The FinCEN Files contain a 20-page “intelligence assessment” on the mirror network and list 54 shell companies which, they say, moved billions of dollars annually from Russia through European securities markets to other jurisdictions beginning as early as 2011.

OVER 100 transactions worth $104.4 million by companies associated with Max Group founder and chairman Analjit Singh were red-flagged by Standard Chartered Bank, New York, to US financial watchdog FinCEN.

These transactions, between July 2014 and November 2016, were between entities in India and those located in Cyprus, UAE, Singapore, South Africa, Jersey and Isle of Man. Some of these companies had Singh as a director as well, according to the bank’s records of Suspicious Activity Reports investigated by The Indian Express.

In two SARs, the bank said that Singapore-based LGO Pte, a company where Analjit Singh is a director, which had an account with the bank, carried out transactions with “unknown entities, located in high-risk jurisdictions.”

Incidentally, Analjit Singh has been probed for his overseas transactions in the past too. In 2012, the Enforcement Directorate (ED) summoned Singh, then the chairman of Vodafone India, with regard to a foreign exchange violations case.

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The bank’s first SAR cited 85 transactions between July 2014 and May 2016, totalling $94.13 million with unidentified entities located in Cyprus, UAE, Singapore and India. “These transactions have the appearance of being conducted in a circular pattern without an identified business purpose. The remittance field section states Loan and/or Loan repayment…In addition, several of the counter-parties have registered addresses in Cyprus and appear to be shell companies with no identifiable line of business or physical locations,” the SAR said.

In its second SAR, the bank identified 19 transactions totalling $10.3 million remitted/received by LGO. These transactions were carried out between June 2016 and November 2016.

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The companies with which LGO Pte conducted these transactions include: Analjit Singh; Pier114 Imports Private Ltd; South Africa-based Leeu Holdings Ltd formerly known as Blue Moral Ltd; Piveta Estates Private Ltd; Varana Global Holdings (based in Isle of Man); LGOX DMCC (based in UAE) and DIXCART Services/ DIXCART Management (based in Cyprus).

Records filed by Max India that provide details on directorship and partnerships of Analjit Singh in other entities (including foreign companies), show that Singh is a director in LGO Pte, the company that is at the centre of these transactions. He is also a director in three other companies that have been named in the SARs: Piveta Estates, Varana Global Holdings and Leeu Holdings Cyprus.

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While the SAR states that one Analjit Singh, located/banking in Singapore, could not be conclusively identified, it said, “an individual with this name was identified as chairman of Max India Group, a healthcare and insurance provider located in India and founder of the Leeu Collection, a hospitality business located in South Africa. A relationship between Leeu and Leeu Collection could not be conclusively established although the names of the entities appear similar.”

In fact, the SAR has listed three transactions that were specifically carried out by Analjit Singh worth $2.19 million between June 6 and June 27, 2016. It said that Singh used Deutsche Bank accounts in Singapore and Switzerland to remit/and or receive the funds. “The transactions lacked transparency and had an unidentifiable business purpose,” the SAR said.

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While highlighting another transaction where LGO Pte sent $1.16 million to Varana Global Holdings, the SAR said that a public search of Varana’s address in Isle of Man “identified several unrelated businesses that utilize this address, suggesting that Varana is possibly a shell company.”

According to the SAR, Varana utilised its account with Union Bank of India UK Ltd, Great Britain to receive the funds. Leeu Holdings, another company registered in Cyprus received three transactions from LGO Pte amounting to $1.65 million in June 2016.

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When asked about the SARs, Analjit Singh and his companies being named in these reports, a spokesperson from the Sponsor Group of Max India said: “All transactions being referred to have been done in the normal course of business and in total compliance with laws. The remittances have RBI approval. We also file an annual update with them as per norm. As you are neither a competent or appointed authority we have no reason to furnish details for each transaction. The funds have been used to invest in hospitality ventures started since last few years and currently operating in South Africa, the Lake District of UK and Florence Italy.”

On the observation in the SAR that Varana is possibly a shell company, the spokesperson said: “Varana is an eco-friendly clothing line which markets its products in UK, while it has a workshop in Bangalore. It counts some highly respected Indians amongst its investors.”

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