1, Mohamad Hu: IN THE SUPREME COURT OF MAURITIUS Abdool Rahim, an estate agent residing at 46 Sir Virgil Naz, Port-Louis ‘and holder of National Identity Card A0B07853820320 MAKE SOLEMN AFFIRMATION AS. SLIM AND SAY THE FOLLOWING: 1 2 lam making this disclosure by virtue of section 49 (1}(b) of the Prevention of Corrup- tion Act whereby at the time | make the disclosure, | believe that on solid, factual, and reasonable grounds that the information | disclose is true and is of such a nature as to warrant an investigation under this act and | shall hence incur no civil or crimi- nal liability aver that | have been solicited by Sylvio Sundunum and through him, I had several meetings with Hon Ravi Yerrigadoo and Dick Kwan Tat to set up a financial structure through the setting up of overseas bank account, namely in Dubai and Switzerland, in order to transfer and legitimise funds. During a meeting with Sylvio Sundunum, Hon. Ravi Yerrigadoo and Dick Kwan Tat, Sylvio Sundunum stated that he has undeclared funds which he wish to legitimise through Bet 365, platform of which | am a regular player. They also discussed that a structure should be set up to accommodate funds which were going to be received subsequently. | verily believe that Hon. Ravi Yerrigadoo went beyond his duties in issuing docu- ments, facilitating procedures for me, drafting my request for variation order, and giving instructions on setting-up of bank accounts abroad. Factual Chronology of Events Before 2014 | used to be self-employed and used to work in the family business from 2008 to 2014 On or about 2014, | started to live on betting in the local horse racing industry and online betting on soccer fixtures with my gains as only source of revenue lam pleading guilty in a case of swindling lodged by Mr Atish Laufur, ref: 400/16 in- termediate court Port-Louis | aver that an agreement has been reached with Mr Laufur to settle the issue through two reimbursements of MUR 250 000 each. aver that when | was arrested for this swindling case, a freezing order was issued upon my bank accounts. As a result, on or about October 2016, | tried to transfer mygains on Bet365 to my MCB account 000072296356 but latter transaction failed as | noticed that the sum of about € 10 000 was not being transferred 10. The agreement of paragraph 8 was signed by both parties in front of Me Pazany Rangasamy, Attorney on 30/11/2016 (Annex 1} 11 On or about November 2016 | came to know Mr. Sylvio Sundunum, General Manager of Dry Cleaning Company Ltd as a training partner at the Gym of the Hotel Le Suffren and we became close friends 12, As early as November 2016 | informed him of my case explained in paragraph 7. 13. Laver that the verbal reply of Sylvio Sundunum was that he would first have a word about it to ASP Monvoisin, then the Attorney General. The name of same ACP Mon- voisin would later be quoted on 3“ July 2017 in a SMS sent to me by Syivio Sundunum as evidenced in (Annex 2) 14. Sylvio Syndunum verbally explained to me that he would ask ASP Monvoisin to con~ vince Mr Laufur to find an agreement with me. 15. A few days later, Sylvio Sundunum verbally informed me that ASP Monvoisin had re- fused to enter into such a process and he would now start talking with the Attorney General, whom he referred to as his “friend”. 16. | aver that at the same period, Sylvio Sundunum had expressed the idea of me help- ing him to obtain gain receipts from Bet365 to normalise some “undeclared funds” which he claimed to be in possession of, 17. On 14th February 2017, upon recommendation of Sylvio Sundunum, | met with Hon. Ravi Yerrigadoo as evidenced by screenshot of my first WhatsApp message to Hon. Ravi Yerrigadoo on his phone number +230 52 50 13 20 (Annex 3) 18, The meeting took place at the office of Hon. Ravi Verrigadoo. I exposed my swindling. case to him and explained the consequences of the freezing order as explained in paragraph 9 of this affidavit. 19. | aver that Hon. Yerrigadoo told me that he would “enquire to FIU and the bank to see what is the exact problem.” 20, Sylvio Sundunum was absent from the country at the time as he was attending a wedding in the Philippines. 21. On the 15" of February 2017, Sylvio Sundunum WhatsApped me a picture of him on aplane to the Philippines. (Annex 4) 22. On the 16” of February 2017, at 9h14, | sent a detailed statement of my MCB ac- count through 7 photos sent by WhatsApp as evidenced by WhatsApp screenshot (Annex 5 and 6} 23. On the 16" of February 2017, at 09h25, Hon. Ravi Yerrigadoo replied to the pictures sent through WhatsApp “Noted. See you at 10.30” (Annex 5}24. On the 16" of February, | had yet another meeting with Hon. Ravi Yerrigadoo. Same was communicated to Sylvio Sundunum by WhatsApp. The latter acknowledged by replying "Good bro, meet and send me a brief later, | know we are in good hands now. Cheers” (Annex 7) 25. After that meeting of 16" February 2017, to expose further the facts of paragraph 16, | sent to Hon. Yerrigadoo, via WhatsApp, & screenshots of transfers from Bet365 to my MCB Visa Debit Card 7822 as evidenced by screenshots and pictures (Annex 8 &9) 26, During that meeting of the 16" February, Hon. Yerrigadoo advised me to firstly get a certificate of character. 27. Later that day, | aver that one of his advisors drove me in his white Nissan Juke to Line Barracks Police station for procedures to get the certificate of character. There, the advisor told the policeman that the process had to be “quick, because the Attor- ney General asked it to be so” 28. At 15h22 that day, through WhatsApp | sent the cause number of my case "400/16" to the advisor who replied “OK” as evidenced by WhatsApp screenshot (Annex 10) 29. On the 17" of February, at 11h10, Sylvio Sundunum enquired about the meeting with the minister the previous day through WhatsApp. He stated that he will “talk to him later to get some feedback.” (Annex 11) 30,1 updated him about the meeting, stating that “almost everything is clear for the transaction for Bet365". During the meeting, as | said on WhatsApp, the subject of my swindling case was also brought up. | stated to Sylvio Sundunum that “For my case he need the bried (sic) which the lawyer will give me today and will give it to Ravi’. (Annex 12) 31. | aver and | verily believe that Syivio Sundunum was back from Philippines via Dubai ‘on or about 22™ February 2017. 32, | aver that at all material times in that period Sylvio Sundunum and | were constantly discussing on WhatsApp about the issue of my case and also about the procedures for him to achieve the objectives set in paragraph 16 of this affidavit as evidenced in WhatsApp screenshots. (Annex 13, 14 and 15) 33. | aver that before Sylvio’s return to Mauritius, during one of the 3 or 4 meetings | had with him at bis office, Ravi Yerrigadoo introduced to one lawyer Dick Kwan Tat and one foreigner, Dennis Zandaza, presented to me as a Swiss n, both of them close to Ravi Yerrigadoo. 34, | aver that Dick Kwan Tat and Dennis Zandaza proposed the services of one wealth management company where I could deposit the gains from my betting. During dis- cussions that day, it became clear to me that Ravi Yerrigadoo was well aware of our objectives set out in paragraph 16 of this affidavit,35. | aver that I never met Dennis Zandaza since that 1* and only meeting mentioned in paragraphs 33 and 34, 36. As for Dick Kwan Tat, he was very much involved in what was going to be decided. It was during a meeting with him, Ravi Yertigadoo, and myself, before Sylvio’s return to Mauritius, that the idea of me travelling to Dubai, France and UK to open bank ac- ‘counts where | could transfer gains from Bet365, was first initiated. This is evidenced in WhatsApp screenshot where Ravi Yerrigadoo and | talk of “variation order”. (An= nex 16) 37. The “variation order” mentioned in paragraph 36 is about getting me to travel de- spite the objection to departure against me. 38. | aver that the application form for “variation order” was written in the office of the ‘Attorney General in the presence of Ravi Yerrigadoo. It was the latter who dictated the count to be mentioned in the applic 2. UAE, France and UK, 39, | verily believe, and this will be explained in further paragraphs, that Ravi Yerrigadoo forgot to add Switzerland in the list of countries. 40. My lawyer in my swindling case, Me Luckeeram, appeared with me for the debates on the variation order. | aver that when he had questioned me about the reasons | needed to travel, | replied “it’s for business with Sylvio Sundunum.” 41.1 aver that when Me Luckeeram questioned me about the identity of those who helped me to fill-in the application form for variation order, | evaded the question and simply replied: “Sylvio's lawyer” 42. | aver that Syivio Sundunum accompanied me to court on the 9" of March for the ruling of the magistrate on the application for variation order. 43, | aver that the magistrate granted me the variation order against guarantee of Rs 300 000. 44, | aver that Sylvio Sundunum tried to settle this sum by cheque on the 9" of March 2017. But the court casher explained that he accepted cash payments. As we neared the closing time for court cashier, Sylvio decided to return to settle the sum in cash, the next day. 45. Laver that, the next day the 10 of March 2017, Sylvio Sundunum paid Rs 300 000 in cash, as evidenced by receipt. (Annex 17) 46. | aver that Dick Kwan Tat also accompanied us to court on 10" of March 2017. 47. Laver that Dick Kwan Tat asked me for Rs 2 000 to “bribe an usher so that he trans- fers the proof of payment of guarantee for variation order immediately to the Pass- port and Immigration Office”. | aver that | received my passport from the PIO on the very same day, and that on the very same day | travelled to Dubai with Syivio Sundunum and Dick Kwan Tat as evidenced by Annex 18.48. | aver that in the meantime that procedures for VISA for UAE were carried out by Syivio Sundunum’s assistant. 49. | aver that during the VISA process, my passport was in the custody of the Passport and Immigration office, because at the time, the variation order hadn't been issued yet. 50. | aver that on 27" February 2017 Dick Kwan Tat accompanied me to the passport and immigration office where one officer after private discussion with Mr. Kwan Tat, allowed us to take photos of my passport for VISA purposes. 51. | aver that at the very moment after taking photos of the passport, Ravi Yerrigadoo asked me for the photos via WhatsApp. “I need scan of first page with your photo” adding, “please send me a clearer photo with just first page with your photo, with no laze lights” (..) “ we need to send with formalities” as evidenced in Annex 19 & 20. 52. | aver that the UAE ministry of interior issued an Entry Permit in UAE in my name on the 7 March 2017 as evidenced In Annex 21. 53.1 aver that in the meantime, | created a bet 365 account in the name of Sylvio ‘Sundunum. The 1 deposit of €250 was made on 1* of March 2017 at 19h05 with reference number D839813629DC through a deposit debit card 1079 as evidenced in picture Annex 22 & 23, 54, Laver that 2 other deposits of €540 and €300 respectively through the same deposit debit card 1079 were made in the following hour on the very same day. 55. | verily aver that that the deposit debit card 1079 is a prepaid card issued to Sylvio, Sundunum by Afrasia Bank as evidenced in Annex 24. 56.1 verily believe that Sylvio Sunundum credited the sum of €10 000 on this prepaid card 1079. 57. | aver that | was physically in the office of Sylvie Sundunum at Dry Cleaning to create this account 58. | will now explain the modus operandi decided by Sylvio Sundunum, Ravi Yerrigadoo and Dick Kwan Tat for me to achieve objective set out in paragraph 16 of this affida- vit 59. | aver that at least once before our departure for Dubai, | met with Sylvio Sundunum, Ravi Yerrigadoo, and Dick Kwan Tat at the house of Sylvio Sundunum at Kensington Palms, Quatre-Bornes. 60. To achieve the objectives set out in paragraph 16 of the affidavit, | advised Sylvio ‘Sundunum to create an account on Bet 365, which is described in paragraph 53 to 56 of this affidavit. 61. My role would be to act as betting advisor and operator on this account and fructify the balance.62, My current Bet365 account would also be credited by Sylvio Sundunum and | had to fructify the balance. 63, The process at paragraph 58 was started as early as March 2017 through various de- posits and bets placed. 64. | aver that the initial setup of laundering was through authentic bets, as explained in paragraph 58. The strategy for the first method has been betting on extreme favour- ite teams to ensure winning, 65. We would then cash out the gains through the prepaid cards which is a service of- fered by Bet365 just as the deposit explained in paragraph 53 to 56. The money cashed out would then be deposited into banks with the authentic receipts being presented as “source of funds”. 66. | aver that a second method of laundering was discussed in the presence all parties concerned mentioned above. This would imply fake Bet365 receipts sent through fake bet365 email addresses hosted by the provider gmail.com. 67. One of the fake Bet365 receipt of € 2 354 350 was fabricated in my presence in Feb- ruary 2017 at the office of Sylvio Sundunum. (Annex 25). This fake receipt was asso- ciated to my Bet 365 account. | verily believe that this sum was going to be obtained from other sources by Ravi Yerrigadoo and Dick Kwan Tat. 68.1 verily believe that many fake Bet365 receipts, associated to the account of Syivio Sundunum have been fabricated. 69. The modus operandi would then be about amalgamating the fake receipts and the authentic activity of the accounts, and an official letter from the Attorney General to convince banks that the deposits can be safely accepted. 70. | aver that such a letter as quoted in paragraph 69 signed on the 10" of March by Ravi Yerrigadoo with the official stamp of the Attorney General's office (Annex 26) was sent to me by email from the email account of Sylvio Sundunum ssundanum@drycleaning.mu on the 31% of March 2017 as evidenced by the email screenshot (Annex 27} TA.| aver that Sylvio Sundunum was in possession of the original letter since March 2017. 72, Laver that same letter was shown to Emirates NBD bank when { was in Dubai on the 13" of March in company of Sylvio Sundanum and Dick Kwan Tat. 73.1 verily believe that Sylvio Sundanum successfully opened a bank account at NBD Bank. 74, | aver that | could not open the account at NBD bank because of some missing doc- uments. This is evidenced in WhatsApp messages (Annex 28) exchanged with Mrs Savita Goswamy, account relationship manager at NDB Bank.75, laver that given the setback for my account in Dubai, decision was taken to travel to Switzerland. France was aiready on our flight plan. Syivio wauld be attending a real estate event in Cannes and | would seize the opportunity for tourism. 76. | verily believe, based on Dick Kwan Tat’s affirmations, that decision to fly to Switzer- land was based on Ravi Yerrigadoo's instructions, 77. aver that Dick Kwan Tat explained that the Swiss bank which would accept opening ‘an account to my name was known to and recommended by Hon. Yerrigadoo. 78.1 aver that decision was taken to take the train from Paris to Geneva through Lyon was taken based on the fact that my variation order only allowed me to stop in Du- bai and France to avoid any immigration controls and problems in Switzerland, 79. aver that according to Dick Kwan Tat, the decision to avoid the immigration con- trols by opting for the train instead of the plane, was an instruction of Hon, Ravi Yer- rigadoo. 80. | aver that from Dubai, the delegation composed of Syivio Sundanum, Dick Kwan Tat and myself flew to France. 81. From France we took the train to Geneva through Lyon as evidenced by the train ticket (Annex 29} 82. | aver that we went to the Compagnie Privée de Conseils et d’Ivestissements S.A a bank in Genave to open an account to my name, and another to Sylvio’s, 83. There we met with André Himmelberger the Deputy General Manager, whose busi- ness card remitted to me is annexed. 84, | aver that we also met with Nabil Jean Sab, the CEO who welcomed us in the follow- : “Ravi already talked to me, let's start”. ing wor 85. | verily believe that Sylvio Sundanum’s account was quickly opened. 86. | aver that André Himmelberger took my passport to start opening my account. 87. aver that after a few minutes, he called on Nabil Jean Sab and they had a discussion in private. 88. aver that Nabil Jean Sab came to us and said in french: “there Is a problem. We cannot open your account. You are on illegal stay on Switzerland territory as your passport stipulates that you are only allowed to travel to UK, France and Dubai. 89.1 aver that Nabil Jean Sab subsequently added in french: “I've always been telling Ravi not to take such risks. Our bank could have gone in real big trouble had we opened this account. Even talking on the phone is risky. I’ve been telling this to Ravi, numerous times”. 90. | aver that from Switzerland Sylvio Sundunum and | took the train to Nice. Dick Kwan Tat stayed behind In Switzerland. | aver that the train we took was forced to be sta-tionary for several hours because a man had committed suicide by throwing himself on the rail in front of the train. 91,| aver that we spent 5 to 6 days on the south of France in the whereabouts of Cannes, Nice, and Céte d’Azur before flying to Paris. 92. | aver that Sylvio and | were blocked in Nice airport for hours because of a minor at- tack in Orly airport. 93. | aver that when we finally landed in Paris, we spent one night in Neptune Hotel, av- enue d'talie, in the 13e arrondissement. | slept in room number 28 and Syivio slept in room number 19. 94. | aver that the following day, Sylvio and I flew to Dubai on the same flight. 95. | aver that Syivio stayed for two days and | stayed back a few days to enjoy some time { had left on my variation order. 96.1 aver that after the departure of Syivio, Dick Kwan Tat came to meet me and we would fly back to Mauritius together. 97. | aver that on 24th March 2017, Ravi Yerrigadoo sent me a WhatsApp message to ask me to meet him in Abu Dhabi, as evidenced in screenshot (Annex 30) 98, | aver that | did not go to Abu Dhabi to meet Ravi Yerrigadoo but instead flew back to Mauritius 99. | aver that a few days after coming back to Mauritius, Syivio and | incorporated a company H.A.S Trade and Investment Ltd, H.A-S standing for Husein and Sylvio. 100. Based on various conversations | had, | verily believe that this company was created to transfer money which would have been cashed into the Swiss and Dubai bank accounts. 101, | aver that on or about the 2" April 2017 in the morning, a meeting was or- ganized at Syivio’s house at Kensington Heights in Quatre-Bornes. 102. Laver that Sylvio Sundanum, Ravi Yerrigadoo, Dick Kwan Tat and myself at- tended. 103. \ aver that Ravi Yerrigadoo wrote the notes on the two sides of the paper (Annex 32) 104, Laver that at the material time Bet365 did not allow cashing out on prepaid cards or by any remote method for gains of more than €30 000. Such payments were to be made only by calling in person at Bet36S in UK. 105. _| aver that the recto of the page is a template of a letter written by Ravi Yer- rigadoo. 106. | aver that we were instructed by Ravi Yerrigadoo to use the template quoted in paragraph 105 when we had to call in person to Bet365 UK as per paragraph 104.107. | aver that C.Adam is a fictitious name just to be used as an example. C.Adam refers to Chloe Adam which is the name of a bot on Bet365. 108. _| aver that decision was taken on that day to travel again to the same desti- nations, to open the accounts to my name, mission which had fatled during the March journey. 109. | aver that request for variation order to travel between 15" April and 15" of May was obtained with this time Switzerland included. (Annex 32) 110. Laver that reservations for tickets were made by Sylvio. (Annex 33) 111, _Laver that a few days before the scheduled departure, | met with Sylvio at his office at Dry Cleaning. He was angry that the balance of the two respective accounts at Bet 365 i.e. mine and Sylvio’s were at O€. 112. {aver that Sylvio told me “I made a lot expenses because of you. Now you must reimburse”. 113. Laver that | argued with Syivio trying to expiain to him that gambling implies gains but also losses. | aver that | showed him all the bets placed on the bet365 ac- counts. 14, J aver that Sylvio did not want to hear any explanation and he asked me to ‘meet in him in two days in the office of Ravi Yerrigadoo. 115. ‘aver that | met with Ravi Yerrigadoo and Sylvio at the office of the Attorney General. 116, aver that one Dimitri, son-in-law of Sylvio and IT Manager of Dry Cleaning was also present. 117. | aver that one police officer Robin Bundhoo was also present. The latter claimed that his mother was sick during that particular week. 118. | aver that police officer Robin Bundhoo started accusing me of accessing a fake bet365 gmail account. 119. aver that | accessed these fake bet365 gmail accounts. As explained in para- graph 66 of this affidavit, these gmail accounts were set-up for the purpose of the other protagonists as set out in paragraph 16. 120. Laver taking the comments of Robin Bundhoo as a threat. 121. | verily believe that Sylvio and the other protagonists were using this fake email address to send the fake bet36S receipts. 122. | aver that Ravi Yerrigadoo didn’t say anything during that meeting. 123. aver that when the meeting ended, myself, Robin Bundhoo and Dimitri left the office. | aver that Sylvio stayed behind.124, | aver that from that moment, Syivio started threatening me. (Annex 34) 125. | aver that this affidavit has the purpose to be used before the ICAC and eventually before any competent court if necessary. SOLEMNLY AFFIRMED BY THE ABOVENAMED ) DEPONDENT AT CHAMBERS SUPREME COURT ) HOUSE, THIS . DAY OF September 2017 ) Drawn up by me Interpreted by me Before me, Mrs N. Hurhangee SUPREME COURT SUPREME COURT ‘Attorney at Law