Sunday, July 20, 2025

The Reservoir Knows No Border: But Senegal’s Silence Draws One

Why The Gambia's rightful claim over transboundary oil must not be ignored.

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Editorial Commentary

Seringe S.T. Touray
Editor-in-Chief
The Fatu Network

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On 24 June 2025, formal letters were dispatched to the Ministry of Petroleum and Energies and the Ministry of Foreign Affairs of Senegal, raising urgent concerns regarding the potential extension of the Sangomar oil reservoir into The Gambia’s A2 block. The letters called for transparency, the commencement of unitisation talks under international law, and clarification of Senegal’s role in recent changes to The Gambia’s offshore boundary demarcation.

As of today, over three weeks later no acknowledgement or response has been received from either ministry. This silence is more than a diplomatic discourtesy. It reflects a worrying disregard for the principles of good faith, regional cooperation, and shared stewardship of transboundary natural resources under the United Nations Convention on the Law of the Sea (UNCLOS).

The letter was written not in protest, but in spirit of dialogue, invoking our shared culture, history and values as sister nations in the MSGBC Basin. It raised valid legal and scientific concerns supported by public filings from FAR Ltd and independent geophysical studies suggesting that the productive Sangomar reservoir may in fact extend into Gambian waters. It also highlighted how recent redrawing of The Gambia’s offshore boundaries, occurring just as FAR exited the country, appears to carve out the most promising oil prospects leaving The Gambia exposed and potentially excluded.

The Government of Senegal, and its national oil company Petrosen, have a moral and legal duty to respond. The failure to do so risks appearing as tacit endorsement of a resource exclusion strategy that benefits a few corporate actors while harming regional stability and equity.

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Like Woodside Energy, FAR Ltd and Petronas, Senegal has chosen silence over fairness.

In the spirit of transparency and public accountability, and because the stakes for The Gambia’s sovereignty and economic future are so high, we have decided to release the original letter in full.

This silence must not stand unchallenged.

ECOWAS will be formally engaged if no reply is received by 24.07.2025 (7) days from publication.

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FULL LETTER TO SENEGAL’S MINISTRY OF PETROLEUM AND ENERGY

OFFICE OF OUSMAN F. M’BAI
C/O FANA FANA CHAMBERS, P.O. Box 990, Banjul, The Gambia

To: Mr Biram Souleye Diop
Ministry of Petroleum and Energies
Avenue Bourguiba, Dakar, Senegal
Email: [email protected]

Date: 24th June 2025
Our Ref: OFM/24/06/25/MinistryMPE.

Subject: Call for Unitisation Talks and Clarification of Maritime Boundary Adjustments near Sangomar and A2 Block

M’bokha, Nuyu Nala Johla Sa Wachuwai — Relative, I greet you and pay my respects.

I write not as a stranger but as a brother, bound by heritage and committed to the principles of justice, transparency, and mutual respect that should govern our shared natural inheritance. The relationship between The Gambia and Senegal is rooted not only in geographic proximity but in kinship cultural, historical, and familial. It is in this spirit of fraternity and constructive engagement that I respectfully draw your attention to pressing concerns surrounding the A2 offshore block, its proximity to the Sangomar field, and the conspicuous absence of unitisation dialogue, despite strong geological evidence of transboundary reservoir connectivity.

As you are aware, under international law including Article 74 and 83 of the United Nations Convention on the Law of the Sea (UNCLOS) where hydrocarbon reservoirs straddle maritime boundaries, there exists both a right and a duty for affected States to initiate negotiations with a view to reaching a unitisation agreement. This obligation is well established and finds further support in the global state practice of equitable resource sharing. Indeed, Senegal has already exemplified this principle through existing unitisation agreements with Mauritania and Guinea-Bissau.

In light of this, the complete absence of engagement or acknowledgement of The Gambia’s sovereign right to participate in discussions relating to the Sangomar extension into the A2 block is a deeply concerning omission. There is now clear geotechnical evidence that the productive S400 series reservoirs of the Sangomar field currently operated by Woodside Energy and Petrosen extend southward into Gambian maritime territory, including the Bambo and Panthera prospects.

The situation is further compounded by regulatory developments within Senegal and The Gambia. The 2023 Block Demarcation Regulation in The Gambia redrew the northern boundary of Block A2, shifting it several kilometres south a revision that excluded the Bambo-1 well, the Solo Deep, and Panthera prospects. This was executed with no public explanation and occurred at the precise moment when FAR Ltd was exiting the country following the receipt of substantial payments from Woodside Energy.

Moreover, Senegal’s recent announcement on 10 June 2025 that it is undertaking a revision of its national maritime code raises legitimate concerns regarding the possible future realignment of maritime boundaries to reinforce control over the Sangomar basin and its southern extensions. Such a development, without consultation or disclosure, would appear not only inequitable but potentially in breach of UNCLOS principles requiring good faith negotiations over overlapping claims.

The effect of these coordinated administrative shifts when viewed alongside the silence surrounding unitisation is to create a regulatory and territorial buffer that tacitly surrenders effective control of a shared hydrocarbon system to Senegal and Woodside Energy, thereby allowing unilateral exploitation of transboundary resources to the exclusion of The Gambia. This cannot be sustained without reputational and possibly legal consequences.

I respectfully call upon your Ministries to:

  1. Acknowledge the geological indicators pointing to a connected reservoir system between Sangomar and Gambia’s A2 block;
  2. Publicly affirm Senegal’s commitment to uphold its obligations under UNCLOS to initiate discussions on a potential unitisation agreement with The Gambia;
  3. Provide clarity on the scope and intent of Senegal’s ongoing maritime code reform, and whether this has any implications for established maritime boundary understandings with The Gambia;
  4. Engage in a transparent, equitable and good-faith dialogue aimed at regional cooperation, conflict avoidance, and sustainable resource sharing.

M’bokha, this is not a plea born of grievance but a call to justice born of kinship. I remain hopeful that new Senegal will rise to its duty of leadership by upholding the values of transparency, accountability, and regional solidarity.

I am available for direct dialogue and willing to provide all supporting documentation substantiating these concerns. I look forward to your response.

With highest respect,

Ousman F. M’Bai
Former UK Financial Crime Prosecutor and Asset Recovery Specialist.
British and Gambian Lawyer

Cc: Mam Yassin Fall, Ministry of African Integration and Foreign Affairs
Place de l’Indépendance, Dakar, Senegal
Email: [email protected]

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