33 Counts of Money Laundering: Mauritian FCC Secures Conviction [March 18, 2026]

According to reports from the Financial Crimes Commission (FCC) and local media dated 18 March 2026, the Financial Crimes Commission and the Financial Crimes Division of the Intermediate Court

• Secured the conviction of:
• Leeneshwar Mohes,
• Director of KDDN Co. Ltd.
• On 33 counts of money laundering linked to falsified training refund claims submitted to the Human Resource Development Council (HRDC).

Details of the Investigation

• Investigators found that KDDN Co. Ltd. submitted fraudulent claims for the reimbursement of training allowances to the HRDC for training that was never actually conducted.
• A network of falsified documents and invoices supported these claims.
• The resulting refunds were treated as proceeds of crime, since the company had no legal entitlement to the funds.

Court Ruling and Penalties

• The Intermediate Court convicted Leeneshwar Mohes under:
• SECTIONS 3(1)(A), 3(1)(B), 6 AND 8 OF THE FINANCIAL INTELLIGENCE AND ANTI-MONEY LAUNDERING ACT 2002 [SEE BELOW]
• SECTION 44(1)(B) OF THE INTERPRETATION AND GENERAL CLAUSES ACT 1974.[SEE BELOW]
• Leeneshwar Mohes was ordered to pay a total monetary penalty of MUR 1,836,500. [£30k/$40k*]
• The court took into account his early guilty plea and other mitigating factors, resulting in a fine rather than a custodial sentence.

Sections 3(1)(a), 3(1)(b), 6, and 8 of the Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA)

• Sections 3(1)(a), 3(1)(b), 6, and 8 of the Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA) represented the foundational criminal provisions against money laundering in Mauritius for over two decades.

These provisions are now of historical significance only:

• Part II of FIAMLA (encompassing sections 3, 6, and 8) was entirely repealed on 29 March 2024 under section 166 of the Financial Crimes Commission Act 2023 (Act 20 of 2023).
• Comparable and, in certain respects, enhanced money laundering offences, procedural rules, and penalties have been consolidated into the new Act's Sub-part II of Part III, as part of a unified approach to addressing financial crimes (including corruption, fraud, and related matters) through the Financial Crimes Commission.
• Collectively, these sections provided a robust, wide-reaching framework that facilitated effective detection, prosecution, and asset recovery, while aligning Mauritius with international AML standards (notably FATF requirements) and supporting the Financial Intelligence Unit's operations.
• The sections deal with
• Sections 3(1)(a) and 3(1)(b) established the main money laundering offences by broadly prohibiting:
• Any transaction involving property suspected (or reasonably suspected) to be the proceeds of crime [3(1)(a)]; and
• Acts such as receiving, holding, concealing, disguising, transferring, converting, or transporting such property across borders [3(1)(b)]. These applied an objective "reasonable suspicion" standard, extended to any underlying crime (domestic or an equivalent foreign offence), and imposed preventive compliance duties on reporting entities such as banks and designated professionals.
• Section 6 introduced prosecution-friendly procedures, enabling:
• Convictions for money laundering without requiring a separate conviction for the predicate offence;
• Combined charging of laundering and predicate crimes; and
• Proof of criminal proceeds through reasonable inference, without needing to identify a specific predicate crime.
• Section 8 prescribed stringent sanctions, including:
• Fines up to 10 million rupees and imprisonment (penal servitude) for up to 20 years;
• A reverse onus for asset forfeiture (property presumed criminal unless proven otherwise); and
• Exclusion of lenient sentencing options like probation.

• See Appendix 1 for more information

• Current position (post-29 March 2024)
• The exact wording above no longer exists in FIAMLA.
• Equivalent (and in some respects strengthened) money laundering offences, procedures, and penalties are now found in the Financial Crimes Commission Act 2023.
• The FIU itself continues to exist and operate under the remaining parts of FIAMLA.

Section 44(1)(b) of the Interpretation and General Clauses Act 1974 (Mauritius)

• Section 44(1)(b)
  • is a key provision dealing with corporate criminal liability (offences committed by bodies corporate) and the personal responsibility of individuals involved in their management.
  • In the context of the Leeneshwar Mohes conviction (for money laundering under the Financial Intelligence and Anti-Money Laundering Act 2002), this section was cited alongside the main offence provisions to hold him personally accountable as a director/company manager for the company's fraudulent actions and the resulting money laundering.
• Text of Section 44(1) (as per the Act)
  • Section 44 is titled "Offence by agent or body corporate".
  • It provides:
    • Where an offence is committed by – (a) an agent, the person for whom the agent is acting; (b) a body corporate, every person who, at the time of the commission of the offence, was concerned in the management of the body corporate or was purporting to act in that capacity, shall also commit the like offence, unless he proves that the offence was committed without his knowledge or consent and that he took all reasonable steps to prevent the commission of the offence.

Key Explanation

• Paragraph (b) specifically addresses offences committed by a body corporate (e.g., a company like KDDN Co. Ltd. in the money laundering case you referenced earlier).
• It establishes that directors, managers, or other persons in management positions (or those purporting to act as such) can be held personally criminally liable for offences committed by the company.
• This is a form of vicarious or derivative liability, the individual is deemed to have committed the same offence as the company unless they can prove a defence:
• The offence occurred without their knowledge or consent, and
• They took all reasonable steps to prevent it.
• This provision applies across Mauritian law unless a specific enactment states otherwise.
• It is commonly invoked in white-collar crime cases, including money laundering, fraud, corruption, and regulatory offences where companies are involved.
• This section mirrors similar provisions in many Commonwealth jurisdictions (e.g., the UK's Companies Act or general interpretation acts) to pierce the corporate veil in criminal matters and ensure individuals cannot hide behind the company structure.

The Interpretation and General Clauses Act 1974 (Mauritius) - https://mauritiuslii.org/akn/mu/act/1974/33/eng@2017-06-30

Why This Case Matters

• The FCC has highlighted that such fraudulent claims undermine the integrity of publicly funded capacity-building programmes like those administered by the HRDC.
• They erode public trust and divert resources away from genuine skills development initiatives.

This case underscores key issues:

1. Governance Failures Create Criminal Exposure. Inadequate internal controls and oversight can enable fraudulent activities.
2. Vulnerability of Public Funding Schemes   HRDC reimbursement mechanisms have been targeted in previous cases, indicating ongoing risks in the sector.
3. Increasing Regulatory Scrutiny,   The FCC continues to intensify efforts against the misuse of public schemes, corruption, and money laundering.

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Appendix 1 - The Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA, Act No. 6 of 2002)

• The Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA, Act No. 6 of 2002) was Mauritius’s foundational legislation for combating money laundering. Enacted on 10 June 2002, it established the Financial Intelligence Unit (FIU) as the central agency for receiving, analysing, and disseminating suspicious transaction reports. It also created a framework for reporting obligations, customer due diligence, record-keeping, and international cooperation.
• Part II (Money Laundering Offences, sections 3–8) contained the core criminal offences of money laundering. These sections remained in force (with amendments) from 2002 until they were repealed in their entirety, effective 29 March 2024, by section 166 of the Financial Crimes Commission Act 2023 (Act 20 of 2023). Money laundering offences are now defined and punished under Sub-part II of Part III of the Financial Crimes Commission Act 2023 (new sections 36 onward).
• The provisions you asked about (sections 3(1)(a), 3(1)(b), 6 and 8) were therefore historically central to Mauritius’s anti-money laundering regime.
• Below is the verbatim text from the last consolidated version of FIAMLA before repeal (as published on official sites such as the Financial Services Commission), together with explanations of their meaning, purpose, and practical impact.

Section 3 – Money Laundering (the core offence)

Verbatim (as last in force):

(1) Any person who – (a) engages in a transaction that involves property which is, or in whole or in part directly or indirectly represents, the proceeds of any crime; or (b) receives, is in possession of, conceals, disguises, transfers, converts, disposes of, removes from or brings into Mauritius any property which is, or in whole or in part directly or indirectly represents, the proceeds of any crime, where he suspects or has reasonable grounds for suspecting that the property is derived or realized, in whole or in part, directly or indirectly from any crime, shall commit an offence.

(2) A reporting person who fails to take such measures as are reasonably necessary to ensure that neither he, nor any service offered by him, is capable of being used by a person to commit or to facilitate the commission of a money laundering offence or the financing of terrorism shall commit an offence.

(3) In this Act, reference to concealing or disguising property … shall include concealing or disguising its true nature, source, location, disposition, movement or ownership of or rights with respect to it. (Amended inter alia by Act 14/2009 and Act 5/2020; earlier versions used “bank, financial institution …” instead of “reporting person”.)

What this meant in practice

• Two alternative ways to commit the offence (the “or” makes them disjunctive):
• 3(1)(a): Simply engaging in any transaction involving criminal proceeds (e.g. depositing, investing, or spending dirty money).
• 3(1)(b): Any classic money-laundering act (possessing, concealing, transferring, converting, moving across borders, etc.).
• The mens rea (“where he suspects or has reasonable grounds for suspecting”) applied to the whole subsection. Mauritius courts treated this as an objective test   actual knowledge or what a reasonable person in the defendant’s position would have suspected.
• Predicate offence: Any “crime” under Mauritian law (or foreign equivalent)   no need for a drug offence or serious crime only.
• Property: Broadly defined (cash, bank accounts, real estate, shares, virtual assets in later amendments).
• Section 3(2) imposed a positive duty on banks, financial institutions, cash dealers and “relevant professions” (lawyers, accountants, etc.) to implement preventive systems. Failure was itself a separate offence.

This section was intentionally wide to catch both the launderer and the person who merely “turns a blind eye”.

Section 6 – Procedure (prosecutorial facilitations)

Verbatim (as last in force):

(1) A person may be convicted of a money laundering offence notwithstanding the absence of a conviction in respect of a crime which generated the proceeds alleged to have been laundered. (2) Any person may, upon single information or upon separate information, be charged with and convicted of both the money laundering offence and of the offence which generated the proceeds alleged to have been laundered. (3) In any proceedings … it shall be sufficient to aver in the information that the property is … the proceeds of a crime, without specifying any particular crime, and the Court … may reasonably infer that the proceeds were … the proceeds of a crime. (4) [added later] Single information possible even if different investigatory authorities handled the predicate and the laundering. (Amended by Act 27/2012 and Act 15/2021.)

Practical effect This made prosecutions much easier. Prosecutors did not have to secure (or even bring) a conviction on the underlying crime (the “predicate”). They could simply prove the property was criminal proceeds by inference from all the evidence. It also allowed “bundling” the ML charge with the predicate charge on the same information. These procedural tools were critical in complex cross-border cases where the predicate occurred abroad or was difficult to prove.

Section 8 – Penalty

Verbatim (as last in force after 2019 amendment):

(1) Any person who – (a) commits an offence under this Part; or (b) disposes or otherwise deals with property subject to a forfeiture order under subsection (2), shall, on conviction, be liable to a fine not exceeding 10 million rupees and to penal servitude for a term not exceeding 20 years.

(2) Any property belonging to or in the possession or under the control of any person who is convicted … shall be deemed, unless the contrary is proved, to be derived from a crime and the Court may … order that the property be forfeited.

(3) Sections 150, 151 and Part X of the Criminal Procedure Act and the Probation of Offenders Act shall not apply to a conviction under this Part. (Original 2002 penalty was only 2 million rupees / 10 years; increased by Act 9/2019.)

Significance

• One of the harshest ML penalties in the region at the time.
• Reverse onus on forfeiture: once convicted, everything the person owned/control was presumed “dirty” unless they proved otherwise.
• No probation, no suspended sentences, no ordinary sentencing discounts under the Criminal Procedure Act.
• In practice, courts routinely ordered full forfeiture of the laundered assets plus hefty fines and long prison terms.

How these sections fitted into the broader FIAMLA 2002 framework

• Linked to reporting (Part IV): Banks, financial institutions, cash dealers and relevant professions had to file Suspicious Transaction Reports (STRs) with the FIU under section 14 whenever a transaction gave “reason to believe” it might involve money laundering (directly tied to the suspicion test in section 3).
• FIU role: Analysed STRs and disseminated intelligence to police, ICAC, etc.
• Preventive measures (section 17): Mandatory customer identification, record-keeping (5+ years), internal controls.
• International alignment: These provisions helped Mauritius exit FATF grey-listing processes in the 2000s–2010s and meet evolving FATF Recommendations (including later additions on terrorism financing and proliferation financing).

Original vs later versions

• 2002 original: narrower “bank/financial institution” language in s.3(2); lower penalties in s.8 (2M/10 yrs); no explicit terrorism financing reference.
• Successive amendments (2003–2021) broadened “reporting persons”, raised penalties, added virtual assets, and aligned with FATF.

Sources

• https://fcc.mu/director-of-company-found-guilty-of-money-laundering-over-fraudulent-hrdc-claims/
• https://topfm.mu/blanchiment-dargent-reconnu-coupable-leeneshwar-mohes-devra-sacquitter-dune-amende-de-plus-de-rs-18

Key Official Sources for the FIAMLA 2002 Text (including historical/consolidated versions)

1. Financial Services Commission (FSC) Mauritius – Full Act PDFhttps://www.fscmauritius.org/media/3652/financial-intelligence-and-anti-money-laundering-act-2002.pdf (This is a comprehensive PDF version with sections 3, 6, and 8 visible in older consolidations.)
2. Laws of Mauritius Official Portal – Consolidated FIAMLAhttps://lawsofmauritius.govmu.org/portal/viewlegislationdocument/web?docnumber=&doctitle=RmluYW5jaWFsIEludGVsbGlnZW5jZSBhbmQgQW50aS1Nb25leSBMYXVuZGVyaW5nIEFjdA%3D%3D%0D%0A&doctype=act (Shows the Act with amendments up to recent dates, notes on repeal of Part II by Act 20/2023, and history of changes to sections like 3, 6, and 8.)
3. Civil Service Bureau / Ethics Page – FIAMLA PDFhttps://civilservice.govmu.org/Documents/ethics/FIAMLA_ActNo6.pdf (Early amended version with sections 3, 6, and 8 included.)
4. Non-Sovereign Securities Commission (or related gov site) – FIAMLA PDFhttps://nssec.govmu.org/Documents/Legislations/The_Financial_Intelligence%20and%20Anti-Money%20Laundering%20Act.pdf (Another full PDF copy of the Act.)
5. Bank of Mauritius – FIAMLA Pagehttps://www.bom.mu/about-bank/legislations/financial-intelligence-and-anti-money-laundering-act-2002 (Links to the Act and related AML guidance; references the text.)

Sources for Repeal and Transition to Financial Crimes Commission Act 2023

6. Financial Crimes Commission Mauritius – FCCA PDF (amended as at May 2025)https://fcc.mu/wp-content/uploads/2025/05/FCCA-amended-as-at-May-2025.pdf (Details section 166 repealing Part II of FIAMLA, with new money laundering provisions replacing sections 3, 6, and 8.)
7. Mauritius National Assembly – Financial Crimes Commission Bill PDFhttps://mauritiusassembly.govmu.org/mauritiusassembly/wp-content/uploads/2023/12/bill2023.pdf (Explanatory notes on repeal of Part II of FIAMLA and replacement framework.)

Additional Useful Sources (with excerpts or context on sections 3, 6, 8)

8. Bank of Mauritius – Guidance Notes on AML/CFThttps://www.bom.mu/sites/default/files/GUIDANCE_AML-CFT20140715.pdf (Discusses FIAMLA framework, including references to sections 3 and related obligations.)
9. Scribd Upload – FIAMLA 2018 Versionhttps://www.scribd.com/document/480561999/FIAMLA-2018 (User-uploaded consolidated PDF; useful for older amended text of sections 3, 6, 8.)
10. VERTIC (Verification Research) – FIAMLA PDFhttps://www.vertic.org/media/National%20Legislation/Mauritius/MU_Financial_Intelligence_Money_Laundering_Act.pdf (Early version with consequential amendments noted.)

official primary source (recommended):

11. The full consolidated text of the Interpretation and General Clauses Act 1974 (Act 33 of 1974, as amended) is available on the official Laws of Mauritius portal operated by the Government of Mauritius (Attorney-General’s Office). Direct link: https://lawsofmauritius.govmu.org/portal/viewlegislationdocument/web/?doctitle=SW50ZXJwcmV0YXRpb24gYW5kIEdlbmVyYWwgQ2xhdXNlcyBBY3Q=&docnumber=&doctype=act
12. This is the authoritative, up-to-date consolidated version. It includes all amendments (listed on the page, e.g., up to Act 5/2022 and earlier ones such as 1/2020, 14/2018, etc.). The full Act can be viewed online; consolidated editions are also typically downloadable or printable from the portal.

Additional reliable sources for reference:

• PDF of the original 1974 Act (Act 33/1974): https://faolex.fao.org/docs/pdf/mat196940.pdf Useful for the historical text, but always cross-check against the official consolidated version above for post-1974 amendments.
• Mauritius (Mauritius Legal Information Institute) – Version as at 30 June 2017: https://mauritiuslii.org/akn/mu/act/1974/33/eng@2017-06-30 Provides a clean, structured version of the Act (free and open access). Note the cut-off date; use the govmu.org portal for any later updates.

Exchange rates

• MUR 1,836,500 (Mauritian Rupees) converts to approximately the following amounts as of March 18, 2026 (using mid-market exchange rates from reliable sources like XE.com and Wise; note that actual rates for transfers or exchanges may vary slightly due to fees or provider margins):
• In USD (US Dollars): ≈ $39,400 (Based on the current rate of ≈ 1 MUR = 0.0215 USD. Calculation: 1,836,500 × 0.0215 ≈ = 39,434.75 USD, rounded to the nearest hundred for simplicity.)
• In GBP (British Pounds): ≈ £29,500 (Based on the current rate of ≈ 1 MUR = 0.0161 GBP. Calculation: 1,836,500 × 0.01606 ≈ = 29,494 GBP, rounded to the nearest hundred.)