ICICI BANK, CASE 6: J. SUNEJA, CLUSTER HEAD; NEERAJ, RELATIONSHIP BANKING/PRIVILEGE BANKING, CENTRAL DELHI

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The complicity permeates all levels, with senior managers as willing as junior staff to turn black into white because it is a common practice for them: “Sir, sachi baat ye hai aap bol rahe hain. Ninenty-nine per cent log karte hain wo bolte nahin hain (Sir, the truth is that you are talking about it. Ninety-nine per cent people actually do it but don’t talk about it)” – J. Suneja

At this ICICI branch in Central Delhi, the Cobrapost journalist first meets Neeraj who suggests a very lucrative, long-term plan, Systematic Retirement Solution, which ensures life-long returns. When the reporter says the transaction has to be done in cash, Neeraj replies: “Cash to hum nahin le sakte (We can’t accept cash).”

But the money belongs to a politician who wants to invest it in three names. It has to be done in cash, and at the earliest. After a pause, Neeraj agrees to look into it: “Mujhe doh minute do. Doh minute mein ye pata kar leta hoon ki cash ka kuch kar sakte hain ya nahin … aap doh minute baitho (Give me 2 minutes. I will find it out in 2 minutes if we can do something about cash or not … you sit here for 2 minutes).”

Neeraj returns shortly with a solution. He begins by exploring the possibility of various proofs of identity that can be submitted for the cash transaction, other than a PAN card: “Mere khayaal se aap samajh hi rahe ho ki PAN card dene se kya problem hogi (I think you understand what problem you may face if you give your PAN card).” Break the money, he suggests, to invest in three–four names.

But why engage in these discussions if cash transactions are not possible?
Neeraj: “Aisa hai na … agar aap tab se keh rahe ho… ye investment hai… theek hai … mehnat se saari cheezein ho hi jaati hain (This is like … if you have been saying for a while … this is the investment … alright … hard work makes everything possible).”

Neeraj proceeds to open up options for investing the illegally gained cash. But it is imperative that it should be a safe mode of transaction, the reporter emphasises. Neeraj knows the perils of laundering money: “Nahin … aapke liye koi dikkat nahin hai, mere liye bahut badi baat hai, naukri chali jayegi (No… it is not a problem for you … but it is a big thing for me … I’ll lose my job).”

Yet he is ready to serve the criminal intentions of his customer: “Hum yeh kar sakte hain ki ek baar mein hum account mein agar zyada paisa dalte hain to nahin … doh ya teen lakh karke teen chaar dino mein daal dein … aur main ye keh raha tha ki ek account mein pachaas lakh nahin rakhiyega, aapke teen chaar account rahein … humare bank mein teen chaar account nahin khul payenge … aisa bhi to hum kar sakte hain ki baaki bankon mein …. jaise HDFC hai ya Kotak hai jahaan log jaanne waale hain, unko bolke wahan pe account khulwa denge (What we can do is…if we put in a large sum of money at a time in an account … not that … put 2 to 3 lakh in 3 or 4 days … and I was saying that you should not put 50 lakh in one account … you should keep 3 or 4 accounts … we cannot open 3 or 4 accounts in our bank … we can also open accounts in other banks … like HDFC or Kotak where people know me … will talk to them and open accounts there).”

So, how do we proceed with these options without linking them with a PAN? Neeraj has a way out: “Aisa kar sakte hain na ki aap sirf passport dijiye, passport ID aur address proof dono ka kaam kar deta hai aur sirf passport se hum yahan to account khol hi dete hain, baaki jagah bhi account khol dete hain … ab yahan pe dus laakh jama karenge, baaki doosre bank mein dus lakh jama karenge …teesre bank mein jama karenge… PAN number hum denge nahin … to track nahin … in the sense ke best try kar sakte hain (We can do it this way. You give only your passport. Passport doubles up as ID and address proof and with just the passport we can open an account here … we can open accounts in other places as well. Now we will deposit 10 lakh here … will deposit 10 lakh in other banks. If we don’t submit the PAN number, then it won’t be tracked … in the sense we can try our best).”

But we should stick to the tried and tested methods. No one wants any trouble later.
Neeraj says: “Ab kya hai ye Karol Bagh ki market hai … yahan maximum log waise cash wala kaam karte hain … baaki logon ka kya hai, kabhi agar aa gayee baat notice mein thoda paise deke nikal lete hain, naam waise kuch as such nahin hota hai. Aap keh rahe ho ki politician hain … naam aana hi kharaab ho jayega … isliye main thoda sa extra precaution le raha hoon (This is Karol Bagh market … here most people operate only through cash… as for the rest, if the matter comes into notice, they pay some money and get away with it … name as such doesn’t come up. You are saying he is a politician … if the name comes out he will get a bad name … which is why I am taking extra precaution).”

Would his bank provide a locker in February to keep Rs. 5–7 crore of cash in bundles of Rs. 500 bills? Neeraj: “Locker wocker ki to koi dikkat nahin hai…ho jayega…paanch sau ya hazaar mein ayenge (Locker is not a problem at all … that will be done … will it be in bills of 500 or 1000)?”
Shouldn’t we get some guidance from his seniors? Neeraj acquiesces and takes the reporter to his Branch Manager J. Suneja who also happens to be the cluster head. He cuts to the chase: “Haan mujhe bataa rahe the … khaata humein cash mein kholna hai, wo koi issue nahin hai (Yes, he was telling me … we have to open an account for cash … that is not an issue at all).”
Suneja points out how a loophole in the system could be used to our benefit: “Aap jab cash jama karte hain khate mein, dus lakh se neeche jama karte hain to waise bhi koi nahin poochta…dus lakh se upar jama karte hain to main aapse poochta hoon source kya hai …to matlab ek process hai jismein aap declaration dete hain bank mein. Agar aap comfortable hain declaration dene mein to I am fine … kya bolein mere ko property mein … wahin ka paisa hai … jo bhi declaration hai jo bhi source hai wo batayein … dus lakh se neeche hai roz aath lakh jama kayayen 10 lakh jama karayein (When you deposit cash in the account, if it is below 10 lakh then no one asks … if it is more than 10 lakh then I will ask you the source of income. There is a process in which you have to give a declaration in the bank. If you are comfortable in giving declaration, then I am fine … like you say you have a property … that’s where the money has come from … whatever your declaration is, tell whatever the source of money is. Below Rs. 10 lakh, you can deposit daily Rs. 8 lakh, Rs. 10 lakh).”

And routing the deposits to investments from the account will not be a problem.
Meanwhile, Suneja leaves the cabin to attend to a call. Turning to Neeraj, our reporter asks if it is the safest place to put in black money. Replies Neeraj: “Bank ke through ye sabse safe hai (It is the safest when done through the bank).”

When Suneja returns, our reporter says that, surely the Income Tax Department will trouble him if he submits his PAN for cash transactions of such a magnitude? Suneja: “Jahaan tak meri understanding hai, maine dekha nahin hai aisa. Abhi bhi aisa koi system nahin bana hai ki … main ye nahin ke sakta ki … nahin bilkul… main nahin bol raha ki 100 per cent safe hai… main jhoot bhi bol sakta hun … lekin ye hai ki point zero one per cent chance hota hai (As far as my understanding goes, I have not seen this to happen. Even now there is no such system in place that can … I cannot say … absolutely not … I am not saying that this is 100 per cent safe…I can also tell you a lie, but there is a .01 per cent chance).”

He goes on: “Ek cheez to main aapko bata deta hun ki bank apne aap kuchh inform nahin karta hai unless it is asked for (I will tell you one thing that bank does not volunteer to give any information unless it is asked for).”

While you’re at it, can you organize a locker so we can store 5–7 crores of cash? Suneja is happy to help: “See locker mein aap kya daalto ho wo humein bataane ki zaroorat bhi nahin hai na… locker aapko issue … locker koi issue nahin. Locker to humare derh sau khaali hain (See, you do not have to tell us what you keep there in the locker … we will issue a locker… locker is not an issue. We have a hundred and fifty lockers lying vacant).”

Suneja calls in another banker called Rijvish who is initially a bit unsure about depositing cash. But
Suneja wants to expedite matters and says briskly: “Koi problem nahin hai woh basically risk kya involved hai usme. Maine kaha risk koi hota nahin hai lekin point one per cent to hai hi (There is no problem at all … what is the risk involved basically. I told him that there is no risk but you can say there is 0.01 per cent risk).”

Directing Rijvish to deal with the client, Suneja leaves the room. Taking his cue from Suneja, Rijvish now says there is no risk involved in depositing cash and routing it through an account. Says Rijvish: “Mote account jo khulte hain main dekhta hun … arre humein kya dikkat hai … hum to business karne ke liye baithe hain (I look after opening of big accounts … we have no problem … we are siting here to do business).” He futher advises that two accounts should not be opened on the same address, to avoid detection or linking.

At the close of the meeting, Suneja shares another truth, over a cup of tea: “Sir, sachi baat ye hai aap bol rahe hain. Niniety-nie per cent log karte hain wo bolte nahin hain (Sir, the truth is that you are talking about it. Ninety-nine per cent people actually do it but don’t talk about it).”

He further assures our reporter that no information is shared with anybody, unless called for by the regulators.

J. Suneja’s reaction to the investigation: Jo bhi hota hota hai RBI guidelines ke according hota hai 

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