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Euro Exim Bank decoded

Euro Exim Bank Decoded

by rtvenglish
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The Euro Exim Bank fake bank guarantee scandal, exposed by RTV, has revealed a massive fraud involving corrupt companies and possibly negligent government officials. As investigations unfold, IAS officers who “innocently” accepted the fake guarantees may face the heat and the contractors who “unknowingly” submitted them may face blacklisting and legal action. National banks are also under scrutiny for their role in issuing referral letters for these fraudulent documents. RTV’s detailed coverage has been crucial in uncovering the extent of the deception and prompting necessary inquiries into all parties involved. Here is the full fact sheet of Euro Exim Bank Ltd

EXECUTIVE SUMMARY

Structure of Euro Exim Group – Open domain profiling and on ground intelligence did not identify for any comprehensive overview of Euro Exim Group’s corporate structure. Euro Exim Group’s website states that the group comprises an entity in Saint Lucia, a representative office in the UK, back office operations in India and satellite employees or offices globally.

Ultimate beneficial owner mapping of Euro Exim Bank, St Lucia –

  • No financial filings noted to have been filed with the UAE corporate registry by Century Holdings Limited or Arabian Star Holding.
  • No shareholding, key management and / or financial information pertaining to Euro Exim Bank, St Lucia is noted to have been filed with the corporate registries of St Lucia.
  • Euro Exim Bank, St Lucia is 100% held by a UAE registered company called Centurion Holdings Limited. The company is an active company as registered in Abu Dhabi.
  • Suat Sokullu, is noted to be the director of the company and it is 100% held by Arabian Star Holding Limited (noted to bear cancelled status and held by a foreign company, whose details are not disclosed with the register).
  • Finance regulators’ registrations –
  • Euro Exim Bank UK is no longer registered with the UK Financial Conduct Authority to conduct financial service activities in the UK.
  •  The Saint Lucian registration of Euro Exim Bank. St Lucia, with the Financial Services Regulatory Authority solely allows Euro to conduct business with offshore third parties.
  • Lack of transparency on filed financials – No consolidated filings noted for Euro Exim Group.
  • As per information published by Euro Exim Group online (with no demarcation of branch / location based entity financials), the overall valuation as on April 2021, is claimed to be USD 227 million. However, this is uncorroborated through any supporting documents and is a self-claim.
  • It is interesting to note that in the latest media releases (as done by the company themselves) as noted for Euro Exim Bank, St Lucia in India, claims the company’s networth to be INR 1900 crores or roughly USD 230 million. This indicates that the Euro Group’s overall valuation is contradicted by themselves at various forums and there is no clarity on the numbers.
  • Misrepresentation of names of Related Parties – Names of related parties holding noted to be
    filed incorrectly in the Annual Reports of Euro Exim Bank, UK.
  • As per the reports, the controlling entity of Euro Exim Bank, St Lucia is Century Holdings as registered in UAE. However, checks as per UAE corporate registry reveals that Euro Exim bank, St Lucia is 100% held by Centurion Holding Limited. Further, checks on the name of Century Holdings, revealed to be known by a well known Omani traders, whose similar business holdings with the name Century may have been included to evoke confidence in those accessing the annual reports.
  • As per the reports, Century Holdings Limited is noted to hold a controlling stake in a New Zealand based company called Century Finance Limited (as per even the latest filing of 2023). However, checks with the New Zealand corporate registry notes that the company changed its name in 2012 and has since then been known as Century Financial Holdings Limited. The reference to a previous name might have been retained keeping in mind the generic references of other companies in New Zealand by similar names, that may cause confusion.
  • Indications of an unprofessional business – A review of media reporting, review sites, employers’ review sites and social media indicate that Euro Exim Group may not be run professionally. This includes references to having no minimum requirements for prospect candidates and no adequate training and policies to provide to its employees. In addition, reviewers that were unrelated to Euro Exim Group indicated that the group was not a genuine business.
  • Absence of information on clientele – No details of any active projects / clientele of the Euro Exim Group, noted during open domain searches. It was noted that the website of Euro Exim Group, did earlier list the details of their clients and trades. However, the same was pulled down in February 2024. The pulling down of the page, raises credibility on the published information and also overall on the representations as made by Euro Exim Group, towards its expertise.
  • References to alleged involvement in scams – Searches identified three recent references to Euro Exim Group having been involved in hiring and bank guarantee scams.
  • Red flags identified for Kaushik’s, Shah’s and Sanjay’s other corporate interests –
  • Searches identified two red flags for Kaushik’s and Adarsh’s trade names/corporate interests in the UK.
  • In 2017, the UK Financial Conduct Authority warned against a trade name that is the same as one of Kaushik’s corporate interests, Century Finance, as it had cloned another lender.
  • Four of Adarsh’s UK corporate interests were incorporated and dissolved within a short period of time and have not filed any financial statements or registered activity in UK corporate records.
  • Searches identified a UK civil and criminal case involving Sanjay, as director of New Zealand registered companies controlled by him, namely Century Financial Holdings Limited and Century Finance Limited.
  • Limited former finance experience found for Euro Exim Bank, UK’s current directors –
    Beyond Adarsh’s former role at the Bank of America, we identified no references to Adarsh or Kaushik having obtained relevant experiences in the finance industry.
  • Predominantly self-generated media reporting – A review of media reporting, review sites, employers’ review sites and social media indicate that nearly all media reporting on Euro Exim Group is self-generated or has been published on press release sites. There is little independent information available on the group.

SCOPE OF WORK
The following checks were undertaken for Euro Exim Bank across geographies of St Lucia, UK and
India:

  1. KEY FINDINGS

Detailed due diligence was undertaken on EEB, Euro Exim Bank Limited, Kaushik and Adarsh. The key findings are compiled as below.

4.1. OVERALL PROFILING OF EURO EXIM GROUP

4.1.1 DECLARED STRUCTURE

Open domain profiling and on ground intelligence did not identify for any comprehensive overview of Euro Exim Group’s corporate structure. Euro Exim Group’s website states that the group comprises an entity in Saint Lucia, a representative office in the UK, back office operations in India and satellite employees or offices globally.

  • The Saint Lucian entity is reportedly a “Class A” International Banking Financial Institution, with a license authorising business across the banking spectrum with third parties across industries and geographies globally.
  • The UK entity may only offer Letters of Credit and Standby Letters of Credit to corporate clients, Euro Exim Group’s website states. The UK entity Euro Exim Group does not provide regulated or controlled services or activities.
  • Since approximately June 2020, Euro Exim Group also works together with a third party back office service provider named TrdFin Support Services Pvt Ltd, which is registered in Chennai, India.

Based on the records filed by Euro Exim Bank (UK), the following group structure of Euro Exim Group can be drawn up:

Euro Exim Bank Limited’s latest financial statements up to 31 March 2023 as found in the UK corporate register lists no subsidiaries for the entity. However, searches have identified affiliate
companies as under:

  • Open domain checks identified 2 other affiliates of Euro Exim Group in UK (Detailed later under Section 4.3)
  • Checks across various proprietary and public databases several other companies with names similar to “Euro Exim” or Euro Exim Bank.6 This includes for example: Euro Exim Limited (Hong Kong); Euro Exim SA (Spain); Euro Exim, Export – Import Sro (Czechia); and Euro Exim Pte Ltd (Singapore).
    Euro Exim Group appears to be actively hiring globally, setting up satellite offices/agents. Open domain searches (as last conducted on July 27, 2024) identified over 140 remote jobs advertised by Euro Exim Group on job advertisement platform Himalayas, with opportunities across the world

including Nicaragua, Tanzania, Tonga and Northern Mariana Islands. Similar search also identified another 491 job advertisements for remote jobs globally advertised by Euro Exim Group on LinkedIn. For the purpose of the present diligence focus has been maintained on Euro Exim Group’s operations in Saint Lucia, UK and India. However, since Trdfin Support Services Private Limited (TSSPL) was noted to not be directly linked to the diligence at hand, the profiling as conducted for the company has been filed under Annexure 1, to maintain brevity of the report.

4.1.2 KEY EMPLOYEE DETAILS OF GROUP

Mapping of various open domain listings identified the names of the following key individuals9 who
are listed to be associated with Euro Exim Group:

NOTE: The history and corporate development of Euro Exim Group and the involvement of various
key management has been detailed under Annexure 2.

Based on the agreed scope detailed profiling has only been undertaken for Kaushik and Adarsh.

However, as evident in the later sections of the report, Sanjay’ role in Euro Exim Group and
other associated companies, some detailed checks have been undertaken in the report.


4.1.3 PROJECTS & CLIENTELE
No details of any active projects / clientele of the Euro Exim Group, noted during open domain
searches.
It is interesting to note that during open domain profiling, a cached version of the Euro Exim Group’s connected site was noted for the website tab of “issuance charges and recent transactions”. The page was noted to have been pulled down as on February 23, 2024 (s per forensic tool analysis) and in its active state listed for 451 deal transaction details24. The details of all such transactions are included under Annexure 3.

The pulling down of the page, raises credibility on the published information and also overall on the representations as made by Euro Exim Group, towards its expertise.

The transactions as mentioned have not been scrutinized in detail in this report for veracity of the listed claims as noted
on open domain

Further, open domain checks conducted in India, identified for multiple listings of projects as claimed to be backed by “Euro Exim Bank Limited” worldwide. However, no specific mention was made in such documents about the projects being backed from St Lucia, UK or other locations of Euro Exim Group. Therefore, they are broadly being considered at a group level and filed under Annexure 4.


4.1.4 FINANCIAL & VALUATIONS

  • No consolidated valuation (formal) noted for Euro Exim Group, as published by the group on
    any public domain.
  • As per information published by Euro Exim Group online (with no demarcation of branch /
    location based entity financials), the overall valuation as on April 2024, is claimed to be USD
    227 million. However, this is uncorroborated through any supporting documents and is a selfclaim.
    o It is interesting to note that in the latest media releases (as done by the company
    themselves) as noted for Euro Exim Bank, St Lucia in India, claims the company’s
    networth to be INR 1900 crores or roughly USD 230 million. This indicates that the
    Euro Group’s overall valuation is contradicted by themselves at various forums and
    there is no clarity on the numbers.
  • Of the associated entities, Euro Exim Bank St Lucia, has not filed for any financial reports /
    disclosures with the corporate registry of St Lucia. Nor has similar information being filed by
    the ultimate holding company of Euro Exim Bank St Lucia, Centurion Holding Limited and /
    or Arabian Star Holding, with authorities in UAE (refer Section 4.2.3).
  • Standalone financials ae available for Euro Exim Bank, UK as covered under Section 4.3.4.
    However, it is to be noted that Euro Exim Bank UK, is exempted from filing audited statements
    with the corporate registry of UK (owing to their nature of registration and size) and therefore
    such filings too are as claimed by the company.
    o The financials and networth as filed by Euro Exim Bank Limited (UK), for FY22/23
    listed only approx. USD 1 million in assets , as also claimed by open domain articles.

Further, a last 3 year trend also reflects for similar asset numbers and make it clear that the company is unable to offer such guarantees with its relatively small-sized net assets.


The above clearly show that revenue of Euro Exim Bank Limited (UK) do indicate ops in UK to be almost negligible. There is no indication of any large deals worked by the UK entity

  • Further, analysis into the asset and liabilities of Euro Exim Bank Limited (UK) also do not reflect for any capability to work on large projects as claimed by the company:

4.2. EURO EXIM BANK, ST LUCIA
4.2.1 INFORMATION AS OBTAINED THROUGH LOCAL REGISTRY

The following information was gathered from the details as gathered during on ground inquiries at St Lucia (with sources in known of the company’s registration details) and also data as collated during open domain checks:

The company’s logo displayed here has been obtained from publicly accessible website and has not undergone
independent verification. Logo is available at: https://euroeximbank.com/

INFORMATION PERTAINING TO TAXATION & LICENSES

  • Euro Exim Bank, St Lucia has an active banking license, granted on 4 July 2024. According to the St Lucia Financial Services Authority, EEB is a “Class A” Licensed International Bank, registered with license number IB/017 (A).
    o This license provides Euro Exim Group with the authorisation to conduct banking business with third parties across industries and geographies worldwide from Saint Lucia.

RESTRICTIONS
As per information gathered via various open domain postings, Euro Exim Bank, St Lucia is not a bank registered in Saint Lucia but is allowed to carry on international banking business operations from Saint Lucia.
4.2.2 INFORMATION NOTED IN OTHER COMPANY RELATED DOCUMENTS
Euro Exim Bank, St Lucia, finds several mentions (as a Related Party) in the Annual Reports as filed by Euro Exim Bank, UK with the UK Corporate Registry. Comparative evaluation of the Annual
Reports (of Euro Exim Bank, UK) as filed across the years of 2018 – 2023, mentions the following
details about the controlling structure of Euro Exim Bank, At Lucia

4.2.3 SEARCHES CONDUCTED IN UAE
(A) SEARCHES RELATED TO CENTURY HOLDING / HOLDINGS LIMITED

  • Searches identified an entity in the UAE corporate register named Century HoldingsLimited (IC20130998), which has been active since 15 July 2023 and is registered in the RAK International Corporate Register branch of the UAE register.
  • Further inquiries identified the said company to be owned by a foreign company by the same name (Century Holding Limited).
  • No details of this foreign company was noted during inquiries.
  • Searches also identified Century Holdings Limited (000002875), which was registered from 21 August 2019 to 20 August 2020 in the ADGM branch of the UAE register. Based on the last filed details of this company, the directors of the company were noted to be Nadeem Sikander Khan and Bal Krishen.
  • The company was noted to be 100% held by one Baqer Zainal Mohebi.
  • No details about the same was available during searches and inquiries.

No information about any company with the name of Century Holding Limited was
noted in UAE corporate records.


(B) OTHER SEARCHES


Local inquiries, followed by searches identified the following details as pertaining to associated
entities of Euro Exim Bank, St Lucia in UAE:

4.2.3 PROFILING OF SHARHOLDER – CENTURION HOLDING LIMITED
Keeping in the information as noted earlier at hand, detailed profiling was conducted of Centurion Holding Limited and the following information was obtained:

PROFILING OF ARABIAN STAR HOLDING, UAE
Keeping in mind that Arabian Star Holding, is the sole owner of Centurion Holding Limited, further profiling was conducted of the former. The details are as follows:

4.2.4 OTHER SEARCHES RELATED TO CENTURY HOLDINGS LIMITED
As per the information filed in the Annual Reports of Euro Exim Bank, UK, the parent company of Euro Exim Bank, St Lucia, Century Holdings Limited (UAE) also has controlling stake in two other entities.

  • Euro Exim Holdings (Seychelles)
  • Century Finance Limited (New Zealand)


While, the scope of the present assignment was restricted to St Lucia, UK and India, open domain searches were conducted on the above entities, keeping in mind that they are connected to St Lucia through the parent / controlling entity, as claimed in the official records of Euro Exim Bank, UK. However, no checks with local registries or detailed due diligence was conducted on the above companies, at this stage.

(A) EURO EXIM LIMITED – SEYCHELLES

  • Searches on Euro Exim Holdings or the words “Euro Exim” yielded no such entity in
    the Seychelles Government’s corporate register.
  • Further open domain checks were not able to identify an entity in corporate data
    aggregators.
  • Searches however, did identify open job advertisements for the Seychelles (Victoria
    branch) of Euro Exim Group, without referring to an exact corporate entity in the
    Seychelles. The same job posting through mentions the location as Seychelles, also is
    noted to claim that the proposed listing is open for work from any country of residence
    and also is a work from home role, with flexible working hours

(B) CENTURY FINANCE LIMITED (NEW ZEALAND)

  • Searches across the New Zealand Corporate Register identified a company named as Century Finance Limited, that is now known as Century Finance Holdings Limited.
    o The company was incorporated on March 9, 2011 as Century Finance and Trust
    Limited with the following details:
  • As per records filed with the company register of New Zealand (snapshot as below), the company changed its name on April 30, 2012 to Century Finance Limited. No other changes in constitution noted at this stage.
  • As per records filed with the company register of New Zealand (snapshot as below),
  • the company changed its name on October 12, 2012 to Century Financial Holdings Limited. No other changes in constitution noted at this stage.

 

  • The present holding structure of the company, as filed with the company register of New Zealand, is as follows:

NOTE: It is to be noted that as per searches conducted on open domain, on July 10, 2012 the Reserve
Bank of New Zealand had issued a warning / public notice against Century Finance, stating that,

  • The entity was not licensed or prudentially supervised by the Reserve Bank of New Zealand or
    any other New Zealand authority.
  • The entity was not licensed to provide banking services.
  • Also that, the use of the name ‘Century Bancorp’ is not permitted by the Reserve Bank of New Zealand.

The Financial Stability Report (2013) also lists that the Reserve Bank issued public notice regarding
unauthorized use of the word ‘bank’ (or any derivation or translation thereof) in breach of section 64
of the Act, in relation to Century Finance Limited, trading as ‘Century Bancorp in 2012.
The company soon after filed for the ‘change of name’ application as mentioned above. The timing for
such a change appears to be important in view of the above public notice.

(C) ROLE OF SANJAY THAKRAR
It is to be noted that Sanjay has been instrumental in the set of Euro Exim Bank Ltd UK and also Century Financial Holdings Limited, New Zealand.
o Sanjay is the alleged founder of Euro Exim Bank Limited.

o Notably, on his LinkedIn profile, Sanjay Thakrar stated that he joined Euro Exim Bank only in December 2021 as Head of Global Operations in Saint Lucia; he was promoted to Head of Global Strategy and Leadership in August 2022. He continues to hold this role to date, his LinkedIn profile states.
o He also remains the sole shareholder of Century Financial Holdings Limited, New Zealand.
o Sanjay also shares corporate interest with Kaushik in the UK-registered entity Century Finance Plc.
o As per data filed with the UK corporate register, Kaushik and Sanjay list the same residential address on records 7 Copse Wood Way, Northwood, Middlesex, HA6 2TP, UK
NOTE: While, the present scope of the report is restricted to cover Kaushik and Adarsh, open
domain searches as conducted briefly on Sanjay, highlighted certain key findings that are
pertinent for the case at hand. However, no detailed profiling of Sanjay has been done at this
stage, can be taken up at a later stage.
(a) Civil case – Century Financial Holdings Limited & Anor vs. Jamtoff Trading Limited & Ors
In this case, the England and Wales High Court ruled in October 2018 on a case between
Century Financial Holdings Limited & Anor vs Jamtoff Trading Limited & Ors (“Jamtoff”).
The background of the case is as follows.

  • In an August 2015 ruling and a supplement ruling of September 2015, a lower UK court
    ruled on a claim of fraudulent misrepresentation brought by the Russian company
    www.primecounselsolutions.com ; See also: https://www.linkedin.com/in/dr-sanjay-thakrar-717689b6/

    Jamtoff against Century Financial Holdings Limited, Sanjay Thakrar and Paresh Thakkar.
  • The case briefly described how Jamtoff entered into two contracts of sale with a company named Expopet Green International Limited (“Expopet”) to sell plastics. Paresh Thakkar was the commercial director of Expopet. Expopet received the consignments but did not pay Jamtoff for the delivery. According to the court, “the payment was meant to be by letters of credit issued by Century Financial Holdings Limited”. Sanjay was Century Financial Holdings Limited’s principal director and majority shareholder at the time. The first letter of credit was never issued; the second
    was issued but not paid out on.
  • Jamtoff argued it had been the victim of a fraud by Century Financial Holdings Limited and Sanjay, as well as Paresh Thakkar and Expopet. There had been two alleged fraudulent representations: the first was that Century Financial Holdings Limited was a bank, which it was not. The second was a representation of the first letter of credit having been issued when it had not been. When deciding on the case, the lower court judge had ruled that the three defendants “were all in it together”.
  • Jamtoff succeeded in a claim for fraudulent misrepresentation against all three defendants and was awarded damages of [presumably GBP] 795,060. In the supplemental ruling it was decided that both Century Financial Holdings Limited and Sanjay on the one hand, and Paresh Thakkar on the other hand, where each 50% liable. After the ruling, none of the damages had been paid to Jamtoff.
  • In 2017, Century Financial Holdings Limited and Thakrar started claims against Paresh Thakkar and Jamtoff, arguing that new evidence had undermined the original judgment. The England and Wales High Court ruled against the applicants.
  • The October 2018 ruling states that there was no permission to appeal by the three defendants as there was no real prospect of appeal.

    (b) Criminal case – Thakrar vs. Crown Prosecution Service
    This criminal case is related to the civil case discussed above. In this case, Sanjay was the claimant in a case against the UK prosecutor Crown Prosecution Service on which the UK Court of Appeal ruled in May 2019.
  • As previously mentioned, Sanjay was the claimant in this case. Previously, he had started criminal proceedings via private prosecution in 2016 against an unnamed number of individuals. In November 2017, the Director of the Public Prosecutions, steered by the UK Crown Prosecution Service, decided that it wanted to take over the
    conduct of the prosecution.
  • Sanjay was in the ruling described as a businessman who was the controlling party of the New Zealand company Century Finance Limited. The subject of the criminal case is the same as the October 2018 civil case involving Sanjay.
  • In June 2012, Expopet agreed to purchase from the Russian group Jamtoff two consignments of plastics to make containers for food and drink, with a total price of approximately [GBP] 800,000. Errors were made by Jamtoff’s staff in arranging delivery. Thus, the two consignments had been dispatched prior to confirmation that the
    relevant letters of credit had been issued and received. There was also no named consignee on the bills of lading. Expopet took delivery of the consignments without payment being made, and subsequently sold the consignments on without payment to Jamtoff. Jamtoff looked for Century Finance Limited for payment as issuer of the relevant letters of credit. Century Finance Limited was liable up to [GBP] 550,000 but could not pay. The letters of credit were rejected by Century Finance Limited.
  • As discussed above, Jamtoff commenced civil proceedings in the English and Wales High Court against Century. Jamtoff claimed that Sanjay and Paresh Thakkar – part of Expopet – had conspired from the outset to defraud Jamtoff by causing loss intentionally without ever intending payment of the two consignments. Alternatively, it was argued
    that Century Finance Limited had misrepresented itself as a bank and that the letters of credit had not been genuine. The English and Wales High Court delivered in August 2015, rejecting the claim of conspiracy but upholding the claim of fraudulent misrepresentation.
  • As previously mentioned, In November 2016, Sanjay started proceedings by private prosecution against Paresh Thakkar and Expopet. In November 2017, the Director of Public Prosecutions took over the conduct of prosecution, and stated that it did not wish to the proceedings to continue. Sanjay was aggrieved by the decision and sought permission to apply for judicial view, which was refused in April 2018. The claimant sought permission in appeal, which was refused on the ground that the Court of Appeal had no jurisdiction.
    NOTE: The corporate records and insolvency filings of Expopet Green Int. Limited, which is currently in compulsory liquidation, were reviewed.
    The records do state that the bankruptcy administrators are conducting an investigation into the company’s insolvency. No explicit links to Euro Exim, Sanjay or Century Financial Holdings Limited, Century Finance
    Limited was mentioned in the documents.
    4.2.5 SEARCHES CONDUCTED IN INDIA
    Very restrictive information is available on open domain linked sources pertaining to India about Euro
    Exim Bank, St Lucia. Scan of all available media identified the following details:
  • As per open domain checks, it was noted that Euro Exim Bank. St Lucia, has established direct contact line with the State Bank of India (SBI) and Union Bank of India.v
    o Further, open domain profiling also identified copies of advice of Bank Guarantee as issued by SBI that state, “”We confirm the authenticity and genuineness of this BG and hereby advise it to you without any risk / responsibility on our side“.

 

  • As per information published on open domain (linked back to sources related to Euro Exim Group and therefore to be considered as self claimed), Euro Exim Bank, St Lucia as per its last filings of FY 23 – 24 has a networth of INR 1900 crores – however, no documents have been provided by the said source in support of the same:


    4.3. EURO EXIM BANK LIMITED, UK

  • Euro Exim Bank Limited was incorporated on 7 February 2011 with company number 07520196. Euro
    Exim Bank Limited’s registered activity as found in the UK corporate register is that of financial
    intermediation
    .
    Euro Exim Bank Limited was formerly registered under the following trade names, UK corporate
    records state:
  • Galaxy Services (UK) Limited (7 February 2011 to 20 February 2015)
  • Galaxy EU Finance Limited (20 February 2015 to 25 April 2015)
    Searches in UK corporate records identified two entities that appear to be affiliates of Euro Exim Bank
    Limited.
  • Euro Exim Holdings Limited, registered on the same Oaks Court address as Euro. Records
    filed with the UK corporate registry lists Kaushik as the sole shareholder of the company.
  • Galaxy EU Finance Limited – this entity was previously registered as Euro Exim Bank
    Limited (15 April 2015 to 25 April 2015) and Sanjay was the company’s sole shareholder.
    The entity dissolved on 27 September 2016.
    4.3.1. CORPORATE RECORD MAPPING
    The following information has been mapped from the records as filed by the company with the corporate registries of UK and also via articles / postings on open domain.
    NAME EURO EXIM BANK LIMITED
  • 4.3.2. DIRECTORSHIP
    The UK corporate register lists the following former and current directors for Euro Exim Bank Limited.
    Some have been reappointed, as listed in the register and shown in the table below.

It is to be noted that in UK, reappointments sometimes occur as the result of a company changing its
registered office services provider.

4.3.3. SHAREHOLDING PATTERN
As per records filed with UK Company Register, the following shareholding pattern was noted (as last
checked on July 26, 2024) as reflecting the current status.


It is to be noted that all the social media profiles as accessed above, have been accessed for the publicly available
information. Considering the restrictive legalities involved, no such profile searches have been conducted. No attempt has
been made to access any information that would be considered to be a breach of privacy and in violation of existing laws
of the land.

Further, the following was noted to be the past shareholding of the Euro Exim Bank Limited:

POINTERS OF NOTE:

  • Review of Euro Exim Bank Limited’s confirmation statements show that the company has
    changed ownership several times.
  • From 2011 to 2014, Bishal Sapkota was the sole owner of Euro – he sold the company to Sanjay
    Thakrar in January 2014.
    o Bishal Sapkota’s background is unclear, although he formerly held a directorship at a
    company in the UK operating a restaurant (2005 to 2012).55
    o Targeted searches on Bishal Sapkota’s name and Euro Exim Bank Limited’s former
    trade name Galaxy yielded no results except for mentions in corporate data aggregators
    and the database of the UK Financial Conduct Authority.
  • Sanjay changed the entity’s name from Galaxy to Euro Exim Bank Limited and transferred all
    ownership onto Euro Exim Bank Limited (Gambia) five months later in May 2015.
    o Sanjay is the alleged founder of Euro Exim Bank Limited.

    o Notably, on his LinkedIn profile, Sanjay Thakrar stated that he joined Euro only in
    December 2021 as Head of Global Operations in Saint Lucia; he was promoted to Head
    of Global Strategy and Leadership in August 2022. He continues to hold this role to
    date, his LinkedIn profile states.
  • From February 2017 to October 2021, Kaushik was holding a stake Euro Exim Bank Limited
    together with Euro Exim Group entities.
    o Since October 2021, Kaushik has been the company’s sole shareholder.
    o Kaushik has been the chair and administration manager of Euro Exim Group since
    September 2015, as per his LinkedIn profile.
  • Checks for the names of the remaining directors on international watchlists yielded no results.
  • Targeted red flag checks in English on their names yielded no results for Kaushik and the Euro
    Exim Group entities.
  • Due to the common names of Sanjay and Bishal Sapkota, these searches yielded several adverse
    media reports for their names. However, since the same could not be corroborated as
    conclusively linked to them (owing to lack of identifiers in such articles) those are being
    exempted from the scope of this report.
    4.3.4. KEY FINANCIAL DETAILS
    The following details have been collated from the information filed by Euro Exim Bank Limited with
    UK corporate records. Further, it is noted that the filed financial statements are limited in nature due
    to the small size of the company’s operations.
    NOTE: No detailed financial evaluation or audit of the financial records has been done under this
    report. This section provides a summary of the key financial records (profit and loss) as made public

Further details on the assets and liabilities are limited, listing only a breakdown in for example
intangible and tangible assets, bank loans, trade creditors and taxation and social security payments.
4.3.5. RELATED PARTIES
Profiling of Euro Exim Bank Limited through open domain and filings of UK corporate records
identifies the following as related parties59 of the company:

  • Premium Brands Distributors Limited, England
  • Currency Square Limited, England
  • Euro Exim Holding Limited, England
  • Exchange Legal Limited, England
  • Euro Exim Holdings Limited, Seychelles (as controlled by Century Holding Limited)
  • Euro Exim Bank Limited, Saint Lucia (as controlled by Century Holding Limited)
    59 No detailed assessment of the companies have been done at this stage. The report does not claim for the list to be
    exhaustive.
    38
  • Century Financial Limited, New Zealand (as controlled by Century Holding Limited)
    4.3.6. REGISTERED ADDRESS
    Euro Exim Bank Limited is currently registered on the following address in the UK:
  • Suite 1E, One Oaks Court, Warwick Road, Borehamwood, Hertfordshire, WD6 1GS, UK (16
    October 2023 to date)
    Searches show that over 135 other companies are registered on this address, indicating that a corporate
    services provider is operating from this address. Euro Exim Bank Limited was registered on several
    other addresses after incorporation:
  • Flat 9 Chesterford House, Portway Gardens, Woolwich, London, SE18 4PF, UK (incorporation up
    to 3 June 2013)
  • 112 Adams Drive, Willesborough, Ashford, Kent, TN24 0FW, UK (3 June 2013 up to 16 April
    2014)
  • 104 Viglen House, Alperton Lane, Wembley, Middlesex, HA0 1HD, UK (16 April 2014 up to 3
    November 2014)
  • Suite 2, 4 and 6, Elstree House, Elstree Way, Borehamwood, Hertfordshire, WD6 1SD, UK (3
    November 2014 up to 21 November 2014)
  • Suite 4, 6 and 8, Elstree House, Elstree Way, Borehamwood, Hertfordshire, WD6 1SD, UK (21
    November 2014 up to 30 September 2015)
  • Suite 1C, One Oaks Court, 1 Warwick Road, Borehamwood, Hertfordshire, WD6 1SD, UK (30
    September 2015 to 16 October 2023)
    Two of these addresses are residential addresses, namely the Chesterford House address and the Adams
    Drive address.
  • The property on the latter address, the Adams Drive address, is owned by Bishal Sapkota, as
    UK Land Registers information. He acquired the property for GBP 200,000 on June 22, 2012.
    Bishal Sapkota is the founder and a former director and shareholder of Euro Exim Bank
    Limited, as mentioned earlier in the report.

    The remaining addresses relate to corporate services offices. These include the Viglen House address,
    the Elstree House address and the One Oaks Court address.

4.4. KEY INDIVIDUAL MAPPING

4.4.1. KAUSHIK AMRITLAL PUNJANI

Kaushik is the current sole shareholder and a director of Euro Exim Bank Limited. He is also appointed as Euro Exim Group’s CEO.

The following profile of Kaushik been tabulated based on the information available on open domain, proprietary database check and as identified during diligence, as gathered till date.

The individual’s photograph as displayed here has been obtained from publicly accessible website and has not undergone

It is to be noted that the education information as mapped is based on investigative research. No corroboration with the
listed Education Institutions has been done. Source: https://www.linkedin.com/in/kaushik-punjani-6678351/ It is to be noted that all the professional media profiles as accessed above, have been accessed for the publicly available
information. Considering the restrictive legalities involved, no such profile searches have been conducted. No attempt has
been made to access any information that would be considered to be a breach of privacy and in violation of existing laws
of the land.
It is to be noted that all the social media profiles as accessed above, have been accessed for the publicly available
information. Considering the restrictive legalities involved, no such profile searches have been conducted. No attempt has been made to access any information that would be considered to be a breach of privacy and in violation of existing laws of the land.


PERSONAL DETAILS

  • Kaushik is a British national resident in England, UK corporate records state. The same records
    state that he was born in October 1951.
  • Searches in a paid database comprising UK birth certificates, marriage certificates and electoral
    roll data yielded no birth or marriage certificates for his name and year of birth. This database is
    not complete. However, it may indicate that Kaushik obtained his British nationality at a later stage
    in his life.
    PROPERTY DETAILS71
    Searches in UK corporate records, a paid database comprising UK birth certificates, marriage
    certificates and electoral roll data and a corporate and electoral roll data aggregator for the UK
    identified the following residential addresses for Kaushik:
  • 200 Empire Road, Perivale, Greenford, Middlesex, UB6 7EE, UK (2002, 2011 to 2013)
    UK land register records list Hrushi Kaushik Punjani and Pinal Gansham Punjani as the registered
    owners of this property’s freehold. The same records state that they also reside on the below
    Torcross Road address. They have been registered as the property’s owners since 25 June 2014.
    The property is encumbered with a charge in favour of Santander UK Plc. No acquisition price has
    been recorded for the property. Streetview imagery shows a terraced house in the town of Perivale.
  • 50 Torcross Road, Ruislip, HA4 0TD, UK (2016 to 2024)
    UK land register records list Hrushi Kaushik Punjani and Pinal Gansham Punjani as the owners of
    the Torcross Road property’s freehold. They acquired the property on 23 March 2015 for GBP
    525,000. The property is encumbered with a mortgage in favour of Clydesdale Bank Plc. Streetview
    imagery shows a semi-detached property in the suburbs of London. Ruislip is commonly known as
    an area where many Southeast Asian expats live.
  • 2A St George Wharf, SW8 2LE, London, UK (no dates)
    70 find-and-update.company-information.service.gov.uk 71 No detailed asset tracing has been conducted on the individual under this report.
    44
    UK land register records state that the UK property developer St George South London Limited
    has been the freeholder of this property since 25 July 1995. No acquisition price has been disclosed
    for the freehold. UK land register records list a British Virgin Islands (BVI) company as the owner
    of the leasehold of this property. This company is named Passonate Corporation and is registered
    on the address Akara Bidg, 24 De Castro Street, Wickhams Bay, 1 Road Town, Tortola, BVI. The
    company acquired the property on 5 August 2015 for an undisclosed price. No charges are listed
    for the property in UK land records, indicating that it was acquired cash (without a mortgage).
    Streetview imagery shows a terraced house in London.
    FAMILY OVERVIEW
    Searches in a corporate and electoral roll data aggregator covering the UK found the following
    individuals with the same last name living on the same addresses as Kaushik. Therefore the family
    relationship is assumed, based on surname / family name match:
  • On the Empire Road address, the following occupants were listed for various periods in the 2010s
    and 2020s: Hrushi Punjani, Jesal Punjani, Nalini Punjani and Pinal Punjani.
  • On the Torcross address, also Hrushi Punjani and Pinal Punjani were listed as former residents
    from 2016 to 2024.
    o Hrushi Punjani is the global head of sales at Euro Exim Group. He joined the company in
    February 2020.
    o Jesal Punjani has been working as a Senior Manager and Senior Executive at Plenitude
    Consulting since 2014, where he focuses on financial crime compliance projects at financial
    institutions.
    o No current positions noted for Pinal Punjani and Nalini Punjani, during open domain
    checks.

    CAREER & CORPORATE AFFILIATIONS
  • No reference for early career noted for Kaushik.
  • The first known position for Kaushik is that of freelance with Sage Software Consultant from 2006
    to 2015.
  • In 2015, Kaushik joined Euro Exim group as Administration Manager and Chair. Both roles he
    holds to date.
    o Media reporting on Euro Exim group also refers to Kaushik as the company’s founder and
    CEO
    .
  • As per UK corporate records, Kaushik has also described himself as consultant and businessman.
  • UK corporate records also list various corporate interests that have been held by Punjani in the UK
    between 2015 to date, as mentioned below:

Century Finance Plc’s trade name has been mentioned on international watchlists. None of the other
corporate interests listed in the above table are mentioned on international watchlists. Targeted red flag
checks in English on the entities yielded no other adverse results for the entities’ names, except for
Century Finance Plc’s trade name.
Further details are mentioned as below (except Euro Exim Bank Limited):
(A) EURO EXIM HOLDINGS LIMITED – Euro Exim Bank Holdings Limited was
incorporated on 17 November 2017. Its sole director and sole shareholder since
incorporation has been Kaushik. Euro Exim Bank Holdings Limited does not appear to
be actively trading. The entity’s micro company accounts up to 30 November 2022 list
total liabilities of GBP 907 and nil employees for the entity.
(B) EEB CONSULTANTS LIMITED –EEB Consultants Limited was incorporated on
11 July 2017. The company is registered on the same Oaks Court address as Euro and
– viewing its name – appears to be Euro Exim Group’s consultancy / representative
branch. Its sole director and sole shareholder since incorporation has been Kaushik.
EEB Consultants Limited does not appear to be actively trading. The entity’s latest
micro company accounts up to 31 December 2023 list net liabilities of GBP 74,791 for
both the financial years 2022 and 2023.
(C) PREMIUM BRAND DISTRIBUTORS LIMITED – Premium Brands Distributors
Limited was founded on 16 June 2003. The company was formerly named Golden Valet
Services Limited (3 September 2003 up to 2 July 2004) and Sterling Three Limited (16
June 2003 to 3 September 2003). The company had six other officers, including Sanjay.
According to the company’s latest updated confirmation statements dated 19 September
2018, Kaushik was its sole shareholder. The latest available financial statements for
Premium Brands Distributors Limited covered the year up to 31 July 2022. They listed
net assets of GBP 12,414 for the company from which the majority comprised current
assets (GBP 20,188). The company does not appear to have a website.
(D) EXPERT COMPOUNDING LIMITED – Expert Compounding Limited was founded
on 19 January 2017 and dissolved on 1 March 2022. The company had only one other
director next to Kaushik, namely the Canadian national Tonjaka (Tonja) Ewart
Hinkson. Tonjaka Hinkson offers fiduciary services and company structuring services
in Saint Lucia. Kaushik was the company’s sole shareholder since incorporation.
Expert Compounding Limited does not appear to have traded. The latest available
dormant accounts for Expert Compounding Limited up to 31 January 2018 list GBP
100 in net assets. The company does not appear to have a website.
(E) CENTURY FINANCE PLC – Century Finance Plc was founded on 12 December
2011 and dissolved on 22 August 2023. The company had 10 other officers next to
Kaushik, including Hrushi Punjani, Sanjay and various other individuals with the last
name Thakrar. The company’s latest confirmation statement up to 31 July 2015 lists
Premium Brand Distributors Limited as its sole shareholder. The latest available
dormant accounts up to 31 January 2021 for Century Finance Plc list net assets of GBP
19,612. Nearly all its assets were debtors (GBP 20,000).
For the trade names Century Finance, Century Finance Services Limited and Century
Finance UK Limited, a website named www.centuryfinance.loan was reported by the
UK financial conduct authority in October 2017 as a company cloning another firm,
Quick Loans Limited, which was located in Barnsley, South Yorkshire, UK. An
archived version of the website does not list further details on its address, corporate
entity or management. Research did not identify any other UK entities named Century
See also: pleasebeinformed.com

Finance Limited or Century Finance UK Limited in the UK corporate register. It is
unclear of this is the same entity as Century Finance Plc.
Searches in corporate data aggregators yielded one corporate interest in Estonia for Kaushik’s full
name, for the date of birth of 20 October 1951. According to this reference, Kaushik was a member of
the board of the now dissolved company EEB Cryptocurrency Trading OU from 13 June 2019 to 1
October 2021. Viewing the name of the Estonian entity – which is similar to Kaushik’s corporate
interest EEB Consultants Limited, it is likely that it will be linked to Euro Exim Bank Limited.
However, keeping in mind the scope of the present report, the same was not delved in detail at this stage.
4.4.2. ADARSH RAJNIKANT SHAH
Adarsh is a present director of Euro Exim Bank Limited.
The following profile has been tabulated based on the information available on open domain,
proprietary database check and as identified during diligence, as obtained till date.

We did identify a UK-registered entity Century Financial Services Limited, which is unrelated to Punjani. 85 The date of birth mapped is as per the UK Company Register and has not been independently verified with relevant
governmental authorities under this report.


PERSONAL DETAILS

  • Adarsh is British national resident in Kenya, UK corporate records state. The same records state
    that he was born in March 1983. No hits matching the exact date of birth was noted for Adarsh.
  • Searches in a paid database comprising UK birth certificates, marriage certificates and electoral
    roll data yielded a copy of original birth records for the name Adarsh Rajnikant Shah, who was
    born in either April, May or June of 1983 (no dates are provided in the copies). The individual
    was born in Hammersmith, a London neighbourhood in the UK. It is therefore likely that the
    record pertains to Adarsh, viewing the full name and year of birth is matching.
  • In an article covering Adarsh’s background, it is mentioned that he grew up in Kenya, then
    moved to the US and returned to Kenya “a few years before” 2014, likely 2012.
  • Adarsh’s LinkedIn profile states that he currently resides in the UK.

    PROPERTY DETAILS:

    Searches in UK corporate records, a paid database comprising UK birth certificates, marriage
    certificates and electoral roll data and a corporate and electoral roll data aggregator for the UK
    identified the following residential addresses for Adarsh:
  • Orchard House, Folly Lane, Bramham, Wetherby, LS23 6RZ, UK (no dates)
    Streetview imagery shows a detached property in a rural area of the UK. The property is currently
    owned by a third party. This may indicate that Adarsh rented this property rather than owned.
    No other residential address noted for Adarsh as matched with his full name.
    88 It is to be noted that all the professional media profiles as accessed above, have been accessed for the publicly available
    information. Considering the restrictive legalities involved, no such profile searches have been conducted. No attempt has
    been made to access any information that would be considered to be a breach of privacy and in violation of existing laws
    of the land.

    FAMILY:
    Limited information is available about Adarsh’s family in online databases and repositories. A media
    article mentions Adarsh’s father to be named a Raju Shah.
    As per the article, Raju Shah is a chartered accountant and reportedly holds an accounting qualification
    (ACA) in the UK.
    No details of any other family member of Adarsh was noted during searches.
    CAREER & CORPORATE AFFILIATIONS
    Limited information identified as pertaining to Adarsh’s career, during open domain searches. Searches
    identified an October 2014 article of How We Made It In Africa discussing Adarsh’s background, which
    report has been supplemented with Adarsh’s LinkedIn profile to create the following career profile:
  • The first known position is that of Adarsh having worked for seven years at the Bank of
    America in Philadelphia, US, from 2005 to 2012. At the bank he reportedly worked towards
    a vice president role in a team that managed a loan portfolio of USD 180 billion. After a short
    visit to Kenya, Adarsh decided to move there, reportedly contemplating that “[he] can be a big
    fish in a small pond and make a more meaningful impact on people’s lives”.
  • According to the 2014 How We Made It in Africa article, in Kenya, Adarsh started working at
    his father’s furniture company, Designwear, where he introduced new divisions focusing on
    road construction, solar street lightning and distribution of health supplies. Designwear was
    founded by Adarsh’s father Raju Shah in 1991. Designwear has two locations in Nairobi.
    92 directory.africa-business.com ; Searches in the register of the ICAEW yielded various individuals named Raj Shah who
    hold a chartered accountant license. Due to limited identifiers being available for Shah’s father, we were unable to confirm
    if any of these individuals is Raju Shah, Shah’s father.
  • We note that Shah’s LinkedIn profile shows a slightly different professional background for
    him compared to what was mentioned in the How We Made It in Africa article. According to
    his profile, after leaving Bank of America in a vice president role, he started working as the
    Chief Human Resources Officer of a human resources and legal consultancy company named
    Waterstone Consultancy Services in Kenya. He continues to hold this position to date. Adarsh
    has a second role in parallel to this: since January 2019, Adarsh has held increasingly senior
    positions at Koko Networks. He currently is appointed in the company’s “senior leadership”,
    his LinkedIn profile states. Koko Networks is a “venture-backed technology company operating
    in East Africa and India.” The company is building a network of sales points in local corner
    stores for goods and services delivered by other major suppliers.
  • On his LinkedIn profile, Adarsh also mentions the company Designwear; however, does not list
    his role or tenure at the firm. On another professional networking site he mentions being
    Designwear’s CEO.
  • Shah has not mentioned any links to Euro on his professional networking profiles. Beyond
    corporate records, no reference noted for Adarsh’s roles and responsibilities at Euro Exim
    Group.
  • Open domain searches also identified a network organization membership for Adarsh. Adarsh
    was appointed as a board member of Kenya’s Entrepreneurs Organisation (EO Kenya) from
    July 2015 to June 2022, his LinkedIn profile states. Open domain searches also identified a
    video on EO Kenya which lists him as member Engagement Chair in 2021.
  • Searches in UK corporate records yielded the following former and current corporate interests
    for Adarsh’s full name:

Searches in corporate data aggregators yielded no corporate interests beyond the UK for

Adarsh’s full name / complete identifiers (excluding partial matches).

Euro, Red Dot Tours Limited and Currency Square London Limited have not been mentioned

on international watchlists.

Targeted red flag checks in English on the entities yielded no issues of concern. Details as

below (except Euro Exim Bank Limited):

A. RED DOT TOURS LIMITED – Red Dot Tours Limited was incorporated on 5

June 2000. The company has had twelve officers in total, from which four are

currently appointed. It appears that, on 21 May 2024, one shareholder sold part of

Red Dot Tours Limited’s shares: on that date, The Fabulous Getaway (Private)

Limited sold allof its ordinary and ordinary A shares to Dinesh de Zoysa, who is the

current entity’s minority shareholder together with the majority shareholder

Priyanjith Weerasooria. Both Dinesh de Zoysa and Priyanjith Weerasooria are

appointed in (non)-executive roles at Finco Holdings, a diversified Sri Lankan

corporate group. The latest available financial statements of Red Dot Tours

Limited up to 31 March 2023 lists net assets of GBP 29,326.

Searches in the public domain found that Red Dot Tours is a Sri Lankan holidays’

specialist.

B. CURRENCY SQAURE LONDON LIMITED – Currency Square London

Limited was founded on 17 October 2022. Nex to Adarsh, the company’s other

director is the accountant Milan Chandravadan Shah, as per UK corporate records.

Since incorporation, Adarsh has been the company’s sole shareholder. The company

does not appear to be actively trading. Currency Square London Limited’s micro

accounts up to 31 October 2023 shows net liabilities of GBP 898.

Searches in the public domain found that Currency Square London offers certified

chartered accountants services. Milan Shah is a UK-based accountant who is

currently also the director of Mirage Accountants Limited in Harrow, UK.

 103 www.reddottours.com 104 currencysquarelondon.com 105 www.linkedin.com

54

4.5. OPEN DOMAIN CHECKS

4.5.1. SANCTIONS CHECKS

A. STANDING WITH UK AUTHORITIES – No major issues of concern relating to EEB, TSSPL,

Euro Exim Bank Limited, Kaushik’s and Adarsh’s standing with UK authorities, identified during

open domain and database checks.

B. POLITICAL CONNECTION CHECKS – No political appointments or connections identified

for EEB, TSSPL, Euro Exim Bank Limited, Kaushik and Adarsh identified in UK, St Lucia and

India, during open domain and database checks.

C. FINANCIAL STANDING – No defaults as pertaining to financial standing identified for EEB,

TSSPL, Euro Exim Bank Limited, Kaushik and Adarsh identified in UK, St Lucia and India,

during open domain and database checks.

D. BANKRUPTCY CHECKS – No mention of EEB, TSSPL, Euro Exim Bank Limited, Kaushik

and Adarsh identified in UK, St Lucia and India, mentioned in any bankruptcy database during

open domain and database checks.

E. REGULATORY STANDING (UK) – Searches on UK regulators’ sites for Euro Exim Bank

Limited’s name broadly confirmed the licensing and memberships of Euro Exim Bank Limited as

described on its website. No punitive regulatory measures identified for EEB, TSSPL, Euro Exim

Bank Limited, Kaushik and Adarsh, during open domain and database checks.

F. REGULATORY DATABASE CHECKS – Checks were conducted across websites of

regulatory bodies in the UK for EEB, TSSPL, Euro Exim Bank Limited, Kaushik and Adarsh.

These searches yielded no punitive measures for all mentioned entities. Searches included but were

not limited to the websites of the UK Serious Fraud Office, the UK Disqualified Directors list, the

UK Health and Safety Executive Body, the UK Competition and Markets Authority and the UK

Financial Conduct Authority.

G. FINANCIAL CONDUCT AUTHORITY (UK) – Euro Exim Bank Limited (reference number 544538) was registered with the UK Financial Conduct Authority. Euro Exim bank Limited was registered as a payment services provider from an unknown date up to 17 February 2017. As contact details, the company provides the Oaks Court address and email address: Sanjay.thakra@euroeximbank.com.

Euro Exim Bank Limited was registered under four trading names with the Financial Conduct

Authority. The entity was registered as trading as Nepal Remit (5 August 2011, no end date),

Galaxy Services (UK) Limited (from 31 March 2011 up to 26 February 2015), Galaxy EU Finance

Limited (26 February 2015 up to 27 April 2015) and Euro Exim Bank Limited (27 April 2015, no

end date). Neither Adarsh nor Kaushik has been listed in the Financial Conduct Authority’s register

as a finance professional.

H. FINANCIAL SERVICES REGULATORY AUTHORITY (SAINT LUCIA) – Euro Exim

Group’s website states that the company holds a “Class A” international banking license from

Financial Services Regulatory Authority (FSRA) of Saint Lucia. This has been confirmed on

the website of the FSRA of Saint Lucia. This license provides EEB with the authorisation to

conduct business with third parties across industries and geographies worldwide from Saint

Lucia.109

I. CARIBBEAN ASSOCIATION OF BANKS – Euro Exim Group’s website states that the bank

is an associate member of the international trade organisation Caribbean Association of Banks Inc. EEB has been listed as a member of the Caribbean Association of Banks Inc on the organisation’s website.

J. INTERNATIONAL CHAMBER OF COMMERCE – Euro Exim Group’s website states that

the company is a member of the International Chamber of Commerce. However searches did

not identify for any reference of Euro Exim Group on the website of the International Chamber of

Commerce listing its members.

K. GLOBAL WATCHLISTS & SANCTIONS SCREENING114 – Searches were conducted within

the records of various global compliance databases which includes coverage of restricted party June 26, 2024. listings, including data from the OSFI Anti-Terrorism List, the World Bank Listing of Ineligible Firms, the Interpol and FBI Watch Lists, FinCEN Listings various sanctions listings, and other relevant data sources were searched for Euro Exim Bank Limited, EEB, TSSPL, Kaushik and Adarsh TSSPL, Kaushik and Adarsh. No hits were noted.

L. OFFSHORE LEAKS DATABASES – Searches in the online domain also included databases which publish offshore leaks and company data, including the Offshore Leaks Database maintained by The International Consortium of Investigative Journalists, The Investigative Dashboard which is operated by the Organized Crime and Corruption Reporting Project, the databases operated by the OpenCorporates Trust, as well as WikiLeaks. These searches yielded no relevant results for Euro Exim Bank Limited, EEB, Kaushik and Adarsh.

4.5.2 MEDIA PROFILING

Euro Exim Group names (along with Adarsh and Kaushik) were searched across proprietary news aggregators covering investigative, national, regional and business newspapers globally. Further checks were also conducted across online news outlets, finance news outlets, online blogs and social media.

Euro Exim Group noted have a relatively large profile compared to the size of Euro Exim Bank Limited’s operations (as detailed earlier in the report). The company is often mentioned in international finance news outlets, Indian lifestyle magazines, news outlets covering the European Union, employers’ review sites and various blogs and social media. However, most of these media reports have been published in lesser-known news sites and appear to be generated or commissioned by Euro

Exim Group itself, as it is explaining its operations in a positive light as in an advertisement. As

such, most media reporting on the company appears to have been self-generated.

To a lesser extent, we identified independently written articles and notifications on Euro Exim Group.

References in independent media was often neutral or factual in tone. For example, in February 2019

and December 2020, the finance news outlets Global Banking News and American Banker reported on

Euro Exim Group as it used a digital tokens program named XRP for cross-border payments, replacing

SWIFT payments, which was considered a new way of payment processing.117 Also many other

blockchain and cryptocurrency focused news outlets reported on this.118 Another example is that the

firm’s bid for the divestment of state-owned insurance enterprises in Sri Lanka was short-listed in April

2024. Euro Exim Group was also present at business networking events in 2024.120

Hits noted towards adverse media, covered under Section 4.6.3

4.5.3. ADVERSE MEDIA CHECKS121

Open domain and database checks were conducted to identify any adverse media/news postings

regarding EEB, Euro Exim Bank Limited, TSSPL, Kaushik and Adarsh. No hits were noted for TSSPL,

Kaushik and Adarsh, however, the following hits were noted pertaining to EEB (as last checked on

July 25, 2024):

Reporting of Hiring Scam

The Ghanan accountant Kingsley Tawiah Lartey published in February 2024 an article on LinkedIn

covering an alleged hiring scam of Euro Exim Group.122 According to the article, the recruitment scam

targeted professionals on LinkedIn with enticing job opportunities. An HR representative named Akila

conducted interviews via WhatsApp with prospect candidates and subsequently requested the

candidates to share personal details, including bank details. The writer does not clearly state if these

personal details were misused but advised readers to exercise caution when sharing details. Similar

concerns were shared on Reddit by the users Comfortable_Dog_3014 and Tayro2.123 It is unclear from

the warnings whether Euro Exim Group is being impersonated by another party.

 117 “How will SEC complaint affect banks’ relationships with Ripple?”, American Banker, 30 December 2020 ; “Euro Exim

Bank integrates xRapid”, Global Banking News, 4 February 2019 ; See also: “INDUSTRY SNAPSHOT; GIS000329

Cryptocurrency and Exchanges 18 May 2020”, Acquisdata Global Industry Snapshot, 23 May 2020 “LIBF Expo 2024: Connecting Worldwide Businesses, Creating Opportunities”, Free Press Journal, 17 January 2024 121 Please note that detailed adverse media checks were not conducted in local language for NHIPL at this stage; however,

Expose by RTV:

In July 2024, the India-focused news outlet RTV Live reported on the same bank guarantee scam as Telangana Today.

According to the article, Euro Exim Group had facilitated bank guarantees of INR 481 crore (approx. GBP 44.5 million) for 31 projects in the Indian state Andhra Pradesh. RTV Live considered this to be an impropriety, as Euro’s financial statements of FY22/23 listed only approx. GBP 1 million in assets (see also Financial statements). It argued that Euro Exim Bank Lmited had been unable to offer such guarantees with its relatively small-sized net assets.

Several employees of the Indian “power department” – namely “Vijayanand, Santhosh Rao, and Padma Janardhan Reddy” – allegedly approved Euro’s “fake” bank guarantees, RTV Live stated. RTV Live ported that also companies linked to Ponguleti Srinivas Reddy were involved in submitting “fraudulent bank guarantees” in Andhra Pradesh. Moreover, several Indian state government institutions approved or accepted the guarantees.

The RTV Live article indicates that Euro acted as the guarantor itself, therefore should have had the financial strength to offer guarantees. Lastly, RTV Live stated that Euro was found to be in breach of RBI regulations.

Karti Chidambaram writes to SBI Chairman

• A recent article by RTV has highlighted serious concerns about fraudulent bank guarantees allegedly submitted to Megha Engineering Company and companies associated with Minister Ponguleti Srinivasa Reddy. In response to these revelations, Congress MP Karti Chidambaram has formally requested an explanation from the State Bank of India regarding their acceptance of Euro Exim Bank guarantees related to these fraudulent claims.

• In a letter addressed to the SBI Chairman, Karti Chidambaram has asked for clarification on whether any letters dated July 19, 2023, and May 5, 2022, were issued by State Bank of India concerning these Euro Exim Bank guarantees. He has urged SBI to conduct a thorough inquiry into the matter and provide a prompt response to address these concerns.

• Karti Chidambaram has emphasized the need for immediate clarification from State Bank of India on this issue.

• Snapshot of letter as below:

Raghava Constructions (India) Private Limited was part of the EEB scam
As per the news article dated July 22, 2024, Maheshwar Reddy, BJP Legislative Party leader alleged
that Raghava Constructions (India) Private Limited, a company of Revenue Minister Ponguleti Srinivas
Reddy was part of the Euro Exim Bank scam. He stated that the company violated RBI guidelines to
get a bank guarantee of Rs.400 crore. He alleged that the company submitted fake documents for taking
bank loans. He also mentioned that the Euro Exim Bank was not in the list of banks in the State, hence
how two nationalised banks gave guarantee to the firm must also be probed.


EEB issued legal notice to RTV Telugu over defamatory broadcast
As per the article date July 18, 2024, EEB has issued a legal notice to Ravi Prakash, Editor and
Publisher of RTV Telugu, a popular Telugu-language news channel. The notice demands a public
apology and removal of allegedly defamatory content aired on July 14, 2024.
Following are key allegations and demands mentioned:

  • Defamatory Statements: RTV Telugu accused Euro Exim Bank of fraud and issuing fake
    bank guarantees.
  • Financial Status Misrepresentation: RTV Telugu misrepresented the bank’s net worth as INR
    8 crore; actual net worth exceeds INR 1900 crore as per financial records for the fiscal year
    2023-24.
  • Accusations of Illicit Fee Collection: RTV Telugu implied the bank collected fees through
    illicit methods like ‘hawala’, however, the bank clarifies fees are collected legally.
  • Demands: EEB demands a public apology, removal of defamatory content within 15 days, or
    faces a defamation lawsuit seeking INR 100 crore in damages.
    128https://medianoise.in/euro-exim-bank-issues-legal-notice-to-rtv-telugu-over-defamatory-broadcast-seeks-apology-rs 100-crore-in-damages/, https://sarkarihelpline.com/euro-exim-bank-files-one-hundred-crore-defamation-lawsuit-against rtv/
    61
    Critical pointers noted during Ripple signing up with EEB
    As per article dated January 29, 2019, the following were mentioned about EEB:
  • EEB is an offshore bank registered in a tax haven, not a London-based bank, despite its
    registered London office operating as a small company in the UK.
  • Additionally, the bank’s website explicitly states that it does not offer services to individuals or
    entities in Saint Lucia, indicating that Euro Exim Bank should not be considered a bank based
    in Saint Lucia.
  • EEB’s registration with the U.K.’s Financial Conduct Authority (FCA) was terminated in
    February 2017, according to information on the FCA website. As a result, the bank is currently
    not authorized to offer regulated financial products and services in the U.K.
  • EEB does not hold a banking license in any country within the European Economic Area
    (EEA), which includes the EU member states, Norway, Iceland, and Liechtenstein. While it


    may be regulated by authorities in Saint Lucia, this regulation does not extend to making it a
    licensed bank in the U.K. or Europe. In order to operate an onshore banking business in the
    U.K. and access the broader EU market, banks must be licensed by the U.K. regulatory
    authorities.
  • EEB lacks an onshore banking license anywhere in the world. EEB as an offshore entity, cannot
    access central bank liquidity or conduct direct currency settlements.
  • The bank relies on correspondent banks for fund clearing, which can delay transactions and
    expose it to risks such as intermediary bank failures (Herstatt risk) and compliance challenges
    related to money laundering and sanctions.
    Posting on X (Twitter)
  • A post dated July 14, 2024, mentioned that EEB is a financial institution and not a bank. The
    company is worth INR 8 crores, however, gave guarantee for 31 projects worth INR 480 crores.
    It was also alleged the Jagan Mohan Reddy who is a Member of Legislative Assembly is behind
    this scam.

  • 4.5.4. MEDIA REVIEWS & SOCIAL MEDIA CHECKS
    A) REVIEWS – Euro Exim Group has received mixed feedback in reviews on its services. Notably,
    most negative reviews indicate that Euro Exim Group is not a genuine operating business.
  • On Google, Euro Exim Group received 200 reviews. On average, the company was rated 4.7
    stars out of five. The vast majority of reviews appear to be from staff members and are positive
    in tone. Negative reviews question Euro Exim Group’s legitimacy and refer to either having
    been scammed themselves by the company or through the aforementioned hiring scam.
  • On Facebook, the company received two positive review and one negative review. The negative
    review stated that Euro Exim Group had “taken his [the individual’s] money” and refused to
    return it.131 On TrustPilot, the company received two positive but poorly argued reviews.132
    B) EMPLOYEE REVIEW SITES – Euro Exim Group has its own profile on employers’ review
    site Glassdoor.133 The company received 62 reviews, resulting in a 4.2 rating out of five. Reviews
    on Euro Exim group were mixed in tone.
  • Analysis of an elaborate anonymous review of a “trade finance consultant” revealed that the
    company is not run professionally: the company purportedly hires unexperienced people with
    little to no English-language skills. The same reviewer stated that employees’ training was
    limited and that procedural documents are often non-existent. When they asked for further
    information, they were pointed towards the onboarding documentation.
  • An anonymised “international trade specialist” made similar statements, mentioning that the
    company offers no “real support” and is still growing therefore creating processes.
  • Another anonymised “international trade specialist” stated that the company “would like to
    employ anyone”, also indicating that Euro Exim Group has limited requirements for new hires.
    In contrast, an anonymous reviewer who worked as an “officer” at Euro Exim Group stated that
    colleagues were knowledgeable.
  • An anonymised “trade finance specialist” stated that adequate training was provided.
  • Several reviews of trade finance managers and executives were identified, who have stated that
    no fixed salary was paid, and that Euro Exim Group pays on a commission basis.
    131 www.facebook.com 132 uk.trustpilot.com 133 www.glassdoor.co.uk
    64
  • Searches also identified a review of someone working at Euro Exim group on YouTube.134
    Positive feedback related to how easy it was to get a job and to have remote working
    opportunities. It also referred to the commission payment scheme.
    C) SOCIAL MEDIA – Social media review included posts of Quora, Reddit, YouTube, Facebook and
    Instagram.
  • Beyond content that has been published by Euro Exim group itself, social media posts on the
    company indicate that many individuals are unclear about the company’s legitimacy and
    operations.135
  • On many platforms, users ask other users to further explain the group’s operations and if reach
    out of recruiters for the group is part of a hiring scam (see above).136 These posts are not
    necessarily negative in tone; users appear to be predominantly unsure about Euro Exim Group’s
    legitimacy.
    www.youtube.com 135 For example: www.instagram.com ; www.facebook.com 136 For example: www.quora.com ; www.reddit.com
    65
    4.5.5. LITIGATION CHECKS
    A. LITIGATION CHECKS UK – Searches were conducted for Euro Exim Bank Limited, Kaushik
    and Adarsh across publicly available litigation databases covering the UK, the UK Court and
    Tribunals Judiciary’s website, the UK Supreme Court’s website and the website of the Scottish
    Courts and Tribunals.
  • Searches were conducted across a paid database administered by the UK Ministry of Justice
    comprising judgments, court orders and fines. These searches require a name and residential
    address. These searches yielded no results for Euro Exim Bank Limited, Kaushik and Adarsh.
  • The publicly available litigation databases of the UK cover predominantly case law produced
    after 1996 and case law for which there is sufficient interest to be made available for publication
    on the internet. Commercial UK litigation databases are not fully comprehensive and mainly
    cover cases from 1997 onwards. The Irish Courts Service’s website includes cases from 2001
    onwards. Keeping the above restrictions at hand, one legal case identified pertaining to UK for
    Euro Exim Bank Limited. Beyond the case reference, no further details to the subject of the
    case have been published.
    Euro Exim Bank Ltd vs Sanjay Thakrar
    On 14 June 2019, the London Circuit Commercial Court ruled on a case between the claimant
    Euro Exim Bank Limited and the defendant Sanjay –the former sole shareholder and director
    of Euro Exim Bank Limited.
    137 The London Circuit Commercial Court rules on business and
    property cases. This case focused on general commercial contracts and arrangements. No
    further details noted for the ruling on the overarching litigation database covering the UK or on
    the website of the Court and Tribunals Judiciary of the UK.
    B. LITIGATION CHECKS INDIA – Online accessible records as made public in India with
    respect to any pending and /or disposed of cases were checked for EEB. The checks for last 10

    years (2014-2024) were conducted in the Supreme Court of India and all available High Courts,
    District Courts, and Consumer Courts, following details were identified: (as last conducted on
    July 25, 2024)

• 02 exact litigation cases were noted for EEB.

Summary:
hence name matches will be reported as possible matches. Erroneous or missing data/attachments provided in e-courts are
subjective in nature due to technicalities. Since e-courts do update old/disposed/new cases or remove entries (including
attachments viz., court orders, CNR No., Case No., and Registration No.) leading to uncertain scenarios in search; In many
scenarios we have encountered no physical cases in court despite its presence in e-courts; This report stands exempted from
any quality issues raising out of such scenarios. All data synchronization between e-courts and our report is subjected to 30
to 45 working days of latency. E-court changes its CNR no. / Case no. / Reg No. frequently due to technical error.All data
provided as part of this report is subjected to the e-court of India’s disclaimer and all data protection act governed by the
land. In India, courts determine which judgement to be published online. Therefore, search conducted is based on online
databases and no manual checks have been done at this stage. Checks have been conducted on the basis of identifiers
available on-hand. In case of any additional identifier, those are excluded.Cases awaiting hearing at the court are not
included in the online databases. Those cases are not covered in the litigation check conducted for the said case

  • On 28 July 2020, the Indian Madras High Court ruled on a case in which Euro Exim Bank and
    Senthil Kumar were the petitioners and the Commissioner of Police Chennai, the Assistant
    Commissioner of Police Chennai and the State Rep of Chennai were the respondents.
  • The petitioners requested the respondents to stop harassing the petitioner in connection to a
    2020 crime pending on a file note held by the respondent.
  • The ruling is brief, and the Madras High Court does not elaborate on the type or nature of the
    alleged crime. In its ruling, the Madras High Court provided guidelines to the respondent for
    its enquiries.
    C. OTHER GLOBAL CHECKS – Searches found a 23 November 2013 ex-parte court case on which
    the Industrial Court of Kenya ruled. The claimant was Mutune Masua and the respondent was
    Designwear. According to the court ruling, Adarsh – referred to by his full name – was the CEO of
    Designwear. Subject of the dispute was whether Designwear had delivered proper services to its
    client. The application was eventually heard on 17 May 2013 – however online records noted to not
    contain the details of the final order.
  1. KEY RISK POINTERS
    The following key risk pointers were noted during diligence that require attention:
  • Finance regulators’ registrations –
    o Euro Exim Bank UK is no longer registered with the UK Financial Conduct Authority to
    conduct financial service activities in the UK.
    o The Saint Lucian registration of Euro Exim Bank. St Lucia, with the Financial Services
    Regulatory Authority solely allows Euro to conduct business with offshore third parties.
  • Lack of transparency on filed financials – No consolidated filings noted for Euro Exim Group.
    Contradictory financial filings noted for Euro Exim Group (including that of Euro Exim Bank, St
    Lucia), as self-published in various open media forums.
  • Misrepresentation of names of Related Parties – Names of related parties holding noted to be
    filed incorrectly in the Annual Reports of Euro Exim Bank, UK.
    o As per the reports, the controlling entity of Euro Exim Bank, St Lucia is Century Holdings
    as registered in UAE. However, checks as per UAE corporate registry reveals that Euro
    Exim bank, St Lucia is 100% held by Centurion Holding Limited. Further, checks on the
    name of Century Holdings, revealed to be known by a well known Omani traders, whose
    similar business holdings with the name Century may have been included to evoke
    confidence in those accessing the annual reports.
    o As per the reports, Century Holdings Limited is noted to hold a controlling stake in a New
    Zealand based company called Century Finance Limited (as per even the latest filing of
    20203). However, checks with the New Zealand corporate registry notes that the company
    changed its name in 2012 and has since then been known as Century Financial Holdings
    Limited. The reference to a previous name might have been retained keeping in mind the
    generic references of other companies in New Zealand by similar names, that may cause
    confusion.
  • Indications of an unprofessional business – A review of media reporting, review sites,
    employers’ review sites and social media indicate that Euro Exim Group may not be run
    professionally. This includes references to having no minimum requirements for prospect
    candidates and no adequate training and policies to provide to its employees. In addition, reviewers
    that were unrelated to Euro Exim Group indicated that the group was not a genuine business.
  • Absence of information on clientele – No details of any active projects / clientele of the Euro
    Exim Group, noted during open domain searches. It was noted that the website of Euro Exim
    Group, did earlier list the details of their clients and trades. However, the same was pulled down in
    February 2024. The pulling down of the page, raises credibility on the published information and
    also overall on the representations as made by Euro Exim Group, towards its expertise.
  • References to alleged involvement in scams – Searches identified three recent references to Euro
    Exim Group having been involved in hiring and bank guarantee scams.
  • Red flags identified for Kaushik’s, Shah’s and Sanjay’s other corporate interests –
    o Searches identified two red flags for Kaushik’s and Adarsh’s trade names/corporate
    interests in the UK.
     In 2017, the UK Financial Conduct Authority warned against a trade name that is
    the same as one of Kaushik’s corporate interests, Century Finance, as it had cloned
    another lender.
     Four of Adarsh’s UK corporate interests were incorporated and dissolved within a
    short period of time and have not filed any financial statements or registered activity
    in UK corporate records.
    o Searches identified a UK civil and criminal case involving Sanjay, as director of New
    Zealand registered companies controlled by him, namely Century Financial Holdings
    Limited and Century Finance Limited.
  • Limited former finance experience found for Euro Exim Bank, UK’s current directors –
    Beyond Adarsh’s former role at the Bank of America, we identified no references to Adarsh or
    Kaushik having obtained relevant experiences in the finance industry.
  • Predominantly self-generated media reporting – A review of media reporting, review sites,
    employers’ review sites and social media indicate that nearly all media reporting on Euro Exim
    Group is self-generated or has been published on press release sites. There is little independent
    information available on the group.
  1. ANNEXURES
    6.1. ANNEXURE – PROFILING OF TSSPL
    Euro Exim Group does not have any formal presence in India, either as a formal office or as a
    representative office. Euro Exim Group’s website, refers to TSSPL as a Global Back Office Support
    Partner’ for the group.
    Further, open domain profiling of TSSPL, identifies its major shareholder and director Senthil Kumar,
    to be a Director of EEB, thereby indicating that TSSPL is an affiliate company of Euro Exim Group.
    5.4.1. CORPORATE RECORD MAPPING
    The following information has been mapped from the records as filed by the company with the
    corporate registries of India and also via articles / postings on open domain.

The company’s logo displayed here has been obtained from publicly accessible website and has not undergone

independent verification. Logo is available at: https://trdfin.in/

5.4.2. KEY MANAGEMENT DETAILS

As per records filed with MCA, the following key management details were noted for TSSPL: (as last checked on July 26, 2024)

Sourced from: https://trdfin.in/contact-us/ 1 The provided GSTIN have been identified as registered on the GST portal under the company’s PAN. 145 The provided list contact number is not comprehensive and may not encompass contact numbers potentially utilized by
the entity but registered under alternate names.
146 The provided list of email addresses is not comprehensive and may not encompass email addresses potentially utilized
by the entity but registered under alternate names. 147 It is to be noted that all the social media profiles as accessed above, have been accessed for the publicly available
information. Considering the restrictive legalities involved, no such profile searches have been conducted. No attempt has
been made to access any information that would be considered to be a breach of privacy and in violation of existing laws
of the land.

B) PAST DIRECTORS

5.4.3. SHAREHOLDING PATTERN

As per the records filed with MCA, the following was noted as the shareholding pattern of TSSPL as last updated on March 31, 2024 (as last checked on July 26, 2024

5.4.4. KEY FINANCIAL DETAILS

NOTE: No detailed financial evaluation or audit of the financial records has been done under this report. This section provides a summary of the key financial records (profit and loss) as made public by the company in its financial statement, and last disclosed to the regulators. (as last updated on March 31, 2022)

STANDALONE STATEMENT

Overall, the company reported an increase in its profit in the FY 2021-22, as compared to the previous FY 2020-21. Given below are the key financials (as last checked on July 26, 2024):

5.4.5. BUSINESS OPERATIONS
Services:

  • As per the records filed with MCA, TSSPL main objective is designing and development of
    software products and solutions, providing all kind of back-office outsourcing solutions, to
    provide all kinds of auxiliary services to banks and financial institutions for collecting and
    vetting proposals for credit facilities, etc.
  • As per the website, TSSPL is engaged in providing software solutions, accounting and CFO
    services and consultancy services such as legal, compliance and due diligence, credit rating
    advisory, recruitment, training & development and marketing.
    Other Related Parties
    As per the records filed with MCA, the related parties148 of the company are
  • Fasta Pizza Private Limited
  • EEB Engineering Design and Consultancy Services Private Limited.
    6.2. ANNEXURE 2 – HISTORY & CORPORATE DEVELOPMENT
    Searches in the English-language public domain yielded a small number of self-authored references to
    Euro Exim Group’s corporate development. No detailed profiling of the companies have been covered under this report. Open domain profiling of Euro Exim Bank Limited makes it clear that Sanjay and Kaushik founded
    Exim Euro Group. Prior to 2015, the entity was headed and owned by Bishal Sapkota, who appears
    to have been a hospitality professional who tried to set up a payments processing company. He left the
    company in 2014. The entity’s ownership and management was subsequently moved to Sanjay.
  • Euro Exim Bank Limited and Sanjay appear to have had a dispute around 2019 (also covered
    later in the report).
  • However, Sanjay continues to work in a leadership position at Euro Exim Bank Limited (Head
    Global Strategy and Leadership). Euro Exim Bank Limited’s current sole shareholder and director is Punjani, who is also Euro Exim Group’s founder and CEO. Adarsh is Euro’s other current director.
    An introduction of Euro Exim Group as found on its YouTube channel stated that the company was
    founded in 2015. Additionally, the following information was gathered from the same source:
  • At inception, the company counted five staff, the YouTube video mentions.
  • A 2021 update of Euro Exim Group stated that the group was “born out of a small payments
    institution
    in the UK” in 2015.
  • The same source stated that, in 2017, the group moved its headquarters from UK to Saint Lucia,
    as it reportedly wanted to be established in a jurisdiction with a potent regulator as well as be
    close to its key markets. Notably, open domain lists a July 2024 interview with an unnamed
    Euro Exim group employee, in which the employee stated that the group was founded in 2018.
  • Aforementioned YouTube video stated that around 2021, Euro opened a back office in Chennai,
    India, as well as associate offices in the United Arab Emirates city Dubai and Singapore.153 By
    that year, their team counted approximately 30 people. Aforementioned 2021 update on Euro
    Exim Group’s website, also referred to over 250 consultants, agents and partners worldwide
    affiliated
    with Euro Exim group. Searches identified a small number of self-authored references to the size of Euro Exim Group’s operations. The aforementioned 2021 update stated that, from 2018 to 2021, the group had proposed trade finance instruments with over USD 3 trillion in value. For comparison, we note that this is about
    the same size as France’s nominal GDP (USD 3.03 trillion).In a July 2024 article on Euro, it is
    mentioned that the company had stated itself that it had a net worth of INR 1900 crore, which is approx.
    USD 254 million.
    Information as analyzed from various regulatory records, indicate that Euro Exim Bank Limited
    formerly operated as a small payments services provider: UK corporate records and the website of the
    UK finance regulator the Financial Conduct Authority state that from 2011 to 2015, Euro was trading
    as Galaxy and offered payment services.

    6.3. ANNEXURE 3 – CACHED WEBPAGE DEAL / TRANSACTION

    DETAILS
  1. A 137,520 USD LC, issued on behalf of an Applicant from United Kingdom, to a Beneficiary in
    Bangladesh, to SOUTHEAST BANK LIMITED, to import Apparel.
    2.A 124,341 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in Tanzania, to
    NMB BANK PLC, to an educational institute in Tanzania.
    3.A 5,000,000 USD SBLC, issued on behalf of an Applicant from Hong Kong, to a Beneficiary in
    China, to AGRICTULTURAL BANK OF CHINA
    4.A 109,999,500 USD SBLC, issued on behalf of an Applicant from Senegal, to a Beneficiary in South
    Africa, to FIRST NATIONAL BANK (FNB)
    154 euroeximbank.com 155 datacatalog.worldbank.org 156 medianoise.in
    76
    5.A 2,370,000 USD LC, issued on behalf of an Applicant from COTE D IVOIRE, to a Beneficiary in
    United Arab Emirates, to FIRST ABU DHABI BANK P.J.S.C, to import Diesel Fuel EN590 10 PPM.
    6.A 388,800 USD LC, issued on behalf of an Applicant from Kenya, to a Beneficiary in India, to
    KOTAK MAHINDRA BANK LTD, to import 12X40 LLDPE ROTO Grade Powder (Non-Hazardous
    and Non-Toxic)
    7.A 189,896.83 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    CANARA Bank, towards Supply of Tower Material.
    8.A 139,848 USD LC, issued on behalf of an Applicant from UNITED KINGDOM to a Beneficiary
    in Bangladesh, to UTTARA BANK LIMITED, to import Apparel.
    9.A 133,076 USD LC, issued on behalf of an Applicant from UNITED KINGDOM to a Beneficiary
    in Bangladesh, to Southeast Bank, to import Apparel.
    10.A 109,763.52 USD APG, issued on behalf of an Applicant from NAGAR, BENGALURU – 560091,
    INDIA, to a Beneficiary in India, to ICICI BANK, to an Air Cargo & Aerospace Company.
    11.A 4,812,500 USD LC, issued on behalf of an Applicant from TANZANIA, to a Beneficiary in
    Malaysia, to MALAYAN Banking Berhad, to import White Sugar ICUMSA 45.
    12.A 4,329,454.14 USD SBLC, issued on behalf of an Applicant from BAMAKO, REPUBLIC OF
    MALI, to a Beneficiary in Turkey, to KUVEYT TURK KATILIM BANKASI A.S.
    13.A 456,765.23 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    ICICI BANK, to a Project Director, Ladakh Renewable.
    14.A 122,869.53 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    JAMMU & KASHMIR BANK, to a Project Director, Kargil Renewable.
    15.A 726,940 USD LC, issued on behalf of an Applicant From Oman, to a Beneficiary in South Korea,
    to KEB HANA BANK, to import Heavy Machinery – DOOSAN WEX DX210WA.
    16.A 1,537,159.7 USD APG, issued on behalf of an Applicant from GHATKOPAR (E), MUMBAI 400077 INDIA, to a Beneficiary in India, to STATE BANK OF India, to Executive Engineer,
    Maharashtra State Department.
    17.A 348,208.37 USD LC, issued on behalf of an Applicant from TELANGANA – 500051, INDIA, to
    a Beneficiary in India, to THE SOUTH INDIAN BANK LIMITED, to import CV 07.
    18.A 405,039.45 USD APG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    a Municipal Corporation in Madurai
    77
    19.A 354,659.16 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    CANARA Bank, towards Supply of Multi Section Digital Axle Counter System (MSDAC) 05 DP &
    02 Track Section.
    20.A 924,734.74 USD APG, issued on behalf of an Applicant from GHATKOPAR (E), MUMBAI –
    400077 INDIA, to a Beneficiary in India, to STATE BANK OF India, to an Executive Engineer in
    Maharashtra State Government Department.
    21.A 3,696,000 USD LC, issued on behalf of an Applicant from South Africa, to a Beneficiary in India,
    to SBI – Trivandrum, towards import of Max-Red Colour Strawberry Male Condoms.
    22.A 125,280 USD LC, issued on behalf of an Applicant from SINGAPORE – 679978, to a Beneficiary
    in Nigeria, to JAIZ BANK PLC, towards import of Raw Cashew Nuts (RCN).
    23.A 422,590.5 USD LC, issued on behalf of an Applicant from Mozambique, to a Beneficiary in
    India, to HDFC BANK, to import Black Braided Silk/Polyglactin 910 Violet USP/ Polyamide Nylon.
    24.A 290,692.69 USD APG, issued on behalf of an Applicant from BANER, PUNE 411045 INDIA,
    to a Beneficiary in India, to Standard Chartered Bank.
    25.A 280,000 USD LC, issued on behalf of an Applicant from Sri Lanka, to a Beneficiary in China, to
    STANDARD CHARTERED BANK (CHINA) LIMITED, to import “PPGL, G350+AZ30, 20/10UM,
    H.S. CODE 7210.70, BACKSIDE PRINT “UNION STEEL KOREA AZ150 0.47MM G350”
    AUTUMN RED”
    26.A 106,812 USD LC, issued on behalf of an Applicant from Sri Lanka, to a Beneficiary in China, to
    BANK OF CHINA LIMITED, to import Pre-Painted Galvalume Autumn Red Steel Coils.
    27.A 124,621.47 USD LC, issued on behalf of an Applicant from PUNE-411048, INDIA, to a
    Beneficiary in India, to KOTAK MAHINDRA BANK, to procure UPVC Profile, Hardware,
    Accessories & Aluminum Profiles.
    28.A 924,734.74 USD APG, issued on behalf of an Applicant from GHATKOPAR (E), MUMBAI 400077 INDIA, to a Beneficiary in India, to STATE BANK OF INDIA, to an Executive Engineer in a
    State Government Department in Maharashtra, India.
    29.A 94,763 USD PG, issued on behalf of an Applicant from INDIA, to a Beneficiary in Kuwait, to
    KUWAIT FINANCE HOUSE
    30.A 110,500 USD LC, issued on behalf of an Applicant from UNITED KINGDOM to a Beneficiary
    in Bangladesh, towards import of Apparels.
    31.A 2,604,370.72 USD PG, issued on behalf of an Applicant from Andhra Pradesh, INDIA, to a
    Beneficiary in India, to STATE BANK OF INDIA, to a Director of a Mines & Geology Department.
    78
    32.A 364,927.68 USD LC, issued on behalf of an Applicant from NETO NO 1157 MOZAMBIQUE,
    to a Beneficiary in India, to THE KALUPUR COMMERCIAL CO-OP BANK LTD, towards import
    of Compound Sodium Lactate (Ringer Lactate Infusion BP) 1000ML with IV Set.
    33.A 122,040 USD LC, issued on behalf of an Applicant from SINGAPORE – 679978, to a Beneficiary
    in Nigeria, to JAIZ BANK PLC, to import Raw Cashew Nuts.
    34.A 140,600 USD LC, issued on behalf of an Applicant from SRILANKA, to a Beneficiary in India,
    to AXIS Bank, towards import of Apparels.
    35.A 183,343.96 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    ICICI BANK LTD, to an Executive Engineer in a State Government Department in West Bengal, India.
    36.A 102,224.82 USD BG, issued on behalf of an Applicant from GHATKOPAR (E), MUMBAI 400077 INDIA, to a Beneficiary in India, to STATE BANK OF India, to an Executive Engineer in a
    State Government Department in Maharashtra, India
    37.A 474,757.38 USD APG, issued on behalf of an Applicant from GHATKOPAR (E), MUMBAI 400077 INDIA, to a Beneficiary in India, to STATE BANK OF INDIA, to an Executive Engineer in
    a State Government Department in Maharashtra, India.
    38.A 361,857.76 USD BG, issued on behalf of an Applicant from GHATKOPAR (E), MUMBAI 400077 INDIA, to a Beneficiary in India, to STATE BANK OF INDIA, to an Executive Engineer in
    a State Government Department in Maharashtra, India.
    39.A 205,386.6 USD PG, issued on behalf of an Applicant from HYDERABAD 500032,
    TELANGANA, INDIA, to a Beneficiary in India, to a Government Collieries Company.
    40.A 90,702.1 USD SBLC, issued on behalf of an Applicant from UGANDA, to a Beneficiary in
    China, to INDUSTRIAL AND COMMERCIAL BANK OF CHINA
    41.A 248,300 USD LC, issued on behalf of an Applicant from KENYA, to a Beneficiary in RWANDA,
    to KCB BANK, to import 1600 KGs/H Washing Powder Machine.
    42.A 4,005,000 USD LC, issued on behalf of an Applicant from UNITED ARAB EMIRATES to a
    Beneficiary in China, to BANK OF CHINA, to import One Step Test for SARS-CoV-2 Antigen
    (Colloidal Gold).
    43.A 131,430.24 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in Singapore,
    to OCBC BANK, towards import of Mustad Brand Fish Hook.
    44.A 193,593.91 USD APG, issued on behalf of an Applicant from BANER, PUNE 411045 INDIA,
    to a Beneficiary in India, to STANDARD CHARTERED BANK
    79
    45.A 25,000,000 USD BG, issued on behalf of an Applicant from India, to a Beneficiary in Malaysia,
    to OCBC BANK
    46.A 8,687,500 USD LC, issued on behalf of an Applicant from SENEGAL, to a Beneficiary in United
    Arab Emirates, to COMMERCIAL BANK OF DUBAI, towards import of UREA N46% PILLED.
    47.A 1,700,000 USD PB, issued on behalf of an Applicant from SOUTH AFRICA to a Beneficiary in
    South Africa, to ABSA
    48.A 31,059.46 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to a
    Heavy Electricals Government Company in India
    49.A 92,876.83 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    STATE BANK OF INDIA, to a Heavy Electricals Government Company in India.
    50.A 97,200 USD LC, issued on behalf of an Applicant from Kenya, to a Beneficiary in India, to
    KOTAK MAHINDRA BANK LTD, towards import of LLDPE ROTO Grade Powder (Non-Hazardous
    & Non Toxic)
    51.A 9,486,000 USD Performance BG, issued on behalf of an Applicant from TELANGANA, INDIA,
    to a Beneficiary in Mongolia, to GOLOMT BANK OF MONGOLIA, towards construction of a
    Refinery in Mongolia
    52.A 29,945,000 USD Performance BG, issued on behalf of an Applicant from TELANGANA,
    INDIA, to a Beneficiary in Mongolia, to GOLOMT BANK OF MONGOLIA, towards construction of
    a Refinery in Mongolia
    53.A 1,110,194.02 USD APG, issued on behalf of an Applicant from India, to a Beneficiary in India,
    to an Industrial Township in Aurangabad, India.
    54.A 735,000 USD LC, issued on behalf of an Applicant from INDIA, to a Beneficiary in Turkey, to
    T.IS BANKASI, towards import of Flow Meters MODEL-TK-12DN-15MM, Without AMR Ready,
    Poly Carbonade Glass, B Class(R100), Length:165MM, Brass Body, Brass Upper Body, Engineering
    Plastic Register Can, MID Approved, Without end connections.
    55.A 130,000 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in United Arab
    Emirates, to EMIRATES NBD, to import 445/95R25 Magna MA03.
    56.A 120,683.53 USD SBLC, issued on behalf of an Applicant from CBD, DAR ES SALAAM,
    TANZANIA, to a Beneficiary in Uganda, to BANK OF AFRICA
    57.A 720,000 USD SBLC, issued on behalf of an Applicant from CYPRUS, to a Beneficiary in Nigeria,
    to Zenith Bank, to a Marine Company.
    80
    58.A 155,752.51 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    HDFC BANK, to procure TMT Steel 8 mm.
    59.A 604,087.86 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    HSBC BANK, to procure Babylog VN600.
    60.A 891,991.36 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    HSBC BANK, to procure Savina 300, System.
    61.A 267,713.73 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    HSBC BANK, to procure Fabius Plus XL.
    62.A 313,610.06 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to an
    Executive Engineer in a State Government Department of Maharashtra, India.
    63.A 522,580 USD LC, issued on behalf of an Applicant from Oman, to a Beneficiary in South Korea,
    to KEB HANA BANK, to import Heavy Machinery – DOOSAN Equipment and Spare Parts Boxes.
    64.A 269,920 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in China, to PING
    AN BANK CO., LTD, to import Pre-Painted Galvalume Steel Coils – G550 + AZ30,20/10 UM Autumn
    Red.
    65.A 100,800 USD SBLC, issued on behalf of an Applicant from UNITED KINGDOM to a
    Beneficiary in India, to ICICI BANK, to a mines and minerals company
    66.A 850,365.74 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to an
    Executive Engineer in a State Government Department of Maharashtra, India.
    67.A 183,714.42 USD BG, issued on behalf of an Applicant from India, to a Beneficiary in
    Mozambique, to ABSA BANK LIMITED, to a Department under Ministry of Education & Health in
    Mozambique
    68.A 544,617.22 USD LC, issued on behalf of an Applicant from United Arab Emirates, to a
    Beneficiary in United Arab Emirates, to HSBC Bank Middle East Limited, towards Project:
    Rehabilitation Of 4 Numbers 33kv/11kv Primary Substations Manaseer And Addf2 Stations For
    Protection Relays And Common Alarm Panels.
    69.A 338,721.25 USD LC, issued on behalf of an Applicant from Oman, to a Beneficiary in United
    Arab Emirates, to FIRST ABU DHABI BANK, to import UV 420 TTR-C H4.
    70.A 70,200 USD LC, issued on behalf of an Applicant from Kenya, to a Beneficiary in India, to
    BANK OF BARODA, for import of LLDPE Roto Powder (65 Percent Black and 35 Percent Light
    Blue)
    81
    71.A 117,391.36 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    HDFC BANK LTD., to a Regional Manager in Uttar Pradesh.
    72.A 31,964.1 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    HDFC BANK LTD, to a Regional Manager in Uttar Pradesh.
    73.A 1,634,375 USD LC, issued on behalf of an Applicant from United States, to a Beneficiary in
    United Arab Emirates, to RAK BANK, towards import of White Wove 90 GSM Size 270mm and
    1500mm.
    74.A 120,619.25 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    HDFC BANK LTD.
    75.A 35,000 USD PG, issued on behalf of an Applicant from Australia, to a Beneficiary in Australia,
    to a Home Health Services Company.
    76.A 35,000 USD PG, issued on behalf of an Applicant from Australia, to a Beneficiary in Australia,
    to a Home Health Services Company.
    77.A 35,000 USD PG, issued on behalf of an Applicant from Australia, to a Beneficiary in Australia,
    to a Home Health Services Company.
    78.A 35,000 USD PG, issued on behalf of an Applicant from Australia, to a Beneficiary in Australia,
    to a Home Health Services Company.
    79.A 35,000 USD PG, issued on behalf of an Applicant from Australia, to a Beneficiary in Australia,
    to a Home Health Services Company.
    80.A 2,033,859.54 USD APG, issued on behalf of an Applicant from India, to a Beneficiary in India,
    to CANARA BANK, to a Rural Drinking Water Department in Karnataka.
    81.A 29,069.24 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to a
    Regional Manager in Uttar Pradesh, India.
    82.A 43,422.93 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to a
    Regional Manager in Uttar Pradesh, India.
    83.A 111,632.54 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to a
    Regional Manager in Uttar Pradesh, India.
    84.A 30,396.05 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to a
    Regional Manager in Uttar Pradesh, India.
    85.A 106,760.1 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to a
    Road Transport Corporation in Uttar Pradesh, India.
    82
    86.A 159,475.06 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    ICICI Bank Ltd., to a Road Transport Corporation in Uttar Pradesh, India.
    87.A 161,758.8 USD LC, issued on behalf of an Applicant from DR Congo, to a Beneficiary in Tunisia,
    to QATAR NATIONAL BANK, to import 75CL White Wine Chardonnay.
    88.A 145,057 USD LC, issued on behalf of an Applicant from UNITED KINGDOM to a Beneficiary
    in Bangladesh, to Southeast Bank Limited, towards import of Men’s Cotton Polos.
    89.A 314,454.39 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to a
    Ministry of Defense organization.
    90.A 594,965.8 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in China, to
    CHINA ZHESHANG BANK, to import Picasso Moving Head 620W 6800K
    91.A 246,063.28 USD BG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    BANK OF INDIA, to a Metro Rail Corporation in India.
    92.A 207,958.85 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to an
    Executive Engineer in a State Government Department of West Bengal, India.
    93.A 27,408.63 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    HSBC BANK, to procure Vyana – Ceiling Supply Unit.
    94.A 330,000 USD LC, issued on behalf of an Applicant from Oman, to a Beneficiary in South Korea,
    to KEB HANA BANK, towards import of Heavy Machinery – Doosan Equipment and Spare Parts
    Boxes.
    95.A 149,688.49 USD PG, issued on behalf of an Applicant from INDIA, to a Beneficiary in India, to
    UNION BANK OF INDIA, to a State Tourism Department in Haryana, India
    96.A 149,688.49 USD PG, issued on behalf of an Applicant from INDIA, to a Beneficiary in India, to
    UNION BANK OF INDIA, to a State Tourism Department in Haryana, India.
    97.A 149,688.49 USD PG, issued on behalf of an Applicant from INDIA, to a Beneficiary in India, to
    UNION BANK OF INDIA, to a State Tourism Department in Haryana, India.
    98.A 149,688.49 USD PG, issued on behalf of an Applicant from INDIA, to a Beneficiary in India, to
    UNION BANK OF INDIA, to a State Tourism Department in Haryana, India.
    99.A 4,812,500 USD LC, issued on behalf of an Applicant from TANZANIA, to a Beneficiary in
    Malaysia, to MALAYAN BANKING BERHAD, towards import of White Sugar ICUMSA 45
    100.A 149,688.49 USD PG, issued on behalf of an Applicant from INDIA, to a Beneficiary in India,
    to UNION BANK OF INDIA, to a State Tourism Department in Haryana, India,
    101.A 94,763 USD PG, issued on behalf of an Applicant from INDIA, to a Beneficiary in Kuwait
    83
    102.A 87,104 USD BG, issued on behalf of an Applicant from COIMBATORE, TAMIL NADU
    641021 INDIA, to a Beneficiary in Jordan, to ARAB BANK
    103.A 150,000 USD APG, issued on behalf of an Applicant from India, to a Beneficiary in
    Mozambique, to a Government Department in Mozambique.
    104.A 119,600 USD LC, issued on behalf of an Applicant from Uganda, to a Beneficiary in India, to
    ICIC BANK LIMITED, to import Indian White Rice 15% Broken
    105.A 224,433.5 USD LC, issued on behalf of an Applicant from OMAN, to a Beneficiary in United
    Arab Emirates, to DEUTSCHE BANK AG, to import BOEHLER FOX CEL 3.2350 MM. 106.A 300,220.24 USD LC, issued on behalf of an Applicant from United Arab Emirates, to a Beneficiary in United Arab Emirates, to EMIRATES NBD, to procure Stainless Steel Plate. 107.A 24,181.14 USD PG, issued on behalf of an Applicant from BENGALURU-560085, INDIA, to a Beneficiary in India, to BANK OF INDIA, 108.A total of 58 Retention Bank Guarantees, issued on behalf of an Applicant in Bangalore in India, to a Beneficiary in India, to Bank of India, to a Medical Education State Government Department in Karnataka, India. 109.A 430,401.86 USD PG, issued on behalf of an Applicant from United Arab Emirates, to a Beneficiary in Poland, to CREDIT AGRICOLE BANK POLSKA S.A WROCLAW 110.A 422,590.5 USD LC, issued on behalf of an Applicant from NETO NO 1157 MOZAMBIQUE, to a Beneficiary in India, to CANARA BANK, to import Black Braided Silk/ Polyglactin 910 Violet USP/ Polyamide Nylon 111.A 349,333 USD LC, issued on behalf of an Applicant from NETO NO 1157 MOZAMBIQUE, to a Beneficiary in India, to INDUSIND BANK, towards import of Syringes. 112.A 142,624.6 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to a Chief Engineer of Procurement. 113.A 114,650 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to a Chief Engineer of Procurement. 114.A 5,000,000 USD SBLC, issued on behalf of an Applicant from BAMAKO, REPUBLIC OF MALI, to a Beneficiary in Bulgaria, to DSK BANK 115.A 227,230.24 USD APG, issued on behalf of an Applicant from Tanzania, to a Beneficiary in Tanzania, to BANK OF TANZANIA, to a Ministry of Communication Department. 116.A 251,491.14 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in India, to THE KARUR VYSYA BANK LTD., to import MS Steel Grade: IS 2062 – E350 & E250 BR. 84 117.A 12,242,314.36 USD LC, issued on behalf of an Applicant from United Arab Emirates, to a Beneficiary in Spain, to CAJA RURAL DEL SUR, to import Ultra-Low Sulfur Diesel EN590 10 PPM 118.A 447,424.68 USD LC, issued on behalf of an Applicant from United Arab Emirates, to a Beneficiary in China, to BANK OF CHINA – ZHENGZHOU HENAN, towards import of Stainless Steel ASTM A240 316L 2B. 119.A 1,040,000 USD LC, issued on behalf of an Applicant from Oman, to a Beneficiary in South Korea, to KEB HANA BANK, towards import of Heavy Machinery – Doosan Equipment and Spare Parts Boxes. 120.A 191,268.75 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in China, to BANK OF CHINA, towards import of Dried Red Chilli. 121.A 1,412,500 USD LC, issued on behalf of an Applicant from TELANGANA 500081, INDIA, to a Beneficiary in India, to AXIS BANK, to procure Biodegradable Granules / Containers. 122.A 3,696,000 USD LC, issued on behalf of an Applicant from South Africa, to a Beneficiary in India, to SBI, to import Male Condoms. 123.A 315,000 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in United States, to JPMORGAN CHASE BANK, to a Grains and Foods Company. 124.A 576,514 USD APG, issued on behalf of an Applicant from INDIA, to a Beneficiary in China, to BANK OF CHINA LTD. 125.A 66,168.01 USD BG, issued on behalf of an Applicant from India, to a Beneficiary in India, to INDUSIND BANK LTD, to a Mines and Geology Department in India. 126.A 930,000 USD LC, issued on behalf of an Applicant from Oman, to a Beneficiary in South Korea, to KEB HANA BANK, to import Heavy Machinery – Doosan Equipment and Spare Parts Boxes. 127.A 561,241.39 USD APG, issued on behalf of an Applicant from India, to a Beneficiary in India, to CANARA BANK, to a Highways Department in India. 128.A 94,686.11 USD BG, issued on behalf of an Applicant from India, to a Beneficiary in India, to a Health and Family Welfare Department in India. 129.A 301,517.98 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to a Director of Medical Education, a State Government Department in India. 130.A 61,691.57 USD BG, issued on behalf of an Applicant from South Africa, to a Beneficiary in South Africa, to FIRSTRAND BANK LIMITED. 131.A 61,691.57 USD BG, issued on behalf of an Applicant from South Africa, to a Beneficiary in South Africa, to FIRSTRAND BANK LIMITED. 85 132.A 61,691.57 USD BG, issued on behalf of an Applicant from South Africa, to a Beneficiary in South Africa, to STANDARD BANK. 133.A 446,534.53 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to STATE BANK OF INDIA, to an Oil and Natural Gas Corporation in India. 134.A 691,636.2 USD BG, issued on behalf of an Applicant from India, to a Beneficiary in India, to STATE BANK OF INDIA, to a Ministry of Defense Organization in India. 135.A 19,500,000 USD SBLC, issued on behalf of an Applicant from Zimbabwe, to a Beneficiary in China, to BANK OF CHINA LIMITED, to a Petro Chemical Co. in China. 136.A 55,750 USD LC, issued on behalf of an Applicant from Sri Lanka, to a Beneficiary in China, to STANDARD CHARTERED BANK (CHINA) LTD, to import PPGL. 137.A 171,750 USD LC, issued on behalf of an Applicant from Sri Lanka, to a Beneficiary in China, to STANDARD CHARTERED BANK (CHINA) LTD, to import PPGL. 138.A 170,085.21 USD PG, issued on behalf of an Applicant from INDIA, to a Beneficiary in India, to CANARA BANK, to a National Arts Centre department in India. 139.A 148,571.62 USD LC, issued on behalf of an Applicant from Tanzania, to a Beneficiary in South Korea, to Korea Exchange Bank, to import Kumho Brand Steel Radial Tyre set. 140.A 265,000 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in China, to Ping An Bank, towards import of Aluminum Extruded Housing With Anodized Finish 141.A 134,385 USD LC, issued on behalf of an Applicant from Tanzania, to a Beneficiary in United Arab Emirates, to EMIRATES NBD BANK PJSC, towards import of Firemax Brand Tyres & Boto Brand tyres. 142.A 120,900 USD LC, issued on behalf of an Applicant from Uganda, to a Beneficiary in India, to HDFC BANK, towards import of IR64 (Long Grain) White Rice 15% Broken, Silky Sortexed. 143.A 550,000 USD LC, issued on behalf of an Applicant from Singapore, to a Beneficiary in Ghana, to CONSOLIDATED BANK GHANA LIMITED, towards import of Dried Raw Cashew nuts. 144.A 272,308.34 USD LC, issued on behalf of an Applicant from United Arab Emirates, to a Beneficiary in United Arab Emirates, to EMIRATES NBD, to procure Mirror Polishing on SS 2B Finish 316L 4.00mm2000*6000
    145.A 265,362.36 USD APG, issued on behalf of an Applicant from India, to a Beneficiary in India,
    to CANARA BANK, to a National Highways Department in India.
    86
    146.A 829,025 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in China, to
    BANK OF CHINA SHEKOU SUB-BRANCH, towards import of Transformer Less PV Grid-Tied
    Inverters.
    147.A 588,506 USD APG, issued on behalf of an Applicant from INDIA, to a Beneficiary in Kuwait,
    to COMMERCIAL BANK OF KUWAIT, to a Petroleum Company in Kuwait.
    148.A 109,763.52 USD APG, issued on behalf of an Applicant from NAGAR, BENGALURU –
    560091, INDIA, to a Beneficiary in India, to ICICI BANK LTD, to an Air Cargo and Aerospace
    Engineering Company.
    149.A 2,000,000 USD SBLC, issued on behalf of an Applicant from Malaysia, to a Beneficiary in
    South Korea, to KEB Hana Bank
    150.A 103,301.34 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    ICICI BANK, to procure Turmeric.
    151.A 81,592 USD BG, issued on behalf of an Applicant from Uganda, to a Beneficiary in Uganda, to
    BANK OF BARODA, to a Tiles Company
    152.A 9,437,500 USD LC, issued on behalf of an Applicant from Senegal, to a Beneficiary in United
    Arab Emirates, to MASHREQ BANK, to import Fertilizer – Urea N46% Prilled.
    153.A 116,200 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in China, to
    BANK OF CHINA, towards import of NM36 100% Linen Bleached Long Fiber Yarn.
    154.A 785,950.23 USD BG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    STATE BANK OF INDIA, to a Ministry of Defense Organization in India.
    155.A 12,392,220.25 USD LC, issued on behalf of an Applicant from United Arab Emirates, to a
    Beneficiary in United Arab Emirates, to NATIONAL BANK OF RAS AL KHAIMAH, towards
    purchase of Diesel 10ppm ULSD (EN 590).
    156.A 451,904.13 USD BG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    a State Expressways Department in Uttar Pradesh, India.
    157.A 75,387.03 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    STATE BANK OF INDIA, to a Ware Housing Corporation in Andhra Pradesh, India
    158.A 120,619.25 USD BG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    a Milk Utpadak Cooperative in India.
    159.A 364,612.5 USD PG, issued on behalf of an Applicant from Australia, to a Beneficiary in
    Australia, to AUSTRALIA AND NEW ZEALAND BANK, to an Institute of Management &
    Technology.
    87
    160.A 351,335 USD LC, issued on behalf of an Applicant from United Kingdom, to a Beneficiary in
    Bangladesh, to Southeast Bank Limited, to import Apparels.
    161.A 88,330 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in Hong Kong,
    to ZHEJIANG CHOUZHOU COMMERCIAL BANK, towards import of Methyl Hydroxyethyl
    Cellulose of Grade MH3500.
    162.A 384,000 USD LC, issued on behalf of an Applicant from United Arab Emirates, to a Beneficiary
    in Portugal, to Banco Atlantico Europe, towards import of Cooking Oil.
    163.A 10,823,635.36 USD SBLC, issued on behalf of an Applicant from United Kingdom, to a
    Beneficiary in United Arab Emirates, to FIRS ABU DHABI BANK
    164.A 640,000 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in Ghana, to
    UNITED BANK FOR AFRICA, towards import of Raw Dried Cashew Nuts
    165.A 324,845.74 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    STATE BANK OF INDIA, to a Public Health Department in West Bengal, India.
    166.A 105,421.23 USD APG, issued on behalf of an Applicant from India, to a Beneficiary in India,
    to HDFC BANK
    167.A 166,136.8 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    ICICI BANK LTD, to a Tollways Company in India.
    168.A 836,647 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in China, to
    BANK OF CHINA SHEKOU SUB-BRANCH, to import Transformer-less PV Grid-tied inverters.
    169.A 103,301.34 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    ICICI BANK LTD, to procure Turmeric.
    170.A 36,600 USD LC, issued on behalf of an Applicant from Tanzania, to a Beneficiary in India, to
    YES BANK LIMITED, towards import of 24F MLT ADSS OFC 300 METER SPAN- Cable/Printing
    / Brand: CLARON Length: 4.0 KM +/-10%
    171.A 159,902 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in China, to
    CHINA MERCHANTS BANKS, towards import of MAGNESIUM ALLOY INGOT.
    172.A 1,083,902.5 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in China, to
    CHINA ZHESHANG BANK, towards import of Led Bulbs and Fittings.
    173.A 68,752.97 USD PG, issued on behalf of an Applicant from India, to a Beneficiary in India, to
    AXIS BANK LTD, to a Commissioner of Municipal Corporation in Maharashtra.
    174.A 381,156.84 USD APG, issued on behalf of an Applicant from India, to a Beneficiary in India,
    to JPMORGAN CHASE BANK N.A
    88
    175.A 161,741.55 USD PG, issued on behalf of an Applicant from Tanzania, to a Beneficiary in
    Tanzania, to a Rural Energy Agency in Tanzania.
    176.A 225,000 USD LC, issued on behalf of an Applicant from India, to a Beneficiary in Burkina Faso,
    to Bank of Africa Burkina, towards import of Cotton Lints Bola S
    177.A 466,842.89 USD LC, issued on behalf of an Applicant from United Arab Emirates, to a
    Beneficiary in United Arab Emirates, to Mashreq Bank, to procure Light Fittings.
    178.A 107,211 USD LC, issued on behalf of an Applicant from Tanzania, to a Beneficiary in United
    Arab Emirates, to EMIRATES NBD BANK PJSC, towards imp