What it means to appear in the ICIJ database, and what his entry actually says

Being in the ICIJ database is a specific thing. It is worth setting out precisely what it is, because the phrase “named in the Pandora Papers” is used loosely and carries a weight the record itself often does not.

The institution

The International Consortium of Investigative Journalists is a non-profit newsroom that coordinates cross-border investigations. It is the organisation behind the Panama Papers, the Paradise Papers and the Pandora Papers, and it maintains the Offshore Leaks Database: a public, searchable index of more than 810,000 offshore entities drawn from five separate leaks.

Those five are Offshore Leaks in 2013, the Panama Papers and Bahamas Leaks in 2016, the Paradise Papers in 2017 and 2018, and the Pandora Papers in 2021. Together the records span more than eighty years, ending in 2020, across more than two hundred countries and territories.

The database is not the leaked documents. ICIJ publishes the corporate structures, the officers and the addresses. It does not publish bank accounts, emails or transactions, and it says so.

The leak his record comes from

The Pandora Papers, published from 3 October 2021: 11.9 million documents, 2.9 terabytes, shared with more than 600 journalists. The material came from 14 offshore service providers and produced reporting on more than three hundred serving and former heads of state and politicians.

His record comes from one of those fourteen: Alemán, Cordero, Galindo & Lee, the Panamanian law firm known as Alcogal. ICIJ analysed 109 suspicious activity reports that Alcogal itself filed to financial authorities. The provider data reaches 2018 and stops there.

The entry, in full

The database holds an officer node in his full legal name:

OFFICER: NARENDERKUMAR DHARAMVEER MANOJ MADNANI Linked countries: United Arab Emirates, United Kingdom Data from: Pandora Papers · Alemán, Cordero, Galindo & Lee (Alcogal) Provider data is current through 2018

One connected entity:

FLINTREE HOLDINGS LIMITED Role: Ultimate beneficial owner Incorporated: 4 April 2010 · Jurisdiction: British Virgin Islands Status: Continuation Out

One address, in Dubai. It is a residential address. This archive has verified it and will not publish it - the editorial standards of this site exclude private addresses, and a rule that only applies when it is convenient is not a rule.

That is the entirety of the record. One officer node, one company, one address.

What ICIJ itself says about it

The consortium prints a caution on every page of the database, and it is not boilerplate. There are legitimate uses for offshore companies and trusts, and ICIJ states that it does not intend to suggest or imply that any person or entity in the database has broken the law or acted improperly.

That caution is recorded here in full, and it is the consortium’s, not a conclusion of this archive’s.

What this archive records is narrower and does not require a view either way. He is not named in that database as a defendant, a suspect or a subject of any proceeding. He is named in it as the ultimate beneficial owner of a British Virgin Islands company, sourced to a Panamanian provider whose files were leaked, in a dataset built from fourteen such providers. That is the entry. It is what it is.

So what does the entry establish

Three things, and only three.

That the name exists in this form. Every profile he publishes uses Manoj Narender Madnani. The leak, like the British statutory register, uses Narenderkumar Dharamveer Manoj Madnani. This is one of only two places on the public internet where the two can be connected.

That he beneficially owned a British Virgin Islands company. Not a directorship, not an advisory seat: ultimate beneficial ownership, the category the whole architecture of offshore secrecy exists to obscure and that the leak exists to reveal.

That it is not on his curriculum vitae. Twenty-seven affiliations appear across his published profiles. Flintree Holdings Limited is not among them.

And what it does not establish

Anything about what the company did. The record is a registration and an owner. Its status - Continuation Out - means it left the British Virgin Islands for a jurisdiction the record does not name, at a date the record does not give.

Where it went, and what it held, nobody has published. The provider data stops in 2018.