ACC investigators have found 54 accounts of Hall-Mark's various companies at the Ruposhi Bangla branch. Al least 34 of the SB accounts were operated by Hall-Mark garments companies for exports. In many cases, those accounts were opened without any introducers, and also without following proper bank procedures. The Know your customer (KYC) forms were not preserved against those accounts, which is mandatory for banks to prevent money laundering activities.

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2. Lavalin, then HPR, AECOM and Oriental. Those considerations lead to a "re-ranking" of the bidders,
which was released on March 28, 2011.
WB have heard many rumors of corruption in the construction supervision contract (CSC) related to
the planned construction of the Padma Bridge in Bangladesh. The WB has a unit that is charged with
the investigation of allegations of fraud, corruption, collusion and other improper activities in
relation to World Bank financed projects. It is called the Vice Presidency for Integrity ("the INT").
The Integrity Vice Presidency (INT) of World Bank received information through e-mail from few
persons in Bangladesh about possible corruption. The had started an investigation in to the
allegation.
The INT investigator had their own styled of investigation to corruption allegation. WB accordingly
informed Bangladesh government and Anti-corruption commission of their findings. The
Bangladesh authority did not find evidence of allegation of corruption the process of selection of
CSC. At one stage WB withdraw from their commitment of funding the project. The World Bank was
a primary lender in relation to the Padma Bridge project.
By this time, In March, 2011, an officer with the Royal Canadian Mounted Police (RCMP) was
approached by an INT of World Bank concerning allegations that had come to the INT's attention
regarding possible corruption involving Canadian Company SNC Lavalin on their finds of the
information provided by 4 tipsters from Bangladesh.
The RCMP investigated the allegation, investigated and finally filed a case against few executives of
LNC Lavalin to the Canadian court for a single offence under the Corruption of Foreign Public
Officials Act, S.C. 1998, c. 34.
The court heard the both sides and the facts came out that the INT investigator Mr Hyes did not
meet or know the identity of tipsters #1 or #3. Investigator did know the identity of tipster #2 at the
request of tipster #2, but refused to reveal identity of tipster no 2 to the Royal Canadian Mountain
Police (RCMP). Haynes also knew the identity of tipster #4.
That identity was revealed by Haynes to the RCMP. However, as it turned out, the information from
tipster #4 was very general in nature and was essentially irrelevant to the allegations that SNC
Lavalin was involved in corrupt practices.
It may also be obvious from the anonymous status of tipster #1 that neither the RCMP, nor the INT,
knew what tipster #1 did. In other words, they did not know if he worked for any of the bidders, or
whether he worked for the Government of Bangladesh, or anything else about him. Indeed, because
the identity of tipster #1 was unknown, no one knew, for certain, whether he was the same, or a
different, person as tipster #2 or tipster #3. In terms of the suggestion that he mentioned the
corruption was involved in the process, the material supplied by tipster #1 himself referred to
"rumors".
Tipster #1 sent a number of emails to the WB. Some of those emails attached various documents.
One such document was described as a "complain". It appeared in different versions. It is unknown
who prepared this document. Consequently, there is no way of knowing whether the contents of the
document are reliable. The World Bank responded to the emails from tipster #1 and asked follow-up
questions.
But those questions went largely unanswered by tipster #1. Instead, he tended to respond by saying
that the World Bank had access to, or could get access to, the bids and could make its own evaluation
of them. In some of his emails, tipster #1 directed the WB to specific people, by name that he said the
World Bank could contact to confirm the information that he was providing.

3. The tipster #2 acknowledged being involved in his own corrupt efforts in respect of the CSC, and
thus his honesty and credibility are open to question. The INT, and the investigator understand the
involvement of tipster #2 in corruption and suggested that it enhanced the credibility of tipster #2.
He is assumed to be familiar and has access to the corrupt practice. Further, the investigation finds
that the information provided by tipster #2, as it related to SNC Lavalin and the others was all
second-hand information.
Tipster #2 had no direct knowledge of the alleged corrupt conduct. Rather, he conveyed information
to the INT that was based on what others had told him. While tipster #2 told the INT the identities of
some of those sources, there is again no evidence that the INT ever spoke to any of those persons to
determine if the information was correct. Certainly the RCMP never did so. Moreover, there is no
evidence that the WB spoke to any of those people.
While the WB investigator of the ITO spoke to tipster #2 over telephone on two occasions. RCMP did
not try to look into the background of tipster #2 to determine his credibility or reliability, nor is there
any evidence that the INT did so.
The identity of tipster #3 was unknown. Tipster #3 sent only a single email to the World Bank. The
email is clearly based on rumor and supposition. For example, the email says: "It is known to all that
the technical Evaluations are manipulated by the evaluation committee". The email further says that
"SNC is promising hefty corrupt payments". There is no indication how tipster #3 neither purports to
know this fact nor, given his anonymity, is there any reason to believe that he would be in a position
to know it.
The Canadian police also investigated and during interrogation in the court says that the authorities
corroborated the following information: Corruption is a problem in Bangladesh; (b) SNC has
engaged in corrupt practices in the past; (c) the Prime Minister's financial advisor was corrupt; (d)a
member of the evaluation committee was corrupt; (e) The evaluation committee was reconstituted;
(f) The financial and technical rankings of the short listed companies; (g) The alleged persons
Mohammad Ismail, Ramesh Shah and Kevin Wallace worked at SNC; (h) According to SNC's
proposal all three were authorized to initial, sign and submit documents related to the proposal; and
(i) Members of the Bangladesh Bridge Authority (BBA) had travelled to Washington in March 2011.
During the hearing, he Judge noted that these are nothing but a recitation of publicly known
information. In one sense, it might be seen as confirming nothing more than the tipsters had access
to the Internet. Any hearsay statement of an informant can provide reasonable and probable grounds
to justify a search.
None of the tipsters had previously provided any further information to the police or to the INT.
During its investigation, the RCMP did not speak with either tipster #1 or tipster #3. An Police
officer did speak with tipster #2, but only by telephone. No police officers actually met with tipster
#2. The RCMP did not contact any of the sources of the hearsay information relayed by the tipsters,
even though some of those sources were identified by the tipsters, and thus were known both to the
INT and to the RCMP.
The Police also rely on evidence from two separate persons for corroboration that bear mention. The
first person is a former accountant for SNC Lavalin, who apparently told the Police, in a completely
separate and earlier investigation, about an alleged practice of SNC Lavalin keeping two sets of books
respecting alleged corrupt practices in Africa. Further, the accountant did not provide any
information regarding SNC Lavalin being involved in corrupt practices in Bangladesh. At most, the
accountant provided unproven allegations regarding alleged corrupt practices, some years earlier,
and on a different continent.
On this latter point, it appears that the information that the accountant did provide, about SNC
Lavalin being allegedly involved in corrupt practices in Africa, was about twenty years old. The

4. Second person is tipsters 2. None of the tipsters had a history of providing reliable information. The
motivation and criminal antecedents, if any, of tipsters #1 and #3 were unknown. The motivation
and criminal antecedents of tipster #2 were known.
Of particular importance on this aspect is the fact that the RCMP did not undertake any independent
investigation of any of the allegations made. They did not speak with any of the persons who were
identified by the tipsters as being in a position to provide direct information regarding the
allegations.
Indeed, the RCMP did not even speak directly with either tipster #1 or tipster #3, nor did they
actually meet with any of the tipsters. It is legal practice that a mere suspicion of criminal activity is
not sufficient. The information provided in the submission was nothing more than speculation,
gossip, and rumor. Nothing that could fairly be referred to as direct factual evidence, to support the
rumors and speculations, was provided or investigated.
Moreover, the communication between WB and tipsters were private in nature. The courts have
indeed recognized that the interception of private communications is a serious matter, to be
considered only for the investigation of serious offences, in the presence of probable grounds, and
with a serious testing of the need for electronic interception in the context of the particular
investigation and its objects.
The honorable judge of Supreme Court of Canada of Toronto Region has turn down the allegation of
corruption on 6th January 2017. The investigation of WB and RCMP were far from establishing
allegation of corruption.
The writer is a legal economist