Skip to content
New source-controlled implementation repository

Use the Phases 3-4 professional repository for authority, trigger, workflow, evidence, consequence and current-source controls.

Home › Knowledge Hubs › PMLA, AML & KYC Hub › Offence of money laundering and proceeds of crime

Offence of money laundering and proceeds of crime

PMLA risk begins with property derived or obtained from criminal activity relating to a scheduled offence and conduct connected with concealment, possessio

Finin2min summary

PMLA risk begins with property derived or obtained from criminal activity relating to a scheduled offence and conduct connected with concealment, possession, acquisition, use or projection/claiming as untainted.

Source review date: 4 July 2026. Read with the official text and the facts of the transaction.

Legal anchors

  • Sections 2(1)(u), 3 and 4
  • The Schedule to PMLA

How to analyse it

  1. Identify the scheduled/predicate offence.
  2. Trace property, value and substitutions.
  3. Separate possession/use from legitimate-source assets.
  4. Preserve source-of-funds and transaction evidence.

Practical illustration

Funds generated from a scheduled fraud are layered through companies and used to acquire property. Later sale proceeds can remain relevant as value or substituted property depending on facts.

What can go wrong?

  • Assuming conviction is irrelevant to strategy
  • Mixing legitimate and tainted funds
  • No source-of-wealth evidence

Evidence pack

  • Bank trail
  • Contracts and invoices
  • Ownership records
  • Predicate-offence documents

Decision workflow

  1. Freeze the facts and effective date.
  2. Identify the controlling Act, rule, notification, circular and jurisdictional overlay.
  3. Prepare a calculation or exposure note.
  4. Collect the evidence pack before filing, payment, signing or response.
  5. Record reviewer conclusion and assumptions.

Quick Q&A

Is the result automatic?

No. Identify the scheduled/predicate offence.

What is the most important control?

Preserve source-of-funds and transaction evidence.

What should be escalated?

Assuming conviction is irrelevant to strategy, especially where money, deadlines, enforcement, personal liability or irreversible transaction steps are involved.

Official source trail

Secondary commentary may help interpretation, but it is not the source of law.

Related repository pages