AML Forensic Report — SB STYLE PROJECTS PVT LTD

Account Holder

SB STYLE PROJECTS PVT LTD

User ID

C000021966_SITA.SENAPATI

Registered Address

Rasulgarh, Mancheswar, Khorda, Odisha

Review Period

29 May – 11 Jun 2026 (14 days)

Statements Analysed

14 daily files · 12,748 lines

Source Application

WPS Office · Locale 2052 (PRC)

1Executive Summary

Over a 14-day window, a single SBM Bank current account belonging to a newly-active Odisha private limited company processed ₹85,909,864 (≈ INR 8.59 crore) in outgoing transfers across 11,887 transactions, while retaining a near-zero end-of-day balance throughout. Funds arrived from a small cluster of "enterprise" remitters in large blocks and were almost immediately dispersed to 9,788 distinct individual beneficiaries in small amounts via IMPS.

This is a textbook collection-and-payout (mule / pass-through) account operated behind a payment-gateway layer. The structure — bulk in, fan-out in sub-₹5,000 increments, daily sweeping to zero, channel-test "ping" transactions, and a ~5% payout-failure rate — is consistent with proceeds-laundering for an online operation (typically illegal gaming, investment/"task" scams, or unlicensed PSP settlement) routed through Zpay.

₹85,909,864

Total outflow (14 days)

11,887

Payout transactions

9,788

Unique beneficiaries

65%

Payouts ≤ ₹5,000

4.9%

Payout failure / reversal rate

~₹0

Typical closing balance

2Money-Flow Architecture

Collection (In)

₹83,657,681

277 credits · concentrated funders
NRTGS / NEFT / IMPS

→

Pass-Through Account

SB STYLE
PROJECTS

Swept to ~₹0 daily
no economic substance

→

Dispersal (Out)

₹85,909,864

11,887 IMPS payouts to
9,788 individuals

Inflow (₹83,657,681) and outflow (₹85,909,864) are near-identical, confirming the account holds no working capital and exists purely to layer funds. The minor surplus of outflow over genuine inflow is absorbed by ₹2,255,423 in failed-payout reversals being recycled.

3Red Flags & Indicators

CRITICALFan-out structuring (smurfing)

65.4% of all 11,887 payouts were ≤ ₹5,000 and 50% were exact multiples of ₹500. Spreading ₹8.59 crore across ~9,800 small, round-value transfers to unrelated individuals is a deliberate technique to stay below scrutiny thresholds and frustrate transaction monitoring.

CRITICALNo economic substance / daily zeroing

A genuine trading company retains working capital. This account was swept to near-zero every single day (closing balances ranged ₹0.93 – ₹109,206 against ₹85L–₹98L of daily throughput). The entity name ("Style Projects") bears no relationship to the financial-flow behaviour.

HIGHConcentrated funders → dispersed payees

Inflow came from a handful of "enterprise" remitters (DEQUA SOLUTION POINT, ALOK ENTERPRISE, KALITA ENTERPRISE, PPN ENTERPRISE) in large blocks, while outflow scattered to thousands of unrelated retail individuals — the asymmetry that defines a collection-and-payout node, not a real B2B business.

HIGHChannel-test "ping" transactions

A single beneficiary ("MS K B S STEEL") received 90 micro-payments of incrementing tiny values (₹18, ₹100, ₹101, ₹102 …). This is automated channel-verification — confirming a mule rail is live before bulk dispersal — and is a strong signal of scripted/programmatic control via the gateway.

HIGHElevated payout-failure rate

584 payouts (4.9%) bounced back as reversals. A failure rate this high indicates large volumes sent to closed, frozen, frequently-changed or invalid beneficiary accounts — characteristic of disposable mule networks, not an established payee book.

MEDIUMExtreme transaction velocity

Bursts reached up to 35 payouts in a single minute and 5 within one second, with single days exceeding 1,395 transactions. Human-initiated banking does not produce this cadence; it implies API/bulk-upload automation behind the gateway.

MEDIUMForeign-gateway origination

Statement files were generated by WPS Office under PRC locale (ID 2052), consistent with the stated Zpay (Chinese payment gateway) involvement. Cross-border control of a domestic INR mule account materially raises CFT and predicate-offence exposure.

4Daily Throughput

Date	Out Txns	Outflow	In Txns	Inflow
5/29/26	1,140	₹2,206,076	9	₹2,180,317
5/30/26	554	₹2,358,240	9	₹2,200,306
5/31/26	521	₹4,701,563	19	₹4,585,125
6/1/26	874	₹4,384,747	15	₹4,326,060
6/2/26	967	₹8,448,009	31	₹8,039,003
6/3/26	822	₹8,302,192	26	₹8,094,691
6/4/26	608	₹5,725,505	19	₹5,585,305
6/5/26	820	₹8,582,299	28	₹8,535,184
6/6/26	1,013	₹9,833,864	26	₹9,534,140
6/7/26	583	₹5,651,372	22	₹5,586,983
6/8/26	1,395	₹9,555,253	22	₹9,169,909
6/9/26	1,071	₹3,588,040	11	₹3,476,291
6/10/26	1,311	₹8,832,357	25	₹8,640,167
6/11/26	208	₹3,740,348	15	₹3,704,200

5Counterparty Analysis

Top Funding Sources (inflow)

Remitter	Txns	Amount
DEQUA SOLUTION POINT	47	₹20,980,073
ALOK ENTERPRISE	66	₹19,508,288
KALITA ENTERPRISE	45	₹14,300,351
PPN ENTERPRISE	23	₹9,275,126
EGGFINITY EGG RETAIL	14	₹6,630,065
DEQUA SOLUTION POINT OPC PRI	10	₹1,801,031
SHREE RADHE RADHETRAD	4	₹1,355,018
NAGMANI TRADING PRIVA	3	₹1,320,013
RIGHT DIRECTION	2	₹1,000,012
NIKEDGE GLOBAL SERVIC	2	₹800,017
PLANETGREEN MILLET SPICES	2	₹620,004
TRAVENTURE ENTERPRISE	2	₹604,015

Most-Repeated Payees (outflow)

Beneficiary	Count	Total
MS K B S STEEL	90x	₹7,171
Beneficiary	62x	₹263,005
RohanRaj	16x	₹44,500
SUNITA DEVI	15x	₹189,000
SATYANARAYANA	14x	₹140,000
ABUL KALAM	14x	₹79,732
ChattaDharaneswar	13x	₹6,760
rajdip dabhi	12x	₹240,000
ALEXANDER	11x	₹117,000
RAHUL KUMAR	10x	₹69,085
Rahul	10x	₹114,721
Rajesh kumari	10x	₹59,257

Payout Size Distribution

Band	Count	Share
≤ ₹2,000	5,266	44.3%
₹2,001–5,000	2,505	21.1%
₹5,001–10,000	1,856	15.6%
₹10,001–25,000	1,391	11.7%
₹25,001–50,000	867	7.3%
> ₹50,000	2	0.0%

Destination Banks (payouts)

Bank	Payouts
State Bank of India	2,199
(unspecified)	413
Union Bank	367
CANARA BANK	358
HDFC BANK	279
AXIS BANK	248
BANK OF BARODA	210
Punjab National Bank	198
STATE B	165
KOTAK	153

6Control Lapses at SBM Bank

The activity below should have triggered intervention well before ₹8.59 crore transited the account:

LAPSEOnboarding / EDD failure

A newly-active private limited company was permitted near-unlimited high-velocity disbursement with no apparent transaction-limit calibration to declared business, turnover or expected activity. The business profile ("Style Projects") never matched the observed payout behaviour.

LAPSETransaction-monitoring gap

Sustained 800–1,400 daily IMPS payouts to thousands of unique payees, daily account-zeroing, and a 5% reversal rate should have generated automated alerts and an STR within the first 24–48 hours. Activity ran unimpeded for the full 14-day window.

LAPSEGateway / TPAP oversight

An external (foreign) payment gateway was effectively operating settlement through a single customer current account — a classic "rent-a-account" / nested-PSP arrangement — without evident scrutiny of the underlying gateway, its merchants, or source of funds.

LAPSEVelocity / structuring rules absent

No effective rule fired on (a) bulk sub-₹5,000 round-value dispersal, (b) >30 transactions/minute, or (c) test-ping micro-payments — all standard, well-documented mule typologies.

7Recommendations for SBM Bank

Immediate (0–48 hrs)

Freeze / debit-restrict the account pending review and file an STR with FIU-IND; given the scale, escalate as a potential mule/layering network rather than a single account.
Trace the cluster: map the concentrated funders (DEQUA, ALOK, KALITA, PPN ENTERPRISE) and high-frequency payees — these are almost certainly other accounts in the same network at SBM and peer banks.
Preserve evidence (statements, login/IP/device logs, gateway integration records) and notify the I4C / NCRP and the account's home-branch RBI nodal officer.

Detective Controls (rebuild monitoring)

Velocity rules: alert on >N IMPS payouts/minute, >N unique payees/day, and same-day credit-then-disburse ("turnaround") ratios approaching 100%.
Structuring rules: flag accounts where a high share of debits are small, round-value, just-below-threshold transfers to unrelated individuals.
Pass-through / sweep detection: alert where end-of-day balance is persistently <1% of daily throughput.
Reversal-rate monitoring: elevated failed-payout ratios (>2–3%) as a standalone mule indicator.
Test-transaction detection: flag clusters of incrementing micro-value payments to a single payee.

Preventive / Onboarding (KYC & EDD)

Calibrate transaction and payout limits to declared turnover and business model at onboarding; require justification before raising limits on young accounts.
Enhanced due diligence and source-of-funds verification for current accounts showing rapid high-volume disbursement, especially newly-incorporated entities and single-director companies.
Beneficial-ownership and gateway scrutiny: identify where an account is functioning as settlement for a third-party (and especially foreign) payment aggregator — this requires the aggregator to be a regulated PA/PSP under RBI, not nested behind a customer account.
Periodic behavioural re-KYC triggered by deviation between declared and observed activity.

Governance & Systemic

Tighten API / bulk-payment access controls for current accounts: step-up authentication, rate-limiting, and merchant-grade onboarding before enabling programmatic disbursement.
Deploy network-link analysis to detect shared funders/payees, device fingerprints and IPs across accounts — mule rings are caught at the graph level, not account-by-account.
Strengthen oversight of third-party payment-gateway relationships, with explicit prohibition on un-vetted (incl. cross-border) gateways settling through individual customer accounts.
Independent lookback review for similar typologies across the current-account book and remediation of monitoring-rule gaps.

Analyst note on limitations. Findings are derived solely from the 14 daily statement exports provided (single account, narration-level data). Counterparty names are taken verbatim from IMPS/NEFT narration strings and may be truncated or non-unique. Beneficiary de-duplication is name-based and approximate. This report is an investigative indicator set to support an STR and further enquiry; it is not a legal determination of guilt.

Prepared as an AML/CFT transaction-forensics review · Source: 14 SBM Bank daily statement files (29 May – 11 Jun 2026) · 12,748 parsed transactions · Figures are analyst-computed from raw narration and may carry rounding. Confidential — for internal compliance and regulatory-reporting use only.