A Christmas Gift for Iraqi Children

A message from the Iraqi Children Foundation (ICF):

Dear friends of Iraqi children,

Need a holiday gift idea for family, friends, employees? Need to increase your year-end tax-deductible donations? We can help!

Make a gift in honor of someone special, and we will send you our two beautiful digital ICF Christmas cards, which you can share by email, or you can print out at home.

These cards are a special token for your gift, designed specially for ICF this year. Read more about our Christmas cards below, and please consider making a year-end contribution here:

Iraqi Children Foundation Special Christmas Cards for 2021:

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Jiyad: IEITI Annual Reports Continue, but Changes are Needed

By Ahmed Mousa Jiyad.

Any opinions expressed are those of the author, and do not necessarily reflect the views of Iraq Business News.

IEITI Annual Reports Continue but Changes in Form, Quality and Substance are Crucial and Needed

Iraq Extractive Industry Transparency Initiative (IEITI) issued its 2018 annual report and, currently, is processing its combined annual report, i.e., for 2019 and 2020 in a single issue.

Releasing the annual reports, though with two year time-lag, is undoubtedly commendable efforts. But the qualitative aspects and lack of impacts of these reports have been constantly identified with flaws and, thus, cause much concerns and raise very serious questions.

Consequently call upon IEITI and EITI is long overdue to undertake thorough revision aiming at making such annual reports different, better, relevant and helpful in enhancing real and effective transparency in the extractive industry in Iraq, more than what has been the case so far.

IEITI issued its tenth annual report, covering 2018, by end March 2021. 2018 preliminary report was delivered on 5 February 2020 and the final version was supposed to be released by latest end of 2020. Due to Covid-19 effect an extension of three months was granted by the International Secretariat of EITI- Oslo; it was release by 20 March 2021.

Currently, IEITI is processing its combined annual report, i.e., for 2019 and 2020 in a single issue; the preliminary report was presented to the MSG on September 2021 and the final report is scheduled for publication on March 2022.

Davinci Consulting / Geneva Group international (DCGGI) was contracted as the Independent Administrator- IP (according to EITI guidelines) to produce the annual reports for 2018, 2019 and 2020.

I reviewed all previous nine IEITI annual reports, and this current review is a continuation of my constant follow-up and monitoring of IEITI activities and my database relating to this topic.

This review covers first IEITI 2018 report followed by brief notes on the preliminary report of the forthcoming 2019/2020 combine report and ends with a few concluding remarks

IEITI 2018 Report

The 2018 Report comprises seven sections with executive summary and list for terms and abbreviations. It is a rather long report, 131 pages, and has 25 files (accessed through different web-links)

After reading the report I can make the following brief remarks on this report.

The executive summary, comparative to previous annual reports, is poor and  limited in coverage, conceptually ambiguous, misleading and, though it is short, its’ data was presented twice in tabular and graphic forms; totally unnecessary.

Except a few substantive improvements much of the contents of the main report were repetition from previous reports and sometimes using the usual copy, modify and paste- CMP method.

The web-links to the above mentioned 25 files indicate those files are either prepared or provided by the related entities, mostly Iraqi entities. Some of the files are in MS Excel with many sheets of varying size, while others are in MS Word.

The consultant, i.e., the IP did not analyse or provide explanatory notes or reconciliation of the contents of most of these files. A random check on the contents of some of these files raises many questions on the validity, accuracy and relevance of their contents. IP left the burden of assessing and using these files on the readers. And since no comments on or revision of the annual report were posted on IEITI website, it seems the MSG members, probably did not read thoroughly the report itself and most or all these 25 files!!!

The reports uses excessively and unjustifiable both tabulations and graphs even for simple two items; this lengthened the report (page wise) and increase its size (bitwise). Moreover, some of the graphs are confused and confusing.

All tables in the reports haves no number and no title and some of them are not professionally done. No references were provided for these tables and thus, it is impossible to check their accuracy or validate their contents.

There are many methodological and conceptual flaws, which could cause serious misunderstanding; below are a few examples.

Neither all activities of the Ministry of Oil nor all activities of the Ministry of Industry and Minerals are “extractive”!!!

Similarly, “associated gas”, “free gas”, “dome gas” all are “natural gas”; but the distinction between them is vital when one considers their data and how it is used. Moreover the term “gas burnt non-investable” is technically wrong and misleading as it justifies flaring!!!!  Also there is difference between “liquid gas” and LPG!!

There is no “Amman” oil in SOMO’s export price setting mechanism for the Asian market. This error has been repeated in previous annual reports due to CMP method; but, why SOMO representative in the MSG did not correct this apparent repetitive flaw!!

Also SOMO do not use “ICE Brent” or “NYMEX WTI” as marker crudes in its price formula for European and Americas markets.

SOMO is not “The revenue recipient government agency” for “Crude oil exports” and not recipient government agency for “the value of oil loaded by IOCs operating within the licensing rounds”.!!!!

Moreover, IOBs do not make direct payment of export revenues to DFI.

When it comes to SOMO, the IP seems to be totally confused in understanding the role of SOMO and the flowchart of oil export revenues, or different parts of the report were written by different people without coordination among them!!!

The focus on “Budget allocation” and “actual transfer” regarding petrodollar and governorate development funds is misleading because it ignores the chronic problems regarding actual spending and how it was done; as the experience since 2010 demonstrates.

There is no West Qurna oilfield; what there are WQ1 and WQ2 oilfields and each is contracted to very different consortiums of IOCs, offered under different bid rounds and thus having different technical service contracts.

Moreover, Majnoon oilfield has been under the National Efforts since mid-2018.

There are no reconciliation done for “Quantities and Values of Crude Oil, Oil Products and Gas provide to Refineries, Oil Products Distribution Company and Ministry of Electricity during” between related entities and MoE.

Occidental (Oxy) relinquished its participation interest in Zubair oilfields in 2016; so why it lifted more than 7.6 million barrels in 2018!!

I have computed that average oil price for “Crude oil lifted by the licensing round companies in exchange for cost recovery and remuneration fees entitled to them” was $64.29426 a barrel, while the average oil price for “Exported crude oil to International Oil Buyers” was $65.73435 a barrel; IP provides no explanation or clarification for this price differentials or aware of it at all??

The report provides no information or data on DFI but refers to 18 page report, so who supposed to do the needed reconciliation comparative to SOMO or IOBs data!!??

The Report says “The revenues of crude oil exports in both the federal Iraq and the Kurdistan region are considered material revenues as their contribution to the total revenues of the extraction sector exceeds the materiality threshold of 1%.” This is a manifestation of gross confusion and total misunderstanding, on part of the IP, of what “materiality threshold of 1%” is all about and what the purpose behind it.

The percentage of unpaid CIT by IOCs amounts to 19% of due CIT; this huge difference should have been investigated, specified and explained in details by the IP, but did not do it convincingly.

Total oil production was reported without making specific reference to the effect of the natural decline on base-line production particularly for the six oilfields contacted under first bid round. Ignoring this fact is erroneous and causes serious miscalculation especially with regards to remuneration fees and related CIT.

The “the value of internal service payments made by the MoF through SOMO to the North Oil Company to cover the cost of production that is exported” does not correspond to oil exported by this company compared to other NOCs such as Missan OC and ThiQar OC; IP provides no clarification or explanation!!

There are more important comments, but I think the above provides enough indication on the quality of the report.

IEITI Forthcoming Joint 2019/2020 Annual Report

Currently, IEITI is processing its combined annual report, i.e., for 2019 and 2020 in a single issue; the preliminary report (99 pages) was presented on September 2021 and the final report is scheduled for publication on March 2022.

The structure of the preliminary report is, in substance, similar to that for 2018, with one important difference or improvement, i.e., MSG remarks on 2019/20 report.

Item twelve of the preliminary report provide 44 different remarks made by MSG members; some of the remarks are broad and generic, while others are specific and to the point.

It remains to be seen whether and how IP addresses, these remarks as well as my notes mentioned in the previous part above, in its final joint report due in March 2022.

As there are only three months left to deadline for releasing the 2019/2020 annual report, it might be a farfetched hope for a well improved report.

Concluding remarks

  • By end March 2022 IEITI have had issued twelve annual reports; on the face of it this is impressive record. IEITI should have accumulated enough human and systemic professional capacity at its National Secretariat to have active, proactive and impacting contribution in preparing the annual reports and to ensure its quality control;
  • It is about time that IEITI and EITI (IS-Oslo) take a stock of the experience so far and revise the structure, contents, methodology and the process for future annual reports that should focus on recent issues and their future implications more than the repetition of a distant past.
  • Future reports should focus on providing detailed and verified data relating to the operational aspects of bid rounds field development in terms of reconciled costs (Capex and Opex), payments, remuneration fees, taxes-CIT among others more than repetition of their contracts terms that have been known since 2009/2010.
  • Comparative data for field manged by national efforts and those manged by IOCs should be provided in as much details as possible and reconciled accordingly.
  • The same applies to different SOMO activities according to a well-articulated matrix comprising different types of crude for different market configurations and related data reconciliation framework. Records of actual oil export price setting during the year should be provide instead of repeating SOMO’s standard document.
  • Corruption has become very serious complex problem in the country, and much of it is in the extractive activities; yet not a single word on corruption was mentioned in IEITI Final Annual Report 2018 or in the preliminary report for 2018/2020 report. Future IEITI should provide sufficient cover on this issue.
  • All contracts signed under the bid rounds have mandatory obligations to undertake at least two Environmental Impact Assessments-EIAs. IEITI annual report should call upon MoO and related IOCs to undertake and publish these EIAs.
  • All contracts signed under the bid rounds have non-refundable contribution to TTS Fund which has a total annual allocation that exceeds $55 million. IEITI annual report should provide comprehensive reconciled data on the annual utilisation for such funding.
  • A “Validation” mission, as per EITI framework, is scheduled for July 2022; it could be an opportunity to address the necessity and feasibility to improve IEITI future annual reports as proposed here. Unless such change and improvement take place, future IEITI reports will be released unnoticed, with no real impacts and become unnecessary formality.

Click here to download the full report in pdf format.

Mr Jiyad is an independent development consultant, scholar and Associate with the former Centre for Global Energy Studies (CGES), London. He was formerly a senior economist with the Iraq National Oil Company and Iraq’s Ministry of Oil, Chief Expert for the Council of Ministers, Director at the Ministry of Trade, and International Specialist with UN organizations in Uganda, Sudan and Jordan. He is now based in Norway (Email: mou-jiya(at)online.no, Skype ID: Ahmed Mousa Jiyad). Read more of Mr Jiyad’s biography here.

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IDC starts Drilling in Mishrif Reservoir

By John Lee.

The Iraqi Drilling Company (IDC) has started drilling a well “Ammara 19” at  Missan Oil Company (MOC)‘s Amara field, within the Mishrif reservoir.

IDC’s Director General, Bassim Abdul Kareem, said the drilling operations were carried out using the 2000-HP drilling rig “IDC 23”.

The planned depth of the well is 3,290 meters.

(Source: Ministry of Oil)

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GKP “on Track” to Meet Production Guidance

Gulf Keystone has provided an operational and corporate update:

Jon Harris, Gulf Keystone’s Chief Executive Officer, said:

We are pleased to announce that we have submitted a draft Field Development Plan to the Ministry of Natural Resources. While the timing of FDP approval is uncertain given the scale of the project, this is an important step forward to develop the significant potential of the Shaikan Field while more than halving CO2 per barrel by eliminating routine flaring.

“Production performance has been strong, reaching a record monthly average high in October, and we are on track to meet our tightened 2021 gross average production guidance. With our leverage to oil prices and low cost base, strong production has translated into robust cash flow generation. We have experienced operational challenges with SH-13 and SH-14 and, subject to well productivity, we are now targeting to increase gross production towards 55,000 bopd in January.

Shaikan Field Development Plan (“FDP”)

  • Following extensive constructive engagement with the Ministry of Natural Resources (“MNR”), Gulf Keystone and its partner Kalegran B.V. (a subsidiary of MOL Hungarian Oil & Gas plc) (“MOL”) have submitted a draft FDP to the MNR
  • The FDP includes the continued ramp-up of Jurassic oil production , an appraisal of the Triassic reservoir and a Gas Management Plan to more than halve CO2 per barrel by eliminating routine flaring
  • The FDP is subject to review and final approval by the MNR, the timing of which is uncertain given the scale of the project. Final investment decision (“FID”) is also subject to approval of both Boards of Directors of Gulf Keystone and MOL, and the Company will provide an update at the appropriate time

Operational

  • Following over 660 days without a Lost Time Incident (“LTI”), we were disappointed to have an LTI during drilling operations in October. Following the incident, we have completed a full investigation and have put in place a number of remedial actions
  • Gross average production from the field in 2021 to date of c.43,300 bopd, in line with tightened 2021 guidance, with record gross average production in October of 45,654 bopd
  • SH-14 has been drilled, completed and is currently being hooked-up , following delays caused by equipment failures and wellbore issues in the subsequent side-track
  • Following the rig move from the SH-13/SH-14 well pad, an acid stimulation programme is now underway on SH-13 to access the broader fracture network in the reservoir after an area of low fracture connectivity was encountered. Acid stimulation is commonly used in carbonate reservoirs such as Shaikan
  • Activities are ongoing to start production from SH-13 and SH-14 and the increase in gross production towards 55,000 bopd, subject to well productivity, is now expected in January
  • Preparations are ongoing to spud SH-15 (formerly referred to as SH-G) which is now expected to be brought onstream in Q2 2022
  • Planned installation of two electric submersible pumps deferred to 2022 after successful trial of lower cost jet pump solution at SH-10 and stronger than expected SH-11 reservoir performance

Financial

  • $283.2 million ($221.7 million net to GKP) received from the Kurdistan Regional Government in 2021 to date for payments of crude oil sales and recovery of outstanding arrears. $32.4 million of the original total net arrears balance of $73.3 million has now been recovered
  • The delayed payment for September 2021 crude oil sales and arrears (gross: $37.8 million; net to GKP: $29.6 million) is expected to be paid shortly
  • Following the payment of the $50 million interim dividend on 8 October 2021, $100 million of dividends have been distributed to shareholders in 2021, in line with the Company’s strategy of balancing investment in growth with shareholder returns
  • Robust balance sheet, with a cash balance of $176 million as at 16 December 2021

Outlook

  • On track to meet tightened 2021 average gross production guidance of 42,000 to 44,000 bopd
  • 2021 net Capex guidance lowered from $75-$85 million to approximately $55 million, principally due to the revised spud date of SH-15 and deferral of installation of SH-10 and SH-11 electric submersible pumps, partially offset by the higher cost of SH-14
  • 2021 gross Opex guidance of $2.5 to $2.9/bbl remains unchanged
  • With continuing strong oil prices and cash flow generation, there may be opportunities to consider further distributions to shareholders and to optimise the capital structure

AGM update

At the Company’s Annual General Meeting (“AGM”) held on 18 June 2021, all resolutions were successfully passed. However, resolutions 2 and 6, being the re-election of the Company’s Chairman and Chief Financial Officer, failed to attain the support of 80% of the shareholders who voted. Voting turnout in general was low relative to prior years, with approximately 49% of the total shareholder register voting. The Company continues to look at ways to increase voting turnout at future general meetings.

Substantially all the votes against resolutions 2 and 6 were from a single major shareholder. In accordance with Provision 4 of the 2018 UK Corporate Governance Code, the Board has consulted with the single shareholder, and, as part of this exercise, also consulted with the Company’s other major shareholders.

Feedback received from the single shareholder encompassed issues principally related to the Company’s operational progress, organisational structure and capital allocation. The Company also received feedback from other major shareholders, all of which were supportive of resolutions 2 and 6. The Board has carefully considered the issues and has addressed them, to the extent possible or necessary. The independent members of the Board continue to hold every confidence in both the Chairman and Chief Financial Officer, recognising the value and contribution each bring to the Company.

The Company will continue to engage with the major shareholder in question and welcomes ongoing engagement and feedback from all shareholders.

(Source: GKP)

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Half of Families in Drought-Affected Iraq need Assistance

One in two families in drought-affected Iraq need food assistance

The scale of suffering inflicted by drought on Iraq’s populations this year is laid bare in new research by the Norwegian Refugee Council (NRC).

It shows that one in two families in drought-affected regions require food assistance because of drought, while one in five do not have sufficient food for everyone in the family.

Communities across Iraq have faced damaging losses to their crops, livestock, and income. Children are eating less, and farmers and displaced populations are hit hardest.

According to NRC’s research, which surveyed 2,800 households in drought-affected areas across the country:

  • 37% of wheat farmers and 30% of barley farmers have suffered crop failure of at least 90% of expected harvest,
  • 37% percent of households have lost cattle, sheep or goats in the last six months, mainly due to insufficient water, inadequate feed or disease,
  • The average monthly income in six out of seven governorates surveyed has dropped lower than the monthly survival threshold.[i]

Samira*, 46, has returned from displacement to Mosul to farm her land with two of her five children, but has already seen reductions in produce. “Our production has decreased due to water shortage recently, which also led to a decrease in our income… I can’t afford the necessary food for my family so I borrow money from my relatives or buy food on credit,” she told NRC.

Over the past few years, drought conditions, rising temperatures and decreasing rainfall have reflected the growing threat of climate change in the country. Water flow from upstream countries has also receded.

“Our harvest has dropped due to drought. Our land was thriving but now it is losing its value day after day and no one seems to care about what farmers are facing. Our land used to produce 20 tonnes each season, now it’s no more than 10 or 11 tonnes,” said Osama, a 27-year-old farmer from Hawija.

Such extreme circumstances have forced people to leave their home, compounding the displacement crisis in Iraq. Of those surveyed, 1 in 15 households told NRC that a family member had migrated in the last 30 days in search of work and income. Many of those had been in displacement at least once before, or had just returned home. Young people are particularly vulnerable as our research shows that 45% of people aged 15-24 had left their farming communities to find a job in towns and cities, while 38% have lost a job.

The outlook for 2022 is worrying, with continued water shortages and drought conditions likely to devastate the coming farming season. This may increase families’ reliance on purchased water as well as poor hygiene practices, which could lead to disease outbreaks. There are signs of waves of displacement already taking place amid water scarcity, income losses, and rising food prices within farming communities.

“Families are telling us they have to borrow money to eat amid soaring prices and dwindling savings. They say their only source of living is vanishing in front of their eyes. Their lands are drying up and there is nothing they can do about it. This is all rooted in a water shortage crisis,” said Maithree Abeyrathna, NRC’s Head of Programmes in Iraq.

“We want to see solid water management plans to support communities badly hit and prevent future shocks, and these plans must be informed by farmers themselves.”

NRC is also calling for international assistance to support livestock farmers and provide irrigation rehabilitation and drought tolerant seeds to reduce crop failure and crop losses. The Governments of Iraq and Kurdish Regional Government are encouraged to incorporate climate-mitigation strategies within national job creation efforts and advocate for water-sharing agreements to be upheld by upstream countries to prepare for the future effects of climate change in Iraq and continued drought conditions.

*Name changed to protect identities

Read the full report here.

Facts and figures:

  • NRC interviewed 2,806 households in Anbar, Basra, Duhok, Kirkuk, Ninewa, Salah Al-Din, and Thi Qar governorates.
  • 300 internally displaced people and 1,500 returnees are among the respondents.
  • An additional survey was conducted with 100 food vendors and livestock traders, as well as 48 key informant interviews with community stakeholders and authorities, namely local authority representatives and employees of the Department of Agriculture or Department of Irrigation.
  • NRC is responding by providing drought-tolerant wheat seed varieties to more than 2,000 families in Kirkuk, Ninewa, and Anbar governorates to help with crop losses and crop failure amidst ongoing drought conditions. NRC has also supported more than 200 families with cash-based livestock feed in Sinjar and Baaj.

(Source: NRC)

(Photo Credit: Fared Baram/ NRC)

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China signs Partnership Contract with Iraqi Drilling Company

By John Lee.

China’s Zhongman Petroleum and Natural Gas Group Corporation (ZPEC) has signed a partnership contract with the Iraqi Drilling Company (IDC).

The Director General of the IDC, Basem Abdul Karim, said that the contract includes the provision of support and completion of the work associated with drilling and reclamation operations at Iraqi oil fields.

It also includes the development of personnel and the transfer of expertise and technology.

(Source: Ministry of Oil)

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How Corruption Erodes Healthcare in Iraq

By Mac Skelton and Abdulameer Mohsin Hussein, for the Konrad-Adenauer-Stiftung.

Medicine Under Fire – How Corruption Erodes Healthcare in Iraq

The April and July 2021 hospital fires in Nasiriya and Baghdad left hundreds dead, adding insult to injury for a medical system that had already buckled under the weight of the COVID-19 pandemic. Why did these deadly fires transpire?

In the media, journalists highlighted a lengthy series of contributing factors leading to the tragedy, including flimsy and highly flammable construction materials, the explosion of mismanaged oxygen tanks, electrical shorts, and a lack of fire safety equipment.

Underlying these defects, ordinary Iraqis pointed to a deeper cause: pervasive corruption in the healthcare sector. Corruption, they alleged, explained why it was that an oil-rich country had not built and maintained safe and secure health facilities.

This preliminary paper looks to the tragic phenomenon of mass-casualty hospital fires in Iraq’s COVID-19 wards to kickstart a larger policy-oriented conversation on the political drivers, key mechanisms, and human costs of corruption in the healthcare sector.

Broadly speaking, the research contends that political parties in control of the healthcare system compromise the safety and efficacy of both public and private hospitals by systematically evading quality controls and maximizing profits from medical supply chains at all costs.

Click here to download the full report.

(Source: Konrad-Adenauer-Stiftung)

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Iraq Oil Revenue Forecasting Model — A Critical Assessment

By Ahmed Mousa Jiyad.

Any opinions expressed are those of the author, and do not necessarily reflect the views of Iraq Business News.

Iraq Revenue Forecasting Model — A Critical Assessment

INTRODUCTION

This review was prepared upon request from known international organization (XXX) regarding two documents prepared by a consultant (CCC) on Iraq Revenue Forecasting Model, and it comprises the following items: Background, which provides brief information on the deadline and the two documents; the Review Objective Criteria, which guides the assessment of the two documents by using six criterion; the Details of the Review comprises two parts corresponding to the two documents and finally the Review Assessment Matrix, which explains and calculate the final score rate for the two documents.

BACKGROUND

After a few email exchanges (XXX) posted two documents on 3 May 2021 and requested the peer review to be delivered by COB on 11 May. The first document entitled “EXPLANATORY NOTE OF IRAQ REVENUE FORECASTING MODEL” is in MS Word; hereinafter referred to as “EXPNOTE”, while the other is in MS Excel Sheet; hereinafter referred to as “EXLSHEET”.

The “EXLSHEET” comprises 22 Sheets and they differ in contents, length and size; they are referred to by their coded-names that appear in the bottom margin of the “EXLSHEET”.

(XXX) email mentions, “The model is currently being reviewed by partners before being shared with the Iraq entity (EEE) and its stakeholders in the Ministry of Oil and international oil companies.”

My assessment was delivered before the deadline and I suggested to share it with the consultant for further consideration, and requested permission to publish my assessment. (XXX) promised to share it with the consultant and asked me to wait for a couple of months before publishing it; it is today 14 December or more than seven months.

For ethical norms and considerations the names of the international organization (XXX), the consultant (CCC), the Iraq entity (EEE) and relevant entities (PPPPPPPPP) in Iraq are not disclosed.

Peer Review Objective Criteria

To conduct the peer review for the “EXPNOTE” and all 22 sheets in the “EXLSHEET” I formulated and was guided by the following criteria:

  1. The conformity and adherence of the two documents to an acceptable standard for consultancy service regarding topics related to upstream petroleum; such standard relates to style, format, substance and research and consulting service ethics;
  2. The qualitative aspects of the consultant methodology, strength of arguments, analysis consistency and coherence; the accuracy, validity, relevance of inputs, particularly used data; quality control of the computation, charts and contents of the “EXLSHEET”;
  3. The “add-value/ knowledge impact” for the intended client, particularly the usefulness of the entire consulting assignment to relevant entities (PPPPPPPPP) in Iraq;
  4. The consultant work is basically relating to 11 oil projects, hence, the work and findings of the consultant was assessed according to the contractual provisions of the related signed contracts; and also since the above mentioned Iraqi entities and IOCs are the direct parties to these contracts.
  5. Also the consultant dwelled heavily on export price and revenues, thus the analysis and finding will be assessed comparative to SOMO’s price setting mechanisms, markets configuration and marketing modalities. Such comparative assessment complies with verification and evidence-based consulting and research methodology;
  6. The test of reality vs. expectation. Experience with modelling and forecasting indicates that reality seldom coincides with expectation. Hence, the consultant’ “forecasting the past” will be tested against actual, historical official data regarding oil production, oil export, oil prices and oil export revenues. The outcome of reality vs. expectation test has implications for assessing the usefulness and reliability of forecasting the future by the same proposed model.

DETAILS OF THE PEER REVIEW

Part one:

EXPLANATORY NOTE OF IRAQ REVENUE FORECASTING MODEL- “EXPNOTE”

The Following remarks are made after deep and thorough examination of “EXPNOTE” text:

  1. This document is by definition an explanatory note, but where is the main report for this assignment? Usually, consulting assignment of quantitative nature comprises a main report, annexes, explanatory note and references. Hence, something was missing and neither the explanatory note nor annexes, in this case the “EXLSHEET”, replaces the main report!!. The consultant seems to apply “trust me” this is a model for forecasting Iraq’s revenue even without specifying, at the outset, what type of revenue!!
  2. “EXPNOTE” says, “The model is built according to the FAST standard of financial modelling”. But what FAST stand for, what are its standard of financial modelling and are the standard peculiar to upstream petroleum or for general purpose!! Does FAST has mathematical, statistical specific format or it is just a computation process using Excel facilities? Is there any reference to FAST and evidence supportive to its usefulness for upstream petroleum projects? Hence, the Model is not provided and FAST modelling is unknown; this is methodological flaw.
  3. One of the model two purposes is to “forecast the past”!!! This is both surprising and erroneous since detailed data on oil production, oil exports and oil production is available on monthly bases since mid-2007! so what is the need to forecast the past??; this not only manifests lack of information on the part of the consultant, but also seems the consultant had committed serious error of judgement, as might be interpreted to reflects arrogance, pompousness mentality thinking, “we know it better than you”!!!!!Further discussion on the validity, reliability and test of “forecast the past” is provided in Part Two below.
  4. “EXPNOTE” states, “although SOMO publishes export sales, these figures are before the recovery of costs and payment of fees to the operating companies”. There are many flaws in such invalid statement: first; SOMO is oil marketing company while cost recovery and payment of fees to IOCs are the responsibility of other entities within the Ministry of Oil-MoO and they are paid in accordance with the related service contracts; second, SOMO export reports are monthly, while payment to IOCs are on quarterly base after auditing and verification of invoices presented in the previous quarter; third, most payment to IOCs are made in kind as per contract provision and oil lifting protocol that is elaborated in each oilfield related service contract (in Addendums two and four). It appears the consultant is not familiar with the technicalities and contractual provisions relating to SOMO’ export reporting and MoO payment to IOCs;
  5. The consultant uses long and tedious calculations to “estimate production which is not exported.” On this I have the following remarks: first, data on oil production and allocation between export and domestic demand has been available for years and they are published on monthly bases. Therefore, there is absolutely no need to estimate what is already available. Second, the approach of “factor the field-level synthesised estimates of production against recorded exports” is conceptually and methodologically incorrect and third, as we shall see and prove that the consultant computation and estimate of production not exported was totally wrong and based on inaccurate understanding (see item 11 in Part Two below). Hence, the consultant argument for “estimate production which is not exported” is not valid and misleading and the computation model is wrong. For example the consultant model estimates 32% of production in February 2021 was for domestic consumption, while actual formal data shows only 12.21% during same month, indicating a margin of error in the consultant model of 148.32%; unusual high error margin in testing the model estimation against actual reality. Therefore, all what is written in “Estimating Production: synthesised field-level production estimates” fail the test of accuracy, validity and relevance.
  6. In “Estimating Price”, the consultant refers to “discounts for Iraqi crudes”. Data and SOMO monthly price setting mechanism disapprove such assertion. SOMO uses different «price formulas” each has its own qualitative variables API, Sulphur content, destination and Marker crude; discounts and premiums are dependent on marketing conditions, in addition to special formula for Jordan, and almost two shipment a month, 2mb each, sold on spot platform that gives “extra price” compared to the usual “term contract” for that particular month. It appears the consultant knows very little about SOMOs oil price setting modalities. Further remarks will be provided later when comparing consultant price estimation to SOMO’s export price (See items 3, 5, 9 and 10 in Part Two below)
  7. The model estimation reported under, “Current Results”, are all wrong because the estimated export sales for 2020 were much higher than actual official export revenues (see further details on the Dashboard Sheet in in Part Two below). Again, the model estimation fails under the test of comparison with actual data: i.e., reality.
  8. The consultant argument regarding “Basra-Ceyhan differentials” is weak, vague. irrelevant and not convincing for the following reasons: first it is not specific whether the consultant argument is related to volume or value of export; second, due to pipeline problem Iraq export through Ceyhan have been very limited (according to final official export data for the first quarter this year 96.239% of Iraqi oil was exported from Basra, generating 96.341% of total oil export revenues); third, State Budget Law 2021 obliges KRG to deliver, at SOMO export price, 250000 per day. Hence the consultant is apparently unaware of these facts!!!
  9. The information and argument presented by the consultant regarding the “R-factor” are also inconsistent, misleading and inaccurate; first, the consultant says “details of the terms of the R-factor are not available”: this is not true as articles addressing this issue and computation of its impact were available on the public domain since 2010!!. Second, disregarding R-factor reduces government take and thus, increases the disparity between actual government take and “net to the government” as called by the consultant; third, the reference to “Faihaa field” is misleading and disingenuous since the field was offered under BR4 (exploration blocks) and it is at very early stage of development and, thus, its contribution to total oil production is very insignificant to have an impact: in the meantime the consultant ignores other important sources of revenues (see next items 10, 11 and 12). Finally, the claim that the analysis “shows a potential margin of error of a maximum of 1.63%” is baseless and deceptive (see item 8 regarding “Analysis Sheet” in Part Two below)
  10. The assignment did not attempt to estimate government revenues from domestically consumed oil!! No reason was provided!! Why, then, the consultant used time and efforts to “synthesized production” when related data are already available on the public domain?? Finally why and in what way domestic revenues impact “Margins of Uncertainty” in the model computation??
  11. Both documents exclude oil production from field managed by National Effort, especially those not contracted to IOCs under the four bid rounds. Also they did not cover two oilfields offered under BR2. It is not clear why the consultant excludes these oilfields and did not say a word about them?? Ignoring oilfields managed by national efforts has significant role in underestimating government revenues and thus, such exclusion is serious flaw.
  12. Also both documents do not include production and export revenues for LPG, NGL, Naphtha and Fuel oil. Why these are out of the consultant scope is unclear, though data on these items is available on the public domain. Again, ignoring them is additional shortcoming of the two documents.
  13. Throughout the two documents data selection and referencing them raises further concerns. Professionally and methodologically it is vital to differentiate between convenient “selectivity” and “thoroughness“. Briefly, when data are available on the public domain but are not used or referred to by the consultant that reflects serious professional weakness, unethical, and manifest lake of thoroughness; i.e., the consultant should have searched thoroughly for the related and relevant data. When data are available on the public domain but are not used by the consultant, instead the consultant “synthesised” or “forecast the past” based on wrong premises and inaccurate understanding of the basic issues, that resembles serious infringement of methodological, professional and research ethics. When the consultant present limited selective referencing to data (mostly in the “EXLSHEET” document) that only reflect convenience for the consultant. Moreover, when that selective referencing is not related to the computed item (e.g. WQ1 “EXLSHEET”: Row 35 vs. Row 59) causes confusion for the intended client or user!!
  14. “EXPNOTE” asserts,”The model is designed to be updated”. But all hundreds, if not thousands, cells in the “EXLSHEET” that contains computable values are codified pursuant to MS Excel program, e.g. all cells in WQ1 “EXLSHEET”: Row 66 to Row 72. To update the model these cells should be changed and, thus, the intended client and user must have good and professional experience with MS Excel; this is highly unlikely. If the clients (e.g., PPPPPPPPP) have good and professional specialists with MS Excel, they could use their model, since there is nothing intrinsic about “EXPNOTE” and “EXLSHEET”. For example the clients specialists can use the “Formulas” offered by MS Excel program and the good data they do have already; they could, then, arrive at more valuable, consistent, tested and acceptable results, much better than “EXPNOTE” and “EXLSHEET” offer!.
  15. All above mentioned remarks, shed serious doubt on the entire work of this consultant, and, hence, limits its value or add knowledge to the intended clients. This view is further enhanced by more remarks on the “EXLSHEET” as summarised in the following part two.

Part Two: Reviewing “EXLSHEET”

“EXLSHEET” comprises 22 Sheets and they differ in contents, length and size; they are  referred to by their coded-names that appear in the bottom margin of the “EXLSHEET” document.

By going through all of them prompted me to register large number of notes, remarks and questions; the more I read and check, the more I became concerned about the contents of the spreadsheets. Thorough and complete review and checking is daunting task and requires much longer time than (XXX) deadline permits. Hence, the following is very condensed peer review of “EXLSHEET”.

1- Excel Sheet “SynthProd” provide a chart titled “Iraq: synthesized field production profile”. The following remarks are made on this sheet: A- there is no “Missan” field; what is there (according to first bid round- BR1) three oilfields in Missan province that were contracted under one contract while they have different profiles and locations (the consultant provides no note on this and thus gives the impression as if it is one field); B- it ignores oilfields developed and managed by National Efforts”; C- it excludes two fields offered under BR2!!! D- as shall be discovered later (see item 11 in part two below) all such synthesized field production profiles were based on wrong premised computations, and this raises serious research and consulting ethical questions and standard.

2- Excel Sheet “RP- Brent”. Many observations are register on this sheet: A- chart titles are missing; B- “Y & X” axis titles and their unites of measurement are missing; C- one chart hast two trend lines and equations without specifying which is which; D- R2 values for the two equations are very low, indicating weak statistical significance. E- Moreover, the table has no title, no unit of measurement and what “Y” and the other two columns represent???? F- These are simple trend-line equations that are computed instantly/automatically by Excel sheet, but the consultant provides absolutely no explanation or notes on the usefulness of these equations and used them regardless; G- the intended client and user have to wonder what these charts and table are about!! Hence, this is serious professional flaw and the sheet has zero value for the client!!

3- Excel Sheet “Brent vs. realised “. Questions on this sheet are: A- which “Brent” was it: dated, futures or spot ( such as the monthly EIA’ STOE or S&P Platts or Argus etc.)?; B- what is the source for the data?; C- for “SOMO weighted realized price” what is/ are the used “weights”, why and what is the source for the used “weights”?; D- how the “SOMO weighted realized price” is different from “SOMO published export prices”?; E- finally what about “Brent” was it also weighted, by what weight or no and why!!!

4- Excel Sheet “Production”. Remarks on this sheet are: A- unit of measurement is missing; B- what is the consultant explanation of an illogical contradiction that SOMO exports were higher than the “Synthesized Production” prior to 01.01.2012, as this shed serious doubt on the consultant calculation??; C- what is the consultant explanation of the odd event as per 01.01.2015 when SOMO Export up while EIA production down compared with previous year??; D- also the consultant fails to explain why  the “Synthesized Production” was higher than EIA production during 2014!!

All that reflect the mechanical manner in preparing the synthesized production without considering well-known major events that impacted Iraq’ production and export!!

5- Excel Sheet “Revenues” calls for the following remarks and questions: A- chart title is ambiguous: does it refer to “total” or “oil export” or “oil sector” revenues; B- the details of IMF and EITI references are missing; C-  was it IEITI or EITI ????; D- the consultant did not explain the pattern of all three data sets: why “EITI” data are higher than both IMF and SOMO during 2010-13, then it turns lower than both during 2014-16, then goes above both after 2016, when IEITI revenue data are provided by SOMO!! Can this be explained by the mixing up, by the consultant, of the usual differences between the “preliminary” and “final” SOMO’s monthly data??!!

6- Excel Sheet “Time-Esc”: this seems to be a templet Sheet for calculations. But comments and clarifications are missing, no definition of terms and acronyms are provided and some components such as discount rate, discount type, inflation rate and index are not used or referred to in other excel sheets; so what is the justification for having and computing them in abstract!! Ironically, some of these rates were computed up to 1 November 2025 (e.g., Rows: 61 and 62 on “inflation index” without specifying whether this applies to “cost recovery” or “oil price” or both; Rows: 71 and 72 on “Discounting rate” without specifying to which cash flow this applies)

The “Timing” rows (from day one of the month to last day) is repeated many times in this sheet and also in all other sheets: this format is totally unnecessary (it could be replaced easily by the name of the month) and, together with other components in this “Time-Esc” could overwhelm the user or the intended client with too many inputs, too much computations and extremely large number of codified cells.

This templet sheet manifests and could also explain the mechanical application of MS Excel by the consultant!!

7- Oilfield Excel Sheets. Most of the remarks mentioned above are generated from the Excel Sheets for the 11 covered oilfields. A comprehensive peer review of each of these sheets takes much longer time. But a quick checking reveals many flaws and shortcomings that shed serious doubt on the accuracy of the entire work.

For example Excel Sheet for Zubair’ Row 136 it was written “”Rumaila daily production”; what Rumaila has to do with Zubair oil production!!!!???? Moreover, “daily production” and “incremental production” Rows: 136, 137 and 139 were assumed to be constant for two years: from 01.01.2020 to 31.12.2022; this is totally against a declared policy by the Ministry of Oil-MoO. The inserted data in Row 148 relates to “IOC Remuneration fee”; it is totally wrong; the consultant was not informed about the changes in the Zubair consortium composition!! Moreover, why the values change when both, “daily production” and “incremental production” were assumed constant!!?? Also what is the difference between “SOC payment to Treasury” (Row 162 which has “45%” of what? but no values inserted in the row) and “SOC Transfer to Treasury” (Row 163, which shows fluctuating values during the entire period despite constant “daily production” and “incremental production”!!! Finally, the consultant provides no further notes on the fiscal system for Zubair oilfields that reflects the situation as on 2020.

The case for Majnoon oilfield is even more disturbing. In addition to all remarks I made above regarding Zubair oilfield are also valid here, the consultant seems unaware that Majnoon oilfield has been relinquished since 2018 and is now developed under the national efforts. This means no cost recovery and remuneration fee to IOC and thus all calculations are invalid and have absolutely zero value. This manifests the mechanical use of MS Excel by the consultant without full, updated and correct understanding of the fiscal system of the upstream petroleum under Iraq’ long term service contracts.

8- Excel Sheet “Analysis”. This is the core sheet for the entire calculations, and it is the largest sheet with column number reaches (FJ) and 554 rows. Thus it deserves careful attention and requires much more time to go through it thoroughly, but based on the below remarks, this sheet causes much concern and raises too many questions and remarks.

The sheet begins with confusion: in Row 1 written “RUMAILA”, but the remaining rows are not confined to Rumaila oilfield!!!.

All data for rows 10 to 20 are or could be wrong; they cannot be in “mbpd”!!!!!!????;

All oilfields offered under first bid round- BR1 were producing on 1.01.2010; therefore the data for 2010 for those oilfields are wrong because each of those fields has “baseline production”, which the consultant excluded them;

Data for rows 10 to 20 are labeled “Historical production”, while data for rows 38 to 49 are labeled “Synthesised production”, but the data are exactly the same to the last digit!! So what is the difference between the two sets of data??? As this causes confusion and also generates and replication consequences on the entire work, calculation and the chart in the consultant Excel spreadsheet;

All data in row 62 are or could be wrong; they cannot be in “mbpd”, and most likely the individual who prepared this Excel spreadsheet is not careful in selecting the “unit of measurement” or inconsistent in using defined acronyms and in using number format for Excel spreadsheet (i.e., a difference between “1066 and 1,066 since 1.066 is not permitted).

A major problem with this Excel Sheet “Analysis” is that it replicates or recycles all type of flaws that are identified in all the 22 Excel Sheets, particularly those related to specific oilfields, oil prices and oil production.

The magnitude of flaws, ambiguities, inaccuracies and absence of explanations in this core spread sheet manifest alarming poor quality control of the entire work under review!!

9- Oil price in Oilfield Excel Sheet. For example “Missan” data on oil “Price” of the related oilfield: rows 103, 104 and 105 and on “Fiscal Regime” (a misconception of revenues!!!! in row 110 (another confused data unit of measurement).

All oilfields covered by their related Excel Sheet have exactly the same oil prices; this “all fields same price” is absolutely not possible, and thus seriously wrong, since these oil fields produce crudes that are qualitatively different  in terms of gravity (API), Sulphur contents and other particulars. The implications of this wrong price estimation should cause serious concerns because the contractual deemed revenues-DR depends largely on the quality of the crude and DR decides the cost recovery. Moreover, DR is, again contractually, is measured at the “delivery point” on the boarder of the oilfield not at the export terminal. Hence, the consultant approach to use unified set of oil price for all oilfields and for the covered period was not only wrong but also leads to higher amount of cost recovery; this is very serious flaw with damaging implications.

10- Another flaw is related to Basra oil price: in Excel Sheet “Mth Inputs” Row 15 the consultant uses “Basra oil price” and in Row 27 uses “Basra light”; but both price sets are identical. From oil marketing this is also wrong and not possible. In reality Iraq markets three qualitatively different crudes from the southern exports outlet: Basra Light, Basra Medium and Basra Heavy, and each have different prices whether that through the usual “Term Contract” or through the monthly limited direct/spot sales.

Finally, the differentials between “Basra light” prices and “all fields same price” was very thin and in five months it was even negative, i.e., “Basra light” prices was lower than “all fields same price”; this almost impossible oil marketing scenario adds more doubt on the professional competence and quality of the consulting work.

11- All calculations relating to the “Incremental production”, (Row 137) in the Excel Sheets for Halfaya, for Gharraf, WQ2, Badra and Majnoon (under BR2), Faihaa (BR4) and Ahdab (converted contract prior to BR1), are wrong since they contravene the related contracts, which has no incremental production. Moreover, the computation equations for the cells in the said row are wrong technically and geologically since it assumes a lasting initial production, i.e. no natural decline!!! As for Rumaila, WQ1, Zubair and the 3 Missan fields (under BR1) all are also wrong since they contravene the related contractual provisions; which has annual natural decline rate of the base-line (initial) production!!!

These wrong calculations lead, logically and practically, to underestimation of fields development efforts and their production, to wrong estimation of cost recovery and remuneration fee for all covered oilfields; what was premised on wrong understanding produces wrong results and, thus, should be disregarded.

12- The “Dashboard” Sheet contains selected charts from other sheets; thus all remarks made on these sheets are valid here. In other words, this “Dashboard” Sheet replicates all flaws, wrong calculations, misconceptions and inaccuracies (The reader is highly advised to see the comments made on Excel Sheets that are reproduced in this “Dashboard” Sheet).

In addition, the following remarks are made on this “Dashboard” Sheet: the “table” referred to in G6 was not provided!!; “Brent Futures Price Scenario” was not explained; the table (on Rows18 to 34) has no unit of measurement; the estimated export sales for 2020 is much higher than actual export oil revenues officially announced by SOMO/MoO by 22.4%. When estimation against actual (historical) data results in such margin of error, that margin of error could be even higher in forecasting the future!!!

Moreover, the cells in Rows 51 to 55 look mysterious with absolutely no explanation or clarifications:

Finally, as was the case with “Analysis” sheet, “Dashboard” sheet replicates or recycles all type of flaws that are identified on the reproduced charts.

13- Operating cost was not mentioned in the two documents “EXPNOTE” and “EXLSHEET”. Not a single row in any of the field’ related sheets mentions the operating cost for oil produced in the related field. The consultant provides no explanation for excluding this significant cost item from estimating government revenues.

Ignoring operating cost is a major and additional flaw that reduces further the soundness and usefulness of “EXPNOTE” and “EXLSHEET”.

14- All Excel sheets and their components could overwhelm (intimidate) the user or the intended client with too many inputs, too much repetition, too much computations and extremely large number of codified cells. One cannot speculate whether that was intentional or due to professional deficiency on the part of the consultant; but, it is highly likely that the current version of “EXPNOTE” and “EXLSHEET” has very limited value, if any, to the user or the intended clients in Iraq.

The Review Assessment Matrix

This final part intends to summarise the result of assessing both documents, “EXPNOTE” and “EXLSHEET” that were presented by the consultant. The following matrix was premised on the six objective criteria mentioned earlier and the evaluation score for each criterion.

The score ranges from (1), which means “bad”, through (3), which means “acceptable but not satisfactory” to (5), which means “very good”.

The six criteria have equall values, and each score was decided in the light of the above details in this peer review:

Total score under the six criteria ranges from total minimum 6 to total maximum 30 and final score rate (%) is the total gained score to maximum score:

Score rate under 50% means unfavourable assessment of the two documents, which means rejecting the consultant work and should not share it with the user or the intended clients;

Score rate at 50% means the work is acceptable but should be revised to address satisfactorily all what the peer review says before sharing it with the user or the intended clients;

Finally, score over 50% means accepting consultant work and recommends sharing it with the intended user or the intended clients.

Criteria/ Score Matrix

 

Peer Review Objective Criteria/ Score 1 2 3 4 5
Conformity with acceptable standard for consultancy service   2      
The qualitative aspects of the consultant methodology   2      
The “add-value/ knowledge impact” for the intended client   2      
The contractual provisions relating to the 11 projects 1        
SOMO’s price setting mechanisms and marketing modalities. 1        
The test of reality vs. expectation 1        
Total Score 3 6 0 0 0
Final Score Rate ((3+6)/30)=30%

The final score rate is 30%, which corresponds to 1.5 on the scale from 1 to 5.

Regretfully, this overall low score indicates that the standard, quality and usefulness of the consultant work are much less than acceptable level.

In an extensive communication with well-respected oil professional and two times oil minister, I learned that the Ministry of Oil has good Ashtar program, which seems to be by far more superior and well-functioning than this “EXLSHEET”; with the presence of Ashtar, the consultancy and its two documents, “EXPNOTE” and “EXLSHEET”, become redundant for the clients in Iraq.

 

Mr Jiyad is an independent development consultant, scholar and Associate with the former Centre for Global Energy Studies (CGES), London. He was formerly a senior economist with the Iraq National Oil Company and Iraq’s Ministry of Oil, Chief Expert for the Council of Ministers, Director at the Ministry of Trade, and International Specialist with UN organizations in Uganda, Sudan and Jordan. He is now based in Norway (Email: mou-jiya(at)online.no, Skype ID: Ahmed Mousa Jiyad). Read more of Mr Jiyad’s biography here.

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KRG hits back at Genel Energy Claims

By John Lee.

The Kurdistan Regional Government (KRG) has responded to the statement on Friday by Genel Energy regarding the production-sharing contracts (PSCs) at Bina Bawi and Miran.

The KRG strongly denies that it is in repudiatory breach of the PSCs, and denies that Genel is entitled to any compensation.

It adds that it will vigorously defend any claim that is brought by Genel, and intends to pursue its own counterclaims for damages resulting from Genel’s renunciation of the PSCs.

The full statement from KRG follows:

On 10 December 2021, the Kurdistan Regional Government received a letter from a subsidiary of Genel Energy plc (“Genel”). In this letter, Genel confirmed that it did not intend to continue to perform its obligations under the Bina Bawi and Miran PSCs, and purported to terminate the PSCs with immediate effect. The Government understands that Genel Energy plc has made the same assertions in a public press release dated 10 December 2021.

Genel’s letter and the related press release were prompted by the Government’s issuance on 5 December 2021 of formal Notices of Termination, which validly terminated the PSCs subject only to the completion of the dispute resolution process set out in the PSCs.

Genel has sought to justify its termination of the PSCs by wrongly asserting that the Government is in repudiatory breach. The Government strongly denies that it is in repudiatory breach of the PSCs. Genel has also falsely claimed that the Government stated it would not perform its obligations under the PSCs. On the contrary, the Government has always acted in accordance with its obligations under the PSCs, and has consistently communicated the same to Genel.

However, Genel’s 10 December 2021 communication confirmed unequivocally that Genel had renounced the PSCs, and the Government has therefore confirmed today to Genel that the PSCs are validly terminated with immediate effect.

The Government regrets that Genel has failed to offer any credible proposals to develop the Bina Bawi and Miran oil and gas fields, and notes that this failure has significantly delayed the ability of the Government to develop those fields on a timely basis.

The Government also notes Genel’s public statement that it will pursue a substantial claim in international arbitration from the Government as a consequence of the termination of the PSCs. The Government strongly denies that Genel is entitled to any compensation. The Government will vigorously defend any claim that is brought by Genel, and intends to pursue its own counterclaims for damages resulting from Genel’s renunciation of the PSCs.

(Source: KRG)

The post KRG hits back at Genel Energy Claims first appeared on Iraq Business News.

Unaoil Bribery Conviction Quashed

By John Lee.

Ziad Akle, Unaoil‘s territory manager for Iraq, has had his conviction for bribery quashed by the UK’s Court of Appeal today (Friday).

He had been sentenced to five years’ imprisonment in July 2020 having been found guilty of paying over $500,000 in bribes to secure a $55-million contract to supply offshore mooring buoys in Iraq.

The court found that the refusal by Serious Fraud Office (SFO) to provide key documents to the defence was “a serious failure by the SFO to comply with their duty,” adding that “that failure was particularly regrettable given that some of the documents had a clear potential to embarrass the SFO in their prosecution of this case.

Paul Bond, a former senior sales manager at SBM Offshore (SBM), which was a client of Unaoil, had his request for leave to appeal against his sentence denied.

The full judgement can be read here.

 More here, here and here.

(Source: England and Wales Court of Appeal – Criminal Division)

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