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DNFBPs, accountants, real-estate activities and TCSPs

Specified professional and business activities can be reporting entities when conducting notified transactions for clients. Applicability turns on activity

Finin2min summary

Specified professional and business activities can be reporting entities when conducting notified transactions for clients. Applicability turns on activity, not merely professional title.

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

Legal anchors

  • Section 2(1)(sa)
  • Relevant Central Government notifications
  • FIU guidelines for accountants/real estate/TCSPs

How to analyse it

  1. Map client services to notified activities.
  2. Separate covered from ordinary advisory work.
  3. Implement CDD and transaction monitoring.
  4. Protect privilege while meeting statutory duties.

Practical illustration

A firm forms companies, provides registered office and arranges directors for clients. TCSP guidance may apply even though it does not handle client cash.

What can go wrong?

  • Assuming professional regulation replaces PMLA
  • No customer risk assessment
  • Unclear privilege/escalation protocol

Evidence pack

  • Service inventory
  • Client files
  • CDD records
  • Reporting decision log

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. Map client services to notified activities.

What is the most important control?

Protect privilege while meeting statutory duties.

What should be escalated?

Assuming professional regulation replaces PMLA, 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.

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