The Nigerian Bar Association has said that Nigerian lawyers who have been disbarred or suspended in the United States for professional misconduct remain entitled to practise in Nigeria, because disciplinary sanctions do not travel across jurisdictions, although the association accepts that such findings carry a heavy reputational burden.
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The association’s spokesman, Mr. Prince Azubuike, described a report cataloguing the disciplinary sanctions imposed on Nigerian lawyers in the United States as “disturbing”, while setting out the association’s position on what those sanctions mean for a lawyer’s standing at the Nigerian Bar.
“They had dual practice licences: one in the United States, one in the Nigerian Bar,” the spokesman said. “So, having been found guilty in the U.S. Bar and appropriate sanctions meted out to them, that does not transfer to the Nigerian situation. So they are still duly called, except another disciplinary measure will be carried out in view of that. But it doesn’t work that way when it comes to disciplinary issues. It’s local to the jurisdiction where that issue happened.”
He said that although disbarment or suspension abroad on grounds of fraudulent activity affects a lawyer’s reputation without affecting the licence to practise in Nigeria, the consequence extends beyond the individual to the standing of the country and its citizens.
“Generally, it will affect their character, because it’s reputational. For you to have been found wanting in professional misconduct shows that there is a character deficit on your part. And it must disturb everybody, not just the legal profession, but every citizen,” he said.
The spokesman said the same principle operates in other regulated professions, citing the treatment of Nigerian medical practitioners sanctioned abroad.
“The same applies to the Medical and Dental Council of Nigeria. Most of them that were having issues in other jurisdictions like the UK, disciplinary issues, it didn’t affect their practice as it concerns their profession here in Nigeria,” he said.
He acknowledged that the consequence nonetheless follows a lawyer across borders in practical terms.
“Again, it’s reputational. So if you now go to another jurisdiction and they raise the issue, you have a character issue or reputational issue in your former jurisdiction, it goes a long way to impact on your practice, how clients see you, how your colleagues in that other jurisdiction see you,” he explained. “It affects it, no doubt, but it doesn’t rob you of your practice in this jurisdiction. So these two distinctions must be clearly established, you know, recognised.”
According to the spokesman, no law compels or requires a lawyer to report to the association any disciplinary action taken against him in a foreign jurisdiction.
He accepted that the arrangement carries a risk, admitting that “the possibility of such a lawyer defrauding his Nigerian clients is also probable.”
He added: “NBA will also need to do serious work with respect to ethical and professional issues in the legal profession.”
The association was responding to a report which stated that at least 17 Nigerian lawyers practising across different jurisdictions in the United States have faced serious disciplinary sanctions, including disbarment and suspension, following findings ranging from misappropriation of clients’ funds and dishonesty to practising law while suspended and other breaches of professional rules.
According to the report, the sanctions span several years and were imposed by state supreme courts, federal courts, the United States Department of Justice’s Executive Office for Immigration Review, the Board of Immigration Appeals and other professional disciplinary bodies, based on court and regulatory records.
The publication named the Chief of Staff to President Bola Ahmed Tinubu, Mr. Femi Gbajabiamila, together with Mr. Owolabi Salis, Mr. Aloysius Ejimakor and Mr. Neda Imasuen, among the Nigerian lawyers affected. The last three are members of the association.
The report recalled its earlier publication in 2023 that the Chief of Staff’s law licence had been terminated by the State Bar of Georgia over ethical lapses, and that he admitted taking 25,000 dollars belonging to a client. It also recalled its 2025 report concerning the Senator representing Edo South, Mr. Imasuen, stating that he was disbarred for life in New York after a finding that he defrauded a client.
Mr. Salis, who gained wide public attention as the first Nigerian to travel to space, on 29 June, was indicted in 2023 and disbarred by the New York State Supreme Court following complaints from clients who said they had lost tens of thousands of dollars through his conduct. The Board of Immigration Appeals dismissed his appeal against the disbarment, in proceedings concerning immigration clients.
The report set out the individual cases on which it relied, each arising from separate proceedings before the relevant state, federal or immigration disciplinary authority.
Alexander Osondu Akpodiete, formerly based in Florida, faced several disciplinary proceedings arising from misconduct between 2005 and 2008, including failing to keep a client adequately informed about a case and taking an unauthorised 1,000 dollars from a credit card used by a client to pay legal fees. Already under suspension, he was disbarred by the Florida Supreme Court in 2010.
Taiwo A. Agbaje, who practised in Maryland, was disbarred at both state and federal levels. The Executive Office for Immigration Review announced his disbarment in June 2016 following a final order of the Board of Immigration Appeals, which relied on his earlier disbarment in Maryland. The findings involved conflict of interest, dishonesty, fraud, deceit or misrepresentation, and conduct prejudicial to the administration of justice. The Maryland proceedings included a finding that he took 40,000 dollars from a client for a proposed real estate investment in Baltimore.
Cyril O. Chukwurah, based in Texas, lost his licence in 2015 after findings of multiple instances of professional misconduct, including practising law while on active suspension, breaching previous disciplinary judgments and failing to properly deliver funds belonging to clients. His disciplinary history was cited when he was barred from practising before the Board of Immigration Appeals, the immigration courts and the Department of Homeland Security.
Wilfred I. Aka, a Los Angeles based lawyer and certified public accountant, was disbarred in 2025 by the United States Tax Court and the Board of Immigration Appeals following earlier proceedings in 2019 and 2020, with findings of failures in duties owed to the court, to clients and to opposing counsel.
Chuck Odifu Egbune, in Colorado, was suspended for professional misconduct in 2023 and disbarred in 2025, the disciplinary record stating that he continued practising while suspended, including representing his sister in court without a valid licence.
Uchechi Okechukwu Nwakanma, also known as Prince Nwakanma, of Houston, was first suspended in 2015 over unpaid professional fees and failure to satisfy continuing legal education requirements, and in 2017 was disbarred from practice before the Board of Immigration Appeals, the immigration courts and the Department of Homeland Security. The Supreme Court of Kansas upheld the disciplinary consequence.
Chinyere Alex Ogoke, a Chicago based attorney licensed in 2005, was disbarred in 2021 after continuing to practise while under suspension. He had earlier been suspended from appearing before the immigration authorities on the basis of an Illinois suspension, and was found to have filed notices of appearance for 11 immigration clients while falsely representing that he was not subject to any order restricting his right to practise. The board described the conduct as serious violations capable of undermining the integrity of the legal system.
Ignatius Chukwuemeka Udeani, based in Minnesota, was indefinitely suspended in 2020 before the Minnesota Supreme Court disbarred him in January 2023, with the Board of Immigration Appeals subsequently relying on that decision. The findings included failure to protect the interests of clients, including vulnerable immigrants, failure to safeguard or return client funds and unearned fees, and failure to cooperate with disciplinary investigations.
John Udo, admitted to the Massachusetts Bar in 1995, was disbarred in Massachusetts and excluded from practice before United States immigration tribunals in 2010, following a ten-count petition involving client funds, neglect of immigration matters and abandonment of professional responsibilities. Later that year the Massachusetts Clients’ Security Board reimbursed 14 former clients after findings that funds had been taken, settlement monies not returned, or fees accepted without the agreed services being provided.
Emeka M. Uyamadu, of Houston, was permanently disbarred in 2010 after felony convictions in Harris County, Texas, involving witness tampering and theft of between 20,000 and 100,000 dollars. He was sentenced to 10 years in the custody of the Texas Department of Criminal Justice, the custodial sentence being suspended in favour of 10 years’ community supervision, a fine of 5,000 dollars and 60 days in the Harris County Jail.
Andrew Ndubisi Ucheomumu, based in Maryland with offices in Bethesda and Chevy Chase, was disbarred in 2018 by the Maryland Court of Appeals, now the Supreme Court of Maryland, his record including failures to provide adequate representation, failure to refund at least 6,200 dollars in unearned fees, and false or misleading statements during proceedings.
Chukwu Uwakwe Oko, also of the Houston area, was disbarred in 2013 after the 133rd Judicial District Court of Harris County found that he violated rules prohibiting dishonesty, fraud, deceit or misrepresentation and practising law while a licence was invalid. The Executive Office for Immigration Review subsequently issued a final order preventing him from appearing before the immigration courts and the Board of Immigration Appeals.
Lloyd F. Ukwu, of the District of Columbia, was disbarred in 2009 by the District of Columbia Court of Appeals following findings that he intentionally misappropriated client funds, forged a client’s signature and made false representations in connection with a settlement, having settled a case without the client’s authority, forged the signature on a settlement cheque and used part of the proceeds for his own purposes.
Anita C. Kanu, also known as Anita C. Justin, of Los Angeles, was disbarred in 2010 by the District of Columbia Court of Appeals, with findings of false or misleading statements, failure to return unearned fees and dishonest or fraudulent conduct, arising from promises to refund fees to two immigration clients if she failed to obtain their requested immigration status. Her exclusion from practice before the immigration courts and the Department of Homeland Security was upheld.
Benjamin Ndi, a New York licensed lawyer operating in Maryland, was disbarred in 2018 following findings of unauthorised practice, misrepresentation of his professional qualifications and violations concerning attorney trust accounts. The Supreme Court of Maryland held that he provided immigration and other legal services in Maryland without holding a Maryland licence, and he was found to have failed to cooperate with Bar Counsel’s investigation, to respond to discovery requests or to appear at scheduled proceedings. His exclusion from practice before the immigration courts and the Department of Homeland Security was also upheld.
Alake Johnson-Ford, a District of Columbia attorney, was disbarred in 2000 over misconduct including misappropriation of client funds, dishonest and criminal conduct, failure to deliver funds to clients and failure to provide competent representation. In 2021 the Board of Immigration Appeals imposed a five-year suspension from practice before immigration tribunals, noting that the earlier District of Columbia order remained in effect.
The report noted that the cases span more than two decades, arose from separate proceedings in different jurisdictions, and do not constitute a single prosecution or coordinated disciplinary exercise.
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