Nigeria’s plan to attract up to $50 billion in new deepwater oil and gas investments could expose the sector to heightened financial crime risks if governance and control systems fail to keep pace with the expected capital inflows, Forensic and Financial Crimes Expert, Oyindamola Aboaba, has warned.

Aboaba, in an interview with The Guardian, said the risk would not necessarily arise from the size of the investment itself, but from the complex web of transactions and relationships that would accompany major oil and gas projects.

She noted that the Nigerian Upstream Regulatory Commission (NUPRC) had indicated that 22 major offshore projects expected between 2026 and 2030 could represent between $30 billion and $50 billion in investment, following more than $57 billion in approved Field Development Plans since 2024.

“Large capital inflows create opportunity, but they also create complexity,” Aboaba said in an interview with The Guardian.
“In a sector like oil and gas, the risk does not come simply from the size of the investment, but from the number of transactions, counterparties and decision points that come with it.”

She explained that the expected investments would move through layers of contractors, subcontractors, joint ventures, consultants, logistics providers and other intermediaries, potentially making it difficult to establish who is being paid, what they are being paid for and whether the price reflects genuine value.

According to her, contract awards, licensing, procurement, project approvals and the engagement of third parties claiming to facilitate access or accelerate processes could present significant financial crime vulnerabilities.

“These are where risks such as bribery, conflicts of interest, procurement fraud, inflated invoices and undisclosed related-party transactions can emerge,” she said.
Aboaba stressed that the key concern was whether Nigeria’s governance and control environment would expand at the same pace as investment.

“The concern is not the $50 billion itself. It is whether the governance and control environment expands at the same pace as the capital,” she told The Guardian.
The forensic expert advised prospective investors to undertake enhanced due diligence where multiple warning signs emerge around companies, contractors and intermediaries.

She identified limited operating history among contractors that consistently win major contracts, unusually high commissions without clearly defined services, supposedly independent bidders sharing directors or addresses, unexplained related-party transactions and frequent ownership changes ahead of major deals as potential red flags.

Payments to jurisdictions unrelated to a transaction and counterparties whose financial capacity appears inconsistent with the size of their contracts should also attract scrutiny, she said.

“None of those facts automatically means wrongdoing has occurred. But they are signals that the investor should stop relying solely on the documents presented and begin independently testing the story behind them,” Aboaba said.
She added that unusual resistance to transparency should also concern investors, especially where it is difficult to establish who owns a company, why an intermediary is necessary, how a vendor was selected or how a fee was calculated.

Aboaba said corruption and procurement irregularities could undermine the economics of otherwise attractive oil and gas investments.
She explained that investment models typically assume competitive procurement, timely project execution and predictable costs, but financial crime could distort these assumptions.

“If contracts are awarded because of relationships rather than capability or price, project costs can become inflated,” she said.
“If vendors are paying kickbacks, part of what appears to be a legitimate project expense may actually represent leakage. If an undisclosed related party repeatedly receives contracts, the investor may be paying above-market prices without realising it.”

She warned that the consequences could extend beyond the immediate financial loss, as poorly selected contractors could cause delays, operational failures and cost overruns.
“Something that begins as a governance issue can eventually become a valuation issue,” Aboaba told The Guardian.

On beneficial ownership, Aboaba acknowledged Nigeria’s progress through the Companies and Allied Matters Act, the Persons with Significant Control Regulations and public beneficial ownership registers.

However, she cautioned investors against treating information contained in the registers as the end of their investigation.
“In complex transactions, legal ownership and actual control do not always sit in the same place,” she said.

Investors, according to her, should trace ownership chains and establish who ultimately benefits economically, who provided the capital and who exercises effective control.

They should also examine directors, shareholders, financing arrangements, common addresses, shared contact information and links between counterparties, including possible connections to politically exposed persons and public officials.

Aboaba further warned that weak governance could affect the bankability of Nigerian oil and gas projects and increase the risk perceived by international investors and lenders.

“Weak controls introduce uncertainty,” she said, noting that such weaknesses could result in cost leakage, regulatory investigations, contractual disputes, sanctions exposure, reputational damage and interruptions to project execution.

She said international investors could also face exposure under anti-bribery and anti-corruption laws in other jurisdictions, depending on the parties and structure of a transaction.

Consequently, investors could impose additional conditions, demand more extensive due diligence, seek higher risk premiums or abandon transactions altogether.

Aboaba said this made governance an important economic factor as Nigeria competes with other oil-producing jurisdictions for global capital.
“For Nigeria, that matters because deep-water projects compete for global capital. Investors have choices,” she said.

“The easier we make it for them to trust the governance around a project, the stronger Nigeria’s position becomes in that competition.”

She identified three key areas investors should establish before committing capital: the people behind the project, the economics of the project and whether its controls work in practice.

For Nigerian oil and gas companies seeking international capital, Aboaba advised them to strengthen ownership transparency, related-party disclosures, procurement procedures, financial records and controls around third parties and payments.

“Sophisticated investors can usually distinguish between controls that exist on paper and controls that are genuinely embedded in how a company operates,” she said.
Ultimately, Aboaba said companies with strong assets and institutional-quality governance would be better positioned to attract long-term international capital.

“Good governance is no longer simply a compliance requirement; it becomes part of the investment proposition,” she said.