Tradebull: The MLM Arm Of GoMillions LLP, Under ED Lens!
In September 2024, Guwahati police registered an FIR that would evolve into a multi-agency probe into alleged unregulated deposits, cheating, and money laundering. The case centres on GoMillions LLP and a platform called TradeBull, linked to partners Joy Modak and Rishiraj (or Rishi Raj) Gogoi. What began as a local police case under the Bharatiya Nyaya Sanhita (BNS) 2023 and the Banning of Unregulated Deposit Schemes Act (BUDS Act) 2019 was transferred to the CBI, produced bail proceedings in the Gauhati High Court, and later formed the predicate offence for an Enforcement Directorate (ED) investigation under the Prevention of Money Laundering Act (PMLA) 2002. In August 2026 the ED provisionally attached assets worth approximately ₹15.25 crore.
The September 2024 FIR and Initial Allegations Against Tradebull and GoMillions
On 4 September 2024, the Officer-in-Charge of Geetanagar Police Station, Guwahati, registered Geetanagar P.S. Case No. 174/2024 (corresponding to G.R. Case No. 5207/2024). The FIR invoked Sections 61(2)(a), 111(3), 316(5) and 318(4) of the Bharatiya Nyaya Sanhita, 2023, read with Sections 21 and 23 of the Banning of Unregulated Deposit Schemes Act, 2019.
According to the FIR narrative recorded in the subsequent High Court order, specific inputs indicated that Joy Modak, Rishi Raj Gogoi and other alleged accomplices were running a stock-trading business under the guise of GoMillions LLP. They had established an office at Hatigarh Chariali, Guwahati. The allegation was that they collected large amounts of public deposits by promising high returns, specifically double or triple growth of the invested amount within a short period.
The money was allegedly invested in the share market for the accused persons’ wrongful personal gain, in violation of SEBI/RBI statutory guidelines. The FIR characterised the arrangement as a major financial scam involving cheating of the public, misappropriation, and criminal conspiracy.
Joy Modak was arrested on 5 September 2024. Rishiraj Gogoi was later arrested (reports place one arrest around mid-October 2024 from Margherita). The defence narrative, as advanced in bail proceedings, portrayed GoMillions LLP as a legitimate business entity. Counsel emphasised that the LLP held an FSSAI registration, a Gauhati Municipal Corporation trade licence, a GST certificate, recognition from the Ministry of Commerce and Industry / Department for Promotion of Industry and Internal Trade, and licences relating to the sale and supply of cosmetics and other products (salts, spices, soups, etc.).
The petitioner claimed to be a businessman and partner who paid taxes and whose receipts were reflected in business records. The defence sought to distinguish a legitimate registered LLP from the alleged investment activity.
The prosecution’s counter-position, as reflected in the case diary material later examined by the High Court, was that corporate registration and ordinary business licences do not automatically authorise the collection of public deposits or the operation of an investment scheme promising high fixed returns. The existence of GST, municipal, and FSSAI credentials does not equate to regulatory permission under SEBI, RBI or the BUDS Act framework for accepting deposits from the public.
Transfer to the CBI and Early Investigative Material
On 9 October 2024 the Government of Assam transferred the investigation of Geetanagar P.S. Case No. 174/2024 to the CBI. Central Government approval followed on 11 October 2024. The case was re-registered as CBI Guwahati Case No. RC 2262023E0002 (the numbering as recorded in the High Court order). Part of the case diary was handed over on 14 October 2024 and the remaining material on 25 October 2024. The CBI Anti-Corruption Branch, Guwahati, took charge.
At the bail stage the CBI placed before the Gauhati High Court material showing large numbers of investors/creditors making internet-banking and UPI credits (often five- or six-digit amounts) into GoMillions LLP accounts, with regular seven-digit debits from those accounts across different banks and branches. Multiple accounts and identities appeared.
A bank statement of an account held jointly by Joy Modak and his wife (covering January to October 2024) was highlighted as showing substantial incoming transfers allegedly linked to investors. The CBI characterised the material as indicating involvement in huge financial transactions and argued that the investigation was incomplete; further tracing of the financial trail was required.
Later reporting (December 2024) indicated that the CBI filed chargesheets in related Assam online-trading scam matters. One report specifically linked Rishiraj Gogoi and Joy Modak to the collection of public deposits under the guise of stock trading through GoMillions LLP (ostensibly formed to sell cosmetics and other products), stating that the funds were not deposited in any regulated scheme. The CBI was said to have traced databases of depositors. The precise content of any chargesheet confined solely to the GoMillions/TradeBull matter is not fully reproduced in open public sources available for this article; the High Court bail order and contemporaneous news remain the primary windows into the 2024 investigative picture.
Joy Modak’s Bail Application and the Gauhati High Court Order of 6 November 2024
Joy Modak filed Bail Application No. 2875/2024 under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023. By the date of hearing he had been in custody for more than 63 days (arrested 5 September 2024; order 6 November 2024). Justice Manash Ranjan Pathak of the Gauhati High Court heard the matter.
Defence arguments included:
– GoMillions LLP was a legitimate registered business with multiple government licences and registrations.
– The petitioner was merely conducting legitimate business; money received was reflected in records and taxes were paid.
– No one had been illegally cheated; the arrangement was characterised by the defence as a chain/pyramid-type system that did not adversely affect participants.
– Sections 111(3) and 316(5) BNS were not attracted on the facts.
– Because those sections were allegedly inapplicable, the remaining offences attracted a 60-day investigation period; more than 60 days having elapsed, the petitioner was entitled to statutory/default bail.
– Reliance was placed on Supreme Court decisions emphasising personal liberty and the principle that bail is the rule and jail the exception (including Sanjay Chandra v. CBI, Arnab Manoranjan Goswami v. State of Maharashtra, and other authorities on procedure and the interaction of general criminal provisions with special statutes).
CBI opposition emphasised:
– The case diary contained sufficient incriminating material linking the petitioner to the alleged offences.
– Large-scale financial transactions, multiple accounts, investor credits (including into a personal joint account), and incomplete investigation of the money trail.
– Economic offences involving numerous victims and complex transactions warrant careful consideration; reliance was placed on Y.S. Jagan Mohan Reddy v. CBI.
– The CBI had only recently received the full case diary and needed time to complete the financial investigation.
The Court examined the case diary and found “sufficient incrementing materials regarding involvement of the petitioner in the alleged crime.” It held that it was not a fit case for grant of bail, notwithstanding the period of detention already undergone. The bail application was rejected. A subsequent bail application by Modak in late November/December 2024 (reported as Bail Application connected to the same CBI case) was also dealt with by the High Court; the earlier rejection remained the principal reported order on the November material.
Critically, the High Court did not conduct a trial or record findings of guilt. It assessed the material available at the bail stage for the limited purpose of deciding whether continued custody was justified. The allegations remained allegations.
The Statutory Framework and Why the “Business vs Scheme” Distinction Mattered
The BUDS Act 2019 prohibits unregulated deposit schemes. Its policy premise is that entities may not collect deposits from the public with promises of returns unless the scheme is regulated and authorised. The prosecution characterised the TradeBull/GoMillions operation as falling within the prohibited category.
The BNS provisions invoked covered criminal conspiracy, organised crime-related aspects (the precise applicability of Section 111(3) was contested), criminal breach of trust or misappropriation-type offences, and cheating. Defence counsel argued that certain sections did not apply, seeking to reduce the applicable default-bail timeline. The Court did not accept the default-bail argument as determinative in the face of the case-diary material.
A recurring theme in financial-crime litigation is that legitimate corporate existence (GST, trade licence, FSSAI, DPIIT recognition) does not immunise specific activities that may violate deposit-taking or securities regulations. The High Court order reflects this distinction: registration of an LLP does not automatically legitimise public solicitation of deposits promising high, rapid returns.
Evolution into the ED’s PMLA Investigation
The ED, Guwahati Zonal Office, initiated a PMLA investigation on the basis of the CBI FIR that itself arose from Geetanagar P.S. Case No. 174/2024. The ED therefore treated the underlying alleged offences under BNS and the BUDS Act as the predicate offences generating “proceeds of crime.”
PMLA proceedings are not a mere duplication of the criminal case. The focus shifts from whether the collection of money constituted the scheduled offence to what happened to the alleged proceeds—whether they were layered, diverted, integrated into assets, or otherwise laundered. Provisional attachment under Section 5 of the PMLA is a protective measure pending adjudication; it is not final confiscation.
What the ED Added: Specific Figures, Server Data, Layering Entities, and Asset Details (August 2026)
On or about 8 August 2026 the ED announced the provisional attachment of assets worth approximately ₹15.25 crore. Official and contemporaneous reports (including the ED’s own communication) state the following investigative findings:
– Data recovered from the entity’s server disclosed more than 25,410 unique investor identities.
– Aggregate payment liability (the amount allegedly owed/payable to investors according to the recovered data) stood at approximately ₹34.93 crore. Care must be taken not to equate this figure automatically with total collections; the ED describes it as payment liability.
– Approximately ₹63.41 crore was credited into the principal bank accounts of GoMillions LLP.
– The alleged proceeds of crime were layered through connected entities, including Rightway Infocom Pvt. Ltd., Carely Solutions Pvt. Ltd., and Lotus Corporation, and subsequently diverted into personal accounts of the promoters and their family members.
– The scheme was operated under the name TradeBull (product-based multi-level marketing enterprise style) and allegedly promised a fixed daily return of 0.85 per cent and doubling of the investment in approximately six months—far more specific than the general “double or triple in a short period” language of the 2024 FIR/High Court record.
– The attached assets comprised bank balances (of entities and individuals), fixed deposits, a stock-trading account, three motor vehicles (including a Porsche and a Mercedes-Benz), and cash. Unaccounted cash had also been recovered during the predicate investigation.
– Further investigation was stated to be under progress.

These details go substantially beyond the material summarised in the November 2024 High Court order. That order spoke of “large numbers of investors,” five- and six-digit credits, seven-digit debits, multiple accounts, and substantial transactions. The ED has quantified investor identities (25,410+), named a concrete liability figure (₹34.93 crore), quantified credits into principal accounts (₹63.41 crore), identified specific layering entities, particularised the alleged return promise (0.85 % daily / doubling in ~six months), and tied specific high-value movable assets (luxury cars, FDs, trading account, cash) to the alleged proceeds.
Corporate-information databases independently list Joy Modak and Rishiraj Gogoi as designated partners of GoMillions LLP and show linkages consistent with the entities named by the ED; such records do not themselves prove money-laundering but supply a documentary backdrop for the layering allegations.
Timeline Summary
– 4 September 2024: Geetanagar P.S. Case No. 174/2024 registered.
– 5 September 2024: Joy Modak arrested.
– October 2024: Investigation transferred to CBI (State order 9 Oct; Centre approval 11 Oct; diary handover mid-to-late October). Rishiraj Gogoi arrested (mid-October reports).
– 6 November 2024: Gauhati High Court rejects Joy Modak’s first bail application after examining the CBI case diary.
– Late 2024: Further CBI proceedings and reporting of chargesheets in related Assam trading-scam matters naming the GoMillions partners among others.
– By August 2026: ED, acting on the CBI/FIR predicate, recovers server data, quantifies investors and flows, traces layering through named entities, and provisionally attaches ≈₹15.25 crore in assets. Press release notes further investigation ongoing.
Key Legal and Practical Distinctions
– Bail vs conviction: The High Court order decides only the question of interim liberty; it does not adjudicate guilt.
– Provisional attachment vs confiscation: ED attachment under PMLA is provisional. It is subject to confirmation by the Adjudicating Authority and ultimately to judicial scrutiny. It is not equivalent to final forfeiture.
– Predicate offence vs PMLA: The BNS/BUDS case asks whether the collection and promises constituted the scheduled offences. The PMLA case asks whether the resulting proceeds were laundered.
– Corporate façade vs activity: Registration of an LLP and ordinary business licences do not automatically legalise unregulated deposit-taking or high-return investment solicitations.
– Default bail argument: The defence’s 60-day argument rested on the claimed inapplicability of certain BNS sections. The Court, having found sufficient material in the diary, refused bail without elaborating a broad new rule of law on default bail in economic offences.

The public record as of August 2026 therefore shows a clear continuum: a September 2024 FIR alleging unregulated high-return deposit collection through GoMillions/TradeBull → CBI takeover and High Court bail rejection on the strength of financial-transaction material → ED PMLA investigation that quantifies investors, credits, liability and layering entities and attaches specific assets valued at ₹15.25 crore. The quantitative and entity-level detail supplied by the ED constitutes the principal expansion of the evidentiary picture beyond the 2024 court record.



