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In September 2022 the EFCC obtained an interim freezing order from the Federal High Court Lagos on ₦19.3bn held in Sterling Bank accounts traced to the Kogi State 2016 salary-bailout disbursement. The Supreme Court, in Kogi State v. EFCC (SC/CV/655/2022, judgment 24 February 2023), set aside the order on grounds of gubernatorial immunity under s.308 of the 1999 Constitution while the then-Governor Yahaya Bello remained in office. Bello left office on 27 January 2024; the EFCC re-arraigned him on 23 April 2024 (FRN v. Yahaya Bello, FHC/ABJ/CR/550/2022) on 19 counts of money laundering, with proceedings ongoing.