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A Socio-Technological Analysis of Cybercrime and Cyber Security in Nigeria
A Socio-Technological Analysis of Cybercrime and Cyber Security in Nigeria
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The Global Information Infrastructure creates unlimited opportunities for commercial, social and other
human activities. However, it is increasingly under attack by cybercriminals; as the number, cost, and
sophistication of attacks are increasing at an alarming rate. This study sets out to examine the
sociological and technological factors that impact cybercrime and cybersecurity and thereby articulates
the relevant circumstances and threats of cybercrime in Nigeria. The study approached the issue of
cybercrime from theoretical and investigative points of views. Structured interviews with law
enforcement agencies and governmental institution for cyber security were also conducted. Data
obtained through these research instruments were subjected to descriptive analysis and frequency
counts in order to explain the activities of Nigerian cybercriminals based on existing theories of crime,
and to understand their intents, purposes and methods. Four theories of crime, namely, Structural
Functionalism Theory, Marxian Theory, Routine Activity Theory and Technology Enabled Crime Theory
were all found to be relevant to Nigerian cybercrime. At the level of existing laws, the study established
that there are no existing laws in the Nigerian statues that directly address cybercrime.
INTRODUCTION
The development of the internet and the widened access radically changed the economics and ease of repro-
to computer technology has created new opportunities for duction (Longe and Chiemeke, 2008). Computer
work and business activities, as well as those who networks have also radically changed the economics of
engage in illegal activities. The rise of technology and distribution. With transmission speeds approaching a
online communication has not only produced a dramatic billion characters per second, networks enable the
increase in the incidence of criminal activities, but has sending of information products worldwide, cheaply and
also resulted in the emergence of what appears to be a almost instantaneously.
new variety of criminal activities. Both the increase in the For Nigeria, a nation in the process of saving her face
incidence of criminal activities and the possible emer- regarding cybercrimes, efforts are now being directed at
gence of new varieties of criminal activity pose challen- the sources and channels through which cybercrimes are
ges for legal systems, as well as for law enforcement perpetuated. The task of re-stigmatizing cybercrime and
(Brenner, 2007). re-dignifying honest is not as easy as that of institu-
While technological advancements have produced tionalising a deterrence mechanism like code of conduct
radical shifts in the ability to reproduce, distribute, control, bureau, Independent Corrupt Practice Commission
and publish information, the internet in particular has (ICPC), Economic and financial crime commission
E-mail: [email protected].
Olayemi 117
(EFCC) and many more. This is after many years at the analysis which lawmakers, policy makers and law enfor-
bottom of the ladder of the corrupt nations of the world, cement agencies in Nigeria can use in order to create
which is based on some index set by the Transparency legal definitions which are meaningful from sociological
International (TI), an anti-corruption crusader group. and technological perspectives of cybercrime and cyber-
security.
The specific objectives are as follows:
Problem statement
1. To identify informal, sociological and technological
The internet creates unlimited opportunities for commer- causes of cybercrime and cybersecurity in Nigeria.
cial, social and other human activities. But with cyber- 2. To analyse the approaches adopted by Nigerian law
crime the Internet introduces its own peculiar risks. What enforcement agencies and cybersecurity stakeholders in
are the menace cybercrime and cybersecurity threats combating cybercrime and ensuring cybersecurity.
poses to Nigeria?
Waziri (2009) spoke about the dreadful level of
corruption as being a threat to Vision 20:2020. Cyber- Research questions
crime is an obstacle that may shut the door of progress
against the nation. This was why Aluko (2004) gave This research study aims to assess the vulnerability of
seventeen (17) ways of stopping financial corruption in the Nigerian society is to crime and abuse on computer
Nigeria. One of these crimes according to him has to do networks and the Global Information Infrastructure at
with cybercrimes. The global village currently records an large.
increasing criminal behaviour. News of cybercriminal The study then attempts to answer the following
activities continue to fill the pages of the newspaper, it is questions:
central to world news and has become a global problem.
There is hardly a place where computers and internet 1. How are Nigeria anti-graft agencies tackling cyber-
facilities are found that cases of crime are not recorded. crime and cyber security threats?
New modes of operation are developing as the Global 2. How effective and efficient are the efforts of the
System for Mobile-telecommunication (GSM) is now used security agencies in combating cybercrime and ensuring
for browsing. A lot of young people are common among cybersecurity in Nigeria?
the perpetrators of these criminal activities. They spend 3. What can be done to improve the state of cybercrime
hours browsing and sometimes stay awake all night to and cybersecurity in Nigeria?
carry out their nefarious activities. The people involved
are mostly found within the ages of fifteen to thirty years.
According to Erhabor (2008), cybercrimes are METHODOLOGY
described as one of the fastest growing criminal activities
A mixed research approach is needed for adequate insight and
on the planet. He repeated the fact that it covers a large knowledge into solving and achieving the research problem and
range of illegal activity including financial scams, com- objectives. The study will approach the issue of cybercrime from
puter hacking, downloading of pornographic images from theoretical and investigative points of views. This study will use a
the internet, virus attacks, stalking and creating websites combination of existing literature studies, direct in-depth primary
that promote hatred. In recent time, young students in the research and secondary materials from the Internet. The study
tertiary engage in forgery of all kinds ranging from false population for this study includes: law enforcement agencies and
cybersecurity governmental agencies
admission paper to school fees receipts, certificates
racketeering and examination malpractice that is,
accessing useful information during examinations through LITERATURE REVIEW
the handset and other electronic devices. Ajao (2008)
said Nigeria, Ghana and South Africa top cybercrime in Cybercrime: Definition and conceptualization
Africa. Nigeria is not spared from the heartache caused
A primarily problem for the analysis of cybercrime is the lack of a
by cybercrimes. consistent and statutory definition for the activities that may
The findings above are worrisome and it is in order to constitute cybercrime (PJCACC, 2004; Yar, 2005). According to
curb and proffer solution to the above that the study Smith et al. (2004), defining cybercrime raises conceptual complexi-
intends to look at the sociological and technological fac- ties. Varied definitions of cybercrime do exist. In addition to the
tors influencing cybercrime and cyber security in Nigeria. difficult of definition, it is also called by variety of terms such as
computer crime, computer-related crime, digital crime, information
technology crime (Maat, 2004), Internet crime (Wall, 2001), virtual
crime (Lastowka and Hunter, 2004; Grabosky, 2001 ), e-crime (AIC,
Research objectives 2006) and net crime (Mann and Sutton, 1998). Cybercrime could
reasonably include a wide variety of criminal offenses and activities.
The general objective is to provide information and At the Tenth United Nations Congress on the Prevention of
118 Int. J. Sociol. Anthropol.
Crime and Treatment of Offenders, in a workshop devoted to the related hardware and software devices, and the information they
issues of crimes related to computer networks, cybercrime was contain and communicate, including software and data, as well as
divided into two categories and defined thus: other elements of cyberspace, from all threats, including threats to
national security;
1. Cybercrime in a narrow sense is any illegal behaviour directed by 2. The degree of protection resulting from the application of these
means of electronic operations that targets the security of activities and measures;
computers systems and the data processed by them. 3. The associate field of professional endeavour, including research
2. Cybercrime in a broader sense is any illegal behaviour committed and analysis, aimed at implementing and those activities and
by means of, or in relation to, a computer system or network, improving their quality.
including such crimes as illegal possession and offering or
distributing information by means of a computer system or network. Cybersecurity is thus more than just information security or data
security, but is closely related to those two fields, because infor-
In the Council of Europe’s Convention on Cybercrime (2001), mation security lies at the heart of the matter. Information security
cybercrime is used as an umbrella term to refer to an array of refers to all aspects of protecting information. Most often, these
criminal activities including offenses against computer data and aspects are classified in three categories: confidentiality, integrity,
systems, computer-related offenses, content offenses, and copy- and availability of information. Confidentiality” refers to the protec-
right offenses (AIC, 2006). The convention covers cybercrime in tion of information from disclosure to unauthenticated parties, while
four main categories: “integrity” refers to the protection of information from unauthorised
changes. “Availability” means the information should be available to
1. Offenses against the confidentiality, integrity, and availability of authorised parties when requested. Sometimes, “accountability” the
computer data and systems such as illegal access, illegal requirement that the actions of an entity be uniquely traceable to
interception, data or system interference, and illegal devices. that entity is added to the list.
2. Computer related offenses like computer-related forgery and The first goal of modern information security has, in effect,
computer-related fraud become to ensure that systems are predictably dependable in the
3. Content-related offenses (e.g. child pornography). face of all sorts of malice and particularly in the face of denial-of-
4. Offenses related to infringements of copyright and related rights. service attacks.
The dominance of network topologies has implications for the
A working definition along these lines is offered by Thomas and shape of the protection policies and, subsequently, in determining
Loader (2000), who conceptualised cybercrime as those “computer- appropriate protection efforts, goals, strategies, and instruments for
mediated activities which are either illegal or considered illicit by problem solution:
certain parties and which can be conducted through global
electronic networks”. The working definition for cybercrime by the 1. Cybersecurity as an Information Technology issue: Cybersecurity
Canadian Police College has increasingly been accepted by can be approached as an IT security or information assurance
Canadian law enforcement agencies; as a criminal offence issue, with a strong focus on Internet security. Policies are thus
involving a computer as the object of the crime, or the tool used to aimed at countering threats to the information infrastructure by
commit a material component of the offence (Statistics Canada, technical means such as firewalls, anti-virus software, or intrusion
2002). Maat (2004), proposed a definition for cybercrime which detection software. The main threats perceived range from
encompasses all illegal activities where the computer, computer accident, system failures, bad programming, and human failures to
systems, information network or data is the target of the crime and hacker attacks.
those known illegal activities or crime that are actively committed 2. Cybersecurity as an economic issue: Cybersecurity is relevant to
through or with the aid of computer, computer systems, information the business continuity, and especially to e- business, which
network or data. It is significant to note that there is no consistent requires permanent access to ICT infrastructures and permanently
and statutory definition for cybercrime. available business processes to ensure satisfactory business
performance. The main actors are representatives of the private
sector. The main threats are viruses and worms, human failures,
Cybersecurity in Perspective but also hacker attacks of all sorts, and acts of cybercrime.
3. Cybersecurity as a law enforcement issue: Cybersecurity is seen
Cybersecurity is concerned with making cyberspace safe from as relevant to cybercrime. Cybercrime is a very broad term with
threats, namely cyber-threats. The notion of “cyber-threat” is rather various meanings, and definition can include everything from
vague and implies the malicious use of information and technology-enabled crimes to crimes committed against individual
communication technology (ICT) either as a target or as a tool by a computers. The main actors are law enforcers. The main threats
wide range of malevolent actors. Cybersecurity is often confused are acts of computer criminality, but also cyber terrorism.
with national security while national security, according to the co- 4. Cybersecurity is a national security issue: Society as a whole and
ordinator of NCWG, Udotai (2002) in Odumesi (2006) may often be its core values are endangered, due to their dependence on ICT.
implicated in some cases of cybersecurity. Cybersecurity as a term Action against the threat is aimed at several levels (the technical,
refers only to security of networks and systems- computers, elec- legislative, organisational, or international levels). The main actors
tronics and ancillary devices. Typical cybersecurity issues, accor- are security specialists. The main threats are terrorists, but also
ding to Udotai (2002) in Odumesi (2006) include: confidentiality of information warfare threats from other states.
information; and integrity of systems and survivability of networks
(CIS). Major objective of cybersecurity includes: protection of
system/networks against unauthorised access and data alteration Theoretical framework
from within; and defense against intrusion from without. As
commonly used, the term “cybersecurity” refers to three things: According to Khan (1999), theoretical framework of the study is a
structure that can hold or support a theory of a research work. It
1. A set of activities and other measures, technical and non- presents the theory which explains why the problem under study
technical, intended to protect computers, computer networks, exists. Thus, the theoretical framework is but a theory that serves
Olayemi 119
as a basis for conducting research. A theoretical framework guides alienation of the majority for the benefits of the elites; a segment
your research, determining what things you will measure, and what disadvantaged citizens who are in the majority have taken to
statistical relationships you will look for. alternative means to survive. Such alternative means includes
The researcher will be adopting the following for this study: prostitution, armed robbery, amongst others. It can be seen that
Structural-Functionalism Theory, Marxian Theory, Routine Activity crimes in Nigeria have been influenced by monumental poverty,
Theory, and the Theory of Technology-enabled Crime. relative social deprivation, rampant corruption, excessive greed and
materialism, amongst others.
The key insight into the theory is that, crime is a natural outgrowth The key insight into the theory is that, it combines several categories
of capitalism and view society as constantly changing in response of criminological theories to help society better understand why
to social inequality and social conflict. Capitalism as an economy crimes co-evolved with computer and telecommunications
system is based on the private ownership of property with personal technologies to become among the most complex and difficult
gain rather than collective well-being is encouraged. The theory forms of crime to prevent, investigate and control. McQuade (1998)
argued that capitalism is itself a crime and it further causes crime. It reveals that understanding and maintaining relatively complex
is based on oppression and economic exploitation of the majority, crime is initially quite difficult, and there is continual competition
and creates a competitive world in which greed, violence and between the criminals and law enforcement for technological
corruption flourish. advantage. As criminals do something new and innovative, law
Bonger (1916) in Giddens (2001) provided a very early inter- enforcement must catch up in order to avert, control, deter, and
pretation of Marxian ideas on crime and deviance. Bonger shared prevent new forms of crime.
with Marx himself a belief that, by nature, humanity is altruistic and McQuade (2006) argues that, technology-enable crime theory
not competitive. Bonger suggests that capitalism itself, as a form of encompasses:
economic organisation, makes humanity greedy and selfish.
Quinney (1973, 1977) in Giddens (2001), in line with Bonger’s 1. Crimes committed directly against computers and computer
argument, argues that under capitalism the law is used to oppress systems.
the working class. He suggests that what we now regard as 2. Activities which fall under this category are often referred to as
‘criminal’ will disappear only once capitalism itself has disappeared. high tech crime, computer crimes or cybercrimes.
He contends that there will be no greed and profit-seeking under 3. The use of technology to commit or facilitate the commission of
socialism; also, the ruling class will not exist to use the law as a traditional crimes.
weapon to define as deviant or criminal those working class 4. Crimes such as fraud, scams, and harassment can be facilitated
activities they do not wish to allow. using technology which brings unique challenges to old crimes.
The Marxian theory is relevant to this study because it provides
significant understanding to why people especially unemployed The theory provides a framework for understanding all forms of
youths engage in crime. Given the level political and economic criminality and especially those that are evolving with computing
instability as well as corruption in Nigeria, it is no surprise that and telecommunications technology inventions and innovations.
cybercrime is rampant. Due to the oppression, exploitation and The theory is pertinent for understanding contemporary threats
120 Int. J. Sociol. Anthropol.
posed by emerging forms of cybercrime, transnational crime and Data collection and data collection methods
terrorism networks that defy traditional methods criminal justice and
security measures for preventing and controlling crime. Law Enforcement Agencies and Governmental Cybersecurity
The theory is relevant to this study because it provide us insight Agency
understanding of the new tools and techniques use by cyber-
criminals; that is, a shift from the simple crime committed using The following questions were asked during the interview section the
simple tools to complex crime committed using complex tools. It EFCC, NPF, and NITDA in order to understand the approaches
also helps in understanding the new forms of deviance, social adopted by Nigerian law enforcement agencies and cybersecurity
abuse or crime committed through innovative use of technology. stakeholders in combating cybercrime and ensuring cybersecurity:
1. Two law enforcement agencies Based on the data collected, we discovered that the
2. One cybersecurity governmental agency Economic and Financial Crime Commission (EFCC) as
well as the Nigerian Police Force (NPF) become aware of
cybercrime activities through complaints and reports by
Sampling techniques victims of cybercrime, online surveillance, and frequent
assessment of cybercafés. They generally get evidences
This study made use of non-probability sample. The non- to ensure conviction through forensic analysis of sus-
probabilistic sampling technique that was used for this study is pects’ computer systems and devices used to perpetuate
purposive sampling. This technique was chosen because the
researcher is interested in a particular information-rich subset of
the crime. Apart from these means, oral testimony of
stakeholders in cyber activities. victims, mails exchanged between the suspects and the
victims and Internet Protocol address results from
Internet Service Providers (ISPs) are also part of the
Sample size evidences used to ensure conviction of those who might
be guilt.
The following sample sizes were chosen for each category of the The Advance Fee Fraud Act of 2006, the Money Laun-
research population:
dering Act of 2004 section 12(1) (c) - (d), the Economic
and Financial Crime Commission Act of 2005, and the
Law Enforcement Agencies
Evidence Act of 1948 are the only available provisions in
the Nigeria criminal law that may be used to convict
The unit of analysis is organisation hence the data collected from perpetrators of cybercrime. These security agencies
the Head of the organization best represent the organisations, ensure cybersecurity through registration of all pros-
which are the Economic and Financial Crime Commission (EFCC) pective cyber cafes and through public enlightenment.
and the Nigeria Police Force (NPF). Some of the challenges encountered in the course of
their duties of ensuring cybersecurity include: lack of
adequate provisions for cybercrime in the criminal code,
Cybersecurity Governmental Agency
non-registration of SIM cards and Internet modems, non-
cooperation of Internet Service Providers (ISPs) and
The unit of analysis is organisation hence the data collected from
the Head of the organisation represent the information needed from telecoms service providers, insufficiently trained person-
the organisation, which is National Information Technology nel and inadequate number of trained personnel as well
Development Agency (NITDA). as lack of opportunities for regular training. Also of
Olayemi 121
relevance is the inadequate knowledge of cybercrime receive. Also, organisations lack institutional memory, as
issues and technicalities by Nigerian Judges, and the people who might have acquired cybercrime training are
duplication of duties and responsibilities among law sometimes placed in positions where the knowledge they
enforcement agencies toward cybercrime activities. have acquired may not be useful to the organisation.
The Economic and Financial Crime Commission Another challenge is the inadequacy of funding which
(EFCC) reports positive results in the fight against makes it difficult for them to set up a forensic laboratory,
cybercrime due to regular raids of public Internet café, equip and train personnel.
arrests and prosecution of suspects; the Nigerian Police The agency recognises the modest successes of the
Force (NPF) did not report positive results and they various law enforcement agencies but remarks that the
attribute this ineffectiveness to lack of adequate Nigerian government often react based on the exigencies
Information Technology skills, lack of adequate funding, at the time. For instance, when corruption became a
and lack of necessary motivation to adequately engage major issue, ICPC was set up; when hard drug became
cybercriminals. an issue, we set up NDLEA; when fake drugs became an
The most recent cybercrime case that demonstrates issue, we set up NAFDAC; etc.
the importance of having a cybercrime law is the case of The agency reports that, there are several cases of
Akeem Adejumo VS the National Aeronautic and Space attempt to tender electronic evidences but they are not
Agency of the United States. The law enforcement acceptable at the law courts. A typical example is the
agencies perceive a low level of general awareness of celebrated case of Femi Fani-Kayode, where the court
cybercrime and cybersecurity among the Internet-using rejected the printout statement of account because the
Nigerian public and they attribute this to the low Evidence Act says you have to produce ledger and right
penetration of Internet access, mass illiteracy, and the now no banks uses ledger anymore. The perception of
inability on Internet users to take precautionary the agency on the general awareness of cybercrime and
measures. cybersecurity in Nigeria is that, most people link them
with only “Yahoo Yahoo Boys”; whereas there are other
equally fundamental dimensions of the problem.
Interview with Governmental Cybersecurity Agency
to be trained specially to handle cybercrimes in Nigeria. cyber-economy optimizing business confidence and
The police should have a Central Computer Crime Res- individual privacy, as well as strategies to promote and
ponse Unit to act as an agency to advise the state and protect the innovation and wealth-creating potential and
other law enforcement agencies to guide and coordinate opportunities of information and computing technologies,
computer crime investigation. including early warning and response mechanisms in
2. The government should set up National Computer case of cyber-attacks. Behind the prevention and
Crime Resource Centre, which should comprise experts prosecution of computer-related crime looms the larger
and professionals to establish rules, regulations and challenge of creating a global culture of cybersecurity,
standards for network security protocols. addressing the needs of all societies, including deve-
loping countries, with their emerging and still vulnerable
Ayofe and Oluwaseyifunmitan (2009) suggested (both in information technology structures.
form of security, education and legislation) following the 2. International cooperation at all levels should be
weak nature of global legal protection against cybercrime: developed further. Because of its universal character, the
United Nations system, with improved internal co-
1. Ensure that all applicable local legislation is com- ordination mechanisms called for by the General
plementary to and in harmony with international laws, Assembly, should have the leading role in intergovern-
treaties and conventions; such as the Council of Europe’s mental activities to ensure the functioning and protection
Convention on Cybercrime. of cyberspace so that it is not abused or exploited by
2. Establishment of a framework for implementation of criminals or terrorists. In particular, the United Nations
information assurance in critical sectors of the economy system should be instrumental in advancing global
such as public utilities, telecommunications, transport, approaches to combating cybercrime and procedures for
tourism, financial services, public sector, manufacturing international cooperation, with a view to averting and
and agriculture and developing a framework for mitigating the negative impact of cybercrime on critical
managing information security risks at all levels. infrastructure, sustainable development, and protection of
3. Establishment of an institutional framework that will be privacy, e-commerce, banking and trade.
responsible for the monitoring of the information security 3. All States should be encouraged to update their
situation, dissemination of advisories on latest infor- criminal laws as soon as possible, in order to address the
mation security alerts and management of information particular nature of cybercrime. With respect to traditional
security risks including the reporting of information forms of crime committed through the use of new
security breaches and incidents. technologies, this updating may be done by clarifying or
4. Firms should secure their network information. When abolishing provisions that are no longer completely
organization provides security for their networks, it adequate, such as statutes unable to address destruction
becomes possible to enforce property rights laws and or theft of intangibles, or by creating new provisions for
punishment for whoever interferes with their property. new crimes, such as unauthorized access to computers
5. Improving awareness and competence in information or computer networks. Such updating should also include
security and sharing of best practices through the procedural laws (for tracing communications, for exam-
development of a culture of Cybersecurity at all levels. ple) and agreements or arrangements on mutual legal
6. Promote secure e-commerce and e-government assistance (for rapid preservation of data, for example).
services. In determining the strength of new legislation, States
7. Safeguarding the privacy rights of individuals when should be encouraged to be inspired by the provisions of
using electronic communications the Council of Europe Convention on Cybercrime.
8. Formalize the coordination and prioritization of cyber 4. Governments, the private sector and non-govern-
security research and development activities; dissemi- mental organizations should work together to bridge the
nate vulnerability advisories and threat warnings in a digital divide, to raise public awareness about the risks of
timely manner. cybercrime and introduce appropriate countermeasures
9. Implement an evaluation/certification programme for and to enhance the capacity of criminal justice profes-
cyber security product and systems. sionals, including law enforcement personnel, prosecutors
and judges. For this purpose, national judicial admini-
United Nations (2005) outlined the following recommen- strations and institutions of legal learning should include
dations to be considered by countries in fighting comprehensive curricula on computer related crime in
cybercrime: their teaching schedules.
5. Cybercrime policy should be evidence-based and
1. A broad, inclusive focus is necessary to address subject to rigorous evaluation to ensure efficiency and
problems of cybercrime, going beyond criminal law, penal effectiveness. Therefore, concerted and coordinated
procedures and law enforcement. The focus should efforts at the international level should be made to
include requirements for the secure functioning of a establish funding mechanisms to facilitate practical
Olayemi 125
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3(1):26.
crime. It is, however, equally important to ensure that
Erhabor IM (2008). Cybercrime and the Youths (PGDE Thesis),
research be internationally coordinated and that research Department of Education, Ambrose Alli University, Ekpoma, Nigeria,
results be made widely available. p.37.
Giddens A (2001). Sociology. Uk: Blackwell Publishers pp.306-501.
Grabosky PN (2001). Virtual criminality: Old wine in new bottles. Social
and Legal Studies 10(2):243-249.
Future research Khan ER (1999). Developing the Theoretical and Conceptual
Framework. Retrieved from: http:// journclasses.pbworks.com/f/
The researcher was unable to gain access to the arrested theoretical+framewor.ppt.
Lastowka FG, Hunter D (2004). Virtual Crimes. New York Law School
cybercriminals within the Special Fraud Unit of The Law Rev. 49:293-316.
Nigeria Police Force (NPF) and the Advance Fee Fraud Longe OB, Chiemeke SC (2008). Cybercrime and criminality in Nigeria
Unit of Economic and Financial Crime Commission – What roles are internet access points in playing? Eur. J. Soc. Sci.
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Maat S (2004). Cybercrime: A Comparative Law Analysis (Doctoral
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Lastly, the researcher recommends a further study into
McQuade S (2006). Understanding and Managing Cybercrime, Boston:
the demographic and sociological characteristics of Allyn & Bacon.
cybercriminals in Nigeria in order to identify the factors Odumesi JO (2006). Combating the menace of cybercrime: The
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Abuja, Nigeria p.45.
Smith RG, Grabosky P, Urbas G (2004). Cyber Criminals on Trial.
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