Is there evidence that the country’s defence institutions have controlling or financial interests in businesses associated with the country’s natural resource exploitation and, if so, are these interests publicly stated and subject to scrutiny?
Is there evidence that the country’s defence institutions have controlling or financial interests in businesses associated with the country’s natural resource exploitation and, if so, are these interests publicly stated and subject to scrutiny?
18a. Legal framework
Score
SCORE: 100/100
Rubric
Benin score: 100/100
Score: 0/100
There are no restrictions on defence institutions or individuals having controlling or financial interests in businesses associated with the country’s natural resource exploitation
Score: 50/100
Defence institutions are, by statutory or constitutional means, somewhat removed from having controlling or financial interests in businesses associated with the country’s natural resource exploitation
Score: 100/100
Defence institutions are, by statutory or constitutional means, entirely prohibited from having controlling or financial interests in businesses associated with the country’s natural resource exploitation
Assessor Explanation
In Benin, the defence institution is the army; and it is not constitutionally allowed to have majority or financial interests in companies associated with the exploitation of the country’s natural resources [1][2]. Public officials, including defence and security forces, must not exercise any function, or engage in any transaction, nor hold a financial or commercial interest incompatible with their professions [3]. The law does not explain what incompatible means. Moreover, in Benin, there is no evidence that defence institutions or members of the armed forces have financial interests or exercise direct control in companies linked to the exploitation of natural resources. Also no legislative text mentions or regulates commercial activities authorizsed for security forces. defence institutions in Benin are limited in their scope to security and national protection missions, and natural resources are generally under the control of specializsed ministries, such as those of Mines and Energy [3].
Assessor Sources
1. Beninese Constitution of 11 December 1990
2.Interview 14, interview with a Captain in the Military stewardship, July 17, 2024 & Interview 15, interview with a Colonel at the General Staff of the Army, June 17, 2024 & Interview 16, interview with a Gender, peace and security Expert, June 20, 2024.
3. Decree N° 2022 related to code of ethics in public administration.
18b. Defence institutions: Financial or controlling interests in practice
Score
SCORE: 100/100
Rubric
Benin score: 100/100
Score: 0/100
Defence institutions involvement in businesses relating to the country’s natural resource exploitation is widespread and mostly illicit.
Score: 25/100
Defence institutions involvement in businesses relating to the country’s natural resource exploitation is widespread, but considered legal.
Score: 50/100
There may be instances of defence institutions involvement in businesses relating to the country’s natural resource exploitation, but activity is unregulated.
Score: 75/100
There may be instances of defence institutions involvement in businesses relating to the country’s natural resource exploitation, but activity is regulated.
Score: 100/100
There are no cases of defence institutions being involved in businesses relating to the country’s natural resource exploitation.
Assessor Explanation
There are no cases of individual defence personnel being involved in businesses relating to the country’s natural resource exploitation. [1] Public officials, including defense and security forces, must not exercise any function, or engage in any transaction, nor hold a financial or commercial interest incompatible with their professions. In Benin, there is no evidence that defense institutions or members of the armed forces have financial interests or exercise direct control in companies linked to the exploitation of natural resources.[2]
Assessor Sources
1.Interview 14, interview with a Captain in the Military stewardship, July 17, 2024 & Interview 15, interview with a Colonel at the General Staff of the Army, June 17, 2024 & Interview 16, interview with a Gender, peace and security Expert, June 20, 2024.
2. Decree N° 2022 related to code of ethics in public administration.
18c. Individual defence personnel: Financial or controlling interests in practice
Score
SCORE: 100/100
Rubric
Benin score: 100/100
Score: 0/100
Individual defence personnel involvement in businesses relating to the country’s natural resource exploitation is widespread and mostly illicit.
Score: 25/100
Individual defence personnel involvement in businesses relating to the country’s natural resource exploitation may be common in areas with major revenue streams.
Score: 50/100
Individual defence personnel involvement in businesses relating to the country’s natural resource exploitation may be common in areas with major revenue streams. The government is actively seeking to tackle or regulate the issue.
Score: 75/100
There may be isolated cases of individual defence personnel being involved in businesses relating to the country’s natural resource exploitation, but activity is illicit.
Score: 100/100
There are no cases of individual defence personnel being involved in businesses relating to the country’s natural resource exploitation, OR there may be isolated cases, but activity is legal.
Assessor Explanation
There are no cases of individual defence institutions personnel being involved in businesses relating to the country’s natural resource exploitation [1]. Public officials, including defense and security forces, must not exercise any function, or engage in any transaction, nor hold a financial or commercial interest incompatible with their professions. In Benin, there is no evidence that defense institutions or personnel of the armed forces have financial interests or exercise direct control in companies linked to the exploitation of natural resources [2].
Assessor Sources
1. Interview 14, interview with a Captain in the Military stewardship, July 17, 2024 & Interview 15, interview with a Colonel at the General Staff of the Army, June 17, 2024 & Interview 16, interview with a Gender, peace and security Expert, June 20, 2024.
2. Decree N° 2022 related to code of ethics in public administration.
18d. Transparency
Score
SCORE: NA/100
Rubric
Benin score: NA/100
Score: 0/100
These interests are not publicly declared and are wholly non-transparent.
Score: 50/100
These interests are publicly declared, though details of their operations and expenditures are not transparent.
Score: 100/100
These interests are publicly declared, with details of sources of income, operations, and expenditures being transparent, fully disclosed, and with standards of governance equivalent to publicly owned commercial enterprises.
Assessor Explanation
Public officials, including defense and security forces, must not exercise any function, or engage in any transaction, nor hold a financial or commercial interest incompatible with their professions. In Benin, there is no evidence that defense institutions or members of the armed forces have financial interests or exercise direct control in companies linked to the exploitation of natural resources [1] [2]. We were not able to find any evidence that such interests exist so this indicator is marked Not Applicable.
Assessor Sources
1.Interview 14, interview with a Captain in the Military stewardship, July 17, 2024 & Interview 15, interview with a Colonel at the General Staff of the Army, June 17, 2024 & Interview 16, interview with a Gender, peace and security Expert, June 20, 2024.
2. Decree N° 2022 related to code of ethics in public administration.
18e. Scrutiny
Score
SCORE: NA/100
Rubric
Benin score: NA/100
Score: 0/100
These interests are subject to no form of scrutiny.
Score: 50/100
These interests are subject to public and/ or parliamentary scrutiny that explicitly analyses the potential for impropriety, but the scrutiny is superficial in nature or rarely conducted.
Score: 100/100
These interests are subject to public and/ or parliamentary scrutiny that explicitly analyses the potential for impropriety.
Assessor Explanation
Public officials, includingdefence and security forces, must not exercise any function, or engage in any transaction, nor hold a financial or commercial interest incompatible with their professions. In Benin, there is no evidence that defense institutions or members of the armed forces have financial interests or exercise direct control in companies linked to the exploitation of natural resources [1] [2]. We were not able to find any evidence that such interests exist so this indicator is marked Not Applicable.
Assessor Sources
1. Interview 14, interview with a Captain in the Military stewardship, July 17, 2024 & Interview 15, interview with a Colonel at the General Staff of the Army, June 17, 2024 & Interview 16, interview with a Gender, peace and security Expert, June 20, 2024.
2. Decree N° 2022 related to code of ethics in public administration.
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Country
18a. Legal framework
18b. Defence institutions: Financial or controlling interests in practice
18c. Individual defence personnel: Financial or controlling interests in practice
18d. Transparency
18e. Scrutiny
Benin
In Benin, the defence institution is the army; and it is not constitutionally allowed to have majority or financial interests in companies associated with the exploitation of the country’s natural resources [1][2]. Public officials, including defence and security forces, must not exercise any function, or engage in any transaction, nor hold a financial or commercial interest incompatible with their professions [3]. The law does not explain what incompatible means. Moreover, in Benin, there is no evidence that defence institutions or members of the armed forces have financial interests or exercise direct control in companies linked to the exploitation of natural resources. Also no legislative text mentions or regulates commercial activities authorizsed for security forces. defence institutions in Benin are limited in their scope to security and national protection missions, and natural resources are generally under the control of specializsed ministries, such as those of Mines and Energy [3].
100 / 100
There are no cases of individual defence personnel being involved in businesses relating to the country’s natural resource exploitation. [1] Public officials, including defense and security forces, must not exercise any function, or engage in any transaction, nor hold a financial or commercial interest incompatible with their professions. In Benin, there is no evidence that defense institutions or members of the armed forces have financial interests or exercise direct control in companies linked to the exploitation of natural resources.[2]
100 / 100
There are no cases of individual defence institutions personnel being involved in businesses relating to the country’s natural resource exploitation [1]. Public officials, including defense and security forces, must not exercise any function, or engage in any transaction, nor hold a financial or commercial interest incompatible with their professions. In Benin, there is no evidence that defense institutions or personnel of the armed forces have financial interests or exercise direct control in companies linked to the exploitation of natural resources [2].
100 / 100
Public officials, including defense and security forces, must not exercise any function, or engage in any transaction, nor hold a financial or commercial interest incompatible with their professions. In Benin, there is no evidence that defense institutions or members of the armed forces have financial interests or exercise direct control in companies linked to the exploitation of natural resources [1] [2]. We were not able to find any evidence that such interests exist so this indicator is marked Not Applicable.
NA
Public officials, includingdefence and security forces, must not exercise any function, or engage in any transaction, nor hold a financial or commercial interest incompatible with their professions. In Benin, there is no evidence that defense institutions or members of the armed forces have financial interests or exercise direct control in companies linked to the exploitation of natural resources [1] [2]. We were not able to find any evidence that such interests exist so this indicator is marked Not Applicable.
NA
Burundi
Whether it is the constitution or the specific law of the Burundi National Defence Force, no text prohibits members of this body from having control or financial interests related to the exploitation of the country’s natural resources [1][2].
0 / 100
The Burundian army is actively involved in exploiting natural resources in DR Congo [1] as there is traditionally little mining in Burundi. The army seems to be present in the new coltan mine in Burundi [2].
25 / 100
Burundian civil society organizations continue to denounce the presence of high-ranking officers in the Burundian commercial sector. In particular, their names come up in the sector of exploitation of natural resources, particularly minerals and tree plantations.The involvement of these high-ranking military officers is completely illegal. [1] [2] [3]
0 / 100
Evidence gathered from the interviews suggests that such individual interests exist. They are reflected in the acquisition of numerous real estate assets by the high-ranking officers involved [1]. However, they are difficult to trace due to the opacity that marks the natural resources sector in general and the mining sector in particular [2].
0 / 100
Evidence from the interviews suggests that there is no form of control around these interests, including any forms of scrutiny [1] [2]. Except for denunciations that civil society organizsations have always tried to make [2].For example, in 2022, the NGO ‘Initiative for Human Rights in Burundi’ denounced the involvement of high-ranking Burundian officials in mineral trafficking, particularly in the Democratic Republic of Congo [3].
0 / 100
Cameroon
There is no specific legal provision restricting defence and security forces from having interests in businesses related to the country’s natural resources or exploitation. However, it is worth highlighting that civil servants (whether civilians or security forces) in Cameroon are legally prohibited from engaging in certain types of businesses, including policemen and soldiers.[1] Moreover, Law No. 2017/010 of 12 July 2017 on the General Statute of the Military Personnel prohibits soldiers from participating in private commercial activities directly or indirectly.[2]
0 / 100
The defence institutions in Cameroon are not involved in businesses related to the country’s natural resource exploitation. Defence institutions are regalian organisations that are not involved in the trade of natural resources.[1] In addition, it is the Ministry of Mines, Industry and Technological Development that handles issues concerning natural resources in Cameroon.[2]
100 / 100
In Cameroon, the military is not directly involved in the exploitation of natural resources. However, they can profit from certain resources, but they are not the owners of wells drilled. For example, Merlin Otou has shown that the military collect taxes from artisanal gold mining in Batouri and Bétaré-Oya in East-Cameroon.[1] In addition, some high-ranking army members have trucks loaded with logs on an informal basis. Offically, however, logging papers are usually in the names of third parties or their relatives, and thus, logging is done by proxyies. As a result, it is often impossible to trace acquisitions based on the human resources of the top brass. The activity may be legal on individual basis, but it is performed by a proxy or an intermediary.[2] Moreover, these activities are illicit firstly because they are carried out by proxies and secondly because they create envivronment that benefits certain individuals while impoverishing the country already impoverished.
According to a study conducted in March 2021 (and again in 2024) as part of the ENACT (Enhancing Africa’s response to transnational organised crime) project, the smuggling of adulterated fuel is perpetuated through collusion between states (Nigeria and Cameroon). This is because the security forces responsible for combating oil trafficking are profiting from the illicit trade they are supposed to curb. According to ENACT, the Cameroonian police and military officers tasked with combating smuggling and cross-border crime belong to the criminal groups organising the oil trafficking from Nigeria. These state agents, responsible for prevention and control seize smuggled oil from illegal importers, then sell it to other merchants who market it.[3][4]
0 / 100
In cases where individuals within the Defence forces have an interest in controling or exploiting the country’s natural resources, these interests are not publicly declared and lack transparency.[1] The profits generated from such activities are often earned fraudulently at the country’s expense. Some interviewees pointed out that such interests are linked to money laundering.[2]
0 / 100
In cases where individuals within the Defence forces have an interest in controlling or exploiting the country’s natural resources, these interests are not subjected to scrutiny.[1] These businesses are carried out covertly or through proxies. As a result, scrutiny is not possible because most of these businesses leave no trace.[2]
0 / 100
Cote d'Ivoire
The Ivorian Constitution and defence legislation do not contain any clear and explicit prohibition specifically prohibiting defence institutions from holding financial or controlling interests in companies involved in the exploitation of natural resources. [1] However, other legislation governing the management of natural resources or the conduct of civil servants may de facto limit such interests. [2][3]
0 / 100
No cases of defence institutions being involved in commercial activities related to the exploitation of the country’s natural resources have been reported in the last five years. [1] [2]
100 / 100
There may be isolated cases of defence personnel involved in commercial activities related to the exploitation of the country’s natural resources [1]. For example, members of the Ministry of Defence were involved in a gold mining case in 2021 [2].
75 / 100
There is no evidence that these interests are publicly declared, although asset declarations are mandatory for civil servants [1]. This could also be explained by the fact that these are isolated cases among defence personnel and that the only case identified concerned illegal gold mining [2].
0 / 100
There is no evidence that these interests are publicly declared, although asset declarations are mandatory for civil servants [1]. There is therefore no evidence that these specific interests are subject to any form of control. This could also be explained by the fact that there are only isolated cases among defence personnel and that the only case identified concerned illegal gold mining [2].
0 / 100
Ghana
The are no existing legal frameworks that prohibit defence institutions and individuals from engaging in business duties of financial interest in the country’s natural resources.[1] There is, however, no case that point to the defence institution engaging in natural resources exploitation. [2]
0 / 100
There are no cases to show that defence institutions have been involved in business activities related to the exploitation of Ghana’s natural resources. [1] However, the state has primarily employed its services to fight against illegal exploration of natural resources in the country. Operation Vanguard and Operation Halt I and II, responsible for combating illegal mining in the country’s mining communities, serve as a prime example. In a courtesy call on March 20224, Hon. Samuel Jinapor, the Minister of Lands and Natural Resources, lauded the GAF for its instrumental role in maintaining the environment and fighting illegal mining in the country. [2] [3]
100 / 100
There are no cases where individuals of the force officially engage in the exploration of natural resources. There are, however, cases where individuals have been caught indulging in illegal natural resource exploration-related activities, and such individuals have faced formal legal processes by the defence institution. (1) (2) (3)
75 / 100
This indicator has been marked ‘Not Applicable’ as defence institutions have not formally declared any interest in resource exploitation in Ghana. (1) (2)
NA
This indicator has been marked ‘Not Applicable’ as defence institutions have not formally declared any interest in resource exploitation in Ghana. (1) (2)
NA
Kenya
In Kenya, there is no explicit legislation prohibiting the military from controlling financial interests in businesses associated with the country’s natural resources [1, 2]. However, the situation differs for military personnel. The Constitution, Kenya Defence Forces Act, Public Officer Ethics Act, and conflict of interest provisions in PPADA limit personnel’s involvement in business activities to prevent conflicts of interest and ensure their focus remains on public duties [3, 4].
The military’s involvement in land ownership and business ventures has been a topic of discussion and concern. According to the most recent Annual Performance Report, the MoD faces significant challenges related to Military Lands [5]. These issues include disputes, conflicts, and encroachment on designated military areas, as well as uncontrolled development on adjacent lands. Such challenges pose a substantial threat to the MoD’s capacity to fulfil its long-term mandate effectively [6].
50 / 100
The KDF and MoD have been involved in multiple land disputes, with orders to vacate encroached land in Marsabit (2,500 hectares) [3], court rulings in Embakasi [2], and stalled cases like the Laikipia training area case [1]. These indicate institutional landholding conflicts, not commercial or resource-related business interests.
There is no publicly available evidence that the Ministry of Defence or its agencies hold or profit from natural resource exploitation ventures [5]. No reports, contracts, or disclosures point to ownership stakes in businesses operating in mining, forestry, oil, or similar sectors. Interpol has noted the presence of organised crime groups in East Africa, controlling some gold mining sites and smuggling routes, but they do not mention the likelihood of KDA’s involvement in these bussinesses [4]. The land disputes appear tied to operational use rather than commercial exploitation [1, 2, 3].
100 / 100
While there are no formal reports linking the KDF to natural resource exploitation, the military faces significant land-related challenges. Currently, KDF is involved in over 20 land dispute cases, including 15 active court litigations. These cases primarily involve allegations of illegal land acquisition, boundary disputes, and community land encroachment, with local communities claiming forced displacement for military bases and training grounds. These ongoing disputes have created tension between KDF and local communities, raising important questions about military land acquisition procedures and compliance with constitutional land rights.
Despite these land disputes, there is no evidence available that shows defence personnel as majority shareholders or controlling directors of major resource-extraction companies in Kenya [4].
100 / 100
Kenyan law requires public officers, including military officers to declare assets and conflicts of interest under the Leadership and Integrity Act (2012) and the Public Officer Ethics Act (2003). These declarations are submitted to the relevant authorities, such as the EACC. However, the declarations are not made public, and there is no evidence that details of income sources, operations, or expenditures of defence officials are disclosed in a transparent manner [3].
25 / 100
Public Officer Ethics Act (2003) and Leadership & Integrity Act (2012) require all public officers, including defence officers, to declare assets, liabilities, and interests [1]. Declarations are submitted internally to the Ethics and Anti-Corruption Commission [2], but they are not made public. As a result, they are not subject to external or public scrutiny, and no records are available to indicate that they are systematically reviewed [3].
0 / 100
Liberia
The 2008 National Defense Act of Liberia explicitly prohibits members of the Armed Forces of Liberia (AFL) from engaging in outside employment without prior written approval from their commanding officer, as stipulated in Chapter 8 as follows: “all members of the AFL shall give a full commitment to their jobs and shall not take up outside pay or remunerative employment without the express written permission of their commanding officer in accordance with the guidelines issued by the Ministry of National Defense.”[1] However, this provision specifically addresses military personnel and does not clearly extend to civilian staff within the Ministry of National Defense.[2]
For civilian public servants, including those in the defence sector, the 2014 Code of Conduct for Public Officials and Employees of the Government of Liberia serves as the primary guideline. This Code mandates the disclosure of personal interests and business affiliations to prevent conflicts of interest. Despite its establishment, adherence to the Code has been inconsistent. The Office of the Ombudsman, created to enforce the Code, has faced delays in becoming fully operational, hindering effective oversight.[2][3][4]
Historically, during the civil conflict, defence institutions were directly involved in natural resource exploitation to finance military activities. Notably, former President Charles Taylor collaborated with companies like the Oriental Timber Company (OTC) and Exotic Tropic Timber Enterprises (ETTE), exchanging timber rights for arms. These actions were highlighted in the Truth and Reconciliation Commission’s reports, which recommended prosecutions for economic crimes related to such exploitations.[5]
In the post-conflict era, while there is no publicly available evidence indicating that current defence institutions hold financial interests in natural resource businesses, concerns may persist regarding conflicts of interest among public officials. While legislative frameworks exist to prevent conflicts of interest among both military and civilian personnel in Liberia’s defence sector, enforcement remains a challenge.
50 / 100
While there is no recent public documentation or findings directly linking current defence institutions in Liberia to businesses in the natural resource sector,[1] historical and systemic issues suggest that regulation and oversight remain inadequate.
Historically, the link between the defence sector and resource exploitation in Liberia is well documented. During Liberia’s civil wars (1989–1996; 1999–2003), leaders of armed factions—who also held formal command over security institutions—actively exploited natural resources to fund conflict. Charles Taylor, then President and Commander-in-Chief of the Armed Forces of Liberia (AFL), facilitated arms-for-timber deals with foreign companies such as the Oriental Timber Company (OTC), managed by Dutch arms dealer Guus Kouwenhoven. Similarly, the Exotic Tropical Timber Enterprise (ETTE) was also implicated in exchanging arms for logging concessions. These exploitative networks were highlighted in Liberia’s Truth and Reconciliation Commission (TRC) Final Report, which described such actions as economic crimes and recommended prosecution of several individuals, including Taylor-era officials such as Benoni Urey.[2]
In the post-conflict era, efforts have been made to reform the natural resource sector. However, reports indicate that illegal practices persist. A 2017 Global Witness investigation revealed that all of Liberia’s large logging contracts were illegal on multiple counts, with some companies owned by powerful government officials, including members of the House of Representatives.[3]
More recently, a 2025 U4 report on Liberia’s mining sector highlights systemic corruption in resource governance, noting that even foreign investors recognise pervasive corruption in areas like mining concessions and procurement, though this did not single out defence institutions.[4]
There is no evidence of systematic oversight of business affiliations or asset declarations for defence personnel, nor are there strong internal or external review mechanisms specifically targeting the defence sector’s potential involvement in the natural resource economy. However, the activity is regulated by law.
75 / 100
The Liberian government has established legal frameworks aimed at regulating the involvement of defence personnel in private enterprises. The 2008 National Defense Act mandates that members of the Armed Forces of Liberia (AFL) must obtain written permission from their commanding officer before engaging in any remunerative employment outside their official duties. Additionally, the Code of Conduct for Public Officials and Employees requires public servants to declare any personal interests or business affiliations to prevent conflicts of interest.[1][2]
Reports indicate that some defence personnel have co-ownership stakes in private security companies (PSCs). These firms primarily offer services such as safeguarding private properties and providing security for various entities. The private security industry in Liberia has expanded significantly, with approximately 127 PSCs employing around 7,000 personnel. These companies often operate in sectors like rubber and logging, providing security services to compensate for the government’s limited capacity to ensure law and order in these areas.[3]
The full extent to which defence personnel are involved in natural resources are unknown. Nonetheless, the government is seeking to regulate practice by trying to enforce the Code of Conduct policy and identify through audits infractions of the law and how it is linked to these private security firms. The Liberian government has established legal frameworks aimed at regulating the involvement of defence personnel in private enterprises.[4]
50 / 100
The transparency of public officials’ interests in Liberia, particularly around asset declarations and conflict of interest, remains a significant challenge. While the Code of Conduct for Public Officials and Employees (2014) mandates asset disclosure and conflict of interest declarations, enforcement has been inconsistent.[1] In February 2025, President Boakai suspended over 450 officials for failing to declare assets on time—an unprecedented enforcement move demonstrating both the rule’s fragility and its potential reach.[2]
However, when it comes to transparency specifically involving defence institutions and their potential entanglements with natural resource exploitation, the situation is unclear.
No public data exists on asset declarations of Defence Ministry officials, senior AFL officers, or Inspector General staff, making it challenging to assess whether they hold interests in sectors such as mining, forestry, among others. Advocacy groups like CENTAL regularly call on the government to enforce the Code in defence institutions, but there appears to be no systematic follow-through or publicly available register for these officials.[3]
Global Witness flagged prominent ownership of logging concessions by politically connected individuals, but it is not verified whether active or retired defence personnel were involved, due to lack of transparent asset registers or conflict of interest disclosures.[4]
Although legal frameworks for asset disclosure and transparency are in place, their application to defence-sector personnel, especially concerning resource-sector affiliations, is not available in the public domain.
0 / 100
The scrutiny of public officials’ financial interests in Liberia, particularly concerning asset declarations, has been largely superficial. The Liberia Anti-Corruption Commission (LACC) is designated as the repository for these declarations. However, compliance has been low. As of July 31, 2024, only 26.5% of the 1,900 identified public officials had submitted their asset declarations. In the Executive Branch, only 322 out of 1,281 officials complied, while in the Judiciary, a mere 28 out of 333 officials fulfilled this requirement. The Legislative Branch also showed poor compliance, with only 12 out of 30 senators and 26 out of 73 representatives declaring their assets. The scrutiny of interest is sometimes politically motivated and not carried out as a matter of procedure or action consistent with the code of conduct as specified in the law. [1][2]
However, there is no evidence of systematic scrutiny of asset declarations or financial interests specifically targeting defence institutions, or investigations into the involvement of defence officials in businesses related to natural resource exploitation. This gap is significant given Liberia’s history of resource-linked conflicts and allegations of military-linked economic crimes during the civil war era. While civil society organisations such as CENTAL have raised concerns about weak enforcement of the Code of Conduct across government,[3] no publicly available reports suggest that defence personnel have been singled out for monitoring in relation to natural resource businesses.
0 / 100
Madagascar
There is a legal vacuum regarding the ability of defense institutions to hold controlling or financial interests in commercial activities associated with the exploitation of the country’s natural resources. No legal provision mentions the possible participation of defense institutions in any commercial activity related to the exploitation of natural resources. Moreover, the Ministry of Defense does not own any commercial enterprise in the natural resources sector [1] [2].
0 / 100
No evidence was found of the institutions responsible for defense being involved in the exploitation of the country’s natural resources [1][2].
100 / 100
According to article 21 of Law No. 96-029 on the General Statute of the Military “the career soldier or the soldier serving under contract can carry out certain lucrative activities on a subsidiary basis without this hindering the smooth running of the service or compromising his independence and his availability under the following conditions: he cannot subscribe no employment contract and he cannot, by himself or through an intermediary, be supplier of foodstuffs, materials and services of any nature whatsoever and intended for a military establishment or organization” [1]. This means that a soldier, as an individual, can have commercial activities relating to the exploitation natural resources of the country and this activity is legal [2]. However, there are no publicly documented cases of uniformed Malagasy defence personnel formally owning or controlling legal concessions in forestry, mining, or other natural-resource enterprises.
100 / 100
Evidence suggests that the institutions responsible for defence are not involved in the exploitation of the country’s natural resources [1][2]. As such, this indicator is scored Not Applicable.
NA
The institutions responsible for defence are not involved in the exploitation of the country’s natural resources [1][2]. As such, this indicator is scored Not Applicable.
NA
Mali
The law prohibits defence institutions from holding controlling or financial interests in commercial activities that exploit the country’s natural resources.[1][2] Furthermore, the constitution confines defence and security institutions to a role of defending the integrity of national territory, the protecting people and their property, the maintaing public order and executing laws. The defence institutions following the various texts which govern the sector, among which the general status of the military, do not authorise them to hold financial controlling interests in commercial activities relating to the exploitation of the country’s natural resources. No report on the defence and security sector has been published by the control and audit bodies since the incident of the presidential plane and military equipment.
100 / 100
There is no proven case of involvement by defence institutions in commercial activities related to the exploitation of natural resources; the State participation in companies and operations relating to the exploitation of natural resources is not reported as of March 31, 2024 by the Ministry of the Economy and Finance. There is no mention of any involvement of defence institutions in the companies in question.[1][2][3]
100 / 100
There might be some isolated cases of individuals being involved, but the activity is totaly illicit. It emerges from the general status of the military, which imposes a constant ban on members of the defence sector from engaging in lucrative activities of any nature whatsoever. Indeed, the normative framework generally does not authorise military personnel from institutions responsible for defence to become involved in ways that allow them to profit from commercial activities, including those related to the exploitation of natural resources.[1] Officially, and if we rely on the formal exploitation activities of natural resources, it appears from various reports, notably those of the EITI for the mining sector and in accordance with the principle of the beneficial owner, no defence personnel are included in the summary table of declarations of real ownership of extractive entities included in the conciliation scope [3]. This notion of beneficial owner is governed by the directive; the notion of beneficial owner is governed in Mali by Community Directive No. 02/2015/CM/UEMOA and Law No. 2016/008/ of March 17, 2006 on the uniform law relating to the fight against money laundering and the financing of terrorism.
75 / 100
There is no evidence that such interests exist so this indicator is marked Not Applicable. It emerges from the general status of the military that there is a constant ban on members of the defence sector from engaging in lucrative activities of any nature whatsoever.[1] Indeed, the normative framework generally does not authorise military personnel in institutions responsible for defence to become involved in ways that could lead to profit from commercial activities, including related to the exploitation of natural resources.[2]
Officially, and based on the formal exploitation activities of natural resources, it appears from the available reports, notably those of the EITI for the mining sector and according to the principle of the beneficial owner, that no defence force personnel are included in the summary table of declarations of real ownership of extractive entities within the scope of conciliation. This notion of beneficial owner is governed in Mali by Community Directive No. 02/2015/CM/UEMOA and Law No. 2016/008/ of March 17, 2006 on the uniform law relating to the fight against money laundering and the financing of terrorism.
NA
There is no evidence that such interests exist so this indicator is marked Not Applicable. It emerges from the general status of the military that there is a constant ban on members of the defence sector from engaging in lucrative activities of any nature whatsoever.[1] Indeed, the normative framework generally does not authorise military personnel in institutions responsible for defence to become involved in ways that could lead to profit from commercial activities, including related to the exploitation of natural resources.[2]
Officially, and based on the formal exploitation activities of natural resources, it appears from the available reports available, notably those of the EITI for the mining sector and according to the principle of the beneficial owner, that no defence force personnel are included in the summary table of declarations of real ownership of extractive entities within the scope of conciliation scope.[3] This notion of beneficial owner is governed in Mali by Community Directive No. 02/2015/CM/UEMOA and Law No. 2016/008/ of March 17, 2006 on the uniform law relating to the fight against money laundering and the financing of terrorism.
NA
Mozambique
The Constitution of the Republic [1], the Defence and Security Policy [2], and the Law on National Defence and the Armed Forces [3] do not explicitly authorise or restrict the involvement of Defence and Security Forces in commercial activities. However, in practice, the Defence and Security Forces operate companies that provide private security services (such as Monte Binga, owned by the Armed Forces) and civil construction services (such as Empresa Dalo, linked to the Police Forces).
Monte Binga has a background of being directly involved in natural resource exploitation activities. Specifically, it formed a joint venture with a Chinese company in aquaculture and fisheries, and participated in the exploitation of gold and other minerals in Niassa Province [5]. Additionally, Monte Binga holds a 50% equity stake in ProIndicus, a company involved in natural resource–related projects alongside SISE (state intelligence), suggesting further strategic ties between defence interests and resource-related firms [6].
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The Constitution of the Republic and Defence Policy would prohibit defence institutions from engaging in business related to the exploitation of the country’s natural resources, as the Armed Forces are state bodies whose exclusive function is to provide for the national defence of the State, guarantee territorial integrity and sovereignty [1, 2]. However, information circulates about security provision contracts between the Ministry of National Defence (Armed Forces) and natural gas exploration companies, to guarantee land and maritime security in the Rovuma Basin, in Cabo Delgado, but which are classified as secret [3]. For example, in August 2024, a courtesy meeting between the Minister of National Defence and the General Director of ENI-Rovuma Basin Mozambique (company that explores liquefied natural gas – LNG) was reported, to assess activities in the Rovuma Basin, where security provision contracts was discussed [4]. Therefore, legally, this type of service that results in charges could not happen, because companies pay taxes, as happened in 2022, where they paid 34.5 million dollars to the Ministry of Economy and Finance [5]. The companies EMATUM, PROINDICUS and MAM had been created by the Defence and Security institutions (Armed Forces, Police and Intelligence Services) to provide security and logistics services in the research, discovery and exploration of hydrocarbons projects in the Rovuma Basin, which culminated in cases of corruption, money laundering and the famous “Hidden Debts” [6].
50 / 100
The Statute of the Military of the Armed Forces of Mozambique states that military personnel, in the exercise of their functions, are exclusively at the service of the Armed Forces and that civilian activities of a political and economic nature, without authorisation, are incompatible with the mission, preventing defence personnel from participating in individual businesses related to the exploitation of natural resources in the country or abroad [1]. However, research indicates that there are unauthorised private interests involving military personnel and former combatants linked to activities related to gold and natural gas mining in Northern Mozambique, providing logistics services and private security, among others [2, 3].
50 / 100
The Constitution of the Republic as well as the Defence Policy attribute the exclusive function of the Armed Forces to guaranteeing the military component of National Defence, and the Statute of the Military of the Armed Forces of Defence of Mozambique states that the military, in the exercise of their functions, is exclusively at the service of the Armed Forces [1, 2]. In terms of transparency, with these two legal requirements, the interests and contracts for the provision of land and maritime security services for the exploration projects of rubies and liquefied natural gas in the North of Mozambique [3, 4] are not publicly declared, not transparent and normally classified as secret [5, 6].
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The interests and business of defence institutions associated with the exploitation of natural resources, particularly in Northern Mozambique, where mineral resources and liquefied natural gas are exploited [1, 2], are only subject to internal scrutiny by the National Defence Inspectorate, in accordance with its powers set out in Ministerial Decree No. 89/2006 of 10 May. This decree approves the Internal Regulations of the General Defence Inspectorate [3], whose reports and recommendations are not in the public domain, as they are classified as secret [4]. Payments are neither public nor included in the State Budget or Budget Execution Reports, to be subject to external scrutiny by the Assembly of the Republic, civil society, journalists or academic institutions [5, 6].
50 / 100
Niger
Niger, a leading global producer of uranium and a significant player in the gold and oil sectors does not have a clear legal framework that explicitly prevents defense institutions from having controlling or financial interests in businesses related to the exploitation of natural resources. The Mining Code 2022 (Law No. 2022-033) [1), along with its amendment through Law No. 2023-03, governs the exploration, exploitation, and management of mineral and fossil resources. While it provides comprehensive regulations for the sector, it does not explicitly address the involvement of defense institutions in natural resource businesses [2].The 2010 7th Constitution established principles of transparency in natural resource contracts (Article 150) and revenue sharing between the central government and local authorities (Article 152). However, while Article 150 mandated that all revenues from natural resources must be disclosed and transferred to the state, it does not explicitly prohibit defense institutions from maintaining controlling or financial interests in these sectors. This regulatory gap leaves room for potential involvement of defense institutions in natural resource businesses without clear oversight or public disclosure [3]. Following the military coup in July 26, 2023, the government took significant actions affecting the natural resource sector, such as lifting the suspension on mining rights on August 27, 2024, which had been in place since January 22, 2024. The new ordinance introduced measures to strengthen national sovereignty over natural resources, including increased taxes and royalties, promotion of national operators, and the application of “polluter-pays” and “extractor-pays” principles. However, these reforms do not explicitly address the role of defense institutions in resource management or business interests [4). Given the absence of explicit restrictions in Niger’s legal framework and the lack of provisions addressing defense institutions’ interests in natural resource businesses, there is no strong evidence of safeguards against such involvement.
0 / 100
Since the military coup of July 26, 2023, and the subsequent strengthening of Niger’s diplomatic ties with Russia, concerns have been raised regarding potential defense sector involvement in mining activities [1]. Such fears were informed by Russia’s influence in other countries like the Central African Republic (RCA) and Mali, where national defense institutions have reportedly become heavily entangled in mining operations [3]. However, in the case of Niger, no verified evidence currently confirms systematic defense sector control over mining sites. Small Arms Survey reports mention isolated cases where individual defense and security personnel are informally involved in mining-related activities, particularly in artisanal mining zones [6]. Allegations of potential uranium deals between Niger’s military regime and Iran, reported by the U.S. government (Africa Intelligence, 2024), have been officially denied by Nigerien authorities [5]. A recent International Atomic Energy Agency (IAEA) inspection visit to key uranium sites, such as Arlit, found no evidence of irregular uranium transfers, confirming that uranium stockpiles remain intact [4]. Therefore, while there is a plausible risk of future defense sector entanglement in the extractive industries—especially given the regional context—there is currently no systematic or regulated involvement of defense institutions in the mining sector in Niger that could be clearly identified by the assessor. Isolated incidents may occur, but there is no structural integration of defense forces into the mining economy, nor foreign (e.g., Russian) military control over mining operations at this time. However, the institution is responsible for protecting mining sites in accordance with decree no. 2024-309/P/CNSP/MDN of 9 May 2024 . [7]
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From 2017 to 2024, Niger has experienced a marked transition in the visibility and documentation of individual defence personnel’s financial or controlling interests in the natural resource sector—particularly gold. While earlier assessments did not confirm individual involvement on a large scale[1], recent events have revealed individual engagement of some security actors in illicit trade networks. For example, in January 2024, 1.4 tonnes of gold were seized in Ethiopia, having departed from Niamey without legal documentation. The Nigerien Minister of Justice, Alio Daouda, confirmed the incident and launched an investigation [2]. Transparency International and the Association Nigérienne de Lutte contre la Corruption (ANLC) identified security agents—including customs, police, gendarmes, and forest officials—as active facilitators of this smuggling operation. This implicates individual defence and security personnel in the practical organization and profit-making of an illegal gold export network [3][4]. These incidents are not isolated or new. Transparency International Niger reported that in 2020, 34.26 tonnes of gold, worth over US $1.74 billion, were exported from Niger to Dubai, while only 18.2 tonnes were officially declared to the Ministry of Mines. This suggests systemic underreporting and long-standing complicity among state actors—including likely involvement of defence or security personnel, given their strategic positions at borders and export hubs [3]. Following the gold seizure, the government removed or reassigned 82 state agents, among them members of the gendarmerie and police, pending judicial action. While disciplinary measures are underway, these incidents underscore personal involvement in illicit commercial activity, driven by access to security infrastructure [5].
0 / 100
Since the military coup on July 26, 2023, and Niger’s growing security and economic ties with Russia [1][2], concerns have emerged regarding the potential involvement of defense institutions in the country’s natural resource sector, particularly mining. While there is no official confirmation of such involvement, the precedent set by similar cases in countries like the Central African Republic (CAR) and Mali suggests that military-linked economic activities could be expanding [3]. Niger, with its vast reserves of uranium, gold, and other minerals, has increasingly placed state functions under military control since the coup. This shift raises the possibility that the defense sector could play a role in resource exploitation, especially as the country seeks new financial partnerships following its diplomatic realignment. In other contexts, such as CAR, security forces and their foreign allies—particularly Russian entities—have been known to exert influence over extractive industries. Given Niger’s current trajectory, similar patterns may be developing. However, there are no official records or public declarations of military ownership or financial interest in mining or other resource industries. Information about such potential involvement remains scarce, and there is no publicly accessible data detailing military-linked businesses in the sector.
0 / 100
Since the military coup on July 26, 2023, and Niger’s increasing alignment with Russia [1][2], concerns have grown regarding the potential involvement of defense institutions in the country’s resource exploitation, particularly in the mining sector. While there is no official confirmation, parallels with other contexts, such as the Central African Republic (CAR) and Mali, suggest that military-linked financial activities may be occurring [3]. Despite these concerns, there are no publicly available mechanisms to scrutinize the defense sector’s potential involvement in natural resource exploitation. No independent audits, parliamentary oversight, or civil society monitoring initiatives have been reported to assess whether military institutions hold controlling or financial stakes in mining operations. The opacity surrounding military-led governance in Niger, particularly after the coup, further complicates efforts to investigate these matters. Additionally, the absence of explicit legal requirements for military-related businesses to disclose financial interests or ownership in extractive industries makes scrutiny even more difficult. Unlike other economic sectors, where some degree of public oversight may exist, resource extraction—especially in remote and conflict-prone areas—remains outside the reach of independent verification.
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Nigeria
Section 16(3) of the 1999 Constitution mandates a national body to review ownership and control of enterprises, including those tied to natural resources, and report to the President [1]. However, there is no legislation explicitly authorising defence institutions to hold stakes in natural resource exploitative businesses. Searches reveal no documented financial interests held by the Nigerian military or MoD entities linked to resource extraction sectors.
Investigation by the Global Initiative Against Transnational Organized Crime (ENACT) in 2022 identified no formal defence-linked companies in oil, mining, or logging ventures. While there are anecdotal claims of military officials facilitating illicit operations (e.g. oil bunkering protection), no service branch is formally owned or financed through natural resource enterprises [2].
100 / 100
Defence institutions involvement in businesses relating to the country’s natural resource exploitation is widespread and mostly illicit. The nation’s defence and security forces have been accused of involvement in oil theft in the Niger Delta [1], illegal fishing/trade in Borno state [2] and illegal mining of resources such as gold [3]. However, allegations that the military is involved in illicit oil transactions such as, illegal oil bunkering and aiding of artisanal oil refining, in Nigeria’s Niger Delta region is rife [4,5]. In June 2023, a former Niger Delta militant leader, Asari Dokubo, alleged that “The military is at the centre of oil theft, and we must clarify this to the Nigerian public that 9% of oil theft can be traced to the Nigerian military — the army and the navy especially” [6]. Although such allegations are rife, the military is often quick to dismiss such allegations are as spurious or unfounded.
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Illicit transactions on crude oil, fishing in the waters of Lake Chad, and illegal mining of gold are the common areas with major revenue streams were allegations of the involvement of individual defence personnel in businesses relating to the country’s natural resource exploitation [1]. However, the government is actively seeking to tackle or regulate the issue through probing of such allegations [2], prosecution of suspects [3] and articulation of new strategies [4]. The Nigerian navy has in the past sacked and demoted some of its personnel for their complicity in oil theft [5].
50 / 100
The legal and regulatory framework does not make it possible for military officials or institutions to have a direct interest in the extractive sector. This can mean that even though such business interests may exist, they are not publicly declared. There are media allegations that some military and security personnel have interests in this business or facilitate illicit transactions in the country’s natural resources. For instance, a report by Peoples Gazette alleged that a top ranking staff of the Nigerian navy was involved in a multibillion-naira oil bunkering and contract-splitting fraud [1].The fact that the Nigerian navy had in the past sacked and demoted two admirals for their role in oil theft confirmed long-held suspicions that some of Nigeria’s top military officers are personally involved in the theft of crude oil in the Niger Delta for sale to tankers waiting offshore [2].
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When allegations of the involvement of miliary officers in businesses associated with the country’s natural resource are reported, these interests are often subjected to public and/ or parliamentary scrutiny to ascertain the potential for impropriety. For example, a top ranking staff of the Nigerian navy was recently accused of being involved in oil bunkering; the Ministry of Defence, Bello Matawalle, set up an investigation panel. He remarked that “Though these allegations might be mischievous, the ministry of defence is committed to upholding the highest standards of integrity and accountability within the Nigerian Armed Forces,” [1]. In July 2024, the Chief of Defence Staff (CDS), Gen Christopher Musa, and the Inspector General of Police (IGP), Kayode Egbetokun, denied that the members of the Armed Forces and security personnel provide security for illegal mining sites and miners in the country. They both spoke at a hearing by the House of Representatives Committee on Mineral Resources, chaired by Hon Jonathan Gaza [2].
Despite sporadic allegations, such as a Navy officer accused of involvement in oil bunkering fuelled investigations from the Minister of Defence, there is no evidence of institutionalised scrutiny, such as:
Regular risk assessments of defence-linked business interests,
Annual reviews or internal/external risk audits focused on commercial activities,
Permanent monitoring units inside MoD targeting resource exploitation [3].
Currently, the Ministry of Defence does not have a specific, Monitoring Unit exclusively dedicated to resource exploration or regular risk assessments of defence-linked business interests. The Ministry only has Planning, Research and Statistics Department within the Ministry with limited mandates to monitoring projects, including those related to capital projects and resource management, across the Ministry and its affiliated agencies [4][5]. Similarly, the Nigerian Navy, a branch of the Ministry, has a dedicated division solely for hardware procurement and monitoring, which includes aspects of resource management related to naval equipment and infrastructure [5].
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Senegal
Senegal’s laws, including military statutes, prohibit armed forces personnel from engaging in private business during active service.The Senegalese army is prohibited from holding financial or controlling interests in companies linked to the exploitation of the country’s natural resources. [1] According to Article 4 of the General Status of the Armed Forces, it is forbidden for any military institution or officer in active service to engage in a private or lucrative activity of any kind on a professional basis. Exceptionally, this prohibition may be waived under conditions to be laid down by decree of the Council of Ministers [2].
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The fundamental mission of the Armed Forces, which is to ensure the defence of national territorial integrity and the security of people and their property, includes the preservation of natural resources. The Armed Forces are therefore facing up to the challenges created or accentuated by the new context linked to the exploitation of offshore hydrocarbons with the discovery of oil and gas in Senegal, as well as the accentuation of maritime security and safety issues. However, this involvement is limited to security and does not involve business. [1] The army supports the work of water and forestry officers. The law establishing the general status of the armed forces prohibits military institutions from engaging in income-generating activities in any field whatsoever, including the exploitation of natural resources.[2]
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There are no cases of individual defence personnel being involved in businesses relating to the country’s natural resource exploitation. However, some military personnel in Casamance have used timer for personal use to build funitures or have facilitated the smuggling of timber accorss the border .[1] [2]
100 / 100
There is no evidence that defence personnel are involved in any large-scale business operations relating to the exploitation of natural resources. [1] [2] As such, this indicator is scored Not Applicable.
NA
There is no evidence that defence personnel are involved in any large-scale business operations relating to the exploitation of natural resources. [1] [2] As such, this indicator is scored Not Applicable.
NA
South Africa
There are no specific legal prohibitions in South African law preventing defence institutions or personnel from engaging in natural resource extraction. However, the Public Finance Management Act (PFMA) and the Mineral and Petroleum Resources Development Act (MPRDA) provide broad regulatory oversight [1]. The PFMA requires all government departments, including the DoD, to disclose any interests or revenues, while the MPRDA ensures that access to natural resources requires licensing. Available records and recent oversight reports confirm that no entities reporting to the DoD currently hold or are applying for rights related to natural resource exploitation [2].
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There are no known cases of South African military institutions’ involvement in natural resource exploitation. South Africa’s two state-owned entities related to defence include Armscor mandated with armaments acquisition on behalf of the Department of Defence, [1] and Denel which includes armaments manufacturing. [2] Neither have interests in natural resources.
100 / 100
There is no direct evidence of individual defence personnel engaging in resource extraction. South Africa’s regulatory framework for obtaining a mining licence for natural resource extraction is comprehensive, requiring various approvals, community consultation and ultimately results in operators being placed on the mining cadastre. [1] Likewise, the DoD Code of Conduct and the Public Service Commission Regulations further restrict public servants, including defence staff, from engaging in private activities that could pose conflicts of interest [2]. These regulatory requirements and the country’s public financial management framework should effectively prevent the defence sector from illegally engaging in natural resource exploitation.
100 / 100
There is no evidence that South African defence institutions have any formal or informal interests in natural resource extraction [1]. Annual Reports from both the Department of Defence and oversight institutions do not reflect any such activities. Furthermore, the Auditor-General’s performance audits consistently assess departmental compliance with the PFMA, and no mention of resource exploitation by the DoD has emerged [2] [3]. Therefore, this indicator is marked Not Applicable.
NA
There is no evidence that South African defence institutions have any formal or informal interests in natural resource extraction [1]. Annual Reports from both the Department of Defence and oversight institutions do not reflect any such activities. Furthermore, the Auditor-General’s performance audits consistently assess departmental compliance with the PFMA, and no mention of resource exploitation by the DoD has emerged [2] [3]. These oversight mechanisms ensure that if such interests were to develop, they would be reportable and subject to scrutiny. Therefore, this indicator is marked Not Applicable.
NA
South Sudan
Legally, there is no formal law or policy restricting the military or individuals from controlling or having financial interests with relation to the country’s natural resources. Even a look at the SPLM Act does not offer any clarity on the same [1]. However, reports indicate that the National Security Service (NSS) is actively engaged in providing security services to oil companies and is also involved in gold mining through various affiliated companies [2].
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While the defence policies are not specific on the involvement of military or its officials in natural resource exploitation [1], there is evidence that the military officials have been involved in illicit financial gains through natural resource exploitation. A report by Sentry revealed that “millions of dollars were paid to several companies partially owned by family members of top officials responsible for funding government-aligned militia or military commanders.” [2] The Global witness also revealed how the state owned oil company NILPET was working closely with international companies and the government military forces to generate revenue which was used to finance the conflict in South Sudan. [3] It has also been noted that the security and defence institutions are the biggest beneficiaries of oil revenues. The global witness also indicated that “by the end of the third quarter of the 2022/23 financial year, the security and rule-of-law sectors had spent over SSP 88 billion (US$675.6 million) combined, while the health and humanitarian sectors had spent less than SSP 10 billion (US$76.8 million).” [3] A recent government report on the use of funds received from the IMF also identified over 420,162 security sector employees on the government payroll, accounting for around 89% of all government employees. [3]. A U.N Security Council report drafted by a panel of experts revealed that The National Security Service has profited from oil revenues through its various enterprises, including Sudd (Suud) Security Services Co. Ltd., which has been compensated for providing services in the oilfields [4]. Additionally, both the National Security Service and the South Sudan People’s Defence Forces have received substantial in-kind contributions for their protection of the oilfields, representing significant non-monetary and off-budget payments.[4]
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Related to the military institution involved in business related to the country’s natural resources all be it in an illicit manner, individuals in the security sector have also been implicated in oil interests [1][2][3]. The International Crisis Group reported that Nilepet frequently receives substantial sums in oil revenues from production companies and the government, often amounting to tens of millions of dollars. However, these funds are not consistently reported, and the financial records have never undergone an audit. The state-owned company is dominated by loyalists to Kiir and members of the security elite, and it seems to be financing aspects of South Sudan’s security forces and military operations [1].
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Security and defence institutions in South Sudan play a central but highly secretive role in the country’s oil sector, with no transparent or independent mechanisms to track how revenue is diverted to political and military elites, as noted by the Council on Foreign Relations [1]. The state‐owned oil company is structured to reinforce executive control: its managing director reports to a board handpicked by the president, which includes trusted figures from the National Security Service and military [2] [3]. This lack of oversight is compounded by stalled public financial reforms and the transitional government’s decision to extend its mandate past February 2023. Moreover, after securing IMF support in March 2023, the government gained renewed latitude—according to the U.S. State Department—to pursue opaque or potentially corrupt transactions [2].
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The audit reports on the ministry of Defence [1] as well as the state-owned oil company [2], point to no evidence that the audits scrutinise the specific interests of defence institutions in businesses related to natural resources exploitation. In 2021, the auditor general had raised concerns that NILEPET (the state owned oil company) had not been audited since it was established [3].
0 / 100
Uganda
The 1995 Constitution emphasises civilian control over the military, ensuring the Uganda People’s Defence Forces (UPDF) focus on national and sovereignty defence, suggesting civilian oversight over engagement on commercial ventures that could lead to conflicts of interest.[1] It doesn’t outright forbid commercial activity but does require that the UPDF operate under civilian authority.
However, the establishment of the National Enterprise Corporation (NEC) in 1989 serves as a notable exception. Created by an Act of Parliament as the commercial arm of the Ministry of Defence and the UPDF, NEC engages in various commercial ventures through its subsidiaries and joint ventures. These activities include production and provision of goods and services beneficial to the defence forces and the general public. While NEC’s primary focus is on sectors like agriculture and manufacturing, its involvement in commercial enterprises indicates a degree of financial interest by defence institutions in business activities.[2]
In recent developments, Uganda established a state-owned mining company to manage the government’s equity interests in mining operations. Under a mining law approved in 2022, the government can acquire a 15% free carry stake in all mining operations within the country. This initiative aims to expand Uganda’s share of its mineral wealth and involves strategic partnerships with private sector developers [3].
While the legal framework intends to prevent direct financial involvement of defence institutions in natural resource exploitation, entities like NEC and historical instances suggest that, in practice, the separation is not absolute. Ongoing monitoring and enforcement are essential to ensure that defence institutions remain focused on their primary responsibilities and to prevent potential conflicts of interest.
50 / 100
In regions rich in natural resources, particularly those with security challenges, defence institutions may become entangled in local economies. This entanglement can range from providing security for resource extraction companies to engaging in informal trade or even direct participation in resource exploitation.
The lack of regulation surrounding these activities creates an environment where accountability is diminished and the potential for abuse is heightened. Without clear oversight mechanisms, it becomes difficult to distinguish between legitimate security operations and unauthorised commercial ventures. Furthermore, the opaque nature of some defence operations and the potential for informal networks to develop can make it difficult to track and regulate these activities.
Historically, there have been concerns about the involvement of Ugandan military personnel in natural resource exploitation, particularly during the conflicts in the Democratic Republic of Congo (DRC). Reports indicate that between 1998 and 2002, the Ugandan army benefited financially from resources such as gold in the DRC, with revenues used to support military expenditures and, in some cases, personal enrichment.[1]
Moreover, allegations surrounding UPDF involvement in natural resource-related activities, specifically within the Zoka Forest, present a complex and often contested picture. The Zoka Forest in northern Uganda has faced significant challenges related to illegal logging and deforestation, and reports have emerged alleging the involvement of some UPDF personnel in these illicit activities. Concerns have been raised by environmental activists and local communities, who have documented instances where security forces are said to be facilitating or profiting from illegal logging operations. [2][3]
However, verifying these claims poses a significant challenge due to the remote location of the Zoka Forest and the inherently sensitive nature of military operations[4]. Information is frequently anecdotal, and official investigations into these allegations are often limited or lack transparency. The involvement of security forces in natural resource exploitation can be a complex issue, as the lines between legitimate security operations and unauthorised commercial activities can become blurred.
50 / 100
While there is no evidence of the defence institutions as a whole having formal, controlling financial interests in natural resource businesses, there are well-documented cases of individual military personnel being involved.
These involvements are often linked to illicit activities, such as illegal logging, mineral smuggling, and illicit mining operations [1][2][3]. For example, there have been reports of UPDF officers involved in the illegal trade of timber and minerals in regions like Karamoja [2] .
Current open sources support enforcement presence and isolated criminal incidents; for instance, the Global Organized Crime Index notes military officials in Uganda are “highly involved” in facilitating smuggling of illicit goods, contextual risk around illicit flows, including minerals [3].
The government has at times acknowledged these issues and taken steps to address them [4][5], but the problem persists in an illicit manner, fitting the description of “isolated cases” where the “activity is illicit.”
75 / 100
Uganda has a legal framework that, in theory, requires public officials, including senior defence personnel, to declare their income, assets, and business interests. Under the Leadership Code Act, officers are obliged to file regular declarations with the Inspectorate of Government (IGG), which can be accessed by the public on request, and the IGG retains powers to verify declarations against bank and property records [1]. Complementing this, the Companies (Beneficial Ownership) Regulations 2023, the Mining and Minerals Act 2022, and Uganda’s membership in the Extractive Industries Transparency Initiative (EITI) require companies to disclose their beneficial owners, including those holding mineral rights, with the intention of publishing such information in a publicly accessible format [2][3][4].
In practice, however, transparency is partial. Asset declarations are not proactively published, and while they are legally public information, access is limited to case-by-case via application to the IGG (with a fee) [5]. Beneficial ownership reporting is improving, with URSB maintaining a register and the Mining Act requiring disclosure by mineral right holders, but current access for the general public remains largely application-based, rather than through comprehensive open data [6]. Furthermore, individuals, including defence personnel, are not required to publish sources of income, company operations, or audited accounts at a level comparable to state-owned enterprises [1].
As a result, while there is no public evidence that serving UPDF officers currently hold controlling interests in natural resource businesses, the opacity of declaration and beneficial ownership systems makes independent verification challenging.
25 / 100
The debate surrounding the Natural Resources Committee’s role and the exploitation of natural resources in Uganda, particularly concerning the Zoka Forest Reserve, extends beyond a superficial level. The committee’s mandate to scrutinise allegations of fraudulent exploitation provides a formal mechanism for addressing concerns. The Deputy Speaker’s directive for the committee to investigate the Zoka Forest Reserve exemplifies this, demonstrating a proactive approach to addressing reported encroachments and depletion [1,2]. This action moves beyond simple discussion, pushing for on-the-ground investigation and potential action.
Furthermore, the involvement of various stakeholders in the case, including Adjumani District leaders, the National Forestry Authority (NFA), and the Uganda People’s Defence Force (UPDF), highlights the complexity of the issue[3]. The persistent accusations against the UPDF for plundering the forest, if substantiated, point to systemic problems that require thorough investigation and resolution. This is not a matter of simple misunderstanding or isolated incidents. The fact that the local leaders and NFA officials are constantly accusing the UPDF shows that this is an ongoing issue, that requires a solution [4]. Therefore, the debate is driven by tangible concerns about environmental degradation and potential corruption, and the committee’s involvement signifies an attempt to address these issues through formal oversight and investigation, making it a matter of real substance.
50 / 100
Zimbabwe
The constitution of Zimbabwe does not prohibit the defence forces from participating any other business for profiteering [1]. There is no control or legal framework which guides how the defence forces should be involved or not involved in businesses associated with natural resources. [1] [2] The involvement of defence forces in the country natural resources business is not prohibited under the law. [2]
0 / 100
The deference institutions are largely involved in the country’s natural resources extraction for their own benefit. The Global Witness assert that the Central Intelligence Organisation (CIO) has a stake in Kusena Diamond, traded in Antwerp and Dubai, and in international markets. [1] Zimbabwe’s military has a partnership with a Chinese investor, Anjin Mining with diamonds sold in Antwerp which violates EU sanctions since the company is linked to the Zimbabwean military. There is no limitation to the practice of expropriating the country’s natural resources [1] [2].
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Individual defence chiefs are significantly involved in extraction industries and businesses related to the country’s natural resources [1] [2]. The Central Intelligence Organisation (CIO) is believed to have a stake in Kusena Diamonds, a Marange diamond mining company that has conducted trade in Antwerp and Dubai. This company has since been merged into the Zimbabwe Consolidated Diamond Company (ZCDC) [1]. Zimbabwe’s military has also partnered with a Chinese investor, Anjin Mining, to sell diamonds in Antwerp [1]. Additionally, Mbada Diamonds, which holds the largest concession in Marange, is partnered with Robert Mhlanga, a retired member of Zimbabwe’s security forces and a known ally of ZANU-PF, who holds a 25% share [1]. These mining ventures reportedly involve senior officers and defence chiefs in senior roles [2].
0 / 100
There is no transparency on defence institutions involvement in the extraction of natural resources as part of defence business [1][2]. The financial interests are not publicly declared [2].
0 / 100
While the constitution has mandated the parliamentary portfolio committee on mining to have an oversight on mining activities, it is a challenge for such a committee to stop the army generals and the military from engaging in mining business [1] [2]. The challenge is that the military is linked with the ruling party, ZANU-PF [2]. The defence institutions, in particular the defence chiefs are not subject to any form of scrutiny [2].