The August 2024 analysis grouped $25.9 million in rice-related documentary credits across three importing companies within the selected disclosure period.

Wadi Al-Kouf, represented in the retained ledger by Abdel Karim Naji Ahmed Wahiba, accounted for approximately $15.5 million, or 60%. Bustan Libya accounted for about $7.8 million, or 30%, and Al-Jaid for approximately $2.6 million, or 10%.

The values were rounded in the original publication and add to its stated total. English transliterations can vary; the Arabic record remains authoritative for names.

60%

of the selected rice-credit value was concentrated in one of the three beneficiary companies.

Concentration is a question, not a conclusion

A large share may reflect capacity, supplier relationships or timing. It does not establish preferential treatment, over-invoicing or a competition violation.

What it establishes is the value of company-level publication. An aggregate total cannot show whether official dollars are spread across a competitive market or concentrated among a few beneficiaries.

What should happen after approval

The credit should be matched to quantity and grade cleared through customs, then compared with landed value, wholesale distribution and retail price.

A reusable concentration measure

Every product category could show total value, beneficiary count, largest share, top-three share, financing banks and stated origins.

What a 60–30–10 market snapshot measures

The three shares describe the distribution of selected credit value, not necessarily the annual rice-import market or retail sales. A company can receive a large credit in one disclosure window because of shipment timing, stock planning or contract size. The period and inclusion rule therefore belong beside every concentration ratio.

Still, a top-three share of 100% within the selected data is a strong reason to publish the full denominator: all rice codes, applicants, banks, amounts, amendments and dates. Without it, the snapshot cannot be mistaken for a national market-share finding.

Value must be joined to grade and quantity

Rice prices differ by grain, quality, origin, packaging and contract terms. A credit total cannot show whether invoiced prices were competitive or how many tonnes should arrive. Customs weight and product description are essential.

The audit test compares each shipment with contemporaneous benchmarks for the same grade and origin, allowing for freight, insurance and packaging. An outlier can be examined without declaring over-invoicing from an aggregate average.

Competition after the border

Import concentration matters if it translates into control of wholesale supply or pricing, but the two are not identical. Traders can sell through multiple distributors, stocks may overlap and other imports may fall outside the selected period.

Competition authorities should link financed imports to customs arrival, warehouse and wholesale data, then observe retail prices and availability across regions. That turns a financing share into a testable market question.

A standard concentration disclosure

For every major food product, the Central Bank can publish applicant count, total value, largest share, top-three share, financing-bank share, origin and execution status. Beneficial ownership should be aggregated across legally separate companies.

Customs can publish corresponding quantities and average unit values by code. The combined series would show whether concentration is persistent, seasonal or simply an artefact of the ten-day or monthly window.

Historical note: The $25.9 million and 60–30–10 split reproduce the selected dataset and date window used in the original publication. They are not presented as a full-year total and imply no wrongdoing.