Anti-money-laundering and financial-crime compliance
Anti-money-laundering (AML) compliance is the set of policies, checks and reports a business keeps to show that it knows its customers and reports suspicious transactions. In India the duty comes from the Prevention of Money Laundering Act, 2002, and from sector rules issued by the RBI, SEBI, IRDAI and the Financial Intelligence Unit (FIU-IND). The practice is led by a partner who holds an AML certification.
Who it applies to
Banks, NBFCs, payment system operators, fintechs and lenders.
Stockbrokers, mutual funds, portfolio managers and insurers.
Real estate agents, and dealers in precious metals and stones.
Professionals, including chartered accountants and company secretaries, when they carry out specified financial transactions for a client.
When you need this
- You are launching a lending, payments or investment product and need an AML framework before you go live.
- A regulator or a banking partner has raised observations on your KYC or monitoring.
- Your policy has not been revisited since the rules changed.
- You need an independent review of your AML programme for your board or a partner.
What we do
AML and CFT policy
A written policy that matches your products, customers and geographies.
KYC and customer due diligence
Onboarding procedures, beneficial-ownership identification, enhanced due diligence for higher-risk customers, and periodic refresh.
Risk assessment
Scoring of customers, products, channels and geographies, documented for the board.
Transaction monitoring
Review of alert rules and thresholds, and of how alerts are cleared.
Reporting
Suspicious transaction reports, cash transaction reports and other filings to FIU-IND, and the Principal Officer's records.
Sanctions screening procedures
Procedures aligned with applicable sanctions requirements.
Training
Training for staff and the Principal Officer.
Independent testing
An annual review of the programme with a written report to the board.
Remediation
After a regulator's inspection or a banking partner's audit.
How an engagement runs
- Gap review of the existing policy and practice against the rules that apply to you.
- Draft policy, procedures and risk assessment, discussed with the Principal Officer.
- Training and a trial period for the monitoring rules.
- Independent test at a set interval, with a report to the board.
What we need from you
- Your product description, customer types, existing policy and procedures, alert and STR logs, and any regulator or partner observations.
Questions people ask
- Who is a reporting entity under the PMLA?
- It is any person the Act or its notifications bring within the reporting duties: banks and financial institutions, intermediaries, and certain others such as real estate agents and, for specified transactions, professionals. Each must register with FIU-IND and report as required.
- What is a suspicious transaction report?
- It is a report to FIU-IND of a transaction that appears to involve proceeds of crime, lacks an economic rationale or is made in unusual circumstances. It must be filed within the time the rules prescribe, and the customer is not told.
- How often should an AML policy be reviewed?
- At least once a year, and whenever the products, customers or regulations change.
- Does a new fintech need an AML programme before launch?
- If it will be a reporting entity or runs on a regulated partner's licence, yes. The partner will usually ask for it before onboarding you.
Related practices
Engagement terms and fees are agreed after the first conversation, based on scope and complexity.
Contact the Office