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SEBI / Portfolio Managers

AML Obligations for Portfolio Managers — Master Circular Reference

A comprehensive guide to AML obligations for Portfolio Managers, including master circular references and compliance requirements.

25 Jul 20263 min read

Anti-Money Laundering (AML) compliance is a critical obligation for portfolio managers. This article explains the AML obligations and master circular references.

The Regulatory Framework

Legal Basis

Portfolio managers are subject to AML obligations under the Prevention of Money Laundering Act, 2002 (PMLA), and SEBI's Anti-Money Laundering (AML) Guidelines.

Master Circular

SEBI has issued a Master Circular on Anti Money Laundering and Combating Financing of Terrorism (AML and CFT) Standards.

Applicability

All reporting entities must comply with the Prevention of Money Laundering (Maintenance of Records) Rules, 2005 (PMLA), as well as any subsequent amendments.

Key AML Obligations

KYC Compliance

Portfolio managers must:

  • Conduct KYC of all clients
  • Verify client identity and address
  • Maintain KYC records
  • Update KYC periodically

Record Keeping

Portfolio managers must maintain records of:

  • All cash transactions worth more than ₹10 lakhs or its equivalent in foreign currency
  • Any series of transactions that are directly or indirectly related and have a combined value greater than ₹10 lakhs

Transaction Monitoring

Portfolio managers must:

  • Monitor transactions for suspicious activity
  • Identify unusual patterns
  • Report suspicious transactions

Reporting

Portfolio managers must:

  • Report suspicious transactions to FIU-IND
  • Submit STRs within 7 days of arriving at a conclusion

Principal Officer

Designation

Portfolio managers must designate a Principal Officer responsible for:

  • AML compliance
  • Reporting suspicious transactions
  • Coordination with FIU

Responsibilities

The Principal Officer must:

  • Ensure compliance with PMLA
  • Review suspicious transactions
  • Submit reports to FIU
  • Maintain records

Client Due Diligence

Verification

Portfolio managers must independently verify compliance during onboarding and transaction approval.

Risk Assessment

Portfolio managers must:

  • Assess client risk
  • Apply enhanced due diligence for high-risk clients
  • Document risk assessment

Ongoing Monitoring

Portfolio managers must:

  • Monitor client transactions
  • Update KYC periodically
  • Re-assess risk

Suspicious Transaction Reporting

Identification

Portfolio managers must identify suspicious transactions, whether or not made in cash.

Reporting

Suspicious Transaction Reports (STRs) shall be submitted within 7 days of arriving at a conclusion that any transaction, whether cash or non-cash or a series of transactions integrally connected is of suspicious nature.

Immediate Reporting

Any suspicious transaction should be reported immediately to the Money Laundering Control Officer (Principal Officer).

Consequences of Non-Compliance

Regulatory Action

Non-compliance with AML obligations can result in:

  • Enforcement action by SEBI
  • Criminal prosecution under PMLA
  • Monetary penalties

Reputational Damage

AML non-compliance can cause significant reputational damage.

Expert Legal Guidance

Anuj Desai & Associates provides expert legal advisory services on AML compliance for portfolio managers. Our securities law experts help clients implement compliant AML programs, conduct due diligence, and ensure regulatory compliance. Contact us for guidance on AML and other regulatory matters.


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