Lotus 300

🔴 High Risk

India’s real estate sector remains a notorious hotspot for money laundering, fueled by systemic financial opacity, weak anti-money laundering enforcement, and entrenched political complicity. Despite regulatory frameworks like the Prevention of Money Laundering Act (PMLA), real estate transactions are often shrouded in secrecy through layered shell companies, nominee ownership, and misuse of luxury property valuations. The Lotus 300 project epitomizes these endemic challenges: involving overvalued assets, opaque ownership structures, cash transactions, and suspected ties to politically exposed persons. India’s failure to enforce stringent ownership transparency and due diligence allows illicit funds to be seamlessly integrated into the property market, undermining legal safeguards and enabling vast asset concealment across the sector. This case highlights the urgent need for reform as real estate laundering distorts market integrity and fuels broader financial crime in the country.

The Lotus 300 real estate project exemplifies systemic issues in India’s property sector facilitating large-scale money laundering and asset concealment. The project’s promoters allegedly used corporate layering, non-transparent sales, and shell companies to misappropriate land and funds, duping buyers and evading regulatory oversight. Despite enforcement actions by the ED, including asset seizures and raids, regulatory weaknesses and political entanglements—evidenced by raids on a former senior public official—highlight endemic financial opacity and the inadequacy of India’s AML framework in real estate. The case underscores the high jurisdictional risk in Indian real estate due to lax enforcement, layered corporate structures, and potential PEP involvement, making it a critical investigative benchmark for laundering typologies in Asia’s property markets.

Location

Sector 107, Noida, India (Northern India, Uttar Pradesh region)

Residential Luxury Apartment Complex (3 & 4 BHK apartments, luxury segment)

Promoted primarily by Hacienda Projects Private Limited (HPPL); ownership involves companies such as Moonlight Propbuild Private Limited and Elco Global Ventures LLP. Evidence of layered ownership involving different private limited companies, some suspected shell entities.

Promoters identified include Ashish Gupta and Aditya Gupta (linked to Cloud 9 Developments). Suspected involvement of entities controlled by these individuals and others related to Hacienda Projects Private Limited. Some ownership links suspected but not fully confirmed to offshore structures or entities used for layering.

Suspected but not confirmed. Investigations included raids on a retired IAS officer and former CEO of Noida Authority, Mohinder Singh, whose residence was raided, indicating possible PEP connections or political complicity.

Mixed acquisition via purported builder-buyer agreements, but with suspicious sales practices. Significant land parcels were sold in violation of agreements. Financing involved layered ownership and possibly offshore or third-party company financing. Large cash transactions also noted in related raids (Rs 1 crore cash seized in investigations).

  • Overvaluation and recursive sales: Land valued at approx ₹236 crore was sold contrary to agreements, with violations suggesting overvaluation or mis-invoicing.

  • Shell companies and layered ownership: Use of multiple private companies (Moonlight Propbuild Pvt Ltd, Elco Global Ventures LLP) for asset holding and transfers, facilitating opacity.

  • Nominee or third-party owners: Properties held under entities that obscure true beneficial ownership.

  • Diversion of project assets: Portions of land and properties sold outside agreed terms indicating layering and asset concealment.

  • Use of cash and valuable assets (diamond jewelry worth ₹12 crore, gold worth ₹7 crore) seized in raids, indicating commingling of illicit proceeds.

  • Project began around 2010-11 on 67,941.45 square meters of land in Noida Sector 107.

  • Builder-buyer agreements executed, but 27,941.45 sq. meters of land was subsequently sold to Prateek Infraprojects Pvt Ltd, violating conditions.

  • Ongoing litigation and probe by Enforcement Directorate (ED) initiated; substantial asset attachment orders issued in 2024.

  • Multiple raids conducted on offices and residences (Noida, Delhi, Meerut, Chandigarh) in 2024 linked to money laundering investigations.

Suspected laundering of assets potentially valued over ₹230 crore in land and real estate; liquid assets and jewels worth in excess of ₹19 crore seized during investigations. Estimated laundered amounts likely higher since full extent is unclear.

  • Enforcement Directorate (ED) money laundering case involving asset attachment orders under the Prevention of Money Laundering Act.

  • Raids linked to Hacienda Projects Pvt Ltd and associated firms.

  • No direct mention in Panama Papers or FinCEN Files publicly, but investigation ongoing with asset tracing.

  • Court cases ongoing regarding ownership and buyer registration with Noida Authority involved.

  • ED has issued provisional asset attachment orders worth ₹23.13 crore in Punjab.

  • Assets attached include four residential plots and agricultural land in Hoshiarpur, Fatehgarh Sahib, and Mohali districts.

  • Enforcement actions continue including raids and seizures of cash, jewelry, and property documents.

  • Noida Authority involved in litigation related to unpaid dues of approx ₹247 crore from promoters.

  • Multiple court orders including Allahabad High Court involved in property registration disputes, indicating regulatory and legal dysfunction.

High — due to India’s well-documented financial opacity, weak AML enforcement in real estate, reported high levels of illicit transactions in property sector, political complicit structures, and extensive use of shell companies.

  • Hacienda Projects Private Limited (HPPL) – Promoter and developer.

  • Moonlight Propbuild Private Limited – Asset holding company.

  • Elco Global Ventures LLP – Asset holding company.

  • Prateek Infraprojects Private Limited – Buyer in disputed land sales.

  • Noida Authority – Regulatory body involved in litigation and enforcement.

  • Individuals: Ashish Gupta, Aditya Gupta, Mohinder Singh (retired IAS officer and former CEO Noida Authority).

Residential, Luxury Apartment

Overvaluation, Layered Ownership, Asset Concealment, Use of Shell Companies

Asia, India, Uttar Pradesh, Noida

High

Lotus 300

Lotus 300
Country:
India
City / Location:
Sector 107, Noida, Uttar Pradesh
Developer / Owner Entity:
Hacienda Projects Private Limited, Moonlight Propbuild Pvt Ltd, Elco Global Ventures LLP
Linked Individuals :

Ashish Gupta, Aditya Gupta (promoters); suspected political links including Mohinder Singh (former IAS officer, Noida Authority CEO)

Source of Funds Suspected:

Embezzlement, land sale proceeds, cash payments (Rs 1 crore seized), possible political corruption

Investment Type:
Residential purchase, construction, resale
Method of Laundering:
Overvaluation, layered ownership via shell companies, cash purchase, asset concealment
Value of Property:
Estimated over ₹230 crore (land and property value), Rs 19 crore worth of cash and jewelry seized
Offshore Entity Involved?
1
Shell Company Used?
1
Project Status:
Complete
Associated Legal / Leak Files:

Enforcement Directorate investigations, asset attachment orders, ongoing litigation

Year of Acquisition / Construction:
🔴 High Risk