full-list-of-charges-against-defunct-unibank-founder-kwabena-duffuor,-eight-others

Full list of charges against defunct uniBank founder Kwabena Duffuor, eight others

The founder of the now-defunct uniBank, Dr. Kwabena Duffuor, is facing 68 counts on charges of fraudulent breach of trust, money laundering, dishonestly receiving and falsification of accounts.

Dr. Duffuor will be facing trial alongside the former Deputy Governor of the Bank of Ghana, Johnson Pandit Asiama, Hoda Holdings Limited, Kwabena Duffour II, Ekow Nyarko Dadzie-Dennis, Elsie Dansoa Kyereh, Jeffrey Amon, Benjamin Ofori and Kwadwo Opoku Okoh.

Find below the charge sheet

Count One

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust, contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II and 2) Ekow Nyarko Dadzie-Dennis, in 2014 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢48,269,477.75 which was entrusted to you in trust for depositors of uniBank Ghana Limited. Page 2 of 26

Count Two

Statement of Offence

Fraudulent breach of trust, contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis, in 2014 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢48,269,477.75 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Three

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis in 2014 in Accra in the Greater-Accra Region transferred the sum of GH¢48,269,477.75 to related parties of uniBank Ghana Limited knowing it to be proceeds of crime.

Count Four

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust, contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1)Kwabena Duffuor II and 2) Ekow Nyarko Dadzie-Dennis, in 2015 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢164,051,706.14 which was entrusted to you in trust for depositors of uniBank Ghana Limited. Page 3 of 26

Count Five

Statement of Offence

Fraudulent breach of trust, contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis, in 2015 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢164,051,706.14 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Six

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis in 2015 in Accra in the Greater-Accra Region transferred the sum of GH¢164,051,706.14 to related parties of uniBank Ghana Limited knowing it to be proceeds of crime.

Count Seven

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust, contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II and 2) Ekow Nyarko Dadzie-Dennis, in 2016 in Accra in the Greater-Accra Region agreed to act together with a common purpose to Page 4 of 26

dishonestly appropriate the sum of GH¢332,039,936.46 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Eight

Statement of Offence

Fraudulent breach of trust, contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis, in 2016 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢332,039,936.46 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Nine

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis in 2016 in Accra in the Greater-Accra Region transferred the sum of GH¢332,039,936.46 to related parties of uniBank Ghana Limited knowing it to be proceeds of crime.

Count Ten

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust, contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29). Page 5 of 26

Particulars of Offence

1) Kwabena Duffuor II and 2) Ekow Nyarko Dadzie-Dennis, in 2017 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢63,522,592.32 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Eleven

Statement of Offence

Fraudulent breach of trust, contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis, in 2017 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢63,522,592.32 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Twelve

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis in 2017 in Accra in the Greater-Accra Region transferred the sum of GH¢63,522,592.32 to related parties of uniBank Ghana Limited knowing it to be proceeds of crime.

Count Thirteen

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust, contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29). Page 6 of 26

Particulars of Offence

1)Kwabena Duffuor II and 2) Ekow Nyarko Dadzie-Dennis, in 2018 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢5,432,500.00 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Fourteen

Statement of Offence

Fraudulent breach of trust, contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1)Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis, in 2018 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢5,432,500.00 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Fifteen

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis in 2018 in Accra in the Greater-Accra Region transferred the sum of GH¢5,432,500.00 to related parties of uniBank Ghana Limited knowing it to be proceeds of crime.

Page 7 of 26

Count Sixteen

Statement of Offence

Dishonestly receiving contrary to section 146 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

Kwabena Duffuor between January 2014 and February 2018 in Accra in the Greater-Accra Region dishonestly received the sum of GH¢663,283,917.19 knowing it to have been obtained by means of a criminal offence.

Count Seventeen

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

Kwabena Duffuor between January 2014 and February 2018 in Accra in the Greater-Accra Region took possession of the sum of GH¢663,283,917.19 knowing it to be proceeds of crime.

Count Eighteen

Statement of Offence

Dishonestly receiving contrary to section 146 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

HODA Holdings Limited between January 2014 and February 2018 in Accra in the Greater-Accra Region dishonestly received the sum of GH¢663,283,917.19 knowing it to have been obtained by means of a criminal offence. Page 8 of 26

Count Nineteen

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

HODA Holdings Limited between January 2014 and February 2018 in Accra in the Greater-Accra Region converted the sum of GH¢663,283,917.19 knowing it to be proceeds of crime.

Count Twenty

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust, contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II and 2) Ekow Nyarko Dadzie-Dennis, on or about 27th April, 2016 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢35,000,000.00 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Twenty-One

Statement of Offence

Fraudulent breach of trust, contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis, on or about 27th April, 2016 in Accra in the Greater-Accra Region dishonestly appropriated the sum of Page 9 of 26

GH¢35,000,000.00 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Twenty-Two

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis on 27th April, 2016 in Accra in the Greater-Accra Region transferred the sum of GH¢35,000,000.00 to Ghana Oil Company Limited knowing it to be proceeds of crime.

Count Twenty-Three

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust, contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II and 2) Ekow Nyarko Dadzie-Dennis, between November 2015 and September 2017 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢74,394,280.92 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Twenty-Four

Statement of Offence

Fraudulent breach of trust, contrary to section 128 of the Criminal Offences Act, 1960 (Act 29). Page 10 of 26

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis between November 2015 and September 2017 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢74,394,280.92 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Twenty-Five

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis between November 2015 and September 2017 in Accra in the Greater-Accra Region transferred the sum of GH¢74,394,280.92 to related parties of uniBank Ghana Limited knowing it to be proceeds of crime.

Count Twenty-Six

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust, contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II and 2) Ekow Nyarko Dadzie-Dennis, in June 2016 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of $13,454,483.47 which was entrusted to you in trust for depositors of uniBank Ghana Limited. Page 11 of 26

Count Twenty-Seven

Statement of Offence

Fraudulent breach of trust, contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis in June 2016 in Accra in the Greater-Accra Region dishonestly appropriated the sum of $13,454,483.47 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Twenty-Eight

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis in June 2016 in Accra in the Greater-Accra Region transferred the sum of $13,454,483.47 to a related party of uniBank Ghana Limited knowing it to be proceeds of crime.

Count Twenty-Nine

Statement of Offence

Contravention of the Bank of Ghana Act, 2002 (Act 612) contrary to sections 46(h) and 67(a) of the Bank of Ghana Act, 2002 (Act 612).

Particulars of Offence

Johnson Pandit Asiama in or about September 2016 in Accra in the Greater-Accra Region granted a facility in the sum of GH₵300 million to Universal Merchant Bank for the benefit of unibank Ghana Limited without satisfying the prescribed conditions set out in the Bank of Ghana Act, 2002 (Act 612). Page 12 of 26

Count Thirty

Statement of Offence

Wilfully causing financial loss to the Republic contrary to section 179A(3)(a) of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

Johnson Pandit Asiama in or about September 2016 in Accra in the Greater-Accra Region, wilfully caused financial loss of GH₵150 million to the Republic.

Count Thirty-One

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II and 2) Ekow Nyarko Dadzie-Dennis, on or about 5th December 2016 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢146,867,169.26 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Thirty-Two

Statement of Offence

Fraudulent breach of trust contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, on or about 5th December 2016, in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢146,867,169.26 which was entrusted to you in trust for depositors of uniBank Ghana Limited. Page 13 of 26

Count Thirty-Three

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis on 5th December 2016, in Accra in the Greater-Accra Region transferred the sum of GH¢146,867,169.26 to Merchant Bank Ghana Limited for the purchase of adb Bank shares knowing it to be proceeds of crime.

Count Thirty-Four

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, and 2) Ekow Nyarko Dadzie-Dennis, on or about 5th December 2016 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢67,314,119.25 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Thirty-Five

Statement of Offence

Fraudulent breach of trust contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, on or about the 5th December 2016 in Accra in the Greater-Accra Region dishonestly appropriated Page 14 of 26

the sum of GH¢67,314,119.25 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Thirty-Six

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis on 5th December, 2016 in Accra in the Greater-Accra Region transferred the sum of GH¢67,314,119.25 to Merchant Bank Ghana Limited for the purchase of adb Bank shares knowing it to be proceeds of crime.

Count Thirty-Seven

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960, Act 29.

Particulars of Offence

1) Kwabena Duffuor II, and 2) Ekow Nyarko Dadzie-Dennis, on or about 5th December 2016 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢61,194,653.86 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Thirty-Eight

Statement of Offence

Fraudulent breach of trust contrary to section 128 of the Criminal Offences Act, 1960 (Act 29). Page 15 of 26

Particulars of Offence

1) Kwabena Duffuor II, and 2) Ekow Nyarko Dadzie-Dennis, on or about 5th December 2016 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢61,194,653.86 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Thirty-Nine

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis on 5th December, 2016 in Accra in the Greater-Accra Region transferred the sum of GH¢61,194,653.86 to Merchant Bank Ghana Limited for the purchase of adb Bank shares knowing it to be proceeds of crime.

Count Forty

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II and 2) Ekow Nyarko Dadzie-Dennis on or about 5th December 2016 in the Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢36,716,792.32 which was entrusted to you in trust for depositors of uniBank Ghana Limited. Page 16 of 26

Count Forty-One

Statement of Offence

Fraudulent breach of trust contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, on or about 5th December 2016 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢36,716,792.32 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Forty-Two

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis on 5th December, 2016 in Accra in the Greater-Accra Region transferred the sum of GH¢36,716,792.32 to Merchant Bank Ghana Limited for the purchase of adb Bank shares knowing it to be proceeds of crime.

Count Forty-Three

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust contrary to sections 23(1) and 128 of the Criminal Offences Act 1960, Act 29.

Particulars of Offence

1) Kwabena Duffuor II, and 2) Ekow Nyarko Dadzie-Dennis, on or about 5th December 2016 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢5,048,560.05 which was entrusted to you in trust for depositors of uniBank Ghana Limited. Page 17 of 26

Count Forty-Four

Statement of Offence

Fraudulent breach of trust contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, on or about 5th December 2016 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢5,048,560.05 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Forty-Five

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis on 5th December 2016 in Accra in the Greater-Accra Region transferred the sum of GH¢5,048,560.05 to Merchant Bank Ghana Limited for the purchase of adb Bank shares knowing it to be proceeds of crime.

Count Forty-Six

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, and 2) Ekow Nyarko Dadzie-Dennis, on or about 5th December 2016 in Accra in the Greater-Accra Region agreed to act together with Page 18 of 26

a common purpose to dishonestly appropriate the sum of GH¢4,130,637.15 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Forty-Seven

Statement of Offence

Fraudulent breach of trust contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, on or about 5th December 2016 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢4,130,637.15 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Forty-Eight

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis on 5th December, 2016 in Accra in the Greater-Accra Region transferred the sum of GH¢4,130,637.15 to Merchant Bank Ghana Limited for the purchase of adb Bank shares knowing it to be proceeds of crime.

Count Forty-Nine

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29). Page 19 of 26

Particulars of Offence

1) Kwabena Duffuor II, and 2) Ekow Nyarko Dadzie-Dennis, on or about 6th December 2016 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢1,588,831.35 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Fifty

Statement of Offence

Fraudulent breach of trust contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, on or about 6th December 2016 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢1,588,831.35 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Fifty-One

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis on or about 6th December, 2016 in Accra in the Greater-Accra Region transferred the sum of GH¢1,588,831.35 to Merchant Bank Ghana Limited for the purchase of adb Bank shares knowing it to be proceeds of crime.

Page 20 of 26

Count Fifty-Two

Statement of Offence

Conspiracy to commit crime namely fraudulent breach of trust contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, and 2) Ekow Nyarko Dadzie-Dennis, on or about 6th December 2016 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate the sum of GH¢1,941,901.45 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Fifty-Three

Statement of Offence

Fraudulent breach of trust contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, on or about 6th December 2016 in Accra in the Greater-Accra Region dishonestly appropriated the sum of GH¢1,941,901.45 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Fifty-Four

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis on or about 6th December, 2016 in Accra in the Greater-Accra Region transferred the sum of

Page 21 of 26

GH¢1,941,901.45 to Merchant Bank Ghana Limited for the purchase of adb Bank shares knowing it to be proceeds of crime.

Count Fifty-Five

Statement of Offence

Conspiracy to commit crime, namely fraudulent breach of trust, contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, and 3) Kwadwo Opoku Okoh between November 2013 and February 2014 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate an amount of $9,546,600.00 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Fifty-Six

Statement of Offence

Fraudulent breach of trust, contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, 3) Kwadwo Opoku Okoh between November 2013 and February 2014 in Accra in the Greater-Accra Region dishonestly appropriated an amount of $9,546,600.00 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Fifty-Seven

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749). Page 22 of 26

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis between November 2013 and February 2014 in Accra in the Greater-Accra Region transferred the sum of $9,546,600.00 to WAICA Reinsurance Corporation Plc for the purchase of shares in WAICA Reinsurance Corporation Plc knowing it to be proceeds of crime.

Count Fifty-Eight

Statement of Offence

Conspiracy to commit crime, namely fraudulent breach of trust, contrary to sections 23(1) and 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, and 3) Kwadwo Opoku Okoh between November 2016 and December 2016 in Accra in the Greater-Accra Region agreed to act together with a common purpose to dishonestly appropriate an amount of $9,167,357.12 which was entrusted to you in trust for depositors of uniBank Ghana Limited.

Count Fifty-Nine

Statement of Offence

Fraudulent breach of trust, contrary to section 128 of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis, 3) Kwadwo Opoku Okoh between November 2016 and December 2016 in Accra in the Greater-Accra Region dishonestly appropriated an amount of $9,167,357.12 which was entrusted to you in trust for depositors of uniBank Ghana Limited. Page 23 of 26

Count Sixty

Statement of Offence

Money Laundering contrary to section 1(1) (a) of the Anti-Money Laundering Act, 2008 (Act 749).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis between November 2016 and December 2016 in Accra in the Greater Accra Region transferred the sum of $9,167,357.12 to WAICA Reinsurance Corporation Plc for the purchase of shares in WAICA Reinsurance Corporation Plc knowing it to be proceeds of crime.

Count Sixty-One

Statement of Offence

Conspiracy to commit crime, namely falsification of accounts, contrary to sections 23(1) and 140(1)(a) of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, and 3) Benjamin Ofori in January 2016 in Accra in the Greater-Accra Region with intent to defraud agreed to act together with a common purpose to falsify accounts of uniBank Ghana Limited to reflect an amount of GH¢227,450,000 as loans.

Count Sixty-Two

Statement of Offence

Falsification of accounts contrary to section 140(1)(a) of the Criminal Offences Act, 1960 (Act 29). Page 24 of 26

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis 3) Benjamin Ofori in January 2016 in Accra in the Greater Accra Region, with intent to defraud, falsified accounts of uniBank Ghana Limited to reflect an amount of GH¢227,450,000 as loans which you knew to be false.

Count Sixty-Three

Statement of Offence

Conspiracy to commit crime, namely falsification of accounts, contrary to sections 23(1) and 140(1)(a) of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, 3) Elsie Dansoa Kyereh and 4) Jeffrey Amon in November 2016 in Accra in the Greater-Accra Region with intent to defraud agreed to act together with a common purpose to falsify accounts of uniBank Ghana Limited to reflect an amount of GH¢601,305,250 as loans.

Count Sixty-Four

Statement of Offence

Falsification of accounts contrary to section 140(1)(a) of the Criminal Offences Act, 1960 (Act29).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis 3) Elsie Dansoa Kyereh 4) Jeffrey Amon, in November 2016 in Accra in the Greater Accra Region, with intent to defraud, falsified the accounts of uniBank Ghana Limited to reflect an amount of GH¢601,305,250 as loans which you knew to be false. Page 25 of 26

Count Sixty-Five

Statement of Offence

Conspiracy to commit crime, namely falsification of accounts, contrary to sections 23(1) and 140(1)(a) of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II, 2) Ekow Nyarko Dadzie-Dennis, 3) Elsie Dansoa Kyereh 4) Jeffrey Amon in November 2017 in Accra in the Greater-Accra Region with intent to defraud agreed to act together with a common purpose to falsify accounts of uniBank Ghana Limited to reflect an amount of $71 million as loan.

Count Sixty-Six

Statement of Offence

Falsification of accounts contrary to section 140(1)(a) of the Criminal Offences Act, 1960 (Act29).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis 3) Elsie Dansoa Kyereh 4) Jeffrey Amon, in November 2017 in Accra in the Greater-Accra Region, with intent to defraud, falsified the accounts of uniBank Ghana Limited to reflect the sum of $71 million as loans which you knew to be false.

Count Sixty-Seven

Statement of Offence

Conspiracy to commit crime namely falsification of account, contrary to sections 23(1) and 140(1)(a) of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis 3) Elsie Dansoa Kyereh and 4) Jeffrey Amon in December, 2017 in Accra in the Greater Accra Region Page 26 of 26

agreed to act together with a common purpose to falsify the accounts of uniBank Ghana Limited to reflect an amount of GH¢102,000,000.00 as loans.

Count Sixty-Eight

Statement of Offence

Falsification of accounts contrary to section 140(1)(a) of the Criminal Offences Act, 1960 (Act 29).

Particulars of Offence

1) Kwabena Duffuor II 2) Ekow Nyarko Dadzie-Dennis 3) Elsie Dansoa Kyereh 4) Jeffrey Amon, in December 2017 in Accra in the Greater Accra Region, with intent to defraud, falsified the accounts of uniBank Ghana Limited to reflect an amount of GH¢102,000,000.00 as loans which you knew to be false.

DATED AT THE OFFICE OF THE ATTORNEY-GENERAL THIS …… DAY OF FEBRUARY 2020.

YVONNE ATAKORA OBUOBISA

DIRECTOR OF PUBLIC PROSECUTIONS