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The Nirav Modi PNB Scam is one of India’s biggest banking frauds, involving fraudulent transactions worth ₹14,000 crore ($2 billion USD). It exposed systemic loopholes in India’s financial system, highlighting weaknesses in banking oversight, risk management, and regulatory enforcement.

Key Players

  • Nirav Modi: A billionaire jeweler and the prime accused
  • Mehul Choksi: Owner of Gitanjali Group and Nirav Modi’s uncle, co-accused in the fraud
  • Punjab National Bank (PNB): India’s second-largest public sector bank, where the fraud originated
  • Bank Officials: Senior executives at PNB who allegedly bypassed regulatory protocols to facilitate fraud

Facts of the Case

  1. Nature of the Scam
    ○ Between 2011 and 2018, Nirav Modi and Mehul Choksi allegedly used fake Letters of Undertaking (LoUs) issued by PNB to secure credit from overseas banks such as Allahabad Bank,
        Axis Bank,  and UCO Bank
    ○ These LoUs were not recorded in the bank’s core banking system (CBS), making the transactions invisible to PNB’s auditors and regulators
    ○ The fraud came to light in January 2018 when a new PNB employee asked for mandatory collateral for fresh LoUs, exposing the scam
  2. Scale of Financial Loss
    ○ PNB reported fraudulent transactions worth ₹14,000 crore ($2 billion), one of the largest financial frauds in Indian banking history
    ○ As a result, PNB’s stock price crashed, and the bank required capital infusion from the government to prevent systemic collapse
Key Allegations
Banking Fraud & Fake LoUs
  • LoUs issued without collateral security
  • Multiple fraudulent transactions bypassed core banking system checks
  • Illegal extensions of credit limits by PNB officials
Money Laundering & Round Tripping​
  • Funds obtained through fake LoUs were laundered via shell companies
  • Modi’s firms used offshore entities to move money between jurisdictions
  • Money was reinvested into his luxury jewelry business to create an illusion of legitimate income  
Regulatory Oversight Failures
  • Failure of internal audit mechanisms in PNB
  • Lack of coordination between banks, RBI, and SWIFT system monitoring 
Red Flags Warning Signs
Shell Companies & Offshore Links: Money was routed through shell companies in Hong Kong, UAE, and other jurisdictions
 
Regulations and Findings
Investigations; Regulatory Actions
  • Central Bureau of Investigation (CBI) Probe
    ○ The CBI registered multiple FIRs against Nirav Modi, Mehul Choksi, and bank  officials under IPC Sections 420 (cheating) and 120B (criminal conspiracy)
    ○ PNB filed a complaint in January 2018, which led to an in-depth investigation into  fraudulent LoUs
  • Enforcement Directorate (ED) Investigation
    ○ The ED charged Modi under the Prevention of Money Laundering Act (PMLA), 2002
    ○ Multiple searches and asset seizures were conducted across India, UAE, UK, and        Hong Kong
    ○ Over ₹1,000 crore worth of assets were seized from Nirav Modi’s jewelry
        businesses
  • International Legal Proceedings
    ○ UK authorities arrested Nirav Modi in 2019, following India’s extradition request
    ○ He fought extradition in UK courts, citing “inhumane prison conditions in India”
    ○ In 2022, the UK High Court allowed his extradition to India
    ○  As of 2024, he remains in Wandsworth Prison, awaiting his final appeal decision
    ○ International Legal Proceedings 
Regulations Misused in the Nirav Modi Scam
    • Prevention of Money Laundering Act (PMLA), 2002
      ○ Modi exploited loopholes in AML (Anti-Money Laundering) compliance to launder funds
      ○ Enforcement Directorate used PMLA to seize his assets globally

    • Fugitive Economic Offenders Act, 2018 (FEOA)
      ○ Nirav Modi was the first major case under FEOA
      ○ Allowed authorities to seize his properties without conviction

    • Foreign Exchange Management Act (FEMA), 1999
      ○ Funds were illegally routed through shell companies abroad
      ○ ED investigated FEMA violations related to round-tripping transactions

    • Companies Act, 2013
      ○ Fake companies were used to launder money
      ○ MCA (Ministry of Corporate Affairs) tightened shell company regulations post-fraud

    • SWIFT Messaging System Loophole
      ○ Fraudulent LoUs were issued without SWIFT alerts
      ○ After the scam, RBI made SWIFT integration mandatory with core banking systems 

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