In Benin no security or military institutions have a private enterprise. The government strictly outlaws any unauthorised private enterprise. However the law it not clear about sanctions in place to deal with offenders [1]. The position of these institutions in maintaining territorial integrity and state security makes it impossible to carry out any private activity [2]. Furthermore, a commercial enterprise for security purposes requires the recruitment of military personnel, who will definitely come from the ranks of those who are qualified for this, particularly in the armed forces. Such a situation is unthorized [3]. There is no solid evidence or official investigation that mentions the involvement of Beninese military or Ministry of Defense employees in unauthorized private business activities. Even military hospitals, for example, are under the supervision of the Ministry of Health rather than being commercial entities under military control.

There is no solid evidence or official investigation that mentions the involvement of Beninese military or Ministry of Defense employees in unauthoriszed private business activities. Even military hospitals, for example, are under the supervision of the Ministry of Health rather than being commercial entities under military control.occur.[1] [2]

The government does not outlaw private enterprise under the umbrella of the state’s defence and security operations. [1] [2]

Several officers of Burundi’s national defence sector are heavily involved in vairous type of business. [1] A top army official, for example, owns a number of companies, some of which are owned by senior army officers, notably, in the mining and microfinance sector. [1] [2] However, the IFC report does not suggest systematic capture of major industry, although this is not prohibited by law. Private enterprise is still mostly uncaptured. [2][3]

Civil servants are legally prohibited from running or being involved in profit-making businesses unless they are formally authorised.[1] Law No. 2017/010 of 12 July 2017 on the General Statute of the Military Personnel forbids soldiers from engaging in private commercial activities, whether directly or indirectly, unless they are authorised.[2] However, in Cameroon, military officers have been reported to engage in private business activities, such as operating private security firms and logistics companies, which leads to conflicts of interest and undermine the integrity of defence operations. Despite existing regulations against these practices, enforcement remains inconsistent. Disciplinary measures, when taken, tend to be reactive and are often driven by external factors like media coverage, rather than proactive oversight. This environment promotes a culture of impunity, where offenders rarely face serious repercussions, thereby eroding public trust in governance within the defence sector.[3][4]

Military personnel, including senior officers, are involved in various private business ventures, particularly in sectors like private security. These firms often operate in areas with significant ties to the government, creating clear conflicts of interest. Military officers involved in these enterprises undermine the integrity and professionalism of the armed forces, eroding public trust [1]. Despite media coverage and international reports highlighting these activities, the government has largely failed to take meaningful action. This lack of enforcement has led to a culture of impunity within the military. There is weak implementation of laws that prevent military personnel from engaging in commercial ventures [3]. Furthermore, government response to such violations remains inadequate, with a failure to hold individuals accountable for their actions, reinforcing a pattern of impunity. Additionally, the Cameroon Open Spending Portal reveals a lack of timely and detailed public financial information, further complicating efforts to assess the extent of military involvement in private businesses [2].

The provisions of the Civil Service Code and the Military Code do not allow ordinary civil servants, let alone military personnel, to acquire private businesses. Military personnel who wish to engage in an activity other than that provided for in the Military Code are required to seek prior authorisation. Penalties may be both financial, with the reimbursement of illicit gains, and disciplinary, such as dismissal or loss of rank [1, 2].

As mentioned above, military personnel are prohibited from engaging in any other activity, and a fortiori any lucrative or commercial activity. Failure to comply with these obligations is punishable. In the past, some warlords engaged in the illicit export of certain products such as cocoa as part of the war economy. Gold mining also developed under the rebel regime [2]. However, several reforms were carried out after the 2017 mutinies to remove former warlords from command and economic activities [3]. The risk of collusion between the FDS and gold miners led the authorities and the CNS to create a special unit to combat illegal gold mining, the Special Group for the Fight against Illegal Gold Mining (GS-LOI) [4].

The participation of members of the military in private enterprises are not outlawed.(1) (2)

Under the Armed Forces Regulations Act Section 19.43 on Civil Employment suggests that no officer on full time service may undertake any commercial activities that will bring into disrepute the image or detrimental to the image of the Ghana Armed Forces as may be determined by his or her Commanding Officer. There are exemptions made for who are on leave preceding release and officers on leave without pay. (1)  
However, it has been alleged that military personnel engages in unauthorised private enterprises, including activities such as support for land acquisition, illegal mining, and debt collection, among others. These actions differ from the legitimate engagement of personnel in legal private activities and therefore pose risks to the integrity and discipline of the armed forces, potentially leading to broader security and governance challenges (2)(3).
In July 2025, the Armed Forces Council issued a sweeping directive ending unauthorized military-provided protection to civilians and businesspeople, underscoring institutional resolve to curb misuse (4). These examples illustrate that unauthorised private enterprise is an isolated issue involving a few individuals, not widespread.

The Kenya Defence Forces Act of 2012 and the Public Officer Ethics Act of 2003 forbid military personnel and Defence Council members from engaging in private enterprises. This prohibition aims to prevent conflicts of interest and the misuse of positions for personal gain. Violations can lead to court-martial convictions, with penalties ranging from imprisonment to fines, depending on the offender’s rank and position [1,2].

There is limited information to suggest that KDF or MoD employees are involved in private business. Unauthorised private enterprise is strictly regulated and does not occur due to the stringent provisions set forth in the KDF Act and the Public Officer Ethics Act of 2003. These legislative measures have been put in place to ensure that all private enterprises operate within the legal framework and adhere to ethical standards. The rigorous enforcement of these acts serves as a deterrent against any potential violations, thereby maintaining the integrity and ethical conduct expected of public officers and affiliated entities [1, 2].
In practice, there is no public evidence of widespread or systematic involvement of KDF personnel in private business. A review of recent Auditor-General reports on defence spending does not highlight unauthorised private enterprise as a recurring issue, and there are no reported cases in the press or parliamentary records suggesting that KDF officers are involved in operating private businesses [3].

There is no law prohibiting defence or ex-military personnel from establishing private enterprises. The practice of military or ex-military personnel establishing private enterprises across the country is not outlawed. A notable example is the Private Security Company (PSC) sector. In 2008, the Ministry of Justice promulgated a regulation for private security companies (PSC).[1] The regulation requires PSC to organise and operate private security companies. More specifically, the regulation requires PSCs to register with the Department of Public Safety under the Ministry of Justice. The regulation also requires that one of the founders of these establishment ought to be a former security or current security personnel.[2]

While specific instances of unauthorised private enterprises by military or defence ministry employees in Liberia are not extensively documented, informal sources suggest that some former officials have engaged in business activities that conflict with Liberia’s Code of Conduct and National Defense Act of 2008.[1] The latest update from 2019 outlines that Liberia had 127 PSCs employing around 7,000 personnel, all required to register with the Department of Public Safety under the 2008 Guidelines [2]. Furthermore. the Department of Public Safety lacks the resources, basic supplies, personnel and logistics to effectively enforce these Guidelines. Despite several companies having violated the Guidelines, very few have been penalised [3]. However, no public data since 2020 confirms military-linked ownership, as this is mostly uncaptured.

Article 21 of the Loi n° 96-029 du 14 novembre 1996 portant Statut Général des Militaires authorises military personnel may engage in certain gainful activities on a subsidiary basis without this hindering the smooth running of the service or compromising his independence and availability. [1]

No unauthorised private activities conducted by military or other Department of Defense employees exist [1] [2].

Defence and security institutions and their personnel, in accordance with the various regulations governing them, may not engage in or have recourse to illegal private companies. This prohibition is general in scope. While one of the missions of the military engineers is to carry out studies and/or work in the public interest at the request of the Government, the military engineers cannot be considered as a company. Under Article 30, the military cannot engage in any lucrative activity directly but can hold shares in companies on condition that this does not undermine the normal functioning, independence, reputation, neutrality of the Armed and Security Forces, or create conflict of interest. When such a conflict is identified by the military institution, the person involved is required to comply with the legislation and regulations in force. [1][2][3][4]

There is not enough information to score this indicator and assess to what extent defence employees engage in unauthorised private enterprises. Under Article 30, the military cannot engage in any lucrative activity directly but can hold shares in companies on condition that this does not undermine the normal functioning, independence, reputation, neutrality of the Armed and Security Forces, or create any conflict of interest.[1][2] In practice, military personnel who engage in this path do not necessarily make it public. Companies also do not generally make shareholder profiles public.

The government does not outlaw private enterprise under the umbrella of the state’s defence and security operations [1]. In the Defence and Security Forces, the only ones who need authorisation to create companies are Intelligence Officers, taking into account the Statute of Members of the Intelligence Services [2].

For legal and institutional aspects, in the Defence Sector, there is no private initiative not authorised by the General Staff of the Armed Forces, because the Military Statute prevents it and treats it as incompatibility [1]. Authorisations are accepted and influenced by criteria such as trust and patriotism, after carrying out several security investigations [2]. However, in practice, it is possible to come across unauthorized private interests involving the military linked to various activities, such as gold mining in Manica and Nampula and ruby mining Montepuez, as well as private security activities in natural gas projects in the Rovuma Basin, in Cabo Delgado [3, 4].

Before the military coup of July 26, 2023, Niger’s legal framework explicitly prohibited military personnel and other defence ministry employees from engaging in private enterprise. Article 129 of the Public Penal Code imposes strict regulations on public officials’ involvement in private business, with sanctions ranging from 100,000 FCFA to 1 million FCFA and a minimum of two years of imprisonment for violations [1]. However, following the dissolution of the Constitution [2] and the transition to military rule, the legal framework governing military engagement in private enterprises is unclear. With weakened institutional checks and oversight, enforcement of anti-corruption laws and financial regulations is likely to be less stringent, increasing the risk of unregulated private business activities by military officials. While the pre-coup legal framework prohibited unauthorized private enterprise by defence officials, the current political context suggests a lack of strong enforcement mechanisms.

Before the military coup of July 26, 2023, Niger’s legal framework explicitly prohibited military personnel and defence ministry employees from engaging in private enterprise. Article 129 of the Public Penal Code imposed strict penalties, including fines ranging from 100,000 to 1 million FCFA and a minimum of two years of imprisonment for violations [1]. However, with the dissolution of the Constitution and the transition to military rule [2], the legal framework governing military involvement in private business remains unclear.
With weakened institutional checks and limited oversight, enforcement of anti-corruption laws has likely become less stringent, increasing the risk of unregulated private business activities by military officials. While there is no confirmed evidence of the government itself openly operating unauthorizsed private enterprises, the current lack of transparency and legal safeguards suggests a growing environment for unauthorized defence sector involvement in private business.
Recent investigations have revealed widespread smuggling of gold and illicit financial flows, facilitated by state security forces:
• In January 2024, 1,400 kg of gold bullion worth over €91.4 million (60 billion FCFA) was seized in Addis Ababa, having been smuggled from Niger to the UAE without official documentation [3].
• Transparency International Niger identified collusion between airport security forces and smuggling networks, prompting the reassignment of 82 officers from customs, police, gendarmerie, and forestry services amid an ongoing investigation [3][4].
• The scale of gold smuggling has resulted in massive tax revenue losses, with 34.26 tonnes of gold exported illegally in 2020, while only 18.2 tonnes were officially declared [3].
These reports indicate significant corruption within Niger’s security forces, suggesting that elements of the defence sector may be complicit in organized criminal activities. Given the high level of state involvement in the illicit economy, particularly in resource smuggling, there is a strong possibility that defence officials are engaged in unauthorized private enterprise and benefiting from illicit financial flows. While far from reaching state capture, the growing influence of organized crime within security forces raises serious concerns about state corruption, illicit enrichment by military officials, and the erosion of economic governance.

Nigeria’s Code of Conduct prohibits employees or public officers from participating in the management or running of any private business [1]. The Code of Conduct Bureau has a committee that investigates and takes the necessary actions against civil servants who engage in direct management of private business, especially during official hours [2]. Similarly, civil service rule also impliedly prohibits private enterprises (except farming) as they could interfere in the employees’ discharge of their functions. However, government’s sanction of defaulters has been very weak [3].

Unauthorized private businesses are common occurrence and majorly blamed on low wages to employees. They, therefore, resort to private businesses to make ends meet, which are rarely captured. It is alleged that some military officers own private businesses such as clubs and hotels which they secretly employ somebody to run it for them [1]. In September 2022, for instance, the Chairman of the Independent Corrupt Practices and other related offences Commission, Prof. Bolaji Owasanoye, disclosed that an ex-military chief embezzled N4 billion from military budget and deposited it into the accounts of two companies where he is the beneficial owner and sole signatory [2].
There are also reported cases of conflict entrepreneurs within the hierarchy of military leadership and the ministries, departments and agencies in the security sector apparently use military funds meant for counter-terrorism operations to enrich themselves.[3]

It is forbidden for any officer, whatever his position, to have for himself or through an intermediary or under any name whatsoever, in an enterprise subject to the control of the Ministry to which he reports or in relation to this Ministry, interests of such a nature as to compromise his independence. For the law to be respected, appropriate sanctions are in place in the law or policy to deal with offenders [1] .

There is not enough to score this indicator. There are not enough evidence to assess if unauthorised private enterprise is a problem in the Senegalese armed forces. [1][2]

In terms of Section 30 of the Public Service Act, government employees are prohibited from engaging in any remunerative work outside of their department unless they have been granted permission and under Public Service Regulations, employees are forbidden from engaging in business with the state. [1] Sanctions include dismissal and criminal prosecution [1][2].

Unauthorised private enterprise is a problem with a small number of individuals with some evidence of state employees engaging in remunerative work without the appropriate authorisation or having undeclared outside business interests. [1] Reports from the Public Service Commission and Parliament identify some incidents, often discovered through lifestyle audits. However, these are not widespread and typically involve individual cases. [1][2]

Legally, the Civil Service Act and the SPLA Act. [1] [2] prohibit civil servants from engaging in private enterprises. However, evidence from different reports show that high ranking defence and security officials are involved in lucrative private commercial deals [3], [4]. For example, a 2020 Sentry report examined the commercial and financial activities of former Army chiefs of staff, along with senior military officers who made a lot of wealth through business deals. [5] The existing laws prohibit unauthorised private enterprise by the organised forces and their affiliates. However, operationalisation of the laws and sanctions remain the biggest challenge.

The involvement of top defence and security officials in private enterprises, sometimes illicit has been documented since South Sudan became independent in 2011. For example, a Sentry report titled Making A Killing: South Sudanese Military Leaders’ Wealth Explained [1] highlights the significant involvement of top army leaders. It also draws attention to military leaders allied with President Salva Kiir. Additionally, some known rebel leaders are mentioned. The report reveals that certain known leaders took advantage of the situation by registering companies under the names of family members, including very young children, to accumulate wealth and hide it abroad. [2]. The allegations against top government officials close to the ruling elite means that their operations were happening with the knowledge of the government.
Additionally, operating illegal checkpoints have become prevalent in some trade routes in the country such as Nimule-Juba Road, Western Equatoria – Western Bhar el Ghazal and along the Nile River. Tensions have arisen between the main peace parties, namely the SPLA-IO and SSPDF, especially in Western Equatorial State and along the Nile River [3].

Section 37 (1) of the Uganda Peoples’ Defence Force (UPDF) Act imposes restrictions on the military during full-time service. It states that subject to subsection (2), no officer or militant on continuing full-time military service shall engage in any civil employment or undertaking which is; a) likely to be detrimental to the interests of the defence forces; b) reflects or likely to reflect discredit upon the defence forces. Subsection 3 states that without prejudice to the general effect of subsection (1), the minister may, by regulations made under this act, specify the types of business that officers and militants shall not engage in. However, there are no clear sanctions in case of breach of these regulations.

The constitutional provisions outlined in Articles 208 and 209 of Uganda’s Constitution, which prohibit the army from engaging in unauthorised private enterprise, are intended to maintain the integrity and focus of the defence forces on their primary duties. However, the reality on the ground sometimes reveals instances where these provisions are circumvented, often by select individuals or institutions within the military. These unauthorised activities can range from individual profiteering to institutional involvement in commercial ventures that fall outside the constitutionally mandated productive activities for the development of Uganda. [2]
Examples of such unauthorised private enterprise can include instances where individual officers leverage their positions to engage in private business dealings, such as illicit trade in natural resources or involvement in private security companies without proper authorisation. There have also been allegations of military personnel engaging in illegal land transactions or using military resources for personal gain. Furthermore, while the National Enterprise Corporation (NEC) is a legitimate commercial arm of the MoDVA, some argue that certain activities undertaken by associated entities or individuals may blur the lines between authorised and unauthorised enterprise, particularly when these activities are not subject to sufficient public scrutiny. [3]
The problem lies not only in the illegality of these ventures but also in the potential for them to erode public trust in the military and divert resources from its core functions.

While the Public Finance Act requires that all state-owned business have to declare their business and submit audited reports [1], unauthorised defence private enterprise do exist, but difficult to account for because there is no law which prohibits the military or any of its employees [2]. The government does not prohibit such operations because the military publicly supports the ruling party in government, ZANU-PF. There is a likelihood of political influence in military involvement in private businesses [2].

While Zimbabwean law does not explicitly authorise military involvement in private commercial enterprises, the military nonetheless continues to participate in a wide range of business activities, particularly in the extractives sector. This involvement is facilitated by its close ties to the ruling ZANU-PF party and is neither prohibited by law nor subject to meaningful oversight [1].
There is extensive reporting that the military holds shares in diamond mining operations, including in Kusena Diamonds, a company owned by the Zimbabwe Mining Development Corporation (ZMDC) [1], as well as in Chinese joint ventures such as Anjin Investments and Jinan Mining, both of which have operated in the Marange diamond fields [1][2]. These arrangements illustrate the military’s continued influence in the natural resources sector, particularly in diamonds and gold mining.
Although these industries are not legally defined as “captured” by the military, their strong presence and controlling interests in key mining companies suggest that parts of the extractive sector are functionally dominated by military-affiliated entities.