventy-nine Naira and eighty-six kobo) in Bankers
Acceptance Account No. 01X0520147400 with Fountain Trust Bank Pie,
Abuja Branch operated by Yeboa Nigeria Ltd, which sum you knew-
represent the proceed of an illegal act to wit: theft, property of
the Nigeria Police Force which aim is to conceal the nature of the
proceeds of the said illegal act and thereby committed an offence
contrary to section 14(l)(a) and punishable under section 14(1) of
Money Laundering Act 2004.

COUNT 24

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Yeboa Investment ltd and Gbenga Ajala, Relationship Manager,
Abuja Branch of Fountain Trust Bank Plc (now at large) between
January 2002 and January 2005 at Abuja in the Abuja Judicial Division
of the Federal High Court did lodge the sum of N254,279,679.85 (two
hundred and fifty-four million, two hundred and seventy-nine
thousand, six hundred and seventy-nine Naira and eighty-five kobo) in
Bankers Acceptance Account No. 01X0520147500 with Fountain Trust Bank
Plc, Abuja Branch operated by Yeboa Investment Ltd, which sum you
knew represent the proceed of an illegal act to wit: theft, property
of the Nigeria Police Force which aim is to conceal the nature of the
proceeds of the said illegal act and thereby committed an offence
contrary to section 14(l)(a) and punishable under section 14(1) of
Money Laundering Act 2004.

COUNT 25

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Yeboa Nigeria Ltd and Gbenga Ajala, Relationship Manager,
Abuja Branch of Fountain Trust Bank Plc (now at large) between
January 2001 and January 2005 at Abuja in the Abuja Judicial Division
of the Federal High Court did lodge the sum of N415,550,274.08 (four
hundred and fifteen million, five hundred and fifty thousand, two
hundred and seventy-four Naira and eight kobo) into Current Account
No. 01C31201473 with Fountain Trust Bank Plc, Abuja Branch operated
by Yeboa Nigeria Ltd, which sum you knew represent the proceed of an
illegal act to wit: theft properly of the Nigeria Police Force which
aim is to conceal illegal nature of the proceeds of the said illegal
act and thereby committed an offence contrary to section 14( 1 )(a)
and punishable under section 14( I) of Money Laundering Act 2004.

COUNT 26

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Renovations Constructions Ltd and Gbenga Ajala, Relationship
Manager, Abuja Branch of Fountain Trust Bank Plc (now at large)
between January 2001 and January 2005 at Abuja in the Abuja Judicial
Division of the Federal High Court did lodge the sum of
N2,028.474.468.23 (two billion twenty-eight million, four hundred and
seventy-four thousand, four hundred and sixty-eight Naira and twenty-
three kobo) into Current Account No. 01C 1201473 with Fountain Trust
Bank Plc, Abuja Branch operated by Renovations Constructions Ltd,
which sum you knew represent the proceed of an illegal act to wit-
theft, property of the Nigeria Police Force which aim is to conceal
the nature of the proceeds of the said illegal act and thereby
committed an offence contrary to section 14(l)(a) and punishable
under section 14(1) of Money Laundering Act 2004.

COUNT 27

That you Tafa Adebayo Balogun being the former Inspector-General of
Police, Olatrade Nigeria ltd and Gbenga Ajala, Relationship Manager,
Abuja Branch of the Fountain Trust Bank Plc (now at large) between
January 2001 and January 2005 at Abuja in the Abuja Judicial division
of the Federal High Court did lodge the sum of N228.082.191.78 (two
hundred and twenty-eight million, eighty-two thousand, one hundred
and ninety- one Naira and seventy-eight kobo) into Call Deposit
Account No. 01D3120119100 with Fountain Trust Bank Plc, Abuja Branch
operated by Olatrade Nigeria Ltd, which sum you knew represent the
proceed of an illegal act to wit: theft, properly of the Nigeria
Police Force which aim is to conceal the nature of the proceeds of
the said illegal act and thereby committed an offence contrary to
section 14(a)(l) and punishable under section 14(1) of Money
Laundering Act 2004.

COUNT 28

That you Tala Adebayo Balognn  being the former Inspector-General of
Police, Olalrade Nigeria Ltd and Gbenga Ajala Relationship Manager,
Abuja Branch of the Fountain Trust Bank Plc (now a large) between
January 2001 and January 2005 al Abuja in the Abuja Judicial Division
of the Federal High Court did lodge the sum of N29,800,000.00 (twenty-
nine million, eight hundred thousand, one hundred and ninety-one
Naira) into Call Deposit Account No. 01D31201 19100 with Fountain
Trust Bank Plc, Abuja Branch operated by Olatrade Nigeria Lid, which
sum you knew represent the proceed of an illegal act to wit: theft,
property of' the Nigeria Police Force which aim is to conceal the
nature of the proceeds of the said illegal act and thereby committed
an offence contrary to section 14(l)(a) and punishable under section
14( 1) of Money Laundering Act 2004.

COUNT 29

That you Tafa Adcbayo Balogun (a.k.a. Adcbayo Mustapha) being the
former Inspector-General of Police, Aworo Investment Ltd and Gbenga
Ajala, Relationship Manager, Abuja Branch of the Fountain Trust Bank
Pie (now at large) between January 2001 and January 2005 at Abuja in
the Abuja Judicial Division of the Federal High Court did lodge the
sum of N25,000,000.00 (twenty-live million Naira) into Call Deposit
Account No.01D3 120127800 with Fountain Trust Bank Plc, Abuja Branch
operated by Aworo Investment Nigeria Ltd. which sum you knew
represent the proceed of an illegal act to wit: theft, property of
the Nigeria Police Force which aim is to conceal the nature of the
proceeds of the said illegal act and thereby committed an offence
contrary to section 14(l)(a) and punishable under section 14(1) of
Money Laundering Act 2004.

COUNT 30

That you Tafa Adebayo Balogun  being the former Inspector-General of
Police, Aworo Investment Ltd and Gbenga Ajala, Relationship Manager,
Abuja Branch of Fountain Trust Bank Plc (now at large) between
January 2001 and January 2005 at Abuja in the Abuja Judicial Division
of the Federal High Court did lodge the sum of N960,999,167.48 (nine
hundred and sixty million, nine hundred and ninety-nine thousand, one
hundred and sixty-seven Naira and forty-eight kobo) into Current
Account No. 01C0120127800 with Fountain Trust Bank Pie, Abuja Branch
operated by Aworo Investment Nigeria Ltd, which sum you knew
represent the proceed of an illegal act to wit: theft, property of
the Nigeria Police Force which aim is to conceal the nature of the
proceeds of the said illegal act and thereby committed an offence
contrary to section 14(l)(a) and punishable under section 14(1) of
Money Laundering Act 2004.

COUNT 31

That you Tafa Adebayo Balogun  being the former Inspector-General of
Police, Aworo Investment Ltd and Cibenga Ajala, Relationship Manager,
Abuja Branch of Fountain Trust bank Plc (now at large) between
January 2001 and January 2005 at Abuja in the Abuja Judicial Division
of the Federal High Court did lodge the sum of N871,2I6, 933.21
(eight hundred and seventy-one million, two hundred and sixteen
thousand, nine hundred and thirty-three Naira and twenty-one kobo)
into Current Account No. 01 CO 1201278 with Fountain Trust Bank Plc,
Abuja Branch operated by Aworo Investment Nigeria Ltd, which sum you
knew represent the proceed of an illegal act to wit: theft, property
of the Nigeria Police force which aim is to conceal the nature of the
proceeds of the said illegal act and thereby committed an offence
contrary to section i4(l)(a) and punishable under section 14( 1 ) of
Money Laundering Act 2004.

COUNT 32

That you Tafa Adebayo Balogun being the former Inspector-General of
Police on or about 11th April 2003 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use the sum of N700 million (Seven hundred Million Naira) property of
tile Nigeria Police Force and thereby committed an offence punishable
under section 289 of the Penal Code Cap 532 Laws of the Federation of
Nigeria 1990. 

COUNT 33

That you Tafa Adebayo Balogun being the former Inspector-General of
Police on or about 22nd June 2004 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use the sum of N100 million (one hundred Million Naira) property of
the Nigeria Police Force and thereby committed an offence punishable
under section 289 of the Penal Code Cap 532 Laws of the Federation of
Nigeria 1990.

COUNT 34

That you Tafa Adebayo Balogun being the former Inspcctor-denei-al of
Police on or about 24th June 2004 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use, the sum of N100 million (one hundred Million Naira) property of
the Nigeria Police Force and thereby committed an offence punishable
under section 289 of the Penal Code Cap 532 Laws of the Federation of
Nigeria 1990.

COUNT 35

That you Tafa Adebayo Balogun being the former Inspector-General of
Police on or about 29th June 2004 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use the sum of N50 million (fifty Million Naira) property of the
Nigeria Police Force and thereby committed an offence punishable
under section 289 of the Penal Code Cap 532 Laws of (lie Federation
of Nigeria I ^90.

COUNT 36

That you Tafa Adebayo Balogun being the former Inspector-General of
Police on or about 9th December 2002 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use the sum of N6,575,360.67 (six million, five hundred and seventy-
five thousand three hundred and sixty Naira and sixty-seven kobo)
property of the Nigeria Police Force and thereby committed an offence
punishable under section 289 of the Penal Code Cap 532 Laws of the
Federation of Nigeria 1990.

COUNT 37

That you Tafa Adebayo Balogun being the former Inspector-General of
Police on or about 3rd February 2002 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use the sum of N1,929,1 55.00 (one million, nine hundred and twenty-
nine thousand. One hundred and fifty-five Naira} property of the
Nigeria Police Force, am thereby committed an offence punishable
under section 289 of the Penal Code Cap 532 Laws of the Federation of
Nigeria 1990.

COUNT 38

That you Tafa Adebayo Balogun  being the former Inspector-General of
Police on or about 24"1 June 2004 at Abuja- in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use, the sum of N1,95 1,413.33 (one million, nine hundred and fifty-
one thousand, four hundred and thirteen Naira and thirty-three kobo)
property of the Nigeria Police Force and thereby committed an offence
punishable under section 289 of the Penal Code Cap 532 Laws of the
Federation of Nigeria 1990.

COUNT 39

That you Tafa Adebayo Balogun  being the former Inspector-General of
Police on or about 31s1 March 2003 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use, the sum of N6,486,666.67 (six million, four hundred and eighty-
six thousand, six hundred and sixty-six Naira and sixty-seven kobo)
property of the Nigeria Police Force and thereby committed an offence
punishable under section 289 of the Penal Code Cap 532 Laws of the
Federation of Nigeria 1990.

COUNT 40

That you Tafa Adcbayo Balogun being the former Inspector-General of
Police on or about 2nd October 2002 at Abuja in (the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use, the sum of N4,5 1 2,328.67 four million, five hundred and twelve
thousand, three hundred and twenty-eight Naira and sixty-seven kobo
property of the Nigeria Police Force and thereby committed an offence
punishable under section 289 of the Penal Code Cap 532 Laws of the
Federation of Nigeria 1990.

COUNT 41

That you Tafa Adebayo Balogun  being the former Inspector-General of
Police on or about 7th August 2002 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use, the sum of N4,229,277.67 (four million, two hundred and twenty-
nine thousand, two hundred and seventy-seven Naira and sixty-seven
kobo) property of the Nigeria Police Force and thereby committed an
offence punishable under section 289 of the Penal Code Cap 532 Laws
of the Federation of Nigeria 1990.

COUNT 42

That you Tafa Adebayo Balogun being the former Inspector-General of
Police on or about 4th September 2002 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use, the sum of N3,743,379.00 (three million, seven hundred and forty-
three thousand, three hundred and seventy-nine Naira) property of the
Nigeria Police Force and thereby committed an offence punishable
under section 289 of the Penal Code Cap 532 Laws of the Federation of
Nigeria 1990.

COUNT 43

That you Tafa Adebayo Balogun being the former Inspector-General of
Police on or about 11th January 2003 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use, the sum of N4,130,041.00 (four million, one hundred and thirty
thousand, and forty-one Naira) property of the Nigeria Police Force
and thereby committed an offence punishable under section 289 of the
Penal Code Cap 532 Laws of the Federation Nigeria 1990.

COUNT 44

That you Tafa Adebayo Balogun  being the former Inspector-General of
Police on or about 4th November 2002 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use, the sum of N5,651,843.00 (five million, six hundred and fifty-
one thousand, eight hundred and forty-three Naira) property of the
Nigeria Police Force and thereby committed an offence punishable
under section 289 of the Penal Code Cap 532 Laws of the Federation of
Nigeria 1990.

COUNT 45

That you Tafa Adebayo Balogun  being the former Inspector-General of
Police on or about 8th May 2003 at Abuja in the Abuja Judicial
Division of the Federal High Court did dishonestly convert to your
use, the sum of N2,377,33(S,33 (two million, three hundred and
seventy-seven thousand, three hundred and thirty-e


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