AML advisory services and corporate investigations
Our AML advisory services help regulated businesses meet their duties under the Prevention of Money-laundering Act, 2002: knowing their customers, keeping records, and reporting cash and suspicious transactions to the Financial Intelligence Unit. We also run internal corporate investigations and due diligence checks on counterparties, from our office in Sanpada, Navi Mumbai.
Last updated 13 September 2026 · VIVS Legal, Sanpada, Navi Mumbai
- Main law
- Prevention of Money-laundering Act, 2002 and its record-keeping rules
- Reporting to
- Financial Intelligence Unit, India (FIU-IND)
- Sector rules
- RBI KYC Master Direction, SEBI and IRDAI AML guidelines
- Investigations
- Internal inquiries and lawful due diligence
- How we work
- From Sanpada, Navi Mumbai, and online
On this page
Who must comply with the PMLA?
The Act places duties on 'reporting entities'. These include banks, NBFCs and other financial institutions, SEBI-registered intermediaries, insurers, payment system operators, real estate agents, dealers in precious metals and stones, and, since 2023, virtual digital asset service providers and certain chartered accountants, company secretaries and cost accountants when they carry out specified financial transactions for clients.
PMLA compliance: the core duties
| Duty | What it means in practice |
|---|---|
| Client due diligence | Verify identity and beneficial ownership at onboarding and keep it updated |
| Record keeping | Keep transaction and identity records for the period the rules require |
| Reporting to FIU-IND | Cash transaction reports, suspicious transaction reports and other prescribed reports |
| Principal officer and designated director | Appoint and register them with FIU-IND |
| Internal policy and training | A board-approved AML policy that staff actually follow |
Sector regulators add their own rules: RBI's Master Direction on KYC, SEBI's master circular on AML, and IRDAI's AML guidelines.
AML advisory services: compliance review and KYC
We review your AML policy, onboarding forms and transaction monitoring rules against the Act and your regulator's directions, and test a sample of files. The output is a written gap report with fixes ranked by risk. For new businesses entering a regulated space, we draft the policy and help register the principal officer.
How should a company run an internal investigation?
- Scope. What is alleged, who will investigate, and who must be kept out because of a conflict.
- Preserve. Secure emails, devices, logs and paper records before anyone is told.
- Review documents. Payments, contracts, approvals and communications.
- Interview. Witnesses first, the person accused last, with notes signed where possible.
- Report. Findings, evidence and recommendations, kept confidential.
- Act. Discipline, recovery, police complaint or regulatory report, as the findings support.
Where forensic accounting or data recovery is needed, qualified examiners are engaged under legal instruction.
Due diligence investigations on counterparties
Before a large contract, loan or acquisition, we check what the public record says about the other side: company filings and charges with the Registrar of Companies, litigation in courts and tribunals, regulatory orders, property records and directors' other interests. We stay within lawful sources; we do not offer surveillance or access to private data.
What if the Enforcement Directorate issues a summons?
A summons under Section 50 of the PMLA obliges you to appear and produce documents, and statements recorded can be used in evidence. The Supreme Court upheld these powers in Vijay Madanlal Choudhary (2022). Before appearing, understand what the ED is investigating, prepare the documents asked for, and get advice on your rights. We help prepare and, where the law allows, accompany clients.
Common AML failures
- Beneficial owners not identified for company or trust customers.
- Suspicious transaction reports not filed because staff were unsure.
- Policies copied from another business and never adapted.
- No periodic KYC updates for high-risk customers.
- Principal officer not registered or not replaced on resignation.
Related pages: fraud risk management and asset verification.
Frequently Asked Questions
Still have a question?
Speak with our legal team about your matter with clarity and confidence.
AML advisory is legal advice on meeting anti-money laundering duties: customer due diligence, record keeping, reporting to FIU-IND, policies and training, under the PMLA and the KYC rules of the sector regulator.
It is a report a reporting entity must file with FIU-IND when a transaction appears to involve proceeds of crime, has no apparent economic purpose, or is unusually complex. It must be filed within the time the rules set and kept confidential from the customer.
Since 2023, chartered accountants, company secretaries and cost accountants are reporting entities when they carry out specified financial transactions on behalf of clients, such as managing client money or creating and operating companies.
A company can review its own records and systems in line with its policies, and often should before confronting anyone. The employee must be given a fair hearing before any disciplinary action, and privacy and data protection rules must be respected.
The Director of FIU-IND can impose penalties and issue directions under Section 13. Regulators may also take action, and serious failures can damage licences and banking relationships.
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