PMLA/AML: Q&A repository
110 practical questions mapped to the hub framework.
| ID | Question | Finin2min answer |
|---|---|---|
| PMQ001 | Is every regulatory offence a scheduled offence? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| PMQ002 | Can a transaction be suspicious below reporting thresholds? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| PMQ003 | Who is the designated director? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| PMQ004 | How quickly must an STR be filed? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| PMQ005 | Can a reporting entity tell a customer that an STR was filed? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| PMQ006 | Do VDA service providers have FIU obligations? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| PMQ007 | What is enhanced due diligence? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| PMQ008 | How long are records maintained? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| PMQ009 | What is beneficial ownership? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| PMQ010 | What is the difference between predicate offence and money laundering? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| PMQ011 | What is the first check for offence of money laundering and proceeds of crime? | Identify the scheduled/predicate offence. |
| PMQ012 | Which law governs offence of money laundering and proceeds of crime? | Sections 2(1)(u), 3 and 4; The Schedule to PMLA |
| PMQ013 | What documents support offence of money laundering and proceeds of crime? | Bank trail, Contracts and invoices, Ownership records, Predicate-offence documents |
| PMQ014 | What is a common risk in offence of money laundering and proceeds of crime? | Assuming conviction is irrelevant to strategy |
| PMQ015 | Give a practical example of offence of money laundering and proceeds of crime. | 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. |
| PMQ016 | What is the first check for scheduled offences and predicate risk? | Identify statute, section and offence date. |
| PMQ017 | Which law governs scheduled offences and predicate risk? | Section 2(1)(y); PMLA Schedule; FIU scheduled-offence resource |
| PMQ018 | What documents support scheduled offences and predicate risk? | FIR/complaint, Charge sheet, Schedule mapping, Proceeds computation |
| PMQ019 | What is a common risk in scheduled offences and predicate risk? | Using broad statute name without section |
| PMQ020 | Give a practical example of scheduled offences and predicate risk. | A regulatory breach is not automatically a scheduled offence. The precise penal section and schedule entry must be established. |
| PMQ021 | What is the first check for provisional attachment and confirmation? | Obtain order and relied material. |
| PMQ022 | Which law governs provisional attachment and confirmation? | Sections 5–10; Relevant attachment and possession rules |
| PMQ023 | What documents support provisional attachment and confirmation? | Attachment order, Title and funding records, Valuation, Third-party contracts |
| PMQ024 | What is a common risk in provisional attachment and confirmation? | Missing response deadline |
| PMQ025 | Give a practical example of provisional attachment and confirmation. | A company asset is attached because an accused shareholder allegedly routed funds into it. The company should trace acquisition funding and challenge the property nexus. |
| PMQ026 | What is the first check for summons, search, seizure and arrest? | Verify authority and scope. |
| PMQ027 | Which law governs summons, search, seizure and arrest? | Sections 11 and 16–24; Applicable procedural rules; Supreme Court jurisprudence |
| PMQ028 | What documents support summons, search, seizure and arrest? | Summons/order, Document index, Chronology, Privilege log |
| PMQ029 | What is a common risk in summons, search, seizure and arrest? | Destroying records |
| PMQ030 | Give a practical example of summons, search, seizure and arrest. | A finance head is summoned for transactions booked years earlier. A reconstructed chronology and document-supported answers are safer than assumptions. |
| PMQ031 | What is the first check for adjudication, confiscation and third-party rights? | Identify each property and claimant. |
| PMQ032 | Which law governs adjudication, confiscation and third-party rights? | Sections 8–10; Special Court provisions |
| PMQ033 | What documents support adjudication, confiscation and third-party rights? | Security documents, Disbursement trail, Due diligence, Possession records |
| PMQ034 | What is a common risk in adjudication, confiscation and third-party rights? | No transaction chronology |
| PMQ035 | Give a practical example of adjudication, confiscation and third-party rights. | A bank holds security created before the alleged offence. Priority and bona fide interest require factual and statutory analysis; security does not end the PMLA inquiry automatically. |
| PMQ036 | What is the first check for bail and special court process? | Obtain and review grounds of arrest. |
| PMQ037 | Which law governs bail and special court process? | Sections 43–47; Current Supreme Court rulings including Vijay Madanlal Choudhary, Pankaj Bansal and Tarsem Lal |
| PMQ038 | What documents support bail and special court process? | Arrest and remand papers, ECIR/complaint material available, Predicate case orders, Bail record |
| PMQ039 | What is a common risk in bail and special court process? | Using an outdated bail note |
| PMQ040 | Give a practical example of bail and special court process. | A person appearing pursuant to court summons is differently situated from a person arrested during investigation; current Supreme Court law should be applied to the exact procedural posture. |
| PMQ041 | What is the first check for reporting entities and governance? | Confirm reporting-entity status. |
| PMQ042 | Which law governs reporting entities and governance? | Sections 11A–15; PML Maintenance of Records Rules, 2005; Sector regulator directions |
| PMQ043 | What documents support reporting entities and governance? | Applicability memo, Appointments, AML policy, FIU registration |
| PMQ044 | What is a common risk in reporting entities and governance? | No applicability review |
| PMQ045 | Give a practical example of reporting entities and governance. | A newly notified professional activity may bring a firm into the reporting-entity regime even if it has no traditional financial licence. |
| PMQ046 | What is the first check for customer due diligence and beneficial ownership? | Identify customer and authorised person. |
| PMQ047 | Which law governs customer due diligence and beneficial ownership? | Section 11A; Rule 9 and Digital KYC Annexure; RBI/SEBI/IRDAI or FIU sector guidance |
| PMQ048 | What documents support customer due diligence and beneficial ownership? | Ownership chart, OVDs and registry extracts, Purpose profile, Risk rating |
| PMQ049 | What is a common risk in customer due diligence and beneficial ownership? | Threshold-only approach |
| PMQ050 | Give a practical example of customer due diligence and beneficial ownership. | A private company is owned through two LLPs and an overseas trust. The reporting entity must identify ultimate natural-person ownership/control, not stop at the first corporate shareholder. |
| PMQ051 | What is the first check for record maintenance and transaction reporting? | Classify reportable transaction types. |
| PMQ052 | Which law governs record maintenance and transaction reporting? | Section 12; Rules 3–8 and 10; FIU reporting formats |
| PMQ053 | What documents support record maintenance and transaction reporting? | Transaction data, Alert disposition, Report acknowledgement, Retention log |
| PMQ054 | What is a common risk in record maintenance and transaction reporting? | Treating thresholds as substitutes for suspicion |
| PMQ055 | Give a practical example of record maintenance and transaction reporting. | Cash and integrally connected cash transactions may require monthly reporting, while an STR requires prompt filing after satisfaction of suspicion. |
| PMQ056 | What is the first check for suspicious transaction monitoring? | Create sector-specific scenarios. |
| PMQ057 | Which law governs suspicious transaction monitoring? | PML Rules definition and reporting obligations; FIU sector guidelines |
| PMQ058 | What documents support suspicious transaction monitoring? | Alert file, Customer profile, Transaction graph, STR decision note |
| PMQ059 | What is a common risk in suspicious transaction monitoring? | Rule-based alerts with no review |
| PMQ060 | Give a practical example of suspicious transaction monitoring. | A dormant account receives rapid third-party credits followed by overseas transfers. Even if individual transactions are below cash thresholds, pattern and purpose can be suspicious. |
| PMQ061 | What is the first check for ctr, ntr, counterfeit and wire-transfer reports? | Map products to report types. |
| PMQ062 | Which law governs ctr, ntr, counterfeit and wire-transfer reports? | Rules 3, 7 and 8; FIU reporting schema and FAQs |
| PMQ063 | What documents support ctr, ntr, counterfeit and wire-transfer reports? | Source-system extract, Validation report, Submission file, Acknowledgement |
| PMQ064 | What is a common risk in ctr, ntr, counterfeit and wire-transfer reports? | Missing linked transactions |
| PMQ065 | Give a practical example of ctr, ntr, counterfeit and wire-transfer reports. | Monthly report generation should include connected cash transactions and corrections, not only single cash entries above threshold. |
| PMQ066 | What is the first check for principal officer and designated director? | Issue formal appointments. |
| PMQ067 | Which law governs principal officer and designated director? | PML Rules definitions and governance requirements; FIU sector guidelines |
| PMQ068 | What documents support principal officer and designated director? | Appointment letters, Role charter, Committee minutes, MI pack |
| PMQ069 | What is a common risk in principal officer and designated director? | Junior appointment without authority |
| PMQ070 | Give a practical example of principal officer and designated director. | A principal officer who cannot obtain customer data or stop onboarding cannot discharge the role effectively. |
| PMQ071 | What is the first check for rbi kyc and banking overlay? | Map entity-specific RBI applicability. |
| PMQ072 | Which law governs rbi kyc and banking overlay? | RBI KYC Direction, 2016 as reviewed; PMLA and PML Rules |
| PMQ073 | What documents support rbi kyc and banking overlay? | KYC policy, Risk model, Customer notices, Updation audit trail |
| PMQ074 | What is a common risk in rbi kyc and banking overlay? | Account restrictions without due notice |
| PMQ075 | Give a practical example of rbi kyc and banking overlay. | A low-risk customer submits a self-declaration for unchanged KYC. The bank should follow the RBI route applicable to risk and customer type and issue acknowledgement. |
| PMQ076 | What is the first check for securities-market aml overlay? | Coordinate KRA and intermediary data. |
| PMQ077 | Which law governs securities-market aml overlay? | SEBI AML/CFT master circular and amendments; PMLA and Rules |
| PMQ078 | What documents support securities-market aml overlay? | KYC/KRA data, Trading and bank linkage, Alert case file, STR decision |
| PMQ079 | What is a common risk in securities-market aml overlay? | Treating exchange surveillance as full AML control |
| PMQ080 | Give a practical example of securities-market aml overlay. | Multiple demat accounts with common devices and rapid off-market transfers can require linked-customer investigation. |
| PMQ081 | What is the first check for insurance-sector aml overlay? | Risk-rank products and distribution. |
| PMQ082 | Which law governs insurance-sector aml overlay? | IRDAI AML/CFT framework; PMLA and Rules |
| PMQ083 | What documents support insurance-sector aml overlay? | Proposal and KYC, Payment trail, Agent records, Claim/surrender review |
| PMQ084 | What is a common risk in insurance-sector aml overlay? | Focusing only on policyholder |
| PMQ085 | Give a practical example of insurance-sector aml overlay. | A high-value policy funded by unrelated third parties and surrendered quickly may be inconsistent with stated purpose. |
| PMQ086 | What is the first check for vda service-provider aml obligations? | Confirm service and territorial nexus. |
| PMQ087 | Which law governs vda service-provider aml obligations? | PMLA notification for VDA activities; FIU AML/CFT Guidelines reviewed 8 January 2026; PML Rules |
| PMQ088 | What documents support vda service-provider aml obligations? | Product map, FIU registration, Wallet analytics, Travel-rule records |
| PMQ089 | What is a common risk in vda service-provider aml obligations? | Geo-blocking assumptions |
| PMQ090 | Give a practical example of vda service-provider aml obligations. | An offshore exchange serving Indian users may have FIU obligations depending on notified activity and India-facing operations. |
| PMQ091 | What is the first check for dnfbps, accountants, real-estate activities and tcsps? | Map client services to notified activities. |
| PMQ092 | Which law governs dnfbps, accountants, real-estate activities and tcsps? | Section 2(1)(sa); Relevant Central Government notifications; FIU guidelines for accountants/real estate/TCSPs |
| PMQ093 | What documents support dnfbps, accountants, real-estate activities and tcsps? | Service inventory, Client files, CDD records, Reporting decision log |
| PMQ094 | What is a common risk in dnfbps, accountants, real-estate activities and tcsps? | Assuming professional regulation replaces PMLA |
| PMQ095 | Give a practical example of dnfbps, accountants, real-estate activities and tcsps. | A firm forms companies, provides registered office and arranges directors for clients. TCSP guidance may apply even though it does not handle client cash. |
| PMQ096 | What is the first check for finnet/fingate registration and reporting operations? | Register legal entity and key officers. |
| PMQ097 | Which law governs finnet/fingate registration and reporting operations? | FIU registration and reporting guides; Rules 7–8 and Section 12A |
| PMQ098 | What documents support finnet/fingate registration and reporting operations? | Registration proof, User-role matrix, Submission log, Rejection/correction log |
| PMQ099 | What is a common risk in finnet/fingate registration and reporting operations? | Single-user dependency |
| PMQ100 | Give a practical example of finnet/fingate registration and reporting operations. | A report is generated but rejected for identifier errors. Until accepted, the reporting obligation may remain unmet; reconciliation and correction control are essential. |
| PMQ101 | What is the first check for sanctions, uapa and wmd screening? | Screen customers, beneficial owners and transactions. |
| PMQ102 | Which law governs sanctions, uapa and wmd screening? | UAPA-related orders; Section 12A of WMD Act and related procedure; RBI/SEBI/FIU directions |
| PMQ103 | What documents support sanctions, uapa and wmd screening? | Screening logs, List version, Match analysis, Freeze/report record |
| PMQ104 | What is a common risk in sanctions, uapa and wmd screening? | Outdated lists |
| PMQ105 | Give a practical example of sanctions, uapa and wmd screening. | A customer name partially matches a designated entity. The case requires controlled investigation, not automatic customer contact. |
| PMQ106 | What is the first check for enterprise aml risk assessment and audit? | Score inherent risk. |
| PMQ107 | Which law governs enterprise aml risk assessment and audit? | PML Rules; FIU and regulator sector guidelines |
| PMQ108 | What documents support enterprise aml risk assessment and audit? | Enterprise risk assessment, Control library, Audit report, Remediation tracker |
| PMQ109 | What is a common risk in enterprise aml risk assessment and audit? | Risk assessment as generic narrative |
| PMQ110 | Give a practical example of enterprise aml risk assessment and audit. | A fintech launches cross-border merchant payouts without revising its AML risk assessment. Product approval should include typology, data and reporting controls. |
Source discipline
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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