AMLPMLAComplianceIndia
AMLEGALS / Services / AML
AML / PMLA · Compliance

Anti money laundering and PMLA compliance advisory

KYC design, suspicious transaction reporting, internal controls and enforcement defence under the Prevention of Money Laundering Act, 2002 and the RBI/SEBI/IRDAI directions.

Counsel that connects the technical, the commercial, and the legal, across ten offices in India.
PMLA
2002 (as amended 2023)
KYC
Framework Design
ED
Enforcement Defence
10
Offices
01

The PMLA compliance framework for regulated entities

  • Customer due diligence (CDD) and enhanced due diligence (EDD) under RBI Master Direction on KYC, 2016 (updated 2023).
  • Suspicious transaction report (STR) and cash transaction report (CTR) filing to the Financial Intelligence Unit (FIU IND).
  • Internal controls, principal officer appointment, record keeping (minimum five years) and employee training obligations.
  • Sectoral overlay: SEBI registered intermediaries, IRDAI regulated entities, DNFBP (designated non financial businesses and professions) and payment system operators.
02

Enforcement defence and provisional attachment

  • Representation before the Adjudicating Authority under Section 5 provisional attachment orders.
  • Appeals before the Appellate Tribunal for PMLA and High Courts.
  • Bail applications and defence strategy in scheduled offence prosecutions.
  • Cross border mutual legal assistance and extradition treaty coordination.
03

AML audit and gap assessment

  • Independent review of KYC, CDD, EDD and transaction monitoring controls.
  • STR and CTR filing accuracy, timeliness and documentation audit.
  • Board level reporting, risk appetite statement and annual compliance certificate preparation.
  • Mock regulatory inspection readiness and remediation roadmap.
04

How AMLEGALS assists

  • PMLA compliance framework design for banks, NBFCs, fintechs and securities intermediaries.
  • FIU IND registration and reporting setup.
  • Enforcement and attachment response with coordinated litigation strategy.
  • Training programmes for compliance officers and board members.
Answers

What clients ask before they commit.

Short, direct, on the record.

01Which entities must comply with the PMLA in India?

Banks, financial institutions, NBFCs, payment system operators, SEBI registered intermediaries, insurance companies and designated non financial businesses and professions (DNFBPs) including real estate agents, dealers in precious metals and stones, and certain professionals as notified by the Central Government.

02What is the penalty for non filing of STR under PMLA?

The Director, FIU IND can impose a monetary penalty under Section 13 of the PMLA. Non compliance with KYC and reporting norms also attracts regulatory action from the sectoral regulator (RBI, SEBI, IRDAI) which can include monetary penalties, restrictions on business and cancellation of registration.

03Can the Enforcement Directorate attach property before conviction?

Yes. Under Section 5 of the PMLA, the ED can provisionally attach property believed to be proceeds of crime. The attachment must be confirmed by the Adjudicating Authority within 180 days. The affected person has a right to be heard and can appeal to the Appellate Tribunal.

04Does PMLA apply to cryptocurrency transactions in India?

Yes. The PMLA was amended in 2023 to include virtual digital asset service providers as reporting entities. They must register with FIU IND, maintain KYC records and file STRs and CTRs.

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