MONEY LAUNDERING IN INDIA: LEGAL PROVISIONS, ISSUES AND

CHALLENGES
VARUN NATARAJAN, AMAN KHERA, ISHITA DAS AND MONICA VIRDI
INTRODUCTION
Money laundering is the processing of the proceeds of criminal acts to disguise their illegal
origin. When a criminal activity generates substantial profits, the individual or group
involved must find a way to control the funds without attracting attention to the underlying
activity or the persons involved. 1 The United States criminal code defines money laundering
as “the concealment of the source and/or destination of money, which has usually been
gained through illegal activities.2
Therefore, money laundering is the process by which criminals attempt to conceal the true
origin and ownership of the proceeds of their criminal activities. If undertaken successfully, it
also allows them to maintain control over those proceeds, and ultimately, to provide a
legitimate cover for their source of funds. 3 The gains of a crime are a direct link between the
crime and the criminal who committed the offence. The gains so made are, therefore, needed
to be concealed and converted, so as to put them into such use that the same may make
legitimate earning for the criminal or that the same can be recoverted for facilitating
commission of further crimes. 4
Money laundering poses a serious threat to financial system integrity. It may emerge as a
parallel economic system, within a nation, controlled by a few. Among the negative effects of
money laundering on countries are a full range of severe macro economic consequences, such
as: unpredictable changes in money demand, prudential risks to the soundness of the financial
institutions and financial system, contamination effect on legal financial transactions,
increased volatility of international capital flows etc.5

Money Laundering: A Three Stage Process

Money laundering process generally comprises of following three stages:
Placement: the first step involves division of the proceeds into smaller lots, so as to make
movements thereof less suspectable. During this stage the cash generated by the crime is

1
See http://www.fatf-gafi.org/pages/faq/moneylaundering/ (Accessed: March 18, 2013)
2
18 USC $1956
3
Ibid at p. 113
4
Tushar V. Shah, Commentary on The Prevention of Money Laundering Act, 2002, 2nd Edn (Current
Publications, Mumbai), p. 112
5
http://www.fatf-gafi.org/pages/faq/moneylaundering/ (Accessed: March 18, 2013)

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gradually attempted to be inserted into the financial system. this is a delicate stage as
transformation attempted is less in transparent and hence vulnerable to be noticed. 6

Layering: this is the second stage during which the funds introduced in the financial system
are rotated, re-mixed, transferred and re-transferred repeatedly. It is as if multiple layers are
formed, one up the other so as to conceal the origin of the fund into the financial system. this
may also involve transfers within the country and across the country. With the advent of wire
transfers, the layering stage has become less traceable. The dirty money introduced in the
financial system is routed through shell corporations, very often existing in offshore banking
havens. The object of layering is to distance the fund from the origin, so as to make it very
difficult to reach back or trace the origin.

Integration: this stage of money laundering concerns itself with successful merging into the
legitimate financial system. This is done by use of diverse financial instruments like bonds,
securities, letters of credit, bills of lading etc. the launderer may choose to invest the funds
across a variety of sectors.
However, there is no one method of money laundering. Commonly used modes in laundering
process are: smuggling out cash currencies, hawala transfers, use of shell companies, under
invoicing and over-invoicing in import-export trade etc.7

Role of Financial Action Task Force (FATF) in prevention of Money Laundering

The FATF is an intergovernmental organization set up to combat money laundering and
terrorism financing. The Forty Recommendations and Nine Special Recommendations of
FATF provide a complete set of counter-measures against money laundering covering the
criminal justice system and law enforcement, the financial system and its regulation, and
international co-operation.8 The current forty recommendations, require states inter alia, to
implement relevant international conventions, criminalise money laundering and enable
authorities to confiscate the proceeds of money laundering, implement customer due
diligence (e.g. identity verification), record keeping and suspicious transaction reporting
requirements for financial institutions and designated non-financial businesses and
professions, establish a financial intelligence unit to receive and disseminate suspicious

6
Ibid at p. 117
7
Id at pp. 117- 18
8
FATF, http://fiuindia.gov.in/international-fatf.htm (Accessed: March 18, 2013)

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transaction reports, and cooperate internationally in investigating and prosecuting money
laundering.9
THE PREVENTION OF MONEY LAUNDERING ACT, 2002: KEY PROVISIONS
The main legislation dealing with the offence of money laundering in India is the Prevention
of Money Laundering Act, 2002 (PMLA). The PMLA was enforced in 2005 to prevent
money laundering and to provide for attachment, seizure and confiscation of proceeds of
crime obtained or derived, directly or indirectly from money laundering and for matters
connected therewith or incidental thereto.10
The offence is defined as follows: Whosoever directly or indirectly attempts to indulge or
knowingly assists or knowingly is a party or is actually involved in any process or activity
connected with the proceeds of crime and projecting it as untainted property shall be guilty of
offence of money laundering.11 Therefore, money laundering essentially involves the
projection of proceeds of crime as untainted property. The term proceeds of crime has been
defined as meaning any property derived or obtained, directly or indirectly, by any person as
a result of criminal activity relating to a scheduled offence or the value of any such
property. 12
The PMLA provides for Scheduled offences 13 the proceeds of which are treated as money
laundering. In addition, it provides for the Director to inspect records of banking companies,
financial institution or other intermediary and impose fines for non compliance. The Central
Government has appointed the Director, Financial Intelligence Unit, India, under Ministry of
Finance, Department of Revenue as the director to exercise powers.14

The PMLA casts obligations on Banking companies, financial institutions and intermediaries
of the securities market to maintain a record of all transactions, furnishing information as to
such transactions, verify and maintain the record of the identity of all its clients. 15 The Act
gives power to the central government, in consultation with the Reserve Bank of India to

9
International Best Practices. Financial Action Task Force on Money Laundering, 20 June 2003,
<http://www.fatf-
gafi.org/media/fatf/documents/recommendations/10%20FATF%20SRIX%20BPP%20SRVI%20June%202003
%202012%20cover.pdf>
10
http://pib.nic.in/newsite/erelease.aspx?relid=39397 (accessed: March 18, 2013)
11
Section 3, PMLA
12
Section 2(u), PMLA
13
Section 2(1)(y), PMLA, referring to the offences specified in Part A, B and C to the Schedule.
14
Vide Notification No. GSR 440(E), dated 1-7-2005
15
Section 12, PMLA, which provides for Obligations of Banking Companies, Financial Institutions and
Intermediaries of securities market.

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prescribe the procedure and manner of maintaining the records under Section 12. 16 This
provides for an important obligation for institutions in the Financial Market such as banks,
stock markets, insurance companies and other like agencies to maintain records of all
transactions, furnishing information and to maintain records of all its clients. This recognizes
the link which exists between money laundering and the financial system, since the financial
market is one of the vulnerable areas into which the money which is laundered is pumped
into.
Given the recognition that financial institutions like banks, insurance companies, stock
markets, etc are most vulnerable to such intrusion, the protection of the financial market is
sought to be achieved through implementation of Know Your Customers policy (KYC), and
Customer Due Diligence (CDD) guidelines across the financial sector. The objective of KYC
and CDD guidelines is to enable the managers to examine and assess their customer‟s
financial dealings from anti-money laundering perspective, so as to make a proper risk
assessment for preventing the tainted money from entering the institution. 17
In this regard, relevant norms for adherence of different financial institutions have been
provided by the different sectoral regulators: Reserve Bank of India, 18 Securities and
Exchange Board of India19 and Insurance Regulatory Development Authority. 20

AMENDMENTS TO THE PMLA

The PMLA was amended in the year 2011 to bring it at par with that of the FATF provisions.
The Prevention of Money Laundering (Amendment) Act, 2011 suitably widened the
definition of money laundering to include cheating, concealment, acquisition, possession and
use of proceeds of crime.21 The amendments were being proposed after FATF found several
shortcomings in it. The provision for fines, of which a maximum of five lakh could be

16
Section 15, PMLA
17
KYC- A Key to the prevention of Money Laundering, Daily News and Analysis, June 26, 2012, <
http://www.dnaindia.com/analysis/comment_kyc-a-key-to-prevention-of-money-laundering_1706717>
18
RBI Circular No RBI/2012-13/45, Master Circular – Know Your Customer (KYC) norms / Anti-Money
Laundering (AML) standards/Combating of Financing of Terrorism (CFT)/Obligation of banks under PMLA,
2002
19
SEBI Circular No CIR/MIRSD/ 11 /2012, dated September 5, 2012, referring to SEBI circulars No
CIR/MIRSD/16/2011 dated August 22, 2011 and MIRSD/SE/Cir-21/2011 dated October 5, 2011
20
IRDA Circular No 013/IRDA/LIFE/ JUL-06, dated July 27, 2006 referring to circular no.
043/IRDA/LIFE/AML/MAR-06 dated 31/03/06
21
LS Passes money laundering amendment Bill, Business Line, November 29, 2012,
<http://www.thehindubusinessline.com/industry-and-economy/banking/ls-passes-money-laundering-
amendment-bill/article4147170.ece>

Electronic copy available at: https://ssrn.com/abstract=2236175

imposed, was also done away with since it was considered to be disproportionately low given
the gravity of the offence of money laundering.22
The Amendment also proposed to make punishments possible for legal persons who are
responsible for money laundering. Certain key proposals were introduced for strengthening of
the KYC and reporting obligations, as well as record keeping obligations, including:
Know Your Customer (KYC) obligations to include “beneficial owner” during KYC for
reporting entities.
Reporting obligations- It was proposed in the legislation that reporting entity has to report
even an attempted transaction.
Record keeping obligations- it was proposed in the Report of the Standing Committee
examining the proposed amendments that KYC documents should be maintained for 10 years
after “the business relationship has ended” instead of “after cessation of transactions”, as at
present. “Account files and business correspondence” also needs to be retained for 10 years;
information about “attempted transactions” reported to FIU also needs to be retained. 23
At present PMLA provides for attachment of property after charge sheet u/s 173 Code of
Criminal Procedure, 1973 has been filed in scheduled offence case and seizure of property
after FIR u/s 157 Code of Criminal Procedure, 1973 has been filed in scheduled offence case.
The new sub-section 17(1A) was proposed to be added for this purpose. Consequential
changes are also proposed in a number of places in the Act, where “seizure” under section 17
or 18 is referred to.24
The Prevention of Money Laundering (Amendment) Bill, 2011 also provides for the order of
the appellate tribunal established under the PMLA to lie to the High Court. This was sought
to be done away with and provisions were made to make appeals directly before the Supreme
Court.25
What is important to be noted is that it was emphasized at the time of passing of the bill that
continuous amendments would be required to meet new challenges. Finance Minister P
Chidambaram stated “We have amended the bill in 2005 and 2009. India is a member of
Financial Action Task Force on money laundering and we need to amend our law to align

22
Lok Sabha approves changes in Money Laundering Bill, Livemint, November 29, 2012
<http://www.livemint.com/Politics/P49KxOKkfZUNmTIC0GjWIJ/Lok-Sabha-approves-changes-in-money-
laundering-Bill.html>
23
56th Report, Standing Committee on Finance, The Prevention of Money Laundering (Amendment) Bill, 2011,
pp. 9-10.
24
Ibid at p 12.
25
Ibid at p 13.

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with the international law.”26 indeed, the problem of money laundering and its implications
for the financial system cannot be overemphasized. This statement only indicates the gravity
of the threat posed by the offence of money laundering on the financial system of the country
as a whole.

SEBI MASTER CIRCULAR ON ANTI MONEY LAUNDERING AND COMBATING FINANCIAL

TERRORISM FOR REGISTERED INTERMEDIARIES:27 SALIENT FEATURES
This Master circular was issued in exercise of powers conferred under Section 11 (1) of the
Securities and Exchange Board of India Act, 1992, and Rule 7 of Prevention of Money-
laundering (Maintenance of Records of the Nature and Value of Transactions, the Procedure
and Manner of Maintaining and Time for Furnishing Information and Verification and
Maintenance of Records of the Identity of the Clients of the Banking Companies, Financial
Institutions and Intermediaries) Rules, 2005. The provisions of this circular would help note
the various steps which have been prescribed to the intermediaries to ensure compliance with
the various requirements of the PMLA and would also help in evaluation of the same.
It is provided in the master circular that all banks, financial institutions and intermediaries
registered under section 12 of the SEBI Act shall have to maintain records of all transactions
including:
 All cash transactions of the value of more than Rs 10 lakh or its equivalent in foreign
currency.
 All series of cash transactions integrally connected to each other which have been
valued below Rs 10 lakh or its equivalent in foreign currency where such series of
transactions take place within one calendar month.
 All suspicious transactions whether or not made in cash.

Each registered intermediary should adopt written procedures to implement the anti money
laundering provisions as envisaged under the Anti Money Laundering Act, 2002. Such
procedures should include inter alia, the following three specific parameters which are related
to the overall „Client Due Diligence Process‟:
 Policy for acceptance of clients

26
Parliament passes stringent law against money laundering, The Economic Times, December 17, 2012, <
http://articles.economictimes.indiatimes.com/2012-12-17/news/35869028_1_financial-action-task-force-bill-
money>
27
Master Circular on Anti Money Laundering and Combating Financial Terrorism For Registered
Intermediaries SD/AML/CIR-1/2008, dated December 19, 2008 (hereinafter SEBI Master Circular)

Electronic copy available at: https://ssrn.com/abstract=2236175

  Procedure for identifying the clients
 Transaction monitoring and reporting especially Suspicious Transactions Reporting
(STR).28

As such, the registered intermediaries should apply each of the customer due diligence
measures on a risk sensitive basis. The basic principle enshrined in this approach is that the
registered intermediaries should adopt an enhanced customer due diligence process for higher
risk categories of customers. The underlying rationale for the same is that certain customers
may be of a higher or lower risk category depending on circumstances such as the customer‟s
background, type of business relationship or transaction etc.29

In order to further strengthen the KYC norms and identify every participant in the securities
market with their respective Permanent Account Number (PAN) thereby ensuring sound
audit trail of all the transactions, PAN has been made sole identification number for all
participants transacting in the securities market, irrespective of the amount of transaction vide
SEBI Circular reference MRD/DoP/Cir-05/2007 dated April 27, 2007.30

Intermediaries should ensure to take appropriate steps to enable suspicious transactions to be

recognised and have appropriate procedures for reporting suspicious transactions.31 A list of
such suspicious transactions was given below, which was stated to be merely indicative and
not exhaustive while emphasizing that whether a particular transaction is suspicious or not
will depend upon the background, details of the transactions and other facts and
circumstances:32
 Clients whose identity verification seems difficult or clients appears not to cooperate;
 Asset management services for clients where the source of the funds is not clear or
not in keeping with clients apparent standing /business activity;
 Clients in high-risk jurisdictions or clients introduced by banks or affiliates or other
clients based in high risk jurisdictions;
 Substantial increases in business without apparent cause;
 Unusually large cash deposits made by an individual or business;

28
Para 4 of the SEBI Master Circular – 2008
29
Para 5.3.1 of the SEBI Master Circular- 2008
30
Para 5.5 Sub-Para 4 of the SEBI Master Circular - 2008
31
Para 10.1 of the SEBI Master Circular -2008
32
Para 10.2 of the SEBI Master Circular - 2008

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  Clients transferring large sums of money to or from overseas locations with
instructions for payment in cash;
 Transfer of investment proceeds to apparently unrelated third parties;
 Unusual transactions by clients and businesses undertaken by shell corporations,
offshore banks /financial services, businesses reported to be in the nature of export-
import of small items.

APPROACH TO ANTI MONEY LAUNDERING REGULATIONS: ISSUES AND CHALLENGES

A survey undertaken by KPMG in regard to the Anti Money Laundering Regulations
(hereinafter AML) indicates that entities are still trying to find their way in relation to the
implementation of an effective AML compliance program in their organizations. Though the
senior management are actively involved in discussing and reviewing the status of AML
compliance, the same may be because of heightened regulatory scrutiny and in light of
imposition of fines by regulators across the globe. 33
It has been observed that the objective has been basic compliance rather than using it as a risk
management practice. This despite the fact that a risk based approach is to be undertaken by
banks, financial institutions and intermediaries. 34 In order of priority, AML compliance, if
not at the same level, would fall after basic regulatory and financial requirements, Basel II
requirements and financial crime (fraud) management requirements of an institution.
The Basel II requirements focus on credit and market risk and more recently operational
risks. As per Basel II guidelines, the operational risk area is the risk of direct or indirect loss
resulting from inadequate, or failed internal processes, people and systems, or from external
events. One of the key requirements of operational risk management is managing the risk of
money laundering which is vulnerable to high regulatory action in turn effecting the reserve
requirements and eventually the profitability of a bank. Hence, managing money laundering
can be considered to be an integral part of the risk management function.
The perception of the industry is slowly undergoing a transformation. Regulators have
become more active and are developing robust processes such as setting up of the Financial
Intelligence Unit (FIU). India has signed several MoU‟s with multiple jurisdictions for
sharing of information and data related to money laundering activities. These developments,
along with the FATF umbrella, would eventually urge institutions to benchmark themselves
33
Anti- Money laundering Survey 2012 Conducted by KPMG, p. 17, available at
http://www.kpmg.com/IN/en/IssuesAndInsights/ThoughtLeadership/AML_Survey_2012.pdf
34
Know Your Customer: Quick Reference Guide, PricewaterhouseCoopers, <
http://www.pwc.com/gx/en/financial-services/assets/know-your-customer-quick-reference-guide.pdf>

Electronic copy available at: https://ssrn.com/abstract=2236175

globally on AML compliance procedures and processes, thus enabling them to make that
strategic move from basic compliance to a risk management outlook towards AML
compliance. 35

CONCLUSION AND RECOMMENDATIONS

To conclude the discussion, it would have to be seen whether enough is being done to combat
the menace of money laundering. It would be helpful to recall the statement of the Finance
Minister while moving the Prevention of Money Laundering (Amendment) Bill, 2011 for
consideration in Parliament that the legislation could see more amendments in recent years.
Taking a cue from this, it can be concluded that problems exist as to the implementation of
the PMLA and the guidelines issued thereunder.
The transaction monitoring system still suffers from the infirmity of not being able to provide
a single and holistic view of a transaction undertaken by a customer, which assumes
significance because all money laundering transactions are operated keeping in mind the
pitfalls of the system, thus a fragmented transaction monitoring system is host for failure of
all Anti Money Laundering measures.
The threshold for transaction monitoring is another area which may be improved by using
statistical modeling and judging the risk perception of the organization to identify the right
mix of thresholds for different types of customers and their risk categorization.
Moreover, the problem of jurisdictional ambiguities between various regulators is also
inhibitive of achieving a single robust transaction monitoring system, the underpinning
rationale being the inability to coordinate transaction having multiple financial
products/instruments in use. This perhaps constitutes the single most daunting task for the
FIU, the nodal agency to oversee anti-money laundering measures in India.
The only positive ray of hope is provided by the 56 th Report by Standing Committee on
Finance relating to introduction of Prevention of Money Laundering Amendment Bill 2011
whose recommendations have been accepted in its entirety. Through these recommendations
the act has been given more teeth due to broadening of the ambit of the legislation itself.
Thus, there still exists an opportunity to root out such practices with well directed and
coordinated efforts.

Recommendations

35
Anti- Money laundering Survey 2012 Conducted by KPMG, available at
http://www.kpmg.com/IN/en/IssuesAndInsights/ThoughtLeadership/AML_Survey_2012.pdf

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The FATF while conducting a Mutual Evaluation of India found a number of problems
associated with the current legal framework, which it sought to address by way of certain
recommendations. Some of the key recommendations made included: 36
 addressing the technical shortcomings in the criminalization of both money
laundering and terrorist financing and in the domestic framework of confiscation and
provisional measures;
 broadening the CDD obligations with clear and specific measures to enhance the
current requirements regarding beneficial ownership;
 improving the reliability of identification documents, the use of pooled accounts, and
non-face-to-face business;
 enhancing the effectiveness of the STR reporting regime; enhance the effectiveness of
the financial sector supervisory regime and ensure that India Post is adequately
supervised; and
 ensuring that the competent supervisory authorities make changes to their sanctioning
regimes to allow for effective, proportionate and dissuasive sanctions for failures to
comply with AML/CFT requirements;

These measures would help ensure that the shortcomings identified by the FATF, would be
overcome, such as absence of any convictions for money laundering. This would also help
the law come in line with the FATF standards which would enhance the preventive measures
taken to combat money laundering rather than ensuring punishments for the offences of
money laundering.

BIBLIOGRAPHY

Books
1. Tushar V. Shah, Commentary on The Prevention of Money Laundering Act, 2002, 2 nd
Edn (Current Publications, Mumbai)

Circulars

36
Mutual Evaluation of India, FATF, June 25, 2010, <http://www.fatf-
gafi.org/media/fatf/documents/reports/mer/MER%20India%20full.pdf>

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 1. RBI Circular No RBI/2012-13/45, Master Circular – Know Your Customer (KYC)
norms / Anti-Money Laundering (AML) standards/Combating of Financing of
Terrorism (CFT)/Obligation of banks under PMLA, 2002
2. SEBI Circular No CIR/MIRSD/ 11 /2012, dated September 5, 2012
3. IRDA Circular No 013/IRDA/LIFE/ JUL-06, dated July 27, 2006
4. Master Circular on Anti Money Laundering and Combating Financial Terrorism For
Registered Intermediaries SD/AML/CIR-1/2008, dated December 19, 2008
Reports/Articles
1. International Best Practices. Financial Action Task Force on Money Laundering, 20
June 2003, <http://www.fatf-
gafi.org/media/fatf/documents/recommendations/10%20FATF%20SRIX%20BPP%2
0SRVI%20June%202003%202012%20cover.pdf>
2. 56th Report, Standing Committee on Finance, The Prevention of Money Laundering
(Amendment) Bill, 2011
3. Anti- Money laundering Survey 2012 Conducted by KPMG, p. 17, available at
http://www.kpmg.com/IN/en/IssuesAndInsights/ThoughtLeadership/AML_Survey_2
012.pdf
4. Know Your Customer: Quick Reference Guide, PricewaterhouseCoopers, <
http://www.pwc.com/gx/en/financial-services/assets/know-your-customer-quick-
reference-guide.pdf>

Websites
1. http://www.fatf-gafi.org/pages/faq/moneylaundering/
2. http://fiuindia.gov.in/international-fatf.htm
3. http://pib.nic.in/newsite/erelease.aspx?relid=39397
4. http://www.dnaindia.com/analysis/comment_kyc-a-key-to-prevention-of-money-
laundering_1706717
5. http://www.thehindubusinessline.com/industry-and-economy/banking/ls-passes-
money-laundering-amendment-bill/article4147170.ece
6. http://www.livemint.com/Politics/P49KxOKkfZUNmTIC0GjWIJ/Lok-Sabha-
approves-changes-in-money-laundering-Bill.html
7. http://articles.economictimes.indiatimes.com/2012-12-
17/news/35869028_1_financial-action-task-force-bill-money

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