Written By Pa Nderry M’Bai

Email: panderrymbai@gmail.com

Tel: 919-749-6319

The Gambian government has been defrauded close to twenty thousand United States dollars ($20,000), following the Central Bank’s move to effect a ten percent contractual payment to a UK based Consultancy firm called — Public Administration International (PAI), Freedom Newspaper can authoritatively report. The funds were allegedly stolen by “a person(s) with knowledge of the transaction using email spoofing to change the banking details and redirect the funds to a fraudulent Barclays Bank Plc personal account.” Highly placed sources at the Ministry of Finance and Gambia’s Financial Intelligence Unit said the fraud occurred when the government had contracted the UK Consultancy firm PAI, to perform consultancy services for the  Personnel Management Office (PMO) on job evaluation pay and grading system. “We are in receipt of a report from the Project Coordination Unit (PCU) of the Ministry of Finance and Economic Affairs (MoFEA) regarding a fraudulent payment that was made through the Central Bank to Barclays Bank Plc on November 21, 2019. Following our analyses of the report, we have concluded that the transaction was most likely hijacked by a person(s) with knowledge of the transaction using email spoofing to change the banking details and redirect the funds to a fraudulent account,”  Momodou Saho, the Deputy Director and Head, Compliance and Prevention Division at Gambia’s Financial Intelligence unit wrote.

Mr. Saho has been soliciting the help of Interpol UK and The Gambia respectively to help recover the stolen funds. The funds haven’t been recovered yet.

PAI said it hasn’t receive the payment that was purportedly made by the Central Bank of The Gambia to their company’s account,  said Finance Ministry sources. The UK company claimed that the CBG payment was made to a wrong personal bank account.

The Freedom Newspaper contacted PAI via its office line, but there was no one in the office to talk to us. Finance Ministry officials were also not available for comment on Friday. Friday is a public holiday in The Gambia, as the country observes Eid.

Ms. Jainaba Faal of the Finance Ministry was among the Finance officials who were communicating with the alleged fraudster posing as an official of the PAI company.  Mr. Saffie Dambelleh, Musa Camara, Sheriff Jallow, and Jainaba Faal were the four other individuals copied in the email. The names of Nfansu Saidykhan, Alfu Jabbi, and Roheya Secka had also featured in the communications.

On November 26, 2019, an email was on this occasion sent to Mrs. Awa K John from email 2 REDACTED XXX following up on the payment insisting that the payment had yet been received.  This was the last mail from email 2.

Mrs. Awa K John responded to the email on December 13, 2019 confirming that the payment had been effected by the CBG on November 21, 2019.

The Financial Intelligence Unit in its investigative report said there was no information at their disposal to ascertain how PAI was awarded the PMO contract.

“Our analyses could not venture into how PAI got awarded the contract in question or who the parties to the contract are as a result of limited information. However, it appears that the Central Bank of The Gambia and World Bank (Gambia) may be aware of the contract and/or are key stakeholders in the project. Notwithstanding, the PCU confirmed that the payment of US $19,943,00, which is equivalent to 10% of the contract value, was meant PAI’s consultancy services on job evaluation pay and grading system for the Personnel Management Office,” Mr. Saho wrote.

Per the document we received from highly placed sources at the Financial Intelligence Unit at 380 Senegambia Highway, Kerr Serign, West Coast Region, the fraudster had posed as if he had used two PAI emails to defraud The Gambian government, when in actual fact, the fraud was perpetrated from one email.

On November 6, 2019, Claire Cameron, Director of PAU through her known email address wrote to the Permanent Secretary, Personnel Management Office, requesting for the payment of ten percent (10%) of the contra value.  She attached an invoice for the payment. However, the SWIFT code and IBAN on the attached invoice C3265/ 1 differed from the SWIFT code and IBAN stated in the contract.

On November 8, 2019, Jainaba Faal received an email from Claire Cameron (email2) enquiring if the payment has been made and suggesting there was an error with the IBAN and that the bank details required correction.

On November 9, 2019, Ms. Faal respondent to email2 that the payment was yet to be effected and supposedly advised Ms. Cameron to correct the bank details and advise accordingly.

On November 12, 2019, Ms. Cameron supposedly responded using email2 and attached an updated invoice with amended bank details. Nonetheless, the invoice still retains the name reference number of C3265/1 contract title and contract reference on the official letter head of PAI.

On November 13, 2019, Ms. Faal acknowledged receipt of the updated invoice.

On November 19, 2019, payment instruction on the updated invoice was dispatched to the Central Bank of The Gambia (CBG) by the PCU.

On November 19, 2019, Ms. Cameron, supposedly using email 2, seeks to enquire from Ms. Faal regarding the status of the payment.

On November 21, 2019, payment instruction was processed by CBG.

On November 26, 2019, Mrs. John supposedly received emails from Ms. Cameron from email 2 to follow up on the payment.

On December 13, 2019, Mrs. John writes back supposedly, to Ms. Cameron on email 2 to confirm that the payments had been effected on November 21, 2019 and the SWIFT notification will be shared.

On December 20, 2019, Ms. Faal received mail from Ms. Cameron through email1 stating that payment on the “first” invoice had been paid to a wrong account and that personal account had been closed.  She pointed out that the SWIFT notice shared with her, did not match the SWIFT/IBAN on her company’s invoice.

January 16, 2020, Ms. Cameron had telephone conversation with Mr. Saidykhan Finance and Admin Manager, PCU followed by an email from Mr. Saidykhan stated that the payment was made on the invoice provided by the company and requesting that she works with the bank to have the funds transferred from the personal account to the correct account instead of initiating to recall the funds and sending it back.

Below is the Financial Intelligence Unit report we received from trusted and dependable FIU Office insiders. Information regarding bank account numbers and email addresses have been redacted. Please read on…..

………………………………………………..

FINANCIAL INTELLIGENCE UNIT OF THE GAMBIA

REF: FIU/00G/119-20

JULY 20, 2020

OFFICE OF THE INSPECTOR GENERAL OF POLICE

POLICE HEADQUARTERS

ECOWAS AVENUE

BANJUL

Dear Sir,

INFORMATION REQUEST TO INTERPOL (UK)

We are in receipt of a report from the Project Coordination Unit (PCU) of the Ministry of Finance and Economic Affairs (MoFEA) regarding a fraudulent payment that was made through the Central Bank to Barclays Bank Plc on November 21, 2019.

Following our analyses of the report, we have concluded that the transaction was most likely hijacked by a person(s) with knowledge of the transaction using email spoofing to change the banking details and redirect the funds to a fraudulent account.  Our Intelligence Report is attached for your perusal.

Nonetheless, given that the transaction account is domiciled outside our jurisdiction, we solicit your assistance in our efforts to escalate this fraud incident against government funds to the relevant authorities of the United Kingdom (UK) through Interpol (Gambia).

While we do not have personal details of the account holder(s) or perpetrators of the fraud, we provide below details of the account the funds were paid into for your use.

Bank Name: Barclays Bank Plc (UK)

Account Number: redacted xxxxxx

Sort Code: xxxxxx

SWIFTBIC: xxxxx

IBAN: xxxxxxxxxxxxxxx

We count on your usual cooperation.

Yours faithfully

Momodou Saho

Deputy Director and Head, Compliance and Prevention Division.

INTELLIGENCE REPORT ON SUSPECTED FRAUD PAYMENT FOR PAI—INVOICE NO: C32GG/1

                   BACKGROUND

The FIU received a letter from the Project Director, Project Coordination Unit (PCU) of the Ministry of Finance and Economic Affairs (MoFEA) on April 28, 2020 regarding a suspected fraud payment.

The fraud occurred while PCU was in the process of making payments to Public Administration (PAI) UK, a company it had contractual relationship with.

BRIEF FACTS

PAI was contracted to perform consultancy services to Personnel Management Office on job evaluation pay and grading system.

On November 6, 2019, Claire Cameron, Director of PAU through her known email address wrote to the Permanent Secretary, Personnel Management Office, requesting for the payment of ten percent (10%) of the contra value.  She attached an invoice for the payment. However, the SWIFT code and IBAN on the attached invoice C3265/ 1 differed from the SWIFT code and IBAN stated in the contract.

On November 8, 2019, Jainaba Faal received an email from Claire Cameron (email2) enquiring if the payment has been made and suggesting there was an error with the IBAN and that the bank details required correction.

On November 9, 2019, Ms. Faal respondent to email2 that the payment was yet to be effected and supposedly advised Ms. Cameron to correct the bank details and advise accordingly.

On November 12, 2019, Ms. Cameron supposedly responded using email2 and attached an updated invoice with amended bank details. Nonetheless, the invoice still retains the name reference number of C3265/1 contract title and contract reference on the official letter head of PAI.

On November 13, 2019, Ms. Faal acknowledged receipt of the updated invoice.

On November 19, 2019, payment instruction on the updated invoice was dispatched to the Central Bank of The Gambia (CBG) by the PCU.

On November 19, 2019, Ms. Cameron, supposedly using email 2, seeks to enquire from Ms. Faal regarding the status of the payment.

On November 21, 2019, payment instruction was processed by CBG.

On November 26, 2019, Mrs. John supposedly received emails from Ms. Cameron from email 2 to follow up on the payment.

On December 13, 2019, Mrs. John writes back supposedly, to Ms. Cameron on email 2 to confirm that the payments had been effected on November 21, 2019 and the SWIFT notification will be shared.

On December 20, 2019, Ms. Faal received mail from Ms. Cameron through email1 stating that payment on the “first” invoice had been paid to a wrong account and that personal account had been closed.  She pointed out that the SWIFT notice shared with her, did not match the SWIFT/IBAN on her company’s invoice.

January 16, 2020, Ms. Cameron had telephone conversation with Mr. Saidykhan Finance and Admin Manager, PCU followed by an email from Mr. Saidykhan stated that the payment was made on the invoice provided by the company and requesting that she works with the bank to have the funds transferred from the personal account to the correct account instead of initiating to recall the funds and sending it back.

FINDINGS

From our view of the information received this far, the Project Director under the MOFEA confirms that PAI was contracted to perform consultancy services on job evaluation, pay and grading system for the Personnel Management Office.

A review of United Kingdom’s Company registry website indicates that PAI was incorporated in the UK on February 14, 1992 as a private limited company. The company has been filing its accounts as a small company.  Since its incorporation, it has had 11 officers as Directors or Secretary.  Nonetheless, there has also been 8 resignations from that 11.  According to the company Registry’s site, the company has only two officers in its file, one Vyacheslav Gromlyuk serves as a Director while Ms. Claire Elizabeth Cameron serves both as the Secretary and a Director of the Company.  While Ms. Cameron joined the company in June 1995, Gromlyuk joined in 2012.

Our analyses could not venture into how PAI got awarded the contract in question or who the parties to the contract are as a result of limited information. However, it appears that the Central Bank of The Gambia and World Bank (Gambia) may be aware of the contract and/or are key stakeholders in the project.

Notwithstanding, the PCU confirmed that the payment of US $19,943,00, which is equivalent to 10% of the contract value, was meant PAI’s consultancy services on job evaluation pay and grading system for the Personnel Management Office.

According to the email transcript, this amount was supposed to be paid into swift code and IBAN number (SWIFT BIC: REDACTED XXXX) as per the contract. However, Ms. Cameron gave instructions on November 6, 2019 in an email to the Permanent Secretary of the Personnel Management Office to pay the funds into an account with separate details on an invoice addressed to Mr. Saffie Dambelleh.  Mr. Dambelleh, Musa Camara, Sheriff Jallow, and Jainaba Faal were the four other individuals copied in the email.

Ms. Cameron sent another email on November 7, 2019 using same email address the following day attaching Inception Report 28 October 2019 as well as the invoice. The email was sent to Jainaba Faal and the rest from the previous email copied. Three other persons in the names of Nfansu Saidykhan, Alfu Jabbi, and Roheya Secka were also copied by her.

Following this two emails to the PS and Ms. Faal respectively by Ms. Cameron using email1, the transcript shows that the first email in which email 2 was spotted was sent to Ms. Faal on November 8, 2019. This mail was enquiring if the payment had been made and noting that the bank details needed to be changed given the error with the IBAN.

From the transcript, it appears when Ms. Faal responded to the email, the following day, she responded to email2 stating that the payment had been effected and supposedly, Ms. Cameron should advise accordingly with the corrected bank details.

Response was subsequently received from email2 three days later on November 12, 2019 with the supposedly corrected bank details.

ACCOUNT NUMBER: REDACTED XXX

Sort Code: XXXX

SWIFTBIC: XXXX

On November 19, 2019 email was received from email2 to Ms. Faal enquiring about the status of the payment. It was on this same day that the PCU sent payment instruction to the CBG for processing on the using the supposedly corrected bank details.  The payment was then effected by the CBG on November 21, 2019.

On November 26, 2019, an email was on this occasion sent to Mrs. Awa K John from email 2 following up on the payment insisting that the payment had yet been received.  This was the last mail from email 2.

Mrs. Awa K John responded to the email on December 13, 2019 confirming that the payment had been effected by the CBG on November 21, 2019.

Based on the transcript, it was not until December 20, 2019 that Ms. Cameron finally wrote to Ms. Faal using email1. In the email, she stated that her bank had traced the funds and told her that the money had been sent to a wrong account. She indicated that the SWIFT/IBAN numbers that the funds were sent to did not march details on the one she has sent on November 6, 2019. She further reported that the account was a personal account and was closed. She then urged Ms. Faal to recall the funds as per Barclays’ advise and resend the funds using the correct bank details.

From our investigations, contrary to the suggestion that there were two emails used to perpetrate this fraud, it turns out that it was only one email. Notice that whoever created this fraudulent email used Ms. Cameron’s email account their name to create email2 using the website mail.com. This site allows any individual to create a customized email within five minutes.

          CONCLUSION

The sequence of events as per the transcript raises many questions, for instance, why did PAI and Ms. Cameron request on November 6 and 7, 2019 that the funds into an account different from the one on the contract?  More important question is why did the PCU/MoFEA seemingly oblige to that change?   These actions created an opportunity for the fraudster to take advantage. It made it possible for the third time all in the guise of correcting a supposedly erroneous IBAN sent earlier by Ms. Cameron.

Another important question is, why did Ms. Cameron wait for over a month (as per the transcript) to follow up on a payment she requested?  Remember, while the fraud was been attempted or executed, the transcript did not show that Ms. Cameron reached out to the PCU/MoFEA using her email or telephone.

From the timeline of events on the transcript, it is clear that the fraud started to conceptualize on November 8, 2019, just two and three days after she requested for the payments on the invoice on November 6 and 7, 2019. Ms. Cameron sent mails using email1. However, from November 9 to 26, 2019, mails were being received from only email2 according to the transcript.  Notice that this was the period that the fraud was being executed.

Nonetheless, what is obvious is that whoever committed this fraud was aware that the payment of this funds was imminent.  All that the individual had to do was to create their own email on mail.com and start exchanging emails to redirect the funds their chosen bank details.  This is a clear case of email spoofing.

It is very difficult to not consider this an inside job giving the number of individuals in the email distribution and the ease with which email spoofing could be done using mail.com.

However, the strange part of this fraud is that the fraudster requested that the funds sent to Barclays Bank Plc, the same bank it was original meant to go to albeit now to a personal account.  The question that arises now is that, is it possible that any of the individuals on the email distribution list (who all have information on the payment) have the ability to open an account with or had an account with Barclays Bank Plc?

Yes PAI maintains accounts with Barclays Bank Plc but it is important to remember the bank is also an international bank that any individual who has the opportunity to travel or who has relatives in the UK could have used their personal/acquaintance’s account to perpetrate this fraud.

Nonetheless, what is worrying is that Ms. Cameron initially attempted to get the PCU to resend the funds without reporting or relaying that the funds had been fraudulently withdrawn. Based on the transcript, she only categorically confirmed that there was fraud on April 6, 2020 which was almost five months after the events.  Given her relationship with the bank, you’d expect that she would press the bank to report the fraud to the appropriate authorities.

Ultimately though, the progress of this case can only be possible if additional information can be obtained from Barclays Bank Plc, perhaps through the Financial Conduct Authority of UK regarding the KYC details of the account used to perpetrate this fraud.