Under FERA, the penalty payable is five times the amount identified. Whether prosecution will be launched with the adjudication remains to be seen.Separate notices are to be issued to those who dealt with Shah in his hawala operations, the list being a virtual who's who of the video and film industry. There's Haresh Hemdev of Indus Video, Mohamad Rafi Lativala of Bombino Video, Nandkishore Prasad of Venus Audio, besides film producer Jhamu Sugand, actors Gulshan Grover and Rishi Kapoor.

Bharat Shah, owner of Roopam and Roopmilan chain of fashion superstores, who was recently gunned down by Chota Shakeel men near the crime branch headquarters, Anwar Lalani of Pink Panther, Chiman Ravji Savla and Velji Gangji Shah ofBenzer Exports, Suresh Chablani of Rose Travels, Arvind Mehra and Rupali Mehra, Kamlesh Kotadia, Ganesh C Jain are others who had dealings with Shah.

Shah ran the Mumbai operations in the racket run by his brother, Ramesh N Shah, a Dubai-based NRI. The SCN relates to the period between 1993-95, when Ramesh allegedly parted with dollars in Dubai against which Dhirubhai received payment in rupees in India. In the reverse, an NRI who wanted to evade the banking channels to send money into India, would pay in foreign currency to Ramesh and the amount would be received by the NRI's beneficiaries in Indian rupees from Dhirubhai.

The ED has identified transactions of Hemdev and Lativala against their travels abroad, as also of Chablani who received an amount from Time Video towards tickets booked abroad for Kishore and Lal Dadlani. A gift deed made to Rupali Mehra via the Immunities under Foreign Remittance Scheme of 1993 is also identified, as against which a payment of Rs 11.41 lakh was made to Dhirubhai inMumbai.

While Dhirubhai was detained under COFEPOSA for some months, the detention was set aside by the advisory board. Ramesh, on the other hand, while claiming that he was too sick to travel, had come to India surreptitiously, and was nabbed at the Sahar airport in an attempt to flee the country in April 96. He later jumped bail and is still absconding, successfully avoiding the service of the COFEPOSA order against him.