On 8 June 2025, Mr. Ousman F. M’Bai wrote an open letter to Woodside Energy as a concerned Gambian and in the name of stakeholders in the MSGBC basin, raising serious questions about the integrity of FAR Ltd.’s drilling operations in The Gambia and the possible implications for resource governance, transboundary equity, and regional trust. The letter set out clear, factual grounds for concern, accompanied by four direct questions inviting clarification.
On 13 June 2025, Woodside Energy responded. Regrettably, that response fails to engage with the substance of the letter. Instead, it simply reiterates the company’s long-held position that it “did not acquire FAR’s Gambian acreage” without addressing any of the issues raised.
This is not a neutral omission. It is a refusal to address three deeply troubling realities:
1. The Proximity Risk Was Real. FAR Ltd.’s Gambian operations (Blocks A2 and A5) directly abutted Senegal’s Sangomar field, in which Woodside acquired FAR’s stake for over half a billion dollars in value. The geophysical proximity and publicly declared “reservoir equivalence” between Bambo-1 and Sangomar demand serious risk assessment, which Woodside has conspicuously refused to confirm was ever undertaken.
2. The Governance Vacuum Was Known. FAR Ltd exited The Gambia without fulfilling its licence obligations, receiving waivers and concessions that defy standard regulatory practice. Woodside, operating in the same basin, cannot credibly claim to be unaware of this, nor immune to its implications for the legitimacy of the asset it acquired.
3. Due Diligence Is an ESG Obligation. As a self-declared ESG-compliant corporation, Woodside has a heightened duty to ensure that its acquisitions do not inadvertently perpetuate the exploitation of under-resourced jurisdictions. Repeating a corporate line without disclosing whether any due diligence was done falls short of that standard.
By publishing both the original letter and Woodside’s response side by side, we invite readers—Gambians, Senegalese, investors, and international observers alike—to ask: Is this the transparency and responsibility we expect from energy majors operating in our region?
This conduct is akin to a suspect giving ‘no comment answers’ while being interviewed by Police under caution.
Woodside Energy may have dismissed its obligations to provide clarity. But we will not dismiss our duty to demand answers.
OPEN LETTER TO WOODSIDE ENERGY
OFFICE OF OUSMAN F. M’BAI
C/O FANA FANA CHAMBERS, Banjul, The Gambia
Date: 8th June 2025
Our Ref: OFM/08/06/25/Woodside Energy.
Open Letter to the Board and ESG Officers of Woodside Energy Ltd.
Re: Ethical Accountability in the MSGBC Basin and FAR Ltd.’s Gambian Operations.
To: The Board of Directors
Woodside Energy Ltd
Mia Yellagonga
11 Mount Street
Perth WA 6000
Australia
Attention: Ms Lianne O’Leary, Head of Legal – Mergers & Acquisitions
Dear Board Members,
I write as a concerned citizen of The Gambia and a legal practitioner committed to anti-corruption and the transparent governance of natural resources in West Africa. My concern relates to the transparency and accountability failures surrounding FAR Ltd.’s operations in The Gambia’s offshore Blocks A2 and A5 between 2017 and its formal withdrawal in 2023.
On 28 August 2024, The Fatu Network wrote directly to Woodside Energy querying whether the company had conducted any due diligence into the risk that FAR Ltd had compromised the integrity or commercial viability of The Gambia’s offshore oil wells. The reply received from Mr Dan Pagoda on 2 September 2024 stated that Woodside “did not purchase FAR’s assets in The Gambia” and referred to your ASX announcement of 3 December 2020 concerning the Sangomar transaction. However, the response did not clarify whether any risk-based due diligence was undertaken regarding FAR Ltd’s closely adjacent Gambian operations, despite their potential geotechnical relevance to the Sangomar acquisition.
It is now established that FAR Gambia Ltd a wholly owned subsidiary of FAR Ltd was permitted by the Gambia Petroleum Commission to relinquish its licences in Blocks A2 and A5 without penalty following two successive Deeds of Amendment in 2022 and 2023. These instruments waived all residual work obligations and relieved FAR Gambia Ltd. of any financial liabilities. This occurred at a time when FAR Ltd. was in default of its capital-call obligations to Woodside, risking forfeiture of its 13% stake in Sangomar. That same stake was sold to Woodside Energy for a reported US $121 million, with a further contingent payment of US $55 million, and a cumulative transaction value exceeding US $500 million when debt assumption is included.
Public filings by FAR Ltd. on the Australia Securities Exchange in August 2022 stated that hydrocarbons encountered in its Bambo-1 well at the S440 and S408 levels “extend into The Gambia” and are “lateral equivalents” of the productive Sangomar reservoirs. However, FAR Ltd. then characterised the same zones as having “no direct commercial significance,” citing alleged poor reservoir quality and unsuccessful oil sampling conclusions that remain unverifiable due to the absence of publicly released pressure data, MDT logs, or seismic interpretations. This opacity is compounded by the Gambia Petroleum Commission’s refusal to disclose any of these materials in response to formal information requests filed under the Access to Information Act 2021.
Further exacerbating concerns is the fact that in late 2023 shortly before FAR’s surrender of the blocks the Government of The Gambia enacted the Petroleum (Exploration, Development and Production) Block Demarcation Regulation, 2023. This instrument quietly redefined the offshore boundary coordinates of A2 and A5. Early analysis suggests that the demarcation appears to reduce the acreage of Block A2 precisely in the deepwater region where it meets the Sangomar field. No technical justification for this change has been made public. This raises legitimate questions about whether The Gambia has tacitly surrendered marine territory or allowed transboundary field connectivity to shift to Senegal’s benefit without any formal resource-sharing arrangement, unlike Senegal’s agreements with Mauritania and Guinea-Bissau.
As an ESG-rated multinational operating in a basin with high geological connectivity, limited regulatory transparency, and significant geopolitical sensitivity, Woodside Energy has a duty of care that extends beyond its narrow contractual transactions. The fact that Sangomar’s 23 wells many separated by vast distances are considered geologically connected undermines the suggestion that FAR Ltd.’s exploration data in neighbouring A2/A5 was irrelevant to your acquisition risk modelling.
In light of the above, I respectfully request that Woodside Energy Ltd:
- Disclose whether any due diligence was undertaken in relation to FAR Ltd.’s activities in The Gambia during your acquisition of its Sangomar interest;
- Confirm whether FAR Ltd. provided any well data, seismic analysis, or internal assessments from its Gambian blocks, and if not, why such data were not sought;
- Clarify what representations, if any, were made by FAR Ltd. concerning its Gambian operations and relinquishment terms in the context of the transaction;
- State whether Woodside has discussed or analysed the implications of the 2023 Gambia Block Demarcation Regulation and its possible effect on the maritime boundaries with Senegal and field connectivity;
- Outline whether Woodside has engaged with the Governments of The Gambia or Senegal on any unitisation prospects or shared-resource frameworks consistent with the United Nations Law of the Sea Convention.
Should Woodside continue to maintain that it bears no responsibility for the governance risks emerging from FAR Ltd.’s conduct in the MSGBC basin, your shareholders, the international ESG community, and the wider West African public are entitled to a full and reasoned explanation.
In the interest of transparency and responsible resource stewardship, this letter will be made public two days from today unless otherwise advised.
Yours sincerely,
Ousman F. M’Bai
WOODSIDE ENERGY’S RESPONSE
Woodside Energy Ltd.
Perth WA, Australia
www.woodside.com
13 June 2025
Attn: Ousman F. M’Bai
C/O Fana Fana Chambers
Banjul, The Gambia
Dear Mr M’Bai
RE: WOODSIDE’S ACQUISITION OF FAR SENEGAL’S INTEREST IN THE RUFISQUE, SANGOMAR AND SANGOMAR DEEP JOINT VENTURE
I confirm that we have received your letter dated 8 June 2025.
As Company Secretary of Woodside Energy Ltd, I would be grateful if you would kindly allow me to respond on behalf of the Board of Directors.
In December 2020, Woodside exercised pre-emption rights to acquire FAR Senegal RSSD SA’s participating interest in the Rufisque, Sangomar and Sangomar Deep (RSSD) joint venture. The transaction completed in 2021 and is not in any way related to any of FAR’s assets in The Gambia. Further details can be found in our announcement released to the Australian Securities Exchange on 3 December 2020.
Yours sincerely
Damien Gare
Vice President & Group Company Secretary
