Use the Phases 3-4 professional repository for authority, trigger, workflow, evidence, consequence and current-source controls.
Module-wise first checks, evidence and escalation triggers.
| No. | Topic | First action | Evidence | Escalate when |
|---|---|---|---|---|
| 01 | Offence of money laundering and proceeds of crime | Identify the scheduled/predicate offence. | Bank trail; Contracts and invoices; Ownership records | Assuming conviction is irrelevant to strategy |
| 02 | Scheduled offences and predicate risk | Identify statute, section and offence date. | FIR/complaint; Charge sheet; Schedule mapping | Using broad statute name without section |
| 03 | Provisional attachment and confirmation | Obtain order and relied material. | Attachment order; Title and funding records; Valuation | Missing response deadline |
| 04 | Summons, search, seizure and arrest | Verify authority and scope. | Summons/order; Document index; Chronology | Destroying records |
| 05 | Adjudication, confiscation and third-party rights | Identify each property and claimant. | Security documents; Disbursement trail; Due diligence | No transaction chronology |
| 06 | Bail and Special Court process | Obtain and review grounds of arrest. | Arrest and remand papers; ECIR/complaint material available; Predicate case orders | Using an outdated bail note |
| 07 | Reporting entities and governance | Confirm reporting-entity status. | Applicability memo; Appointments; AML policy | No applicability review |
| 08 | Customer due diligence and beneficial ownership | Identify customer and authorised person. | Ownership chart; OVDs and registry extracts; Purpose profile | Threshold-only approach |
| 09 | Record maintenance and transaction reporting | Classify reportable transaction types. | Transaction data; Alert disposition; Report acknowledgement | Treating thresholds as substitutes for suspicion |
| 10 | Suspicious transaction monitoring | Create sector-specific scenarios. | Alert file; Customer profile; Transaction graph | Rule-based alerts with no review |
| 11 | CTR, NTR, counterfeit and wire-transfer reports | Map products to report types. | Source-system extract; Validation report; Submission file | Missing linked transactions |
| 12 | Principal Officer and Designated Director | Issue formal appointments. | Appointment letters; Role charter; Committee minutes | Junior appointment without authority |
| 13 | RBI KYC and banking overlay | Map entity-specific RBI applicability. | KYC policy; Risk model; Customer notices | Account restrictions without due notice |
| 14 | Securities-market AML overlay | Coordinate KRA and intermediary data. | KYC/KRA data; Trading and bank linkage; Alert case file | Treating exchange surveillance as full AML control |
| 15 | Insurance-sector AML overlay | Risk-rank products and distribution. | Proposal and KYC; Payment trail; Agent records | Focusing only on policyholder |
| 16 | VDA service-provider AML obligations | Confirm service and territorial nexus. | Product map; FIU registration; Wallet analytics | Geo-blocking assumptions |
| 17 | DNFBPs, accountants, real-estate activities and TCSPs | Map client services to notified activities. | Service inventory; Client files; CDD records | Assuming professional regulation replaces PMLA |
| 18 | FINnet/FINGate registration and reporting operations | Register legal entity and key officers. | Registration proof; User-role matrix; Submission log | Single-user dependency |
| 19 | Sanctions, UAPA and WMD screening | Screen customers, beneficial owners and transactions. | Screening logs; List version; Match analysis | Outdated lists |
| 20 | Enterprise AML risk assessment and audit | Score inherent risk. | Enterprise risk assessment; Control library; Audit report | Risk assessment as generic narrative |
This page is an editorial navigation layer. The linked official Act, rule, regulation, notification, circular, portal instruction or judgment remains controlling.