ANTI-CORRUPTION LAW SERIES-7


ANTI-CORRUPTION LAW SERIES-7

Black Money (Undisclosed Foreign Income & Assets) and Imposition of Tax Act, 2015
This enactment levies penal rates of tax on any undisclosed asset or income held abroad by a person resident in India and penalises individuals for non-disclosure of foreign income or assets, wilful attempt to evade tax, failure to furnish requisite returns, etc.  The objective of the Act is to target undisclosed incomes and assets (potentially derived through illegal means, including corruption), which have been stashed offshore by resident Indians.
The Fugitive Economic Offenders Act, 2018
In order to prevent offenders accused of economic offences from evading prosecution within the country, the Fugitive Economic Offenders Act, 2018 (‘FEOA’) was recently enacted on July 31, 2018.  The FEOA targets fugitive economic offenders against whom an arrest warrant has been issued for certain predicate economic offences involving Rs. 100 crores and who have either left the country to avoid criminal prosecution or are abroad and refuse to return to face criminal prosecution.  Predicate offences under the FEOA cover cheating and counterfeiting under the Indian Penal Code, 1860, offences under the PCA, PMLA, corporate fraud under the Companies Act, benami transactions and tax evasion.  The strength of the FEOA lies in its far-reaching measures of immediate confiscation of all properties of any abscondee, which act as a strong deterrent against any desertion from the country.
The past few years have witnessed a stark change in the approach towards enforcement of anti-corruption laws.  One of the driving forces behind this change has been the increased public focus on the issue of corruption in government, combined with an active role played by the judiciary in corruption matters.  This movement was triggered by the discovery of several instances of large-scale corruption by highly influential ministers and bureaucrats (in particular, scams concerning the allotment of telecom spectrum and organization of the Commonwealth Games in Delhi in 2010).  This led to a public outcry regarding the impact of corruption on the Indian economy and its citizens – amidst growing public dissatisfaction regarding the state of affairs, the government reacted by enacting various legislative measures, such as the Lokpal and Lokayuktas Act, 2013, to bolster perceived weaknesses in India’s anti-corruption laws.  Further, the judiciary also undertook a supervisory role in the investigation into the telecom spectrum case and closely scrutinized the progress of the investigative agencies.
On account of an increasing number of delinquent borrowers and non-performing assets, anti-corruption enforcement has recently directed its focus towards corruption in the financial services sector, particularly in the approval of large loans.  The Supreme Court of India took an expansive view of banking law by holding that employees of banks (whether public or private) are considered public servants under the PCA.1  In 2016, the CBI arrested the former chairman and managing director of the  United Bank of India for having obtained funds to benefit herself and a private firm owned by her husband and son from private companies to whom various credit facilities were granted by the bank.  Law enforcement agencies have initiated proceedings against various corporate giants and multi-millionaire businessmen for defrauding public and private sector banks. While certain accused individuals have fled India, the Indian government has, in parallel, increased its efforts to extradite such individuals and has charged them under provisions of the PCA, PMLA and the Black Money (Undisclosed Foreign Income & Assets) and Imposition of Tax Act, 2015.
Another growing trend is that enforcement agencies have become more sophisticated in unravelling complex corporate or financial structures, and have increased their reliance on technological tools.  Importantly, they have also shown a willingness to take the assistance of specialists such as private forensic auditors or investigators to help them in this endeavor, and provide expertise that they may lack themselves.  Indian enforcement agencies have also strengthened their relationships with agencies from other jurisdictions, and we have witnessed far more cooperation and coordination in cross-border enforcement efforts.
Perhaps the most welcome change has been an increased appetite among enforcement agencies to aggressively investigate and pursue corruption cases, even against high-profile politicians and powerful bureaucrats – this marks a clear departure from the past, where such cases may have been approached with lethargy and caution.  Recent years have seen instances where former central government ministers (telecom spectrum scam), high-ranking politicians and bureaucrats (Commonwealth Games scam), a former head of the Indian air force (defence procurement scam), etc., have been investigated, charged and prosecuted by Indian enforcement agencies – such cases remain under trial as of date.  Recently, an influential state politician was convicted by the Supreme Court of India for possessing disproportionate assets.
At the outset, it should be noted that unlike the US Foreign Corrupt Practices Act, the PCA expressly prohibits the payment of ‘facilitation payments’ or ‘grease money’.  It is important to recognise that, unlike the Service Rules or the FCRA, the PCA does not provide for any de minimis thresholds for gifts, meals, or hospitality in respect of public servants and the thresholds specified under the Service Rules and the FCRA can, at best, be viewed as guidelines for de minimis amounts, on the assumption that there is no intent to violate the PCA.  Moreover, the Supreme Court of India has held that the quantum paid as gratification is immaterial and that conviction will ultimately depend upon the conduct of the delinquent public official and proof established by the prosecution regarding the acceptance of such illegal gratification.2  It should be noted that the true test of whether a person shall be prosecuted under any anti-bribery legislation is whether the mens rea to commit an act of corruption or violate any anti-bribery law existed as on the date of such payment.
Therefore, the receipt of gratification or valuable things (however insignificant their value) by a public servant, which is not within the legal remuneration of the public servant, could potentially attract prosecution under the PCA.  The provision of gifts, meals, or hospitality of a nominal value (and below the thresholds specified in the Service Rules or FCRA) could also be considered inconsistent with the PCA and constitute an illegal act.  Additionally, the PCA does not have an ‘adequate procedures’ defence – however, the compliance measures undertaken by a company may be helpful in demonstrating its lack of mens rea to commit an offence under the PCA (for example, where an employee performs an unauthorized act of bribery).

In view of the foregoing, the compliance regimes of multinational organisations operating in India have to be carefully crafted and catered to the Indian legal framework, and specific legal advice ought to be obtained in this regard.
Attorney-client privilege

Indian law recognizes that communications between an attorney and a client are privileged.  It is, however, important that advice on Indian law be sought when evaluating the availability of privilege in the specific facts of every case.  In the context of an investigation, we suggest that the company should appoint an Indian law firm to conduct the investigation, and (although this position remains untested as a matter of law) any experts, investigators, or auditors should be appointed by the law firm to extend the privilege (to the extent available) to any work product prepared by such experts, investigators, or auditors.

S.No
Dear Ngo leaders promote activities such as :-

(All forms of corruption must be ended to secure the basic rights of all people and ensure a world where everyone can live in dignity)

1.
Organize, communicate, and raise awareness on Anti corruption laws to your target people.
2.
Identify the victims and witnesses of corruption in your working area

3.
Identify the need of Legal consultancy for Consumer rights, women’s rights, Child rights, aged rights, revenue, education, documents registration, social welfare, public and temple property panchayat, forest, insurance, and all government department corruptions related issues etc

4.
Contact for such issues with an affidavit and we will make the difference


We also know that corruption can’t be rooted out in one big sweep. Rather, fighting it is a step-by-step, project-by-project process.


MANISHANKAR
CEO-Anti-Corruption And Human Rights Movement®-Chennai
Mobile:91 9087856137
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Twitter @anticorp_2007          
    







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