The Adani $3 Billion Shadow Portfolio: Swiss Bank Documents Expose a Hidden Stock Empire

Internal banking records from one of Switzerland's most prestigious private banks reveal how two men closely connected to the Adani family secretly held $3 billion in Adani stock through a labyrinth of offshore vehicles - even as Swiss prosecutors froze $311 million, US federal charges wound through court, and India's own regulator refused to look too closely.

Financial markets operate in public. The money behind them often does not. (Unsplash)

In February 2023, two men walked into a discreet meeting at the offices of Reyl Finance in Dubai. They were there, at the request of their bank's compliance team, to explain why they held what appeared to be billions of dollars in stock connected to a conglomerate that was, at that exact moment, under investigation for market manipulation on three continents.

They confirmed it. Nasser Ali Shaban Ahli, a UAE national, and Chang Chung-Ling, a Taiwanese businessman, signed a written statement admitting they held the accounts. They said they trusted the Adani family's business acumen. They denied wrongdoing. They promised, eventually, to diversify.

Three years later, what those documents reveal is both simpler and more damning than anything the Adani Group's lawyers have argued in court. OCCRP obtained internal banking records from REYL Intesa Sanpaolo, a Swiss private banking group headquartered in Geneva, detailing $3.04 billion in Adani-linked holdings managed through three Bermuda-based hedge funds. Those funds were accessed via British Virgin Islands companies. The cash moved through Dubai. The ultimate beneficiary, investigators allege, was one of the world's most politically connected conglomerates - a company that has repeatedly insisted it follows the law to the letter.

The money trail is patient. It doesn't rush. It simply follows the accounts.

The Two Men Behind the Curtain

Nasser Ali Shaban Ahli and Chang Chung-Ling are not household names. That, investigators say, was the point.

Ahli is a UAE national who for years appeared in the footnotes of Indian regulatory inquiries and occasional court filings, but never in headlines. Chang is a Taiwanese national who, notably, once shared a Singapore residential address with Vinod Adani - the low-profile older brother of the conglomerate's chairman, Gautam Adani. This detail emerged during a 2007 investigation by India's Directorate of Revenue Intelligence (DRI) into an alleged diamond trading scheme involving Adani companies.

Both men have been linked to the Adani family across multiple regulatory investigations spanning nearly two decades. Both repeatedly appeared as directors or representatives of companies that handled transactions scrutinized by Indian authorities. Both were, according to OCCRP's previous reporting in partnership with the Financial Times and the Guardian, secretly trading Adani stock for years.

The new Swiss bank documents add the financial scale that was previously missing. Ahli held approximately $2.02 billion through his BVI-registered company, Gulf Asia Trade and Investment Ltd. Almost the entire sum was parked in hedge funds that, the bank noted, had seen "significant increases in value over the last three years" and were "likely" invested in Adani Group companies.

Chang Chung-Ling held approximately $1.02 billion through his own BVI vehicle, Lingo Investment Ltd., in the same category of hedge funds - described by Reyl MEA as "probably being invested in Adani Group companies." Chang's accounts were at the same Dubai subsidiary of the Swiss bank. Both men were clients of Reyl Finance (MEA) Ltd., a Dubai-registered unit of REYL Intesa Sanpaolo.

A third account also surfaced in the bank's internal investigation: Vinod Adani himself, holding $6.5 million through his UAE company, Kommerce Trade and Services. The bank flagged some transactions between his company and Chang's - described as "loan-related transactions of a not particularly significant amount." Vinod Adani did not respond to requests for comment.

The Adani Group controls ports, airports, energy infrastructure, and defense contracts across South Asia. (Unsplash)

The Offshore Architecture: BVI, Bermuda, Dubai, Mauritius

What makes the Adani case a textbook study in offshore financial engineering is not the amounts - though $3 billion is substantial - but the structural layering. Every link in the chain serves a purpose. The BVI companies provide anonymity at the ownership layer. The Bermuda hedge funds provide distance at the asset layer. Dubai provides the banking interface for high-net-worth clients in the Gulf. Mauritius provides another layer of treaty-advantaged access to Indian markets.

The three Bermuda-based hedge funds identified by the Italian parent company's internal investigation - Gleneagles Investment Fund, Pangea Fund, and Oyster Bay Fund - were all administered by Apex Fund Services. That same administrator also managed a fourth Bermuda fund, Global Opportunities Fund, through which $430 million had been invested in Adani stock. That fund was identified in OCCRP's earlier reporting on Ahli and Chang.

Two of the three funds - Pangea and Oyster Bay - list Elara Capital Ltd. as their investment manager. Elara also managed two Mauritius-registered funds with reported concentrated positions in Adani stock: the Elara India Opportunities Fund and Vespera Fund Ltd. Both were flagged in the original Hindenburg Research report as part of the alleged insider manipulation scheme. Elara Capital and Apex Fund Services did not respond to requests for comment from OCCRP.

The structure explains why India's market regulator, SEBI, told the Supreme Court it had "drawn a blank" on identifying the ultimate owners of certain offshore entities during its investigation. The architecture was built for exactly that outcome.

Indian securities law imposes limits on how much stock insiders and their associates can hold. If the promoter group holds more than the legally disclosed amount, it constitutes market manipulation - the precise allegation made by Hindenburg Research in January 2023. The offshore structure is what made the alleged concealment possible.

A Decade-Long Paper Trail: The Prior Investigations

This is not the first time Ahli and Chang have appeared in documents connected to Adani family business. Their names have surfaced in regulatory files going back to 2007 - a pattern that investigators now argue is not coincidental.

The first major investigation was in 2007, when India's Directorate of Revenue Intelligence examined an allegedly illegal diamond trading scheme involving Adani Group companies. The DRI's report described Chang Chung-Ling as the director of three Adani companies implicated in the scheme. Nasser Ahli represented a trading firm also involved. The revelation that Chang shared a Singapore address with Vinod Adani - Gautam's older brother - was embedded in the same investigation file.

The second investigation came in 2014. The DRI alleged that Adani Group companies were systematically over-invoicing imports of power generation equipment - paying a foreign subsidiary up to $1 billion more than fair market value. The excess payments left India as a capital outflow disguised as legitimate trade. Both Ahli and Chang appeared again: at separate times, each served as director of two companies later owned by Vinod Adani that received and handled the alleged proceeds - one in the UAE, one in Mauritius.

Both investigations were eventually dismissed. The Adani Group denied wrongdoing in both cases. But investigators noted that the same people, the same jurisdictions, and the same structural patterns kept reappearing across different schemes and different years. When Hindenburg Research published its 2023 report, it was drawing on a foundation of documented irregularities that Indian authorities had, repeatedly, declined to prosecute.

"Any suggestion that promoter shareholding has been misstated or concealed is incorrect and contrary to disclosures made in accordance with applicable law." - Adani Group spokesperson, in response to OCCRP's February 2026 investigation

The Hindenburg Detonation and Its Aftermath

On January 24, 2023, Hindenburg Research - the American short-selling firm known for detailed financial forensics - published a 106-page report on the Adani Group. The document alleged that the conglomerate had engaged in "brazen stock manipulation and accounting fraud" over decades, and that the group's decade-long stock rally had been improperly fueled by undisclosed insider holdings routed through offshore entities.

The immediate market reaction was catastrophic for Adani. The group's listed companies lost a combined $150 billion in market capitalization within days. Gautam Adani, then briefly the third-richest person in the world, saw his net worth collapse by tens of billions of dollars. A planned $2.5 billion share offering was pulled.

The Adani Group's response was equally forceful. A 413-page rebuttal called the report an "attack on India" and accused Hindenburg of representing "Soros-funded interests." Indian nationalism was deployed explicitly as a shield. The group pursued journalists through the courts. Senior politicians aligned with Prime Minister Narendra Modi's government dismissed the affair as foreign interference in Indian financial markets.

But it was precisely during this period - February 2023, the height of the scandal - that Ahli and Chang met with their bankers in Dubai and confirmed, in writing, that they held $3 billion in Adani-linked stock. They signed that statement. The bank has it. OCCRP has it. The Swiss prosecutors have it.

The Adani stock recovered. The investigations did not go away.

Swiss banking secrecy made the hidden accounts possible. Swiss prosecutors are now using those same banks' internal records to build a criminal case. (Unsplash)

Switzerland Moves First: $311 Million Frozen

While Indian regulators were closing cases and the Supreme Court was declining to order a fresh probe, Swiss prosecutors were doing something different: following the money to its source.

According to an August 2024 ruling by the Swiss Federal Criminal Court, prosecutors had been conducting a criminal investigation into Chang Chung-Ling since 2021 - two years before Hindenburg published its report, and two years before Chang and Ahli met with their Dubai bankers to confirm the holdings.

Swiss prosecutors suspect Chang of acting as a "front man" for the Adani Group in a scheme to allow insiders to own a larger share of Adani stock than is permitted under Indian securities law. The investigation was initially opened by prosecutors in Geneva, then transferred to the Federal Prosecutor's Office in Bern, reflecting its national-level significance.

In connection with the case, Swiss prosecutors froze $311 million held by Chang across five bank accounts. When Chang's company, Lingo Investment Ltd. - the very same BVI vehicle that held the $1 billion in Adani-linked holdings identified by REYL's internal investigation - appealed to the Federal Criminal Court to have the accounts unfrozen, the court refused.

"The prosecuting authority must have time to conduct its investigation. It should be noted that the appellant is clearly unable to provide [prosecutors] with the explanations - in the form of supporting documents - which it should be able to provide in order to dispel the doubts legitimately raised." - Swiss Federal Criminal Court, August 2024 ruling rejecting Chang Chung-Ling's appeal to unfreeze $311 million

The Federal Prosecutor's Office, asked about the case's current status, confirmed only that a criminal investigation into "money laundering and forgery of documents" was underway. It declined to name Chang specifically.

The REYL Intesa Sanpaolo bank's own internal records show that Swiss judicial authorities had sent "specific information requests" to the bank about accounts held by Ahli and Chang even before the Hindenburg report was published - in mid-2022. The bank filed suspicious transaction reports to Switzerland's Financial Intelligence Unit in relation to both men, and to Vinod Adani. The relevant accounts were closed in December 2022 due to lack of activity - but by then, the investigation was already running.

The US Federal Indictment: Bribery at the Highest Level

Switzerland was not the only jurisdiction moving. In November 2024, federal prosecutors in the Eastern District of New York unsealed an indictment charging Gautam Adani himself - the chairman and founder of the Adani Group, one of the world's wealthiest individuals - and his nephew Sagar Adani with conspiracy to pay bribes to Indian government officials.

The indictment alleged that the pair orchestrated a scheme to pay approximately $265 million in bribes to officials across multiple Indian state governments. The alleged purpose: to secure solar energy supply contracts for Adani Green Energy, the group's renewable energy arm. Those contracts, prosecutors alleged, were worth billions in future revenue. The bribes, allegedly, were the cost of doing business.

The SEC filed a parallel civil complaint. As of January 2026, that complaint was confirmed as ongoing, following a procedural ruling in the Southern District.

The Adani Group called the indictment "baseless" and vowed to pursue "all possible legal recourse." Gautam Adani has not been arrested. He has not appeared before US authorities. He has continued to run his conglomerate from India, where he enjoys political proximity to the ruling government and where no corresponding criminal charges have been filed.

The DOJ spokesman for the Eastern District of New York declined to comment on the current status of the case when approached by OCCRP.

India's Regulatory Blind Spot

The contrast between how international regulators and India's own institutions have handled the Adani affair is stark enough to require its own accounting.

SEBI, India's Securities and Exchange Board, was conducting investigations into Adani when the Hindenburg report dropped in January 2023. The Supreme Court, responding to petitions from public-interest litigants, ordered SEBI to continue its investigations and expand their scope. A court-appointed expert committee was tasked with evaluating the episode.

That expert committee ultimately found no evidence of regulatory failure - but also noted that SEBI had "drawn a blank" on the ultimate beneficial owners of certain offshore entities. In other words: the regulator couldn't determine who actually owned the money. This finding, which in most jurisdictions would trigger an escalation and potentially a referral to law enforcement, was treated in India as a reason to close the matter.

In January 2024, the Supreme Court rejected petitions demanding a court-supervised investigation, finding that SEBI's work "inspires confidence" and that there was no reason to remove the case from the regulator. By September 2025, SEBI had issued formal orders in two sets of cases - finding the Hindenburg allegations "not established." Reuters reported that more than a dozen cases were still awaiting final orders, with no public timeline for completion.

SEBI has not published a comprehensive public report on the totality of its Adani investigations. The full findings, if any, have not been aired. The regulator did not respond to requests for comment.

Indian corporate law adds another dimension to this picture. As the Adani Group's spokesperson pointed out in response to OCCRP's inquiries: "Under Indian law, a listed company neither controls nor directs who purchases publicly traded shares." This is technically accurate. It is also precisely why investigators argue the offshore architecture was designed the way it was - to use the letter of the law as cover for what the spirit of the law was designed to prevent.

"Treasury will continue to target Iranian networks and corrupt elites that enrich themselves at the expense of the Iranian people... This includes the regime's attempts to exploit digital assets to evade sanctions." - US Treasury Secretary Scott Bessent, January 30, 2026 (on a separate sanctions action - illustrating the global pattern of offshore financial concealment)

The Pattern Behind the Portfolio

What the Swiss bank documents establish, above all else, is not a new allegation. It is a confirmed fact. Two men with documented, multi-decade ties to the Adani family held $3 billion in Adani-linked assets through offshore structures specifically designed to keep beneficial ownership opaque - and they confirmed this to their own bank, in writing, at the precise moment when investigators across three jurisdictions were asking exactly that question.

The Hindenburg report, when it dropped in January 2023, was widely characterized as a short-seller attack on Indian business and Indian national pride. The Adani Group's communications machine was effective at reframing the narrative. But the Swiss bank documents did not originate with a short-seller. They originated inside one of Europe's most established private banking institutions, produced as part of an internal anti-money-laundering compliance review that the bank was legally required to conduct.

Ahli and Chang wrote and signed their statement of their own accord, with counsel, in the presence of Reyl MEA's CEO and a board member. They confirmed the accounts. They confirmed the amounts. They confirmed the Adani connection. They asked the bank to give them time to diversify. That statement now sits in the files of the Swiss Federal Prosecutor's Office.

What emerges from the trail is a structural argument that is difficult to argue away: when the same individuals appear repeatedly across different investigations, different jurisdictions, different years, and different alleged schemes - and when those individuals are consistently connected to the same family and the same conglomerate - the pattern itself becomes evidence. Not proof of a specific crime. But evidence of a system.

The Timeline: Twenty Years of Connections

What Happens Next

The Adani Group remains one of the most powerful private entities in Asia. Its interests span ports, airports, power generation, renewable energy, defense manufacturing, media, and cement. Its political relationships in India are among the most discussed and least openly examined aspects of its rise. Gautam Adani remains at the helm.

But the legal architecture closing in on the group is now genuinely multi-jurisdictional and increasingly difficult to manage through press statements alone.

In the US, the DOJ indictment of Gautam Adani personally - not a subsidiary, not a former executive, but the chairman himself - is an unprecedented exposure. If that case progresses to trial, the discovery process alone could produce documents that Indian regulators have never seen. The SEC civil complaint adds a parallel financial liability. US federal cases grind slowly, but they do not typically disappear.

In Switzerland, the Chang investigation has been running for five years. The court has refused to release the $311 million. The Federal Prosecutor's Office has confirmed money laundering and document forgery are the active charges. Swiss prosecutors work methodically, and they have the bank documents - both the ones from REYL and, presumably, others gathered through international legal assistance channels.

In India, SEBI's silence on twelve-plus pending investigations is itself a data point. The regulator has issued no comprehensive public accounting of its findings. A full picture of what SEBI knows - and has chosen not to publish - remains invisible to the Indian public and to the Supreme Court that trusted it to deliver one.

The Adani Group's consistent response has been denial plus deflection: the allegations are baseless, the investigations are foreign interference, the critics are enemies of India. That framing has worked domestically. It has not stopped Swiss prosecutors from freezing $311 million. It has not stopped a US grand jury from returning an indictment. It has not made the signed February 2023 statement from Ahli and Chang disappear from the files of a Swiss bank's compliance department.

The $3 billion is in the documents. The documents are with the prosecutors. The prosecutors are not done.