This letter is a complaint submitted to the SIT on Black Money regarding an investigation into alleged money laundering and siphoning of Rs 6500 crores involving Reliance Industries Limited and ICICI Bank. The complaint references a 2011 letter from the Indian High Commission in Singapore that reported a one-room company in Singapore with no real business, assets, or tax filings invested Rs 6530 crores in Reliance, with most going to a company owned by Mukesh Ambani. The letter questions how ICICI Bank provided a loan of thousands of crores to this shell company, and whether the bank was complicit in money laundering by Reliance. The complainant requests the SIT investigate this case and

1. PRASHANT BHUSHAN
ADVOCATE
RESI. OFFICE. CHAMBER
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Dated: July 08, 2014
To,
Shri M L Meena
(Joint Secretary)
Member Secretary
SIT on Black Money
Room No. 46, Dept of Revenue
Ministry of Finance, New Delhi
Dear Sir,
SUB: Complaint of huge money laundering and siphoning of Rs 6500 crores
I am writing this complaint to the SIT on black money constituted pursuant to the
orders of the Hon’ble Supreme Court of India. This complaint is regarding the huge
money laundering and siphoning of money involving India’s biggest corporate group
(RIL) and India’s largest private sector bank (ICICI) that the SIT ought to investigate
and prosecute.
We all know that there have been two detailed CAG reports that Reliance Industries
Limited (RIL) is involved in inflation of capital expenditure, over invoicing and
siphoning of money from the KG Basin D6 Block. There is a clear suspicion that
such amounts are being laundered and funneled back into Reliance companies.
In this light, an alarming letter was written by the Indian High Commission in
Singapore on 31st August 2011. The High Commission had stated that Rs 6530
crores have come into India from Bio Metrix Marketing Ltd., a one room company in
Singapore that does not do any business. It was pointed out that this is a company
with no assets, no equity and does not file an income tax returns in Singapore
claiming to be a small company. Yet, this huge investment by this company of Rs
6530 crores is the single biggest FDI into India from Singapore.

2. The High Commission had stated that all this money has gone into Reliance group of
companies in India with the major chunk going to Reliance Gas Transportation
Infrastructure Ltd which is a company 100% owned by Mr. Mukesh Ambani
personally. A copy of the letter sent by the Indian High Commission in Singapore is
annexed as Annexure A.
The Commission had pointed out that one Mr. Atul Shanti Kumar Dayal effectively
owns this company Bio Metrix. Mr. Dayal is nothing but a front for Reliance since he
is a Director in 32 Reliance group companies. Profile of Mr. Dayal is annexed as
Annexure B. Now it has come to light that this company BioMetrix has closed down
(Annexure C).
Thus it became absolutely clear that Reliance is laundering its ill-gotten profits from
KG Basin through Singapore and depositing the same into accounts of Mr. Mukesh
Ambani.
On 27th February, I had released to the media the above referred letter written by the
Indian High Commission in Singapore. Pursuant to the press conference held by me,
Reliance immediately went on the defensive and issued a press statement.
According to several media reports, Reliance stated: “These investments in the
Indian companies were made by Biometrix out of loans raised from ICICI Bank,
Singapore branch.” The ICICI bank did not issue any denial to the press statement
issued by Reliance.
This Reliance statement raises more questions than it answers. The ICICI bank had
given a loan of thousands of crores to a company with no equity, no assets and no
business. What was the collateral or security taken by the ICICI bank before issuing
such a huge loan? What was the due diligence done by the ICICI bank before
issuing this loan?
The bank does not give any small loan to an ordinary person, even for purchasing a
car or house, without proper security and documentation. But who sanctioned the Rs

3. 6530 crores of loan to this company with no business? Has the loan been returned
by Biometrix to the ICICI bank? Now this company Biomentrix has closed down. So
how will the bank recover this loan?
Under the international conventions on money laundering, the duty is put on the
financial institutions to observe due diligence and transparency to prevent money
laundering. It is also the duty of the Government to investigate all such transactions.
The question therefore arises, was the ICICI bank an accomplice in the money
laundering operation carried out by Reliance?
The Government of India has just sat over these facts for the about three years now.
The Government has not bothered to investigate this case of money laundering
perhaps because powerful entities like Reliance and ICICI bank are involved.
Therefore, I request you to investigate this case thoroughly. Kindly acknowledge the
receipt of this letter and inform me the action the SIT would take in this matter.
I would also like to meet the SIT personally to make my suggestions about what
needs to be done to deal with the issue of illicit and laundered money. I had earlier
on 23rd Jule 2014 sent a letter to the Prime Minister, a copy of which was also sent to
the Chairperson and Vice-Chairperson of the SIT.
Yours sincerely,
PRASHANT BHUSHAN
COPY TO:
1. JUSTICE M. B. SHAH
CHAIRPERSON, SIT
2. JUSTICE ARIJIT PASAYAT
VICE CHAIRPERSON, SIT