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Welcome to the June edition of the White-Collar Crime and Investigations Newsletter, highlighting significant enforcement actions, judicial pronouncements, and regulatory developments across India's white-collar crime and investigations landscape. This edition covers key actions by the Enforcement Directorate ("ED"), the Central Bureau of Investigation ("CBI"), and other enforcement agencies, alongside important decisions of the Supreme Court and various High Courts on issues relating to the Prevention of Money Laundering Act, 2002 ("PMLA"), the Prevention of Corruption Act, 1988 ("PCA"), and corporate investigations.
The newsletter also provides an overview of notable global enforcement developments and key regulatory updates, offering practical insights into the evolving enforcement landscape and its implications for businesses, financial institutions, and compliance professionals.
In this issue:
- Enforcement Action
- Latest case laws
- Global enforcement roundup
- Indian Regulatory updates
Enforcement Action
Directorate of Enforcement (ED)
ED's Hyderabad zonal office arrested Nowhera Shaik in the Heera Group of Companies matter
ED's Hyderabad zonal office arrested Smt. Nowhera Shaik on 21st May 2026 from Gurugram after she absconded and evaded a Supreme Court-mandated auction of her attached properties. The case relates to an alleged Rs. 3,000 crore investment fraud on over 1.72 lakh depositors of the Heera Group run on promised returns of around 36% p.a. that were allegedly never paid. The Supreme Court had earlier ordered her to cooperate in auctioning attached properties; she allegedly obstructed this and gave false affidavits to revenue officials, prompting a non-bailable warrant. She was arrested under the Prevention of Money Laundering Act, 2002 (“PMLA”), produced before the Special PMLA Court, Hyderabad, and remanded to judicial custody.
ED Attaches Rs. 634.12 crore assets linked to Unitech’s Noida UGCC Project
ED, Headquarters Investigation Unit, New Delhi, issued a Provisional Attachment Order (“PAO”) on 27th May 2026 under the PMLA, attaching properties linked to the Unitech Golf & Country Club Project located in Noida. The attachment covers assets valued at Rs. 634.12 crore, identified as alleged proceeds of crime arising from the diversion of funds received from homebuyers and financial institutions. ED stated that the present fair market value of the attached assets is approximately Rs. 8,115 crore.
The investigation was initiated on the basis of 76 FIRs registered by the Delhi Police and the CBI against Unitech Limited, its promoters, directors, and others for alleged offences including cheating, criminal conspiracy, and diversion of homebuyers’ funds. ED stated that, so far, it has attached 1,296 movable and immovable properties worth Rs. 2,281.07 crore and has already filed one prosecution complaint and two supplementary prosecution complaints before the Special PMLA Court, Delhi.
ED's Chandigarh Zonal Office arrests real estate businessman Mr. Vikram Wadhwa
ED, Chandigarh Zonal Office has arrested real estate businessman Mr. Vikram Wadhwa on 29th May 2026 under the PMLA, in connection with an alleged Rs. 645 crore fraud involving IDFC First Bank. According to the ED, the investigation concerns an alleged embezzlement of funds from bank accounts of Haryana Government departments, the Chandigarh Administration, and two private schools. The agency alleges that Mr. Wadhwa, along with other accused persons, including bank and government officials, played a significant role in the generation, layering, and concealment of the alleged proceeds of crime.
ED has stated that Mr. Wadhwa allegedly received more than Rs. 70 crores in his personal accounts and further invested the funds in various entities and immovable properties. According to the ED, substantial amounts were transferred to jewelers, who allegedly provided cash against these transactions, which was subsequently distributed among various beneficiaries.
ED’s Mumbai Zonal Office conducted searches at 17 locations across the country as part of its investigation into the Cyprus-based online betting platform, Parimatch
ED, Mumbai Zonal Office, on 26th May 2026 conducted searches at 17 locations (across the country) against the online betting platform Parimatch. During the searches, ED has seized movable assets worth approximately Rs. 1.56 crore, including cash of around Rs. 1.2 crore, and frozen bank balances of about Rs. 3.8 crore. Various incriminating documents and digital devices were also seized. The investigation was initiated based on an FIR registered by Cyber Police Station, Mumbai, alleging that the platform duped users through online betting activities and generated more than Rs. 3,000 crores in a year.
The ED alleges that Parimatch operated through a sophisticated network of mule accounts, fintech entities, Business Correspondent networks, Grahak Seva Kendras, and retail outlets to collect, layer, and route user funds while concealing the money trail. Funds were allegedly channeled through seemingly legitimate business accounts, with certain proceeds ultimately transferred abroad through hawala routes. The platform also allegedly promoted its betting operations through surrogate advertising under the brands of Parimatch Sports and Parimatch News, including sponsorship of local sporting events and advertisements on quick-commerce platforms.
Central Bureau of Investigation (CBI)
First Chargesheet filed against Reliance Communications
CBI filed its first chargesheet on 29th May 2026 against 16 accused including Reliance Communications, five senior executives, and 10 bank officials over misuse of a Rs. 1,200 crore SBI term loan and LC facilities from Bank of Maharashtra and Syndicate Bank. Charges include conspiracy and cheating under the Bharatiya Nyaya Sanhita, 2023 (“BNS”) and criminal misconduct under the Prevention of Corruption Act (“PCA”).
Homebuyer fraud - 12th chargesheet filed by the CBI
CBI has filed its 12th chargesheet against M/s Decent Buildwell Pvt. Ltd. and its Director for allegedly defrauding homebuyers in a Greater Noida housing project. The investigation found that the accused allegedly induced purchasers through false assurances and misleading representations, resulting in wrongful losses to homebuyers and unlawful gains to the builder. The chargesheet has been filed under provisions relating to criminal conspiracy, cheating, and criminal breach of trust. The case forms part of a larger Supreme Court monitored exercise under which the CBI is investigating 37 similar cases involving alleged diversion of homebuyers’ funds by real estate developers and has already filed multiple charge sheets against several builder companies and certain officials of banks and financial institutions.
Central Bureau of Investigation
Latest case laws
Supreme Court of India
Supreme Court Dismisses Challenge to ED Searches in Tasmac Money Laundering Probe
The Supreme Court in P.R. Rajesh Kumar v. Enforcement Directorate., S.L.P. (Crl.) No. 11553/2026 has dismissed a challenge to the legality of searches conducted by the ED in 2025 in the TASMAC money-laundering investigation, upholding the Madras High Court's view that once the Adjudicating Authority has confirmed an attachment under Section 8 of the PMLA, and an appeal is pending before the Appellate Tribunal, a separate challenge to search legality will not ordinarily be entertained.
In this case, the Madras High Court had declined to examine the validity of the ED’s search and seizure proceedings, observing that the attachment had already been confirmed under Section 8 of the PMLA. In view of this, the Supreme Court dismissed the Petition while expressly preserving the Petitioner’s right to raise all available objections before the PMLA Appellate Tribunal.
Presence of a Public Servant in the Premises where Bribe has been Allegedly Accepted Not Enough to Establish Criminal Conspiracy under the Indian Penal Code, 1860
The Supreme Court of India in State of Uttar Pradesh v. A.K. Gaba ETC., Criminal Appeal No. (s). 3383-3385/2025 has categorically laid down that in cases alleging bribery under PCA along with the charge of conspiracy as defined under Section 120-B of the Indian Penal Code, 1860 (“IPC”), conviction cannot be inferred merely on the basis of ‘suspicion’ or ‘association’ and that there must be cogent material indicating meeting of minds between the accused.
Upholding the judgment of the Allahabad High Court acquitting the accused, the Supreme Court found that the prosecution had failed to establish the essential ingredients of demand, acceptance, and conspiracy beyond reasonable doubt to establish their allegations.
On the allegation of conspiracy, the Court observed that no independent material had been produced to establish any prior agreement or concert between the accused persons. Mere presence at relevant locations or association with the principal accused was held insufficient to infer criminal conspiracy. Finding the High Court’s view to be a plausible and well-reasoned appreciation of the evidence, the Supreme Court declined to interfere under Article 136 of the Constitution and dismissed the appeals.
In a Compliant Arising under the PMLA, Pre-Cognizance Hearing is Mandatory After the Commencement of the Bharatiya Nagarik Suraksha Sanhita, 2023
In a significant ruling, the Supreme Court while hearing Parvinder Singh v. Enforcement Directorate, 2026 SCC OnLine SC 903 has clarified that where cognizance of an offence under the PMLA is taken after the Bharatiya Nagarik Suraksha Sanhita, 2023 (“BNSS”) came into force, compliance with its first proviso to Section 223(1) of the BNSS is mandatory. The Court held that failure to grant the accused an opportunity of hearing prior to taking cognizance vitiates the PMLA proceedings, even where the underlying complaint was filed prior to the commencement of the BNSS. The Supreme Court held that the opportunity of being heard is substantive and mandatory in nature and confers a vital right upon the accused that forms an integral part of the right to a fair trial enshrined under Article 21 of the Constitution of India.
Payment of Salaries from Frozen Accounts Prohibited: Supreme Court Sets Aside Karnataka High Court's Order
In a recent judgment in Directorate of Enforcement v. M/s ZO Private Limited., S.L.P No. 12671/2026 the question before the Supreme Court arose from a limited but significant question: whether the Karnataka High Court was justified in permitting the respondent company to withdraw funds from bank accounts frozen under Section 17(1A) of the PMLA, specifically for the purpose of payment of employee salaries, while also directing it to pursue remedies before the Adjudicating Authority?
The Supreme Court held that such discretionary relief was inconsistent with the statutory scheme governing attachment and adjudication proceedings. It therefore set aside that part of the High Court’s order, leaving the issue of continuance of the freezing order to be decided by the Adjudicating Authority. While noting that the relief was granted to facilitate payment of employee salaries, the Court declined to approve such intervention outside the statutory framework and directed the Adjudicating Authority to dispose of the proceedings expeditiously.
High Courts
Delhi High Court Quashes Case Against M/S PPK Newsclick Studio Pvt. Ltd.: Holds the Underlying FIR and ECIR Were Based on Mere Assertions Without Any Basis
The Delhi High Court in PPK Newsclick Studio Pvt. Ltd. v. State (NCT of Delhi)., W.P. (C) No. 1130/2021 quashed both the FIR and the ECIR against the PPK Newsclick, holding that the allegations relating to foreign investment and alleged fund diversion in terms of the Foreign Exchange Management Act, 1999 (“FEMA”) were based on mere assertions unsupported by any substantive material. The Court found that the essential ingredients of cheating, criminal breach of trust, and criminal conspiracy under Sections 420, 406 or 120-B of the IPC were absent, particularly as there was no complaint from the investor and no evidence of inducement, deception, or unlawful gain. Concluding that the proceedings were founded on vague and legally untenable allegations, the Delhi High Court held that their continuation would amount to an abuse of the process of law.
Return the Excess Recovered Amount: Delhi High Court Directs the ED to Release Excess Recovered Amount Subject to Furnishing a Bank Guarantee of the Same Amount
The Delhi High Court in Satyam Caterers Pvt. Ltd. v. Directorate of Enforcement., Misc. Appl. (PMLA) 14/2026 has held that the mere pendency of the ED’s appeal against an order reducing the quantified proceeds of crime could not justify withholding the consequential benefit accruing to the appellant. The Court observed that, having partly succeeded before the Adjudicating Authority, the appellant was entitled to receive the excess amount recovered, unless a specific contrary order had been passed. Accordingly, the Court directed release of Rs. 1.54 crore upon furnishing a bank guarantee of an equivalent amount, while directing that the remaining Rs. 3.08 crore to continue to remain invested in a fixed deposit pending final adjudication of the appeals.
Gauhati High Court Refers Question of Disclosure of ‘Reason to Believe’ in Provisional Attachment Order to Larger Bench
The Gauhati High Court in Mrig. Mrinal Dhawan v. Union of India., W.P. (C) No. 2531/2026 has referred to a larger bench the question of whether the ED’s recorded ‘reasons to believe’ under the PMLA proceedings are confidential in nature or can these reasons be incorporated into a PAO. The reference arose after this bench expressed a view differing from that of a coordinate bench in Aftabuddin Ahmed & Anr. v. Enforcement Directorate & Ors., (2024) 4 GLR 466. While the earlier bench had treated such reasons as confidential and not liable to be disclosed, the High Court opined that there is no legal bar to include these reasons in the PAO and that their disclosure is consistent with principles of natural justice.
Punjab & Haryana High Court: No Vested Right to Pre-Cognizance Hearing in SFIO Prosecutions under the Companies Act, 2013
The Punjab and Haryana High Court in Vivo India Private Limited v. Serious Fraud Investigation Office, Ministry of Corporate Affairs, Union of India CRM-M-10158-2026 has held that the mandatory pre-cognizance hearing for accused persons under the first proviso to Section 223 of the BNSS does not apply to prosecutions initiated by the Serious Fraud Investigation Office (“SFIO”) under the Companies Act, 2013. The petitioner had challenged a Special Court’s order denying a pre-cognizance hearing, arguing that the BNSS introduced a substantive safeguard in favor of proposed accused in complaint cases.
Dismissing the petition, the Court reasoned that Section 212(15) of the Companies Act creates a “deeming fiction” that treats an SFIO investigation report as a “police report” rather than a private complaint. Since Section 2(1)(h) of the BNSS expressly excludes police reports from the definition of a “complaint”, the procedural requirements of Section 223 BNSS, which apply exclusively to cases instituted upon complaints, are inapplicable to prosecutions led by the SFIO. This ruling distinguishes SFIO prosecutions from PMLA proceedings where pre-cognizance hearings have recently been held mandatory.
Global enforcement roundup
United States
Judge refuses to rubber-stamp dismissal against Gautam, Sagar Adani and Others
Judge Nicholas Garaufis has refused to immediately grant DOJ's motion to drop, with prejudice, the FCPA and securities-fraud indictment against Gautam Adani, Sagar Adani, Vineet Jain and five others, calling DOJ's justification “terse, bland and conclusory” and invoking Rule 48(a), Federal Rules of Criminal Procedure, which he called a “sunshine provision” requiring the government to actually justify dropping a case rather than merely assert prosecutorial discretion. DOJ’s motion relates to allegations with respect to an alleged $250 million bribery scheme tied to solar energy contracts in India.
DOJ filed its detailed justification on 3rd July 2026, arguing the case “should never have been brought” and warning that judicial scrutiny of dismissal motions exposes privileged internal deliberations. The DOJ has defended its decision to permanently abandon the criminal case against Adani Group chairman Gautam Adani and seven others. The department argued before a federal judge that the prosecution was legally flawed, diplomatically counterproductive, and inconsistent with the Trump administration's enforcement priorities.
In a further development, on 8th July 2026, Judge Nicholas Garaufis ordered Gautam Adani to disclose by 15th July, on affidavit, whether any promises or agreements were made to the DOJ in exchange for its decision to drop the foreign bribery and securities fraud charges against him.
Parallel Securities and Exchange Commission and Office of Foreign Assets Control resolutions already in place
Separately, the SEC has agreed to settle its civil case against Gautam and Sagar Adani for $6 million and $12 million respectively (without admission of wrongdoing), while Adani Enterprises has paid $275 million to the US Treasury's Office of Foreign Assets Control (OFAC) to resolve allegations of breaching Iran sanctions through LPG cargoes that masked their true origin. Both resolutions proceed independently of how the criminal dismissal motion is decided.
SEC.gov | Gautam Adani and Sagar Adani
United Kingdom
SFO's first bribery DPA in nearly five years
The UK Serious Fraud Office (“SFO”) has entered into its first Deferred Prosecution Agreement (“DPA”) in five years with Ultra Electronics Holdings Limited, a UK-based defence, security, and aerospace company. The DPA relates to allegations that the company failed to prevent bribery by overseas third-party agents, contrary to the UK Bribery Act 2010. The SFO's investigation commenced in 2018 following a voluntary self-report by Ultra concerning suspected corruption in Algeria. The investigation was subsequently expanded to Oman in 2022 and later broadened in 2024 to cover the company’s operations across all relevant jurisdictions.
Under the terms of the DPA, Ultra has agreed to pay a sum of around £10 million financial penalty and £4.8 million towards the SFO’s investigation costs. The company is also required to comply with enhanced anti-bribery and corruption measures, including annual reporting to the SFO and demonstrating sustained compliance improvements and corporate reform over a three-year monitoring period.
SFO secures £10m from British defence supplier - GOV.UK
SFO DPA with Ultra Electronics Holdings Limited (formerly plc) - GOV.UK
Indian regulatory updates
CBI Meets DFS, PSBs, IDBI Bank and LIC to fast-track bank fraud investigations
CBI convened a coordination meeting on 25th June 2026 with the Department of Financial Services (DFS), Chief Vigilance Officers (CVOs) of Public Sector Banks, IDBI Bank and LIC of India to strengthen inter-agency cooperation and expedite investigations into pending bank fraud cases. The meeting deliberated key issues including approvals under Section 17A and prosecution sanctions under Section 19 of the PCA, pending documents, bank fraud complaints, One Time Settlement matters, recent judicial developments, and mule account-related concerns.
Detailed presentations were made by the CBI and participating financial institutions, followed by bank-wise discussions to address operational and case-specific issues. The participants emphasized the need for timely sharing of relied-upon documents, streamlining approval processes, and enhancing institutional coordination to overcome procedural bottlenecks. The meeting concluded with a consensus to maintain structured engagement between the CBI and financial institutions to facilitate expeditious investigation and resolution of bank fraud cases.
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