This letter describes the evolution of contractual relations of the U.S. law firm of Shulman Rogers, Gandal, Pordy & Ecker, P.A. (hereafter "Shulman Rogers”) initially with the Transitional Federal Government (TFG) of Somalia dating back to 2010 and subsequently with the FGS since 2013. It describes the practices of Somali authorities, Shulman Rogers and associated entities and individuals in the effort to recover Somali overseas assets in a manner contrary to the public good and the measures to protect vested interests in the privatisation of these funds, including through a ‘counter-investigation’ undertaken with FTI Consulting that was designed to cover-up the findings of the Monitoring Group’s previous report (S/2013/413), particularly those findings related to corruption and mismanagement of Central Bank funds. This letter further describes the role of an entity called Haden Global Services in the ‘counter-investigation’, in the recovery effort for overseas assets and as a mechanism for payments by Shulman Rogers to its facilitators, namely Musa Haji Mohamed Ganjab and Abdiaziz Hassan Giyaajo Amalo, who in a conflict of interest also acted as advisors to the Somali President, Hassan Sheikh Mohamud. In addition, this letter describes the use of the Podesta Group, Inc. for public and political relations in aid of the asset recovery enterprise. Finally, this letter makes reference to an arms transfer to Al-Shabaab involving Musa Haji Mohamed Ganjab and Abdiaziz Hassan Giyaajo Amalo, which is a case being further developed for the final report on Somalia of the Monitoring Group. As such, this letter raises concerns about any funds from overseas assets that may have been diverted to Al- Shabaab.

At this stage of the investigations of the Monitoring Group, the material presented below reflects exploitation of public authority for private interests and indicates at the minimum a conspiracy to divert the recovery of overseas assets in an irregular manner, involving Shulman Rogers, President Mohamud and his Office, Fawzia Yusuf H. Adam, then Deputy Prime Minister and Minister of Foreign Affairs and International Cooperation of the FGS, as well as Musa Haji Mohamed Ganjab and Abdiaziz Hassan Giyaajo Amalo. In addition, a complex architecture of multiple secret contracts, which defied a separation of powers between the Presidency and the Central Bank, created the opportunity and rationalization for the misappropriation of public resources. ‘Pie-cutting’ of overseas assets by those involved in the project entailed retention of excessive percentages and direct payments from recovered assets as well as attempts to circumvent deposits in the Central Bank of Somalia. While one transfer from Shulman Rogers to a Central Bank account in Turkey has to date been protected by the current Governor, the overall list of identified assets remains undisclosed and millions of dollars of funds are unaccounted for. Meanwhile, there are indefinite claims by Shulman Rogers and Haden Global Services on percentages of assets to be recovered in the future, which raise concerns given the association between Al-Shabaab, Musa Haji Mohamed Ganjab and Abdiaziz Hassan Giyaajo Amalo.

With the consent of President Mohamud and Prime Minister Abdiweli Sheikh Ahmed, the Monitoring Group has sought to provide the FGS with advance notice of the findings of this letter, including through the Financial Governance Committee, which is also duly copied below.

In response to a Reuters article ("Graft allegations test West’s ties to Somali president”, 14 February 2014), former Foreign Minister Adam issued a press release on 22 February 2014 referring to documentary evidence supporting her position. On 25 February 2014, the Monitoring Group requested a meeting with former Foreign Minister Adam as well as the documentary evidence referred to, both of which are pending pursuant to exchanges of correspondence.