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PMLA/AML: Q&A repository

110 practical questions mapped to the hub framework.

IDQuestionFinin2min answer
PMQ001Is every regulatory offence a scheduled offence?Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date.
PMQ002Can a transaction be suspicious below reporting thresholds?Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date.
PMQ003Who is the designated director?Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date.
PMQ004How quickly must an STR be filed?Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date.
PMQ005Can 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.
PMQ006Do VDA service providers have FIU obligations?Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date.
PMQ007What is enhanced due diligence?Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date.
PMQ008How long are records maintained?Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date.
PMQ009What is beneficial ownership?Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date.
PMQ010What 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.
PMQ011What is the first check for offence of money laundering and proceeds of crime?Identify the scheduled/predicate offence.
PMQ012Which law governs offence of money laundering and proceeds of crime?Sections 2(1)(u), 3 and 4; The Schedule to PMLA
PMQ013What documents support offence of money laundering and proceeds of crime?Bank trail, Contracts and invoices, Ownership records, Predicate-offence documents
PMQ014What is a common risk in offence of money laundering and proceeds of crime?Assuming conviction is irrelevant to strategy
PMQ015Give 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.
PMQ016What is the first check for scheduled offences and predicate risk?Identify statute, section and offence date.
PMQ017Which law governs scheduled offences and predicate risk?Section 2(1)(y); PMLA Schedule; FIU scheduled-offence resource
PMQ018What documents support scheduled offences and predicate risk?FIR/complaint, Charge sheet, Schedule mapping, Proceeds computation
PMQ019What is a common risk in scheduled offences and predicate risk?Using broad statute name without section
PMQ020Give 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.
PMQ021What is the first check for provisional attachment and confirmation?Obtain order and relied material.
PMQ022Which law governs provisional attachment and confirmation?Sections 5–10; Relevant attachment and possession rules
PMQ023What documents support provisional attachment and confirmation?Attachment order, Title and funding records, Valuation, Third-party contracts
PMQ024What is a common risk in provisional attachment and confirmation?Missing response deadline
PMQ025Give 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.
PMQ026What is the first check for summons, search, seizure and arrest?Verify authority and scope.
PMQ027Which law governs summons, search, seizure and arrest?Sections 11 and 16–24; Applicable procedural rules; Supreme Court jurisprudence
PMQ028What documents support summons, search, seizure and arrest?Summons/order, Document index, Chronology, Privilege log
PMQ029What is a common risk in summons, search, seizure and arrest?Destroying records
PMQ030Give 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.
PMQ031What is the first check for adjudication, confiscation and third-party rights?Identify each property and claimant.
PMQ032Which law governs adjudication, confiscation and third-party rights?Sections 8–10; Special Court provisions
PMQ033What documents support adjudication, confiscation and third-party rights?Security documents, Disbursement trail, Due diligence, Possession records
PMQ034What is a common risk in adjudication, confiscation and third-party rights?No transaction chronology
PMQ035Give 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.
PMQ036What is the first check for bail and special court process?Obtain and review grounds of arrest.
PMQ037Which law governs bail and special court process?Sections 43–47; Current Supreme Court rulings including Vijay Madanlal Choudhary, Pankaj Bansal and Tarsem Lal
PMQ038What documents support bail and special court process?Arrest and remand papers, ECIR/complaint material available, Predicate case orders, Bail record
PMQ039What is a common risk in bail and special court process?Using an outdated bail note
PMQ040Give 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.
PMQ041What is the first check for reporting entities and governance?Confirm reporting-entity status.
PMQ042Which law governs reporting entities and governance?Sections 11A–15; PML Maintenance of Records Rules, 2005; Sector regulator directions
PMQ043What documents support reporting entities and governance?Applicability memo, Appointments, AML policy, FIU registration
PMQ044What is a common risk in reporting entities and governance?No applicability review
PMQ045Give 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.
PMQ046What is the first check for customer due diligence and beneficial ownership?Identify customer and authorised person.
PMQ047Which law governs customer due diligence and beneficial ownership?Section 11A; Rule 9 and Digital KYC Annexure; RBI/SEBI/IRDAI or FIU sector guidance
PMQ048What documents support customer due diligence and beneficial ownership?Ownership chart, OVDs and registry extracts, Purpose profile, Risk rating
PMQ049What is a common risk in customer due diligence and beneficial ownership?Threshold-only approach
PMQ050Give 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.
PMQ051What is the first check for record maintenance and transaction reporting?Classify reportable transaction types.
PMQ052Which law governs record maintenance and transaction reporting?Section 12; Rules 3–8 and 10; FIU reporting formats
PMQ053What documents support record maintenance and transaction reporting?Transaction data, Alert disposition, Report acknowledgement, Retention log
PMQ054What is a common risk in record maintenance and transaction reporting?Treating thresholds as substitutes for suspicion
PMQ055Give 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.
PMQ056What is the first check for suspicious transaction monitoring?Create sector-specific scenarios.
PMQ057Which law governs suspicious transaction monitoring?PML Rules definition and reporting obligations; FIU sector guidelines
PMQ058What documents support suspicious transaction monitoring?Alert file, Customer profile, Transaction graph, STR decision note
PMQ059What is a common risk in suspicious transaction monitoring?Rule-based alerts with no review
PMQ060Give 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.
PMQ061What is the first check for ctr, ntr, counterfeit and wire-transfer reports?Map products to report types.
PMQ062Which law governs ctr, ntr, counterfeit and wire-transfer reports?Rules 3, 7 and 8; FIU reporting schema and FAQs
PMQ063What documents support ctr, ntr, counterfeit and wire-transfer reports?Source-system extract, Validation report, Submission file, Acknowledgement
PMQ064What is a common risk in ctr, ntr, counterfeit and wire-transfer reports?Missing linked transactions
PMQ065Give 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.
PMQ066What is the first check for principal officer and designated director?Issue formal appointments.
PMQ067Which law governs principal officer and designated director?PML Rules definitions and governance requirements; FIU sector guidelines
PMQ068What documents support principal officer and designated director?Appointment letters, Role charter, Committee minutes, MI pack
PMQ069What is a common risk in principal officer and designated director?Junior appointment without authority
PMQ070Give 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.
PMQ071What is the first check for rbi kyc and banking overlay?Map entity-specific RBI applicability.
PMQ072Which law governs rbi kyc and banking overlay?RBI KYC Direction, 2016 as reviewed; PMLA and PML Rules
PMQ073What documents support rbi kyc and banking overlay?KYC policy, Risk model, Customer notices, Updation audit trail
PMQ074What is a common risk in rbi kyc and banking overlay?Account restrictions without due notice
PMQ075Give 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.
PMQ076What is the first check for securities-market aml overlay?Coordinate KRA and intermediary data.
PMQ077Which law governs securities-market aml overlay?SEBI AML/CFT master circular and amendments; PMLA and Rules
PMQ078What documents support securities-market aml overlay?KYC/KRA data, Trading and bank linkage, Alert case file, STR decision
PMQ079What is a common risk in securities-market aml overlay?Treating exchange surveillance as full AML control
PMQ080Give a practical example of securities-market aml overlay.Multiple demat accounts with common devices and rapid off-market transfers can require linked-customer investigation.
PMQ081What is the first check for insurance-sector aml overlay?Risk-rank products and distribution.
PMQ082Which law governs insurance-sector aml overlay?IRDAI AML/CFT framework; PMLA and Rules
PMQ083What documents support insurance-sector aml overlay?Proposal and KYC, Payment trail, Agent records, Claim/surrender review
PMQ084What is a common risk in insurance-sector aml overlay?Focusing only on policyholder
PMQ085Give 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.
PMQ086What is the first check for vda service-provider aml obligations?Confirm service and territorial nexus.
PMQ087Which law governs vda service-provider aml obligations?PMLA notification for VDA activities; FIU AML/CFT Guidelines reviewed 8 January 2026; PML Rules
PMQ088What documents support vda service-provider aml obligations?Product map, FIU registration, Wallet analytics, Travel-rule records
PMQ089What is a common risk in vda service-provider aml obligations?Geo-blocking assumptions
PMQ090Give 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.
PMQ091What is the first check for dnfbps, accountants, real-estate activities and tcsps?Map client services to notified activities.
PMQ092Which law governs dnfbps, accountants, real-estate activities and tcsps?Section 2(1)(sa); Relevant Central Government notifications; FIU guidelines for accountants/real estate/TCSPs
PMQ093What documents support dnfbps, accountants, real-estate activities and tcsps?Service inventory, Client files, CDD records, Reporting decision log
PMQ094What is a common risk in dnfbps, accountants, real-estate activities and tcsps?Assuming professional regulation replaces PMLA
PMQ095Give 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.
PMQ096What is the first check for finnet/fingate registration and reporting operations?Register legal entity and key officers.
PMQ097Which law governs finnet/fingate registration and reporting operations?FIU registration and reporting guides; Rules 7–8 and Section 12A
PMQ098What documents support finnet/fingate registration and reporting operations?Registration proof, User-role matrix, Submission log, Rejection/correction log
PMQ099What is a common risk in finnet/fingate registration and reporting operations?Single-user dependency
PMQ100Give 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.
PMQ101What is the first check for sanctions, uapa and wmd screening?Screen customers, beneficial owners and transactions.
PMQ102Which law governs sanctions, uapa and wmd screening?UAPA-related orders; Section 12A of WMD Act and related procedure; RBI/SEBI/FIU directions
PMQ103What documents support sanctions, uapa and wmd screening?Screening logs, List version, Match analysis, Freeze/report record
PMQ104What is a common risk in sanctions, uapa and wmd screening?Outdated lists
PMQ105Give 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.
PMQ106What is the first check for enterprise aml risk assessment and audit?Score inherent risk.
PMQ107Which law governs enterprise aml risk assessment and audit?PML Rules; FIU and regulator sector guidelines
PMQ108What documents support enterprise aml risk assessment and audit?Enterprise risk assessment, Control library, Audit report, Remediation tracker
PMQ109What is a common risk in enterprise aml risk assessment and audit?Risk assessment as generic narrative
PMQ110Give 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.

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