Securities-market AML overlay

SEBI intermediaries must apply PMLA controls to account opening, beneficial ownership, ongoing monitoring, intermediaries, wire transfers and market-abuse

Finin2min summary

SEBI intermediaries must apply PMLA controls to account opening, beneficial ownership, ongoing monitoring, intermediaries, wire transfers and market-abuse typologies.

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

Legal anchors

SEBI AML/CFT master circular and amendments
PMLA and Rules

How to analyse it

Coordinate KRA and intermediary data.
Monitor off-market, circular and layered activity.
Review high-risk jurisdictions and PEPs.
Document reliance on third parties.

Practical illustration

Multiple demat accounts with common devices and rapid off-market transfers can require linked-customer investigation.

What can go wrong?

Treating exchange surveillance as full AML control
No device/IP linkage
Stale KYC

Evidence pack

KYC/KRA data
Trading and bank linkage
Alert case file
STR decision

Decision workflow

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

Quick Q&A

Is the result automatic?

No. Coordinate KRA and intermediary data.

What is the most important control?

Document reliance on third parties.

What should be escalated?

Treating exchange surveillance as full AML control, 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.