ANTI-MONEY LAUNDERING COMPLIANCE – A BIG CHALLENGE FOR THE CORPORATE WORLD:

SATHISH PUTHAN MADATHIL, FORMERLY OFFICER, CENTRAL BUREAU OF INVESTIGATION (C.B.I.), BANK SECURITIES AND FRAUDS CELL(EOW-IV), BANGALORE, INDIA. PRESENTLY WORKING AS GENERAL MANAGER, CORPORATE SERVICES, SECURITY & VIGILANCE, AUROBINDO PHARMA LTD., HEAD OFFICE, HYDERABAD, INDIA.

‘MONEY LAUNDERING’ Defined:

The process of creating the appearance that large amounts of money obtained from serious crimes, such as drug trafficking or terrorist activity, is from a legitimate source is called money laundering. Cleaning the money or whitening the money are the popular terms used by the people for Money Laundering. It is like laundering of black money. It is also the process of making “dirty money” look like “clean money”[1]

Money Laundering is very popularly used for the success of conversion of tax evaded money, money generated out of corrupt practice, money made out of drug trafficking, or for doing or perpetrating terrorist activities. The connection between money laundering and terrorism may be bit more complex, but it is seen that it plays a crucial role in the sustainability of terrorist organizations. When India had started process of demonetization, one of the main success was it controlled, stopped and prevented terrorist funding activities done by many of the groups in India and neighboring countries. The money they amazed becomes value less and it was difficult for them to bring it to the banks within the statutory deadline and limit of the amount permissible for Cash Deposit in the post demonetization era. Since huge money deposit were subject to the scrutiny by the enforcement agencies, they were afraid of bringing the money in to the legal channel through various methods. The Money Launders who were planning for terrorist funding for convenience had largely kept the money in Rs. 500 and Rs. 1000 denominations which become suddenly value less. The people who were involved in the terrorist funding were getting money from various sources including the foreign sources through ‘Hawala’ routes and other illegal channels or even legal channels like charity, religious propagation purpose etc. [Source :Various Articles, Ministry of Finance, Government of India]

It is learned and believed that most of the people who financially supporting the terrorist organisations do not simply pay it by their own bank cheque and hand over to the beneficiary. They send the money in roundabout ways that allow them to fund terrorism and maintaining anonymity. Money trailing is also not possible to find out the source of such funds and the identity of the person sending it. In other words terrorist or smugglers does not use legal form of transfers or instruments for transferring the funds so that they can buy weapons or drugs or any other contraband / restricted items. They need money to purchase weapons, or paying for the tickets or stay in plush hotels without any suspicion (for example Srilankan attack case, some of the terrorists reportedly stayed in the Five Star Hotel), or to pay the handlers of the terrorism only by way of cash so that the investigators or the authorities cannot trace them back or find out the source of funding and also foil the attacks or terrorist activities.[2] If the authorities are successful in cutting the channel of the funds flow, then we can prevent such activities. Cutting the financial resources to the terrorist groups are the best way to stop their activities. It is therefore very clear that Money Laundering will be an aid or help or facilitate to dangerous activities in the society like Terrorism or narcotic drug menace or Espionage or subversive activities.

What are the Money Laundering Process?

         The Money Laundering processes are discussed in detail and referred in the following paragraphs which are generally a three way process:-

I.                 Placement:

This is the stage at which the perpetrator of this crime or launderer inserts the dirty money into legitimate financial institutions like banks, or NBFC or other popular financial institutions which receives money from the public. This is often in the form of Cash Bank deposits. This is the riskiest stage of the laundering process because large amounts of cash are pretty conspicuous. In one of the cases a huge amount of money had transferred to a middle east based student who was studying in the European University, as if it looks like fund for doing a PhD Course which having duration for four to five years and people will not suspect such transfer of money to the banks.

The money was transferred through the international SWIFT transfer channel to a popular Bank in Europe. The investigating agencies monitoring the transfer of money from certain countries detected this high value transfer and picked up the beneficiary of the funds transfer. During the investigation he had argued that it was the fund transferred by his billionaire father from an Arab Country towards his educational activities, however further investigation has revealed that his activities in the pretext of study was for the terrorist activities / funding and the funds had come from some suspicious institution functioning in the middle east and not from his father. He was immediately arrested and further investigations had found the terrorist plots organized by a Jihad group in that country. The enforcement agencies therefore successfully prevented a big plot to do terrorist activities in that country through an AML Check, because the funds transferred which was under tracking. Banks are always advised by the enforcement agencies in the countries to report high value transfers of money or transactions immediately to such agencies and are subject to scrutiny. One of the prompt reporting of such a bank had prevented a very dangerous plot.

II.              Layering:

This process involves sending the money through various financial transactions to change its form and make it difficult to follow.  Layering transactions to change its form and make it difficult to follow.[3] It may consist of transfer of money from various banks to other banks (bank-to-bank transfers), wire transfers between different accounts in different names in different countries, making the deposits and withdrawing the money continually vary the amount of money in the accounts, changing the form of currency of different countries and also by buying high value items like properties, costly cars, gold, diamonds, narcotic drugs of high value, so that it can be changed or liquidate in the form of money at any time. In one of the instances, the terrorist bought an expensive property in a prime locality of a big city in Europe by using billions of Pounds Sterling. The idea was to sell it later even for a very higher price and again generating even 30 to 40 % more than the money invested, which again will add for the terrorist funding. This is the most complex step in the Laundering Scheme, and it’s all about making the original dirty money as hard to trace as possible.

III.          Integration:

At this stage the money re-enters in the mainstream economy in a legitimate-looking form- it appears to come from a legal transaction. It will always look like a genuine legal transaction, so that nobody suspect about the nature of the end use of the funds. This usually involves a final bank transfer in to the account of a local business man or an institution or even to a charity institution or NGO or any other registered local institution which has a legal identity so that nobody suspect it. Many times it may come like stake or investment for a profit so that money will grow so that more money can be used for the purpose. It is also experienced that the money is invested to a country through Foreign Direct Investments.

At this point of time, the perpetrators of the crime can use the money without getting caught. It is experienced by the investigating or statutory authorities to catch the criminal at this stage, if there is no documentation during the previous stages and therefore the source of the money will not be identified. It is also experienced that the Launderers had done investment in the popular blue chip companies by way of huge amounts on equity basis or as investment in the stocks and shares. It is also experienced that they use big and reputed international financial investment companies of Tax heavens for this purpose. Money will be parked in some Oil companies or big industries by way of stake or shares or Debentures. It is also experienced that they target big financial investment companies which are looking for the money from the market coming to their Company. Some time the companies are carried away by big investors, without knowing that who actually funding or behind such investors. I am not writing this for the purpose creating a fear but due diligence at this stage is very essential to verify the antecedence of the investors.

           It is believed that criminals in the world launder anywhere between USD 500 Billion and USD 1 trillion worldwide every year. This is quite lot of money and is a very dangerous situation for the society. I used to believe that developed countries which have strong enforcement mechanism developed well in advance must be free from such situation. But now it is found that more Money Laundering is happening in the developed and rich countries. [Source: Industry Articles].

Effects of Money Laundering:

           The Global effect is staggering in social, Economical, political and security terms.

1.     Social Effects: 

On the socio-cultural end of the spectrum, successfully laundering money means that criminal activity actually does pay off. This success encourages criminals to continue their illicit schemes because they get to spend the profit with no repercussions.[4] This means more fraud, more corporate embezzling (for example workers losing their pensions or Provident Fund contributions when corporation collapses), more narcotic drugs trading going on the streets (when the launderer try to liquidate the money put on the drugs), more drug related crimes, youngsters / youth in Punjab for example attracted to the narcotic drugs and the social issues happened there is a typical example of the acts of Money Launderers. The terrorists used to bring money to India by way of narcotics purchased in Afghanistan, smuggled in to Punjab through Pakistan boarder then sell and liquidate for the money / Cash actually resulting in the social effect due to drug menace.[5] When the law-enforcement resources stretched beyond their means and general loss of morale on the part of legitimate business people who do not break the law and do not make nearly the profits that criminals do. The problem will be the public perception develops in the society that the good business people are also doing this and stigma attached to such a situation. The people will be confused, whom to believe and whom not is a social concern. Strong enforcement mechanism can create public confidence in this area. If we suspect everything then we cannot do business right?

II.     Economic Effects:

The economic effects are on a broader scale. Developing countries bear the “brunt of modern money”[6] because the governments are still in the process of establishing regulations for their newly privatized financial sectors. This makes them prime target. Other major issues facing the world’s economies include errors in economic policy resulting from artificially inflated financial sectors.[7] This makes them prime target and other major issues facing the world’s economic effects includes errors in economic policy resulting from artificially inflated financial sectors. Financial bubbles in the American Economy which collapsed the high street are example for this. One fine morning sky rocket price of the scrip fallen to a very low resulting in the huge loss to the investors. The set back in the investment banking happened in USA and Europe are also the examples of this situation. 

Massive influx of dirty cash into particular areas of the economy that are desirable to money launderers create false demand and officials to control this act on this new demand by adjusting economic policy. When the laundering process reach to a certain stage or if law enforcement start to show interest, all that money suddenly disappears without any predicable economic cause and the financial sector falls apart.[8] Conversion of dirty or black money to the white money and pushing it in to the mainstream legal economy slowly is the cause of inflation. Without an impact of GNP, the market flood with the money can create high level of inflation. Some problems on a more local scale relate to taxation and small business competition.[9] Laundered money is usually untaxed, meaning the rest of us ultimately have make up the loss in tax revenue. It is a fiscal loss for any country. Also legitimate small businesses cannot compete with money laundering from businesses that can afford to sell a product far cheaper because their primary purpose is to get clean money or white Money and not to earn profit.[10] They have so much cash coming in that they might even sell a product or service below cost. This can create havoc in the market and the genuine business people who have investment and overheads will be in dangerous situation and will find difficult to even work on break-even. 

TRADE BASED MONEY LAUNDERING (TBML)

         The author of this article while serving in the premier investigating agency of India had seen many instances of trade based money laundering. The perpetrators of the crime pump money in to the trade through various means (which will be discussed in the coming paragraphs) and convert their black money in to white money. Financial Action Task Force (FATF) defines Trade based money Laundering (herein after referred as TBML), as the process of disguising the proceeds of the crime and moving value through the use of trade transactions in an attempt to legitimize their illicit origins. In the simpler terms, TBML is the process of transferring / moving money through trade transactions. In practice this can be achieved through the misrepresentation of the price, quantity or quality imports or exports. The following are some of the TBML practices popularly seen by the investigating and enforcement agencies in the world:-

(i)                Over-invoicing or ‘Under-invoicing’ of goods and services – Money laundering through the over-invoicing and under invoicing of good and services, which is one of the oldest methods of fraudulently transferring value of money across borders, remains a very common practice popularly done by the perpetrators of this crime. The key element of this modus-operandi is the misrepresentation of the price of the goods and services. Earlier it used to be in the tangible products or goods but now days it is being done in the case of the intangible services like software products, Consultancy Services etc. By doing this they will succeed in transferring additional value between importer and exporter and money come in to the legal channel through this. For example goods or services worth Rs. 1 Billion Dollar can be transacted as 5 Billion Dollars; by doing over-invoicing therefore 4 Billion Dollars money laundering has been committed. [Source : Various industry articles and other sources].

(ii)              Over invoicing is the most common trade based money laundering technique used to move money from one place to the other for a bad purpose. This reflects the fact that primary focus of most customs agencies is to stop the import of contraband and ensure that appropriate import duties are levied and collected. This will prevent this practice. But at the destination if the Customs policy is liberal and duty free then this will be largely used by the perpetrators.

(iii)            Multiple-invoicing of goods and services. This is another technique used to launder funds involves issuing more than one invoice for the same trade transaction. The author of this article has investigated one of the Bank scam case in which this technique was used for defrauding the bank and money laundering. That was the time the Bill of Lading was copied by using the color Copier machines and made another sets of export documents and then Invoicing to other country and getting funds again in another bank in another country through trade financing mechanism of bills discounting. The bills accepted under ‘DA basis were discounted several times in several countries for the same consignment of the goods and four to five times funds were raised from various banks, located in different countries by duplicating the documents. Since the color Xerox were not very popular the banks never had the suspicion about the genuineness of the documents. [Source : Industry sources].

(iv)            By doing Multiple Invoicing technique Launderers and Terrorists are also able to justify multiple payments for the same shipment of goods or delivery of services. In this case the perpetrator or criminal need not over invoice or under invoice, (Misrepresentation of the price) but just multiple the numbers of the Invoices and other export documents like Bill of Lading and Airway Bills and facilitate multiple payments.

(v)              Over-shipment and under-shipment of goods and services in addition to manipulating export and import prices, is another method. The Money Launderer can overstate or understate the quantity of the goods being shipped or services being provided. It is also observed that in one of the instances, the exporter never do any export but only the documents are traveled. Sometime consignment will be some stones or rags packed in the boxes, which does not have any value but such goods travel and at the destination they were thrown out. The exporters manage it in the export documentation with the help of Customs officials. This is very commonly seen in Middle East countries like UAE where such paper companies exist to do such sham transactions, for money laundering and also to do the Customs fraud like Duty draw back (Export incentive frauds done by many exporters from India. This is also called ‘Phantom Shipment’. Another example is an exporter may ship relatively inexpensive goods or services and falsely invoice it as more expensive item or entirely different (as mentioned in the example referred above). This creates a discrepancy between what appears on the shipping physically and what shown in the Customs documents. 

(vi)            The use of false descriptions can also be used in the trade in services such as financial advice, Consulting services, market research and software exports. Generally cases of over-invoicing or under-invoicing primarily designed to gain a tax advantage are popularly done by the exporters to evade tax or get more export incentives. For example a mechanical assembly which consisting of several items will cost more, but actually only a part of the item which actually cost less will be physically exported, but in the Invoice it will be shown as full set or assembly of items. Then they manage during the export documentation with various agencies and show the export for very high value.

PREVENTION OF MONEY LAUNDERING ACT (PMLA) 2005.

           After the abolition of Foreign Exchange Regulation Act (FERA) and enactment of Foreign Exchange Management Act (FEMA), it was become necessary to have an Act which has some teeth to control the money laundering activities. FEMA was more considered as a Management Act and not a Regulatory Act. PMLA is a criminal law which came in to force on 01st July 2005. Under this Act, money laundering is linked to the predicate scheduled offences is liable for punishment. There are 156 offences in 28 different statutes which are scheduled offences under PMLA.[11] Enforcement Directorate in India had got very good deterrent power through this Act. Since the criminal offences are there they can invoke the actions like Arrest, Searches and seizures etc. PMLA is considered as a deterrent economic offences law. 

PROCESS OF PMLA INVESTIGATIONS

         Once the agency concerned with a predicate scheduled offence registers a case, Enforcement Directorate (hereinafter referred as ED), India, takes up investigations under PMLA to ascertain the proceeds of crime generated from the predicate offence booked by the Law Enforcement Agency.[12] In the event of prima-facie case of generation proceeds of crime and laundering is made out, PMLA provides for seizure and attachment of laundered properties. The action of seizure and attachment is required to be adjudged by the Adjudicating Authority under PMLA.[13]

           The persons, both natural and legal (artificial) entities, who are accused of the offence of money laundering linked to the scheduled offence, can be prosecuted in the Special Courts in India. PMLA provides rigorous imprisonment of minimum three years which can extend up to seven years and a fine up to Rs. 5 Lakhs on conviction by the Court of persons who have been accused of the offences of Money Laundering. The conviction can extend up to 10 years if the offence of money laundering is linked to narcotic trafficking. The property attached under the PMLA can be confiscated by the Adjudicating Authority after the conviction by the Court of the accused in the trial for scheduled offence.[14]

           It often seen that the perpetrators park their money or proceeds in the overseas, which can be restituted through mutual legal assistance after the collection of such evidence through the process of Letter of Requests with the foreign administration. PMLA also sets out the procedure for reciprocal arrangements with contracting states for seizure, attachment and confiscation of assets found lying in the overseas. India has signed Mutual Legal Assistance Treaty (MLAT) with 26 countries and by virtue of the provisions of the PMLA, Government of India is fully armed with legal measures to get the tainted assets repatriated back to the country on conviction of persons accused of Money Laundering.[15]

           Till the conviction, the asset traced at overseas can be requested to be seized or frozen by foreign jurisdictions. We have seen such actions by the ED in PMLA against alleged bank fraudsters in the recent past. Section 12 of PMLA requires financial sector entities (Banking Companies, financial institutions & intermediaries) to verify the identity of their clients, maintain records, and report suspicious / cash transactions (STR/CTR) to FIU-IND, Director, FIU, India is empowered to conduct inquiry and impose sanctions against financial sector entities for non-compliance with the Section 12 of the PMLA.[16]

           It is the practice that FIU, India conducts analysis of the information received under the PMLA and inappropriate cases, disseminates information to relevant intelligence / enforcement agency as the case may be applicable, which includes CBDT, CBEC, ED, NCB, CBI and Intelligence agencies and regulators of the financial sector like RBI, SEBI, Department of Corporate Affairs etc. It is also seen that under the FEMA and PMLA, investigation is initiated against specific persons, both natural and legal, and such action is initiated on the basis of the specific information / input.[17]

           In the case of banks, RBI is having a mechanism by which, if any Export Outstanding is there, the banks have to submit XOS Statement (Export Outstanding Statement) which means export happened but, the proceeds are not repatriated back to India, such details to be informed to the Reserve Bank of India (RBI). If the RBI feels that in any specific cases, Money Laundering or suspicious activities are there, according to my knowledge they also refers the cases to the investigating agencies like ED or FIU or CBI for further verifications.

Anti-Money Laundering (AML) Compliance

           Anti-Money laundering Compliance initiatives are very important for the corporate in the world. Most of the Companies and organizations are taking very proactive actions in their organizations for monitoring the suspicious transactions and preventive measures which is very encouraging trend. Organisations wanted to avoid punitive actions and legal issues related to this area and so are stressing the importance of AML Compliance culture in the respective organisation. 

           Given the increasing regulatory scrutiny related to AML issues and complex challenges faced by the financial institutions in that regard, institutions are realizing the importance of implementing and maintaining robust AML program. Companies are also realizing the importance of implementing risk-based Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Compliance program that be applied across diverse business lines. However, evaluating the money laundering risks in an organisation, and the tools and techniques available, for mitigating these risks can present a significant challenge.[18]

           Now a days the corporate recruit AML Experts or Practitioners who are like former financial and regulatory experts, Government Enforcement Agency agents (Police officers), Financial Institutions Compliance Officers, Fraud and Forensic specialists, former Financial Fraud and AML investigators, technology experts, Digital Forensic Experts, and also people with hands on experience of working in financial institutions to deal with the AML issues. These experts are found to have considerable experience in advising the corporate on such issues, particularly on preventive measures and for implementing AML / CFT programs in the organizations. They are also capable of conducting Money Laundering Investigations wherever necessary or issues reported.[19] 

Lookback:

Before we consider the challenges and lessons that corporate to learn on AML Compliance let us understand the concept "Look Back". Regulators may require the financial institutions to perform a "transaction review of historical activity” when they consider or determine that the financial institutions does not have and adequate transaction monitoring program and / or has evidenced sound decision making in determining whether any transaction happened as the case may be suspicious or not. This sort of going back and see the transaction suspicious or in other words the scope of “look back” may be for a shorter period or for even years. This is like a verification or forensic audit or check which may usually be done by third party agencies like a Big Four firm or such an agency which neutral to the issue. Many times the regulators may insist on such third party verification or “look back”[20] to find out or detect the suspicious transaction in a financial institution. 

           Considering the increasing regulatory scrutiny related to AML issues and complex challenges involved in this financial crime which is faced by the financial institutions, the companies are realizing the importance of implementing and maintaining robust AML program in their respective institutions.[21] 

PREVENTIVE Vs PUNITIVE:

All will agree with me that such an exercise particularly if it is for a period covering several years will be an expensive affair and time consuming. Such exercises are also considered as “Punitive exercise”[22] or postmortem by the industry experts. According to Carol Beaumier, Senior Managing Director, Risk and Compliance, Protiviti which I quote “If your institution is facing a lookback, consider the top ten lessons[23]. She discuss in detail about the lessons learned for maximizing the efficiency and value. They are;-

1.     Select the right party: When you are doing the independent third party engagements for providing services for your organisation, be careful during the selection process. Select the firm or agency that will be creditable with the regulators (who often will need to provide a non-objection) that it has lookback experience comparable to the scale of your lookback and that it understands the customers you serve, the geographic markets in which you engage and the products and services you offer.[24]

2.     Understand the approach: Ask the third party who is going to give you service, how it will approach the lookback to achieve maximum efficiency – for example what transaction data will and will not be in scope, how it will produce alerts, what will be the final deliverable etc. If the third part is unable to answer these questions or address these issues then don’t engage such third party and try to find somebody else, who qualify the criteria mentioned. This is like a due diligence process.[25]

3.     Be candid and open about the challenges: If you know from your own experience that the third party is underestimating the number of potential alerts, that certain information will be challenging to retrieve, or that certain customers / counterparties are likely not to be cooperative in responding to questions because of privacy laws in their home country or because you terminated your relationship with them subsequent to the lookback period, tell the third party. This will help to ensure that they build a realistic project plant and timetable. [Source Carol Beaumier, Senior MD, Risk & Compliance, Protiviti]

4.     Get regulatory buy-in: Whether it is required or not ask for the regulators' feedback on the planned approach and deliverables. This will help to ensure that the lookback methodology and final deliverables will align with regulatory expectations.[ Source: Carol Beaumier].

5.     Ensure availability, access and understanding of data: It is always advisable that we spent some time at the beginning of the project to ensure that the third party performing the lookback has access to all the required systems like; transaction monitoring systems, Core systems, Know your Customer Systems [KYC) etc. and take the time to explain these systems and their configurations. The point is that if wrong or inadequate data is used, then the third party performing the Lookback will not give desired results to us. [ Source: Carol Beaumier].

6.     Establish and communicate operating protocols: Effective and timely communication is very important in meeting the lookback project timeline. Make sure you and the third party are on the same page with respect to how and to whom questions will be escalated. The final result is expected to include information on the disposition of any activity referred to you by the third party for SAR filing considerations. The expectation is that disagreements between you and third party on when SAR should be filed will be minimal, but when they do occur, you should document your rationale clearly and completely. [ Source: Carol Beaumier].

7.     Stay engaged: The Third party should provide with regular status reports and hold periodic status meetings. If this is not the case, you should required this. The status report of Lookback should be collected from the Third party and should stay engaged. Regulators will expect this of you and you certainly don't want to be blindsided at the end of a lookback project by finding out that you need to file an unexpectedly large number of SARs.[ Source: Carol Beaumier].

8.     Consider how the results of the lookback will be integrated into your monitoring program: Lookback usually perform by the third party in a system environment provided by us. But that is segregated from your production environment. Make sure you understand how the information developed during lookback will be integrated in to your case management system at the completion of the feedback so that we have complete records. [Source: Carol Beaumier].

9.     Ask for recommendations: Although the primary objective of the third party is to identify potentially suspicious activities that you may have missed, the third party will learn a lot about your customers and their activity, and your existing transaction monitoring capabilities and processes. Ask the firm to provide you with recommendations on changes you can make to enhance your transaction monitoring.[Source: Carol Beaumier].

10. Respect the independence of the third party: It is important to the credibility of the lookback that both you and the third party respect the boundaries of independence. Functional freedom is very important for better results. We must always expect the independent third party to ask for your factual review of deliverable and, while you are always free to suggest other changes, you should understand that the third party may not always agree with you and is obliged to report its findings objectively, based on its own work and convictions. It is not desirable to push or press on our conclusions or ideas on the third party and we must respect the independence of the third party. We should be in a guidance mood or Supplementary mood only. [Source: Carol Beaumier].

 CONCLUSION:

Money Laundering is a serious threat to the country and to the organisations. As far as corporate are concerned it is the need of time to monitor this and do the AML Compliance system in all the organisations which are engaging in the financial activities. The essay tried to understand the Money Laundering as a financial crime and how to prevent it, process involved and the statutory agency dealing with such incidents and its investigation. Every organisation doing financial services should set up the AML process in their organisation and should escape from the lack of compliance, which can create risk, loss and legal implications to the organisations, particularly the financial services organisations.   

 [1] Industry articles / publications on AML

[2] Terrorist funding and Money Laundering – Articles in the international publications.

[3] Layering of Money Laundering – Various Articles and sources.

[4] Articles on Social Impacts of Money Laundering. 

[5] Articles on drug menace in Punjab. 

[6] Articles on Economic Effects on Money Laundering.

[7] Ibid.

[8] Article on collapsing financial bubbles in Europe and USA.

[9] Economic impact of Money Laundering.

[10] Ibid.

[11] PMLA 2005.

[12] Enforcement Directorate, ED, India. https://enforcementdirectorate.gov.in   

[13] ED, India

[14] ED, India.

[15] Ibid.

[16] PMLA 2005, FIU Sources.

[17] FEMA, PMLA. Enforcement Directorate, India.

[18] Source : Various Industry Journals and Articles on Money Laundering Compliance.

[19] Industry Sources and AML Compliance Journals.

[20] Carol Beaumier, Senior MD, Director, Risk and Compliance, Protiviti.

[21] Various articles published on AML Compliance by the experts.

[22] Carol Beaumier, Senior MD, Director, Risk and Compliance, Protiviti.

[23] Ibid.

[24] Ibid.

[25] Ibid.