Senior officials at Standard Chartered saw an investment in TMB shares as an opportunity that might ripen into eventually larger ownership for the bank,» Sushil Kumar, the enforcement agency's special director, said in the order. 46,862 shares were transferred to foreign investors including GHI, Swiss Re Investors, FI Investments, Cuna Group and Sub-Continental Equities, an affiliate of Standard Chartered in April 2008. The transfers were made through escrow accounts with Standard Chartered, which acted as both a transaction agent and a lender to one of the investors on the deal. Standard Chartered through its affiliate Subcontinental was a proposed and eventually an actual investor in TMB shares to be purchased through the escrow agreement arrangements, Kumar added. Separately, TMB was fined almost 170 million rupees ($2.3 million) for similar charges.