United States: A Special Report On The Nigerian Banking System: The Ripple Effects Of Lehman - A Tale Of Sin And Redemption?

Last Updated: December 8 2014
Article by Stephen Phillips and Alexander Janes

​This article focuses on the banking sector crisis which engulfed the Nigerian financial sector from 2008 to 2011, and the steps taken by the Central Bank of Nigeria (CBN) in restoring financial stability. We discuss the impact and the opportunities for international and domestic investors resulting from the crisis.

Introduction

In 2005, the CBN mandated all Nigerian banks to increase their capital base1 from ₦2 billion (c.US$12.5 million) to ₦25 billion (c. US$156.3 million) in order to improve their competitiveness on the international market and to increase profitability. Significant capital was raised and as a result, the banks were under pressure to realise greater profits and in turn, generate higher returns to shareholders. Nigerian banks became involved in securities trading, margin lending as well as huge oil and gas financings due to the increase in oil and gas prices at the time, thus fuelling a market bubble. When it hit in 2008, the global recession had a significant ripple effect on the Nigerian banking system. The result was that investors and traders in Nigeria had to liquidate their positions in profitable markets to fund their losses elsewhere. This led to huge exit of foreign investors from the Nigerian capital market and the attendant fall in share prices.

Outset of the Nigerian Banking Sector Crisis

Nigerian banks which had funded acquisitions of shares on the Nigerian stock exchange, found themselves with shares which were worthless and borrowers who were unable to service their loans. Liquidity problems arose for banks due to panic in the financial system and banks had to borrow from the CBN's expanded discount window, through which banks access short term borrowing from the CBN, as a lender of last resort. The CBN having observed the increased activity of a number of banks in the expanded discount window initiated an examination of all banks to ascertain their state of health. This examination revealed a disquieting state of affairs which if not addressed immediately, would have resulted in the systemic collapse of the Nigerian banking sector. The CBN took a number of steps aimed at ensuring the stability of the Nigerian financial system and also restoring public confidence in the banking sector. These steps included, (i) changing the management of the banks; (ii) injecting funds into ailing banks; (iii) providing a guarantee to cover exposure to correspondence and other international banks; (iv) establishing an asset management company to take the non-performing loan (NPLs) out of the Nigerian banking system; (v) recapitalising affected banks; (vi) adopting  a bridge bank model to avoid the liquidation of the ailing banks; (vii) reversing the universal banking model and imposing tighter regulations.

Special Examination of Nigerian Banks

In 2009, the CBN ordered that special examinations be carried out on all banks operating in Nigeria. This special examination carried out by officials of both the CBN and the NDIC2, was in exercise of the CBN's powers under the Banking and Other Financial Institutions Act, 2004 (BOFIA)3, to ascertain the wellbeing of the banks, with particular focus on liquidity, capital adequacy, risk management and corporate governance. The examination revealed that ten of the banks had huge non-performing loan portfolios and nine of the banks were in a grave situation due to deficiencies in capital adequacy. These banks were also found to have significant deficiencies in liquidity, risk management practices and corporate governance4.

The special examination revealed significant erosion of capital and extensive corporate governance malpractices driven by the huge surge of capital availability in banks at a time when corporate governance standards were weak. As banks grew in size and complexity, the growth in assets and the profits of the institutions lulled the management and board of the banks into a false sense of well-being and due to the lack of corporate governance, rules were broken and policies were not complied with. The market thus witnessed insider trading, share manipulation, improper granting of unsecured loans to friends, family and directors and creation of risky assets without any thoughts for the depositors. Disclosures in respect of accounts were falsified; certain banks reported false growth and also inflated their profits and capital. Some banks manipulated their books by colluding with other banks to artificially enhance financial positions and therefore stock prices. Practices such as converting NPLs into commercial paper and bank acceptances and setting up off-balance sheet special purpose vehicles to hide losses were prevalent5.

The examination reports were finalised and revealed that banks had sizable off-balance sheet instruments that concealed NPLs, while in other cases, NPLs were rolled over or otherwise classified as performing loans. Significant governance problems were also identified6. There were many cases of connected lending and undercapitalisation. As a result of the findings, the CBN had to take a number of steps to strengthen the banking industry and to protect depositors' funds. In addition, the CBN had to provide comfort to creditors including depositors and the international community in order to safeguard the integrity of the Nigerian banking system and to prevent a run on the banks. A number of the steps taken are discussed below.

The Reform

Statutory Intervention

Due to the extent of corporate governance weaknesses in the banks which appear to have played a big role in the erosion of the banks' capital, the CBN Governor in exercise of his statutory powers promptly removed the chief executive officers and the executive directors of eight Nigerian banks and appointed new managing and executive directors to serve on the boards of the banks in the interim period. In addition, all ten affected banks were mandated to shore up their capital within a stipulated time frame. The said eight affected banks7 (the Eight) however had to go through a managed/assisted process.

Maintaining Financial Stability through Bailout

The CBN in a bid to ensure that the banks were able to meet their day-to-day liquidity requirements, prevent a bank run and avoid a collapse of the banking sector (since most of the banks involved had large retail networks), injected fresh capital into totalling ₦620 billion (c. US$3.9 billion) as a stopgap. This capital was provided to the affected banks as Tier 2 capital8 in the form of unsecured subordinated convertible loans. In addition, the CBN provided a guarantee of all interbank lending transactions (expired end-December 2011), foreign credit lines, and pension deposits9.

Establishment of the Asset Management Corporation of Nigeria (AMCON)

Due to the enormous volume of NPLs found on the books of all Nigerian banks and especially on the books of the Eight, the CBN conceived the idea of creating an asset management company which would assist in cleaning the balance sheets of these banks and thus assist in restoring stability to the Nigerian financial system. In view of the nature of the role that the asset management corporation was intended to play and following the experience in Ireland and Thailand, it was considered important that such a body should have statutory backing. As a result, a bill for an Act to set up AMCON was sponsored by the CBN. Having passed through the various stages on the floor of the Nigerian National Assembly, the President of the Federal Republic of Nigeria gave his assent to the bill on 19 July, 2010, formally passing it into law10.

NPL Purchases and Bond Issuance

Upon its establishment, AMCON purchased the first set of non-performing loans in December 2010 in exchange for three-year zero-coupon bonds issued by AMCON and guaranteed by the Federal Government of Nigeria. The purchase of NPLs went on into 2012, by which time all the NPLs on the balance sheet of grave situation banks had been cleaned out and the NPLs on the books of all other banks were reduced to 5%. With AMCON's intervention, the banking industry ratio of non-performing loans to total credit was reduced from 34.4 per cent in November 2010 to 4.95 per cent by December 201111.

Recapitalisation – Managed Acquisitions

As part of the resolution of the banking crisis, the Eight were given timelines within which to raise their capital to the regulatory minimum. This process was supervised by the CBN to avoid a repeat of the previous era, where in some cases, capital was fictitiously purported to have been raised. This process involved a number of bidders both international and local, including banks, private equity funds and investor groups. As a result, 5 of the Eight, Intercontinental Bank Plc, Oceanic Bank Plc, Union Bank Plc, Equitorial Trust Bank Plc, and Finbank Plc, were able to find committed investors. However, due to the huge capital deficit within the banks, AMCON had to inject capital into the Eight in order to restore to zero their net asset value, while the capital raised them above the regulatory requirement. In consideration for the capital injection, AMCON was issued equity in these banks12.

The Bridge Banks

Despite the prescribed ultimatum of September 30, 2011 for the recapitalisation of the Eight, three of the Eight (the Three) were unable to secure investors. As a result of this development, in the interest of depositors and in a bid to avoid the costly process of liquidating the banks, which would have been the option available to the NDIC, in view of the negative net asset value of the banks, the NDIC invoked its statutory powers and for the first time since it was established, adopted the Bridge Bank resolution process.

A bridge bank is a temporary national bank organised by the deposit insurance corporation, to takeover and maintain, banking services for the customers of a failed bank. It is designed to "bridge" the gap between the failure of a bank and the time when the deposit insurance corporation can implement a satisfactory acquisition by a third party. Bridge banks are designed to aid in the resolution of complicated, large failing banks and provide the time the deposit insurance corporation needs to take control of a failing bank's business, stabilise the situation, effectively market the bank's franchise, and determine an appropriate resolution. This option which has been adopted a number of times by the FDIC13 in the US is known to assist in resolving complex and large bank failings14. A similar mechanic is available under the European Bank Recovery and Resolution Directive15.

In adopting this measure, the NDIC after due consultation with the CBN as required by law, incorporated three entities which were duly licenced to carry on banking business by the CBN. These bridge banks which had NDIC nominees as shareholders thereafter acquired certain assets and assumed certain liabilities of the Three, pursuant to a purchase and assumption agreement. Under the terms of this agreement, the three bridge banks, namely, Mainstreet Bank Limited, Keystone Bank Limited and Enterprise Bank Limited each acquired all the deposit liabilities and certain other liabilities and the assets of Afribank Nigeria Plc, Bank PHB Plc and Spring Bank Plc respectively. By the provisions of the NDIC Act, Bridge banks are to exist for a maximum period of two years unless otherwise extended by the NDIC. However, the bridge bank status of these banks did not last for two years as AMCON stepped in again to acquire substantial equity holdings in the banks and thereby brought their capital to the required minimum levels.

This step ensured that there was no disruption in banking business, avoided the potential run on the banks and restored public confidence. The bridge banks acquired the assets and liabilities on a Friday and opened their doors to customers of the erstwhile banks on Monday under the bridge banks' names and licences. As a result, the employees of the Three who wanted to continue with the bridge banks were employed whilst those who wanted to leave were allowed to. This process thus not only saved depositors' funds, it also ensured that a lot of jobs were saved.

Prosecutions

Whilst the resolution process was going on, the CBN and the office of the Attorney General of the Federation of Nigeria initiated both criminal actions against the board members of the Eight, who had been implicated in the course of investigations by the Economic and Financial Crimes commission (EFCC). The EFCC had been called in to carry out further investigations following the outcome of forensic audits carried out on the institutions further to the special examinations. As a result, the managing director of one of the banks was convicted further to a plea bargain and was sentenced to prison for her role in the failure of the bank.

AMCON's Mandate

As mentioned earlier, AMCON was established as a stabilisation tool to revive the Nigerian financial system through the efficient resolution of the non-performing loan assets of Nigerian banks. This mandate has been followed through by AMCON through the purchase of Eligible Bank Assets16 at a fair value in accordance with the valuation methodology prescribed in the AMCON Guidelines17. The assets acquired by AMCON are thereafter put to economic use to ensure the realisation of the best achievable financial returns on the assets having regards, to the need to protect or otherwise enhance the long-term economic value of the assets, the cost of acquiring the assets, AMCON's cost of capital and other costs as well as guidelines and directives issued by the CBN18.

In furtherance of this mandate, AMCON acquired about 12,537 NPLs across various sectors, including oil and gas, general commerce, capital markets, manufacturing, finance and insurance19. As consideration for the NPLs purchased by AMCON and capital acquired in the Eight, it has issued bonds to Nigerian banks, worth about ₦5.6 trillion (c. US$35 billion). Some of these bonds have become due and have been repaid, however a large portion of the instruments were refinanced by the CBN in December, 2013. As part of the purchase of NPLs, AMCON has also acquired a significant number of underlying assets which were collaterals for the loans. These assets include, shares in various companies, real estate, bonds and other debt instruments, and other assets. Though most of the NPLs are secured in one form or the other, about 27% of the NPLs are unsecured, leaving AMCON to pursue recovery or restructuring.

In realising its objectives, AMCON has adopted different approaches including restructuring of the loan assets, loan workouts, instituting actions for debt recovery, conversion of debt to equity in order to secure control of the debtor company ahead of a planned divestment, forbearances, etc.

Banking sector sinking fund

One rationale behind establishing AMCON was to achieve a resolution of the banking crisis with minimal impact on depositors, other creditors of the banks, and taxpayers. As a result, the capital of AMCON was a contribution from the CBN and the Ministry of Finance. In addition, it is expected that AMCON would be able to generate enough funds from the loan recoveries as well as realisation of underlying assets to enable it pay off its obligations to bondholders. However, in recognition of the fact that it would require some time to do this, most of the bonds were issued as zero-coupon bonds with a bullet payment at maturity, thus giving AMCON time to work the assets ahead of the maturity of its obligations. In addition, in realisation of the challenge with distressed assets and the average rate of recovery, the CBN together with all Nigerian banks agreed to establish a sinking fund, tagged the Banking Sector Resolution Cost Fund. This sinking fund is to act as a credit enhancement and a form of security in the event that AMCON is unable to generate enough returns from the loan assets to meet its obligations. As a further security and assurance to the bondholders, the bonds are statutorily required to be backed by the full faith and credit of the Federal Government of Nigeria.

The Opportunities

In furtherance of its mandate, AMCON has acquired assets spanning different sectors of the Nigerian economy, including oil and gas, general commerce, capital markets, manufacturing, finance and insurance. Having being in operation for about four years, it has commenced the divestment of its interests in some of these assets with a view to achieving the best realisable financial returns on the assets. These interests include equity interests in companies, including banks, manufacturing companies, etc. In addition, it has plans to divest its interests in physical assets which are part of its asset portfolio.

These assets have generated a lot of interest from both the local and the foreign markets as seen by the number of bids submitted for the purchase of the erstwhile bridge banks, two of which were put on the market further to the request for expressions of interest by AMCON. This process has resulted in Heritage Bank acquiring AMCON's interest in Enterprise Bank Ltd and Skye Bank being named as the preferred bidder for the sale of AMCON's interest in Mainstreet Bank Ltd.  

In addition to the above assets, AMCON recently concluded transactions with Qatar National Bank resulting in the acquisition of AMCON's 12.5% interest in Ecobank Transnational Incorporated and Atlas Mara resulting in its acquisition of 20.9% of Union Bank Plc (formerly Barclays). If these transactions are anything to go by, it is without doubt that the next few years would see a lot of divestments by AMCON from its holdings in various companies and possibly a transfer of the loan assets it has acquired.

Another resolution in the offing

Recent reports20 have alluded to the fact that the Nigerian banking sector may be in need of a rescue soon following the huge exposure of the banks to the Nigerian power sector, further to the privatisation of Nigeria's power sector amounting to about US$1.6bn and the current challenges being faced by the investors in the power assets in servicing their loans. Although AMCON is of the view that its job of acquiring NPLs of Nigerian banks is complete, there may be a requirement for the banks to find a way to clean the NPLs off their balance sheets by selling to AMCON or to other entities.

Conclusion

Resolving the Nigerian banking sector crisis has not been without its hitches and challenges. The CBN, in a bid to avoid a repeat of the banking crisis, instituted tighter regulations and supervisory practices and encouraged healthier cooperation between the various regulators. In addition, the universal banking model was revoked and banks can only carry out the business of banking as envisaged under the BOFIA. This led to a few banks transforming into bank holding companies and others divesting their interests in their non-banking subsidiaries.

A number of court actions were instituted to challenge the bridge bank process as well as the banking reform. AMCON has also faced significant challenges in the performance of its obligations as there has been significant resistance from debtors in relation to AMCON's ability to realise the debts or transfer the underlying assets. A number of hurdles have been overcome by AMCON. In a bid to assist in paving a smoother path for AMCON to carry out its remaining tasks, a draft amendment bill is currently pending before the National Assembly to address some of the challenges being experienced and to make clearer the ambit of AMCON's powers. 

Footnotes

1. Paid up capital and reserves unimpaired by losses

2. Nigeria Deposit Insurance Corporation

3. Section 33, Cap B3 Laws of the Federation of Nigeria, 2004

4. Sanusi Lamido Sanusi, Consolidating the Gains of the Banking Sector Reforms, Lecture delivered at the Sylvester Monye Foundation lecture series on 9 July, 2010. See also CBN Public Statement on the Recapitalisation of Eight Nigerian Banks date 9 June, 2011 available at http://www.cenbank.org/out/2011/pressrelease/gvd/press%20statement%20-%20gov.pdf  

5. See Sanusi L. Sanisu "The Nigerian Banking Industry: what went wrong and the way forward", a paper delivered at the Bayero University, Kano on 26 February, 2010

6. IMF Financial Sector Assessment Program Nigeria – Crisis Management and Crisis Preparedness Frameworks Technical Note May 2013 available on http://www.imf.org/external/pubs/ft/scr/2013/cr13143.pdf 

7. Oceanic Bank International Nigeria Plc, Intercontinental Bank Plc: Equitorial Trust Bank Ltd, Union Bank of Nigeria Plc, Spring Bank Plc, Finbank Plc, Afribank Nigeria Plc, and Bank PHB Plc 

8. Press release issued by the NDIC on 5 August, 2011

9. IMF Country Report No.13/143, May 2013

10. Asset Management Corporation of Nigeria Act, No.29, 2010, hereinafter referred to as AMCON Act

11. Sanusi Lamido Sanusi, Banking Reform and its Impact on the Nigerian Economy, a paper delivered at the University of Warwick's Economic Summit, 17 February 2012, available at http://www.cenbank.org/OUT/SPEECHES/2012/GOV_WARWICK_150211.PDF

12. It should be noted that due to the transaction structures adopted by some of the banks, AMCON's equity was in the acquiring entity and not the target bank.

13. Federal Deposit Insurance Corporation

14. https://www.fdic.gov/bank/historical/managing/history1-06.pdf

15. 2014/59/EU 

16. S.61 of the AMCON Act defined by Eligible Bank Assets as those assets of a bank specified by the governor as being eligible for acquisition by AMCON in accordance with the provision of the Act

17. Issued by the Governor of the CBN further to powers conferred under the AMCON Act

18. Section 4, AMCON Act

19. See www.amcon.com.ng

20. http://allafrica.com/stories/201409220314.html

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Authors
Stephen Phillips
 
In association with
Related Video
Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
Mondaq on Twitter
 
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
 
Email Address
Company Name
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of www.mondaq.com

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.

Disclaimer

Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.

Registration

Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.

Cookies

A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Links

This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.

Mail-A-Friend

If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.

Emails

From time to time Mondaq may send you emails promoting Mondaq services including new services. You may opt out of receiving such emails by clicking below.

*** If you do not wish to receive any future announcements of services offered by Mondaq you may opt out by clicking here .

Security

This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.