The D-Companies

Trade documents accessed by The Caravan from the United Kingdom, United States of America, Singapore and the Cayman Islands show that the National Security Advisor Ajit Doval’s younger son, Vivek Doval, runs a hedge fund in the Cayman Islands, an established tax haven. This hedge fund was registered merely 13 days after Prime Minister Narendra Modi’s government demonetised all existing Rs 500 and Rs 1,000 currency notes, in 2016. Vivek Doval’s business is linked inextricably to businesses run by his brother Shaurya Doval, a Bharatiya Janata Party politician who heads the India Foundation, a think tank that enjoys close proximity to the Modi government. That Vivek Doval runs an offshore hedge fund based out of a tax haven is notable in light of the established public position taken by his father—in 2011, Ajit Doval authored a report that advocated a strict crackdown on tax havens and offshore entities.

Vivek Doval, a chartered financial analyst who is a citizen of the UK and resides in Singapore, is the director of the hedge fund, named GNY Asia Fund. According to July 2018 document, Don W Ebanks and Mohamed Althaf Musliam Veetil are directors as well. Ebanks is named in the Paradise Papers—a leaked database of over 13 million documents regarding offshore entities—as the director of two firms, both registered in the Cayman Islands. He was formerly employed with the Cayman Islands government, and advised its finance secretary and cabinet ministers. Mohamed Althaf is a regional director for the Lulu Group International, which operates one of the fastest growing chains of hypermarkets in West Asia. The legal address of GNY Asia fund shows that it is under the care of Walkers Corporate Limited, a firm that finds a mention in the Paradise Papers as well as the Panama Papers, another leaked database that includes attorney-client information of millions of offshore entities.

The Caravan found administrative interlinks between Vivek’s firms and those run by his elder brother Shaurya Doval—several employees working for Shaurya’s businesses in India are closely involved with GNY Asia and entities connected to it. The overlaps between the brothers’ businesses indicate a larger financial universe run by them, with companies that are connected to the House of Saud, the ruling dynasty in Saudi Arabia.

In 2011, Ajit Doval, who was formerly a director of the Intelligence Bureau, submitted a report to the Bharatiya Janata Party, titled, “Indian Black Money Abroad: In Secret Banks and Tax Havens.” Among Doval’s co-authors was S Gurumurthy, a Rashtriya Swayamsevak Sangh ideologue who is currently serving as a director of the Reserve Bank of India. The report calls for a fierce crackdown on tax havens.

The Cayman Islands does not levy a corporate tax, making it an ideal destination for firms to register corporate entities without facing much scrutiny. By setting up complex, multi-layered ownership structures that include companies based in such tax havens, businesses of all variety are able to shield in parts or in full their taxable incomes.

GNY Asia was registered in the Cayman Islands on 21 November 2016. Amit Sharma, a chartered financial analyst, works as the hedge fund’s research head and its portfolio manager. Documents accessed by The Caravan show that Gordian Capital Singapore Private Limited, an asset-management firm, is a beneficial owner of the hedge fund—it enjoys three percent of all proceeds arising from GNY Asia. According to Gordian Capital’s website, GNY Capital Limited, a London-based company, “acts as an advisor” to GNY Asia.

Both Vivek and Sharma are listed as directors of GNY Capital. A document filed with the Companies House, the UK government’s registrar of companies, shows that the net worth of GNY Capital was close to £5,400 in October 2016—about Rs 4.4 lakh, based on the exchange rates prevailing at the time.

For the hedge fund to be operational, it would have required initial seed funding or capital—essentially, money that it could then invest ahead. The initial seed funding secured by GNY Asia is not known. Speaking to the business-news publication Bloomberg a few days after the hedge fund was registered, Sharma said that it will “get the majority of its seed money from strategic investors in the Middle East.” The article stated that the hedge fund would begin trading in December that year, that it would hold “concentrated positions in 30 stocks on average,” and that it would target an annual return of 15 percent. Sharma did not disclose the value of the assets that GNY Asia was managing at the time. A document filed with the US Securities and Exchange Commission in July 2018 put the total value of the fund at $11.19 million, or Rs 77 crore.

Edelweiss Custodial Services Limited is the official custodian for GNY Asia. Essentially, it holds assets on behalf of the hedge fund, and would be empowered to execute market transactions in its stead. In February 2017, the Edelweiss Group hosted the Edelweiss India Conference, an investor’s conclave. Such conferences offer large companies a platform to meet and suss out future investors.

Documents accessed by The Caravan show that GNY Asia attended this conference. A little over two months after it was registered in the Cayman Islands, GNY Asia was present at several meetings with some of the largest corporate players in the Indian market, including formidable banking institutions. At one such meeting with a private-sector bank, a research analyst named Akul Jhajharia represented the hedge fund. GNY Asia attended at least two other investor meetings in June 2017, with sizeable corporate enterprises. No GNY Asia representative aside from Jhajharia has been named in the documents we accessed.

A comparatively new and small fund, Vivek Doval’s GNY Asia stood out at these meetings. It shared its place at these tables with the likes of Goldman Sachs Asset Management Private Limited, which was incorporated in 2008; ICICI Prudential Asset Management Company Limited, incorporated in 1993; Kotak Mahindra Asset Management Company Limited, incorporated in 1994; and the SBI Life Insurance Company Limited, which was incorporated in 2000.

Though the value of GNY Asia at the time the meetings took place is not known, per the document submitted to the US government, it was valued at $11.19 million over a year later, in mid 2018. By comparison, Motilal Oswal Asset Management, a company that was present at one of the meetings in February 2017, held close to $2.5 billion or Rs 17,000 crore, of equity assets under its management at the time. HDFC Life Insurance Company was also present at two of the February meetings. By then, it was managing assets worth nearly Rs 92,000 crore. Kotak Mahindra Asset Management Company, another large insurance firm that was present at one of the meetings, was managing assets worth at least Rs 88,000 crore.

Curiously, when the meetings took place, GNY Asia did not have a Legal Entity Identifier code. The LEI is a 20-character code that acts as a unique identifier for a firm, company or any business that seeks to enter into a financial transaction. In the aftermath of the financial crisis that struck the American and European markets in the late 2000s, markets across the world were besieged by a common problem of lack of clarity and accountability in commercial transactions. To resolve this, the LEI number was devised as a measure of affixing a distinct identity for all financial entities. The number is now regarded globally as a risk-management parameter. GNY Asia was issued its LEI number in September 2017.

The procedure that led Edelweiss to include GNY Asia, a little-known, relatively small fund, domiciled in what global banks consider a high-risk jurisdiction, and lacking a key safety parameter, remains a mystery. The Caravan sent a questionnaire to Edelweiss Custodial Services, asking what parameters were considered before accepting GNY Asia as a client, and including it in the investors’ conference. We did not receive a response.

In 2014, SEBI classified several categories of foreign investors under the umbrella term, “foreign portfolio investor,” or FPI, aligning India’s classification with global norms. SEBI also began categorising FPIs into three types, based on the risk they posed as investors. Registering as an FPI allows SEBI to regulate and supervise the investor, through Know Your Customer requirements. At the time of publishing, GNY Asia was not registered as an FPI.

In early November 2018, the operating address for GNY Capital, the firm advising GNY Asia, was changed from a location in Hampstead, London, to one in Bounds Green, in the same city. Data on companies registered in the UK, which The Caravan accessed, shows that there are 120 companies registered at GNY Capital’s new address.

Media reports indicate that Vivek Doval was in Noida in mid January 2017. Along with his father, the NSA Ajit Doval, Vivek arrived at a registry office in Noida to complete ownership formalities of a flat purchased in his name in a complex called Unitech Horizon, in Greater Noida.

The Caravan sent a detailed questionnaire to Vivek Doval regarding GNY Asia—its assets, its seed capital, and its trading history, among others. We asked Vivek if, during this trip to India, he met any officers from the companies whose investors’ meetings GNY Asia attended in the subsequent months. We did not receive any response.

Edelweiss Custodial Service’s turnover has seen exciting rises in recent years—from Rs 5.64 crore in the financial year 2015–2016, Edelweiss Custodial’s business jumped to Rs 34.97 crore in the next financial year. It then climbed even higher, to Rs 166.8 crore in the financial year 2017–2018—near-magical jumps of approximately 520 percent and 380 percent, respectively. With regards to net profit, the financial year 2015–2016 was disappointing for the custody agent, as it registered a loss of Rs 80 lakh. But it scripted a turnaround here as well—in the next financial year, it clocked a profit of Rs 11.4 crore, which rose by over 330 percent to Rs 49.35 crore in the financial year 2017–2018.

In 2017, foreign direct investments—money coming into Indian markets from abroad—from the Cayman Islands rose meteorically. Data from the RBI’s annual report for that financial year shows that FDI inflows from the Cayman Islands shot up by 2,226 percent, rising to $1,140 million from $49 million in the previous financial year. In two quarters alone—one ending in December 2017 and another ending in March 2018—the cumulative FDI inflow from the Cayman Islands stood at $1.08 billion. The money which came to India from the Cayman Islands in the financial year 2017–2018 is nearly as much as the money which came to India from the same tax haven in the first 16 years of the century.

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Documents accessed by The Caravan also show that Vivek Doval’s overseas ventures are inextricably linked to businesses run by his elder brother, Shaurya Doval, in Asia. The elder Doval brother has emerged into public life in recent years—after a career as an investment banker abroad, Shaurya returned to India in 2009. Not long after, he became the director of the India Foundation, working alongside Ram Madhav, an RSS leader who is now a national general secretary of the BJP.

The organisation worked behind the scenes in Delhi for a few years, but its star rose after Narendra Modi was elected to power at the centre. The foundation has since organised various meetings with foreign ambassadors and dignitaries, and helped organise events for the prime minister’s foreign trips, including his high-profile rally at the Madison Square Garden in New York. Several BJP ministers serve as India Foundation’s directors, and its role as a close advisor of the central government is an open secret. Media reports indicate that Shaurya is now considering a political career as well. In December 2017, he attended the BJP’s state executive committee meeting in Uttarakhand, and has been officially residing in the state in recent months. The Doval family hails from the state’s Pauri Garwhal district, and it is this seat that Shaurya is reportedly likely to contest in the 2019 Lok Sabha elections. In mid 2018, Shaurya launched social programmes in Pauri Garwhal, aimed at improving employment, health and education in the district.

Shaurya’s public work has not obstructed his business—he sits firmly at the heart of a complex web of Asia-based companies that are intertwined with his brother’s ventures in the UK and the Cayman Islands. Shaurya is currently the CEO of Torch Investment Management, a Singapore-based asset-management company that is part of an umbrella group named Torch Financial Services. He was formerly the head of Zeus Caps, an equity and asset-management firm based in India. In early 2017, Zeus Caps’s operations merged with those of Torch Investment Management, forming Torch Financial Services. In January 2019, in his capacity as the head of Torch Investment, Shaurya delivered a talk at the Raisina Dialogue, a highly publicised conference on geopolitics, organised by the Observer Research Foundation.

The Caravan found that several people who are in business with the younger Doval brother are connected to the older one as well, or vice versa. Aside from his roles at GNY Asia and GNY Capital, Amit Sharma also serves as a director for YFin Advisor, a Delhi-based company. Shaurya Doval is the only individual with a share in the company. Jhajharia, who represented GNY Asia at an investors meeting in February 2017, was, according to his public profiles, formerly employed with Zeus Caps, which Shaurya co founded. Jhajharia also claims to be an associate at ZAD Support Services Private Limited—the former title of a company now named Torcia Advisors Private Limited, where Shaurya is a director. Another employee of Torch Investment, Priyanka Dua, an economist by profession, has a LinkedIn profile that states she is working with GNY Capital.

On the supervisory board of Torch Financial Services is Mishaal bin Abdullah bin Turki bin Abdulaziz Al-Saud, from the House of Saud, the family that rules over Saudi Arabia.

Torcia Advisors is registered to a residence in Dwarka that is owned by the NSA Ajit Doval. In October 2015, in a letter to the registrar of companies, Ajit Doval had declared that he had “no objections” if ZAD, as Torcia was then known, were to use this residence as its registered office.

The Indian job portal wisdomjobs.com recently featured a post from Zeus Strategic Management Advisors Private Limited. Shaurya and his mother serve on the board of directors for Zeus Strategic, alongside one Puneet Kamra—who is also a director at Torcia Advisors. The post was soliciting applications for a business analyst for GNY Capital, Vivek’s UK-based firm.

The Caravan sent Shaurya Doval a detailed questionnaire regarding his business ventures and the overlaps with his brother’s firms. He did not respond. Our request for comment to the National Security Advisor Ajit Doval, too, went unanswered. We will update the report if and when we receive responses.

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In his 2011 report on offshore entities and tax havens, Ajit Doval wrote, “Let us look at the volume of the untaxed black money that is estimated to circulate in and dominate the global financial markets unquestioned and unsupervised.” The report, which had been commissioned by the BJP, said. “These monies, which have no declared or known owners, are laundered into the official financial markets of the world through the intervention of tax havens, which are countries that levy no tax or levy what is an apology for tax, so as to attract capital to their countries. These tax havens are largely tiny tots in the global geography and demography but they hold the rest of the world to ransom … This money, besides being tax evaded, is entirely unsupervised.”

The report recommended that every electoral candidate confirm in their election affidavit that they do not hold illegal money abroad. According to the report, it “does not need to pontificate on the evil effect of this kind of untaxed, unmonitored and uncontrolled money, to the global financial system.”