PMLA for Market Intermediaries: Moving From Policy to Practice
13 Oct 2026 · 1 min read · Jay Kular
A well-written AML policy is not enough. How intermediaries can operationalise client due diligence and suspicious transaction reporting.
Every SEBI-registered intermediary is required to have an Anti-Money Laundering policy. Yet inspection observations repeatedly show a gap between the written policy and day-to-day practice.
Common gaps
- Risk categorisation of clients done once and never revisited
- Alerts generated but not reviewed or documented
- Principal Officer and Designated Director registrations not updated with FIU-IND
- Training records for staff missing
Making it work
Effective PMLA compliance requires a documented process: client risk categorisation, periodic review, alert generation, investigation notes, and decision logs for every suspicious transaction considered.
Our role
We review your AML framework, test samples of client files and alerts, and help you close gaps before they become inspection findings.
Note: Please refer to the latest SEBI master circular on AML/CFT and PMLA rules for current obligations.