A $2-billion fraud at the Punjab National Bank (PNB) may have been orchestrated by a few rogue employees, but it escaped detection because of widespread risk-control and monitoring lapses in many areas of the bank, the bank’s own internal probe has found.

PNB, India’s second-biggest state-controlled lender, has previously alleged that a handful of staff at a single Mumbai branch issued fake bank guarantees over several years to help two jewellery groups – controlled by Indian diamond magnate Nirav Modi and his uncle Mehul Choksi – raise billions of dollars in foreign credit and commit India’s biggest-ever bank fraud.

The bank’s CEO Sunil Mehta told Reuters in April he had suspended 21 officials, and “will not spare” others found involved in lapses, but he also described the fraud as a “small turmoil”.

However, a 162-page internal report, produced by PNB officials tasked with probing the fraud, lays bare lapses that go far beyond a few branch officers.

The report, a copy of which was reviewed by Reuters, lays out how failings by 54 PNB officials – ranging from clerks to foreign exchange managers, and auditors to heads of regional offices – allowed the fraud to be perpetrated.

Eight of the 54 are among those who have been charged by the police for their roles in the scandal.

The report, which the PNB officials presented to the bank’s fraud risk management arm on April 5, along with dozens of pages of annexed bank records and internal e-mails, is also part of the evidence submitted by the police in its court case against those allegedly involved in the fraud.

The report’s findings have not previously been made public.

The unearthing of the fraud in January has not only exposed shortcomings in the management of PNB, but has also undermined confidence in India’s state-run banking sector, which controls over two-thirds of the nation’s bank assets. The damning conclusions of the report stand in contrast to the lack of regulatory action taken by the authorities since the fraud was reported.

No penalty has been imposed on PNB as a result of the fraud and there has been no senior management shake-up.

A PNB spokesman told Reuters the bank “cannot share details on a sub-judice case”. He added: “We must reiterate that we will not spare anybody who is found guilty irrespective of the level or position in the bank,” he said.

PNB did not respond to a question about what action was taken against the “erring” officials mentioned in the report.

The Reserve Bank of India and the Banking Secretary, Rajiv Kumar, did not respond to requests for comment.

The report does not say whether the PNB investigators believe those involved in the monitoring failures were aware of the fraud.

Significantly, they said one of the reasons the fraud went undetected for years was because of lapses within some of the bank’s critical areas at its New Delhi headquarters, such as its credit review and international banking units.

Fraud at Brady House

The epicentre of the fraud was PNB’s Brady House branch, housed in a building with an imposing colonial facade in downtown Mumbai. From there, deputy manager Gokulnath Shetty for years issued fraudulent credit guarantees over the SWIFT interbank messaging network, the bank and prosecutors have alleged.

Using those guarantees, companies controlled by Nirav Modi, whose jewellery creations were once adorned by global celebrities, and Choksi, received credit from banks overseas to fraudulently fund their businesses, PNB alleges.

Modi and Choksi, both of whom left India before PNB filed its first police complaint on January 29, have denied any wrongdoing.

Shetty’s lawyer has said his client is not guilty.

As per protocol, the daily reconciliation reports should travel up the chain to PNB’s headquarters in New Delhi. Along the way, they would be signed off by the Brady House branch head and sent each month to a Mumbai city regional office that would issue all-clear certificates for the branches it controls.

But despite receiving just two of the 12 monthly reports from the Brady House branch last year, the regional office signed off on a “false” compliance certificate, signalling a clean bill of health for the branch, the report said.

Shetty joined the forex division at Brady House in April 2010. In March 2011, the branch issued the first fake credit guarantees of $15.5 million to Modi’s firms through SWIFT messages, bypassing the internal banking system, the PNB investigators said.

Over the coming years, Shetty authorised more than 1,200 fraudulent credit guarantees, the report added.

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