PMLA/AML: Action checklists

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	Arrest and remand papers; ECIR/complaint material available; Predicate case orders	Using an outdated bail note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

Source discipline

This page is an editorial navigation layer. The linked official Act, rule, regulation, notification, circular, portal instruction or judgment remains controlling.

Source and review trail

Use the current official instrument, portal or regulator publication before acting. This panel separates the category authority from page-specific references.

Official starting point: www.indiacode.gov.in