Savannah Seeks CFAF 228.6bn in Cotco Arbitration Involving SNH and Chad

September 28, 2026

By: Baudouin Enama

 

Savannah Midstream Investment Limited (SMIL) is seeking more than $397 million, or about CFAF 228.6 billion including principal and interest, in arbitration before the International Chamber of Commerce (ICC) over its rights in Cameroon Oil Transportation Company (Cotco). Société Nationale des Hydrocarbures (SNH) is one of five respondents, alongside the Republic of Chad, SHT Overseas Petroleum (Cameroon) Limited, SHT Doba Pipeline Investment Inc. and Cotco.

The claim includes about $330 million in principal, or nearly CFAF 190 billion, plus more than $67 million in interest, or at least CFAF 38.6 billion, as well as costs. Savannah describes the claim as approximately $330 million, plus more than $67 million in estimated interest and costs. The currency conversions are indicative and based on an exchange rate of about CFAF 576 to the dollar.

The amounts, first disclosed in February 2026, remained unchanged in Savannah's August 25, 2026 regulatory filing. The proceedings are registered as ICC Case No. 27914/SP and are governed by the ICC's 2021 Arbitration Rules. The seat of arbitration is Paris, while publicly available case records identify Cameroonian law as the applicable law.

SNH's presence among the respondents does not mean it would be liable for the entire $397 million claim. The public documents reviewed by Investir au Cameroun do not indicate how much, if any, could ultimately be attributed to each of the five respondents.

Counterclaims of $58.7 Million

The dispute also includes financial claims against SMIL. Savannah says the Republic of Chad, SHT Overseas Petroleum (Cameroon) Limited, Cotco and certain other Cotco shareholders have filed counterclaims totaling about $58.7 million, excluding interest and costs.

SMIL disputes the counterclaims and describes them as "baseless and without merit." That is Savannah's original wording in its English-language regulatory disclosures. The public documents reviewed do not show that a final ruling has been issued on those claims.

The counterclaims were formally raised in the respondents' September 29, 2023 Response to the Request for Arbitration and Counterclaims. Procedural Order No. 3, dated May 8, 2024, states that they asked the tribunal to dismiss SMIL's claims, find that the disputed share transfer was unlawful, identify breaches of Cotco's articles of association and award compensation for the alleged harm.

The tribunal hearing the case is chaired by Gabrielle Kaufmann-Kohler, with Nicolas Molfessis and Laurent Aynès serving as co-arbitrators. At the April 8, 2024 hearing, SNH was represented by Gill Dingomé of Dingomé, Ngando & Associés.

A Dispute Over Savannah's Rights in Cotco

Savannah argues that several decisions taken in 2023 infringed its shareholder, governance and operating rights in Cotco. The company also says the disputed actions breached Cotco's articles of association, the services agreement between Cotco and SMIL and Cameroonian law.

The arbitration is tied to the broader shareholder dispute surrounding the proposed sale of a 10% stake in Cotco to SNH. On April 20, 2023, Savannah announced that SMIL had signed a Share Purchase Agreement with the Cameroonian state-owned company covering the stake for $44.9 million.

SNH paid the amount, but the shares have still not been legally transferred. Savannah's regulatory filings state that formal completion can occur only after certain conditions are met, including amendments to Cotco's bylaws.

Until the sale is legally completed, Savannah continues to own a 41.06% stake in Cotco. The company says completion of the transfer would reduce that holding to 31.06%.

The public documents do not support attributing the full $330 million claimed by Savannah solely to the stalled share transfer. SMIL's claims relate more broadly to alleged breaches of its shareholder, governance and operating rights in Cotco.

SNH Has Already Paid CFAF 26.9 Billion for the 10% Stake

In its accounts, SNH reports a CFAF 26.912 billion receivable from Savannah Midstream Investment Limited representing the $44.9 million paid for the acquisition of the 10% stake in Cotco.

The Cameroonian state-owned company's 2025 financial statements show that SNH has booked a CFAF 10.765 billion provision against the receivable, equivalent to 40% of the amount. Investir au Cameroun reported the information on July 24, 2026, in an article on the unfinished acquisition of the 10% Cotco stake.

The provision does not mean SNH has definitively lost CFAF 10.765 billion. It reflects the risk that part of the receivable may not be recovered while the share transfer remains incomplete.

In its 2023 annual report, SNH's statutory auditor had already said that, in a subsequent reporting period, it would need to verify either that the company had legally acquired the 10% stake or that it could recover the money paid.

Interim Measures Issued in July 2023

Before the tribunal hearing the case was constituted, SMIL applied to an emergency arbitrator. In an order dated July 28, 2023, Marc Henry suspended some of the effects of resolutions adopted at Cotco's May 24, 2023 general meetings and by its board of directors on July 4, 2023. The emergency order is publicly available under ICC Case No. 27914/SP.

He declined, however, to immediately declare that the legally recognized board was the board registered with the registry of the Douala-Bonanjo Court of First Instance on June 6, 2023. He also rejected SMIL's request to prevent Cotco from carrying out most transactions through its bank accounts.

The ICC administrative costs and the emergency arbitrator's fees were split equally between SMIL and respondents 1 to 3 and 5. Those respondents were also ordered to reimburse SMIL $20,000, or about CFAF 11.5 million. SNH, respondent No. 4, was not included in that group.

903 Km of Pipeline on Cameroonian Territory

Cotco owns and operates the 903-km Cameroonian section of the Chad-Cameroon oil pipeline, the Kome Kribi 1 floating storage and offloading facility and related infrastructure.

The pipeline has a nominal capacity of 250,000 barrels per day. In its April 20, 2023 announcement, Savannah said Cotco transported an average of 124,000 barrels per day in 2022, with an estimated value of $4.6 billion based on prevailing Brent crude prices.

The arbitration will determine the competing financial claims brought by SMIL and the respondents. For SNH, the case is unfolding alongside the still-unfinished transfer of the 10% Cotco stake for which it has already paid $44.9 million.

SOURCE: Baudouin Enama