ORDER

06.03.2025

By this appeal, a challenge has been made to the Order dated 15.03.2023 passed by the Adjudicating Authority confirming the seizure/freezing order dated 19.10.2022. The following properties / digital devices of M/s Code Payments India Ltd. have been seized.

2. It is a case where an FIR was registered for the offence under Section 420 and Section 120-B of Indian Penal Code, 1860 (in short “IPC”) having cross-border implications as defined under Section 2(ra)(ii) of the Prevention of Money- Laundering Act, 2022 ( in short “the Act of 2002”). The allegation is for generation of proceeds of crime by cheating and defrauding Indian user of „Garena Free Fire‟ by M/s Garena International with the help of M/s Coda Payments India Private Limited. The payments were transferred to Garena International, Singapore through the group entities of M/s Coda Payments Singapore Pte. Limited. After the FIR, an ECIR was recorded under the Act of 2002. At this stage, it is relevant to refer that the Cyber Crime Police Station, Hyderabad forwarded 10 copies of the FIR registeredagainst the accused at various Police Stations across the State.

3. As per the allegations, Garena Free Fire game, a Battle Royale genre game, an online multiplayer video game genre that blends last-man-standing gameplay with the survival, exploration and scavenging elements of a survival game. Battle royale games involve dozens to hundred of players, who start with the minimal equipment and then must eliminate all other opponents while avoiding being trapped outside of a shrinking “safe area” or “safe zone” with the winner being the last player or team alive, was developed for mobile platforms targeting children, mainly between 10 to 16 years of age. Due to the lockdowns in the wake of Covid- 19, parents were compelled to give smartphones / laptops to their children to attend online classes. Children besides attending the online classes, also played online games using their devices or the devices of their parents or elders.

4. During the course of investigation, documents were obtained from banks as well as statement of Indian Resident Director of the Company, Shri Chandra Prathap was recorded under section 50 of PMLA. The order revealed as under:

“In 2018, M/s Coda Payments Pte Limited, Singapore established its Indian subsidiary M/s Coda Payments India Private Limited. M/s Coda Payments Pvt. Ltd. India is a 100% subsidiary of M/s Coda Payments Pte. Ltd. Singapore. This company sells digital tokens which are used for gaming platform and NETFIX. The Singapore Company is the real owner of the digital tokens and the Indian company receives all these tokens and the Indian company receives all these tokens from Singapore. There is an online platform, named Coda Shop, for digital token where interested person can buy those tokens. For the sale of these tokens in India, the Singapore Company raises invoices against the Indian company. The final beneficiary of the revenue generated through the sale of tokens in India is M/s Coda Payments Pte. Ltd. Singapore. Sh. Raymond Wijaya and Sh. Philippe Zean Yves Limes and Sh. Chandra Prathap are current directors of the company. At the time of incorporation Sh. Neil Frederic Davidson was director who was replaced by Sh. Raymond Wijaya.

M/s Coda Payments India Private Limited has many prominent Games / apps like Garena Free Fire, Call on Duty, Teen Patti Gold etc. as its clients. One of its client Garena International Private Limited does not have any registered entity in India, therefore it signed an agreement with Coda Payments India Private Limited for providing payment services in India. Further Coda Payments India Private Limited made an agreement with Paytm and other payment gateways / aggregators for payment gateway services. Coda Payments India Private Limited (CPIPL) is acting as a medium between user and Garena International Private Limited and transferring funds to their parent company Coda Payments Singapore Pte. Ltd. (CP