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★★★ Flagship Practice

Anti-Money Laundering

PMLA, FATF, VDA desk — the only Indian team that understands AML from having designed and stress-tested programmes under FATF-compliant regimes in the DIFC and Australia, not merely from having read the guidelines.

CAMS-certified AML specialist on team
PMLA · ED proceedings · VDA / Crypto desk
The Practice

When the Enforcement Directorate arrives — or before it does — you need counsel who has been inside the system, not just opposite it.

The ED has issued a provisional attachment order against your company's accounts. Or your bank has frozen transactions pending an AML review triggered by a correspondent bank query. Or the Financial Intelligence Unit has raised a suspicious transaction report against your business and you have received a notice under the Prevention of Money Laundering Act. Or your fintech startup is preparing to launch a VDA platform and needs a complete AML/CFT framework before your RBI application. Each of these situations is different. All of them require counsel who understands the PMLA not as text, but as a living enforcement mechanism operated by the ED and the courts.

Goldschmidt Pallonji's AML practice is built on a credential that no other Indian firm can claim. Our founding director is CAMS-certified — holding the Certified Anti-Money Laundering Specialist qualification administered by ACAMS — and has designed and implemented AML compliance programmes under FATF-compliant regulatory regimes in the DIFC (Dubai) and Australia. This is not academic knowledge of FATF guidelines. It is operational knowledge of what a functioning, stress-tested AML programme looks like from the inside — the kind of knowledge that allows GP to build programmes that actually work under regulatory scrutiny, not programmes that merely check compliance boxes.

Our AML practice covers the full spectrum — from proactive compliance programme design for banks, NBFCs, fintechs, VDA platforms, and reporting entities under the PMLA, through to defence of individuals and companies in ED investigations, provisional attachment proceedings, prosecution complaint responses, and PMLA appellate proceedings before the Adjudicating Authority, Appellate Tribunal, and High Courts.

Key Statutes & Regulators
PMLA 2002 Enforcement Directorate Financial Intelligence Unit FATF Recommendations RBI AML Master Directions SEBI AML Circular VDA / VASP Framework FEMA + PMLA Intersection
Practice at a Glance
Tier
★★★ Flagship
Key Forums
ED · FIU · PMLA Adjudicating Authority · PMLA Appellate Tribunal · High Courts · Supreme Court
Key Credential
CAMS-certified (ACAMS) · FATF programme design · DIFC & Australia AML experience
International Corridors
🇦🇪 DIFC / Dubai 🇦🇺 Australia 🇸🇬 Singapore 🇬🇧 UK
Also Covers
VDA / Crypto AML · Sanctions Compliance · FEMA-PMLA overlap · Benami Transactions
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What We Do

Our Services

From proactive AML programme design to active defence in ED investigations — the complete AML and financial crime practice.

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AML Compliance Programme Design

Design and implementation of end-to-end AML/CFT frameworks for banks, NBFCs, fintechs, payment aggregators, and VDA service providers. KYC/CDD/EDD policies, transaction monitoring systems, STR/CTR filing protocols, MLRO appointment, and staff training programmes calibrated to FATF Recommendations and RBI/SEBI AML guidelines.

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ED Investigation Defence

Immediate response to ED summons, statements under Section 50 PMLA, search and seizure operations, provisional attachment orders under Section 5, and confirmation of attachment before the Adjudicating Authority. Personal representation of directors and individuals facing personal liability under PMLA. Emergency bail applications where arrest is threatened.

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Provisional Attachment Challenges

Challenge to provisional attachment orders before the PMLA Adjudicating Authority. Representation in confirmation proceedings, response to the ED's Show Cause Notice, High Court writ petitions challenging attachment on constitutional and statutory grounds. Asset release strategy including interim stay applications.

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VDA / Crypto AML & Regulatory

AML/CFT frameworks for Virtual Digital Asset Service Providers (VASPs) under India's PMLA VASP notification. FIU-IND registration compliance, transaction monitoring for crypto exchanges, NFT platform compliance, and regulatory interface with the ED on crypto-related investigations. FATF Travel Rule compliance for VDA platforms.

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Cross-Border AML & Sanctions

Sanctions screening and compliance for Indian companies dealing with international counterparties subject to OFAC, EU, UN, and UK sanctions. FEMA-PMLA overlap analysis for cross-border transactions. Correspondent banking relationship support where Indian entities face de-risking by foreign banks. Mutual Legal Assistance Treaty (MLAT) responses.

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AML Audits & Regulatory Reviews

Independent AML audits for reporting entities under the PMLA to assess the adequacy of existing compliance programmes. Regulatory inspection preparation, response to RBI/SEBI/FIU show cause notices on AML deficiencies, and remediation planning. Our forensic accounting team supports transaction-level AML reviews where required.

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Key Highlights

The credentials that make GP the right choice when AML compliance or ED action puts your business or liberty at risk.

CAMS Certified
Our founding director holds the CAMS certification (Certified Anti-Money Laundering Specialist) from ACAMS — the globally recognised professional standard for AML specialists. There is no equivalent qualification at any other Indian Tier 1 law firm.
DIFC & Australia
We have designed and stress-tested AML programmes under FATF-compliant regulatory regimes in the DIFC (Dubai Financial Services Authority) and in Australia (AUSTRAC). We understand what a functioning AML programme looks like from the inside — because we built them in jurisdictions where FATF compliance is enforced with real consequences.
PMLA + FEMA
The most dangerous AML situations in India arise at the intersection of the PMLA and FEMA — where a forex violation becomes a money laundering allegation, or where a cross-border payment that was lawful under FEMA is characterised as proceeds of crime under PMLA. GP's team handles both statutes, which means the overlap is managed by one team with full visibility, not two separate counsel working in parallel.
VDA Desk
India's VDA framework — the PMLA VASP notification, FIU-IND registration, and the forthcoming VDA regulatory regime — is creating the largest new AML compliance obligation in the financial sector since the PMLA itself. GP's VDA desk is the only practice in India combining AML legal expertise, FATF operational knowledge, and crypto-native regulatory understanding.
When the ED Calls — What to Do in the First 24 Hours

The first 24 hours of an ED action determine the outcome of the next two years. The statement recorded under Section 50 PMLA cannot be retracted. The documents surrendered during a search cannot be unretrieved. The provisional attachment order, once issued, runs for 180 days before confirmation proceedings. GP provides immediate, same-day advice when the ED arrives — before a single statement is given and before a single document is handed over.

For Foreign Companies Operating in India

Foreign companies with Indian operations face AML risk from two directions simultaneously — their home country regulator's expectations (AUSTRAC, FCA, MAS, DFSA) and India's PMLA framework. GP is uniquely positioned to bridge these — advising on Indian PMLA compliance in a way that is comprehensible and credible to an Australian, GCC, or Singapore parent company's compliance function.

For Individuals Personally Named in ED Proceedings

You are a company director. The ED has issued a summons to you personally under Section 50 of the PMLA. The ED officer who called says it is "just for information." It is not. Any statement you give can be — and is regularly — used against you in criminal prosecution. Before you attend a single ED meeting, speak to GP. The advice you receive in the first conversation may determine whether this matter ends with an explanation or with a prosecution complaint naming you personally.

The GP Difference

Why GP for Anti-Money Laundering

1

We understand FATF from inside a FATF-compliant regime

Most Indian lawyers advise on FATF compliance by reading the 40 Recommendations and India's PMLA. Our founding director has operated inside FATF-compliant frameworks — in the DIFC under DFSA supervision and in Australia under AUSTRAC. This means GP's AML compliance advice is calibrated to what regulators actually look for when they examine a programme — not what the guidelines say they should look for.

2

Compliance and defence — one team, one strategy

The best AML compliance programmes are built by lawyers who have defended PMLA prosecutions — because they know exactly what the ED looks for, what evidence gaps become prosecution points, and what documentation weaknesses become attachable. GP's compliance team and defence team are the same people. The programme we design for your company is stress-tested against real ED investigation patterns — not theoretical risk scenarios.

3

Forensic accounting + AML = complete financial crime capability

ED investigations are fundamentally financial in nature — trail of funds, layering through multiple entities, integration into legitimate assets. GP's in-house forensic accounting team works alongside our AML lawyers in every significant matter. This means the financial narrative that the ED constructs can be countered with equal financial sophistication — transaction by transaction, entity by entity, with our own forensic analysis presented to the Adjudicating Authority.

Representative Matters

The type of work we do.

Complete confidentiality is maintained. These matters illustrate the nature of our AML and financial crime practice.

India ED Provisional Attachment

Real estate developer — ₹180Cr provisional attachment successfully challenged

The ED attached ₹180Cr of a real estate developer's receivables under PMLA alleging proceeds of crime from a predicate fraud. GP filed a comprehensive reply before the Adjudicating Authority challenging the nexus between the predicate offence and the attached property. Attachment confirmed partially but ₹120Cr released following GP's financial tracing analysis presented to the Authority.

India VDA AML Programme

Crypto exchange — complete PMLA VASP compliance framework

Designed and implemented a full PMLA/AML compliance framework for a mid-sized Indian cryptocurrency exchange post the PMLA VASP notification. FIU-IND registration, KYC/CDD/EDD policies for crypto customers, transaction monitoring system requirements, FATF Travel Rule implementation, and STR/CTR filing protocols.

GCC + India Cross-Border AML

GCC NBFC — de-risking response and correspondent bank restoration

An Indian subsidiary of a GCC NBFC had its correspondent banking relationships suspended by two international banks following AML de-risking. GP conducted a full AML programme gap analysis calibrated to FATF standards, remediated identified deficiencies, and provided the AML compliance attestation that restored correspondent banking access within 90 days.

Practice Leadership

Our AML practice is led by India's only CAMS-certified lawyer who has designed AML programmes under FATF-compliant regimes internationally.

The Managing Director leads our AML practice with a credential that is unique in Indian legal practice — CAMS certification from ACAMS, combined with operational experience designing and implementing AML programmes under DFSA (DIFC) and AUSTRAC (Australia) supervision. When GP advises on AML compliance, the advice comes from someone who has been on the regulator's side of the examination — who knows what examiners look for, what documentation they scrutinise, and what gaps become enforcement actions.

MD
Managing Director
Practice Lead — Anti-Money Laundering
CAMS (ACAMS) DFSA / DIFC experience AUSTRAC experience NSW Solicitor + India Advocate
AML programme design: DIFC (DFSA) · Australia (AUSTRAC) · India (PMLA / FIU-IND) · FATF Recommendations specialist
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Latest Insights
PMLA Bulletin

India PMLA Enforcement Review 2026 — ED Action Trends

Analysis of ED provisional attachment orders, prosecution complaint trends, and the Supreme Court's evolving jurisprudence on the burden of proof in PMLA proceedings.

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VDA Desk

India VDA AML Framework 2026 — FATF Travel Rule & FIU-IND Compliance

What crypto exchanges and VDA service providers must do now under the PMLA VASP notification — FIU registration, transaction monitoring, STR obligations, and the coming Travel Rule implementation.

Read Bulletin →
GP
Anti-Money Laundering

Speak to Our AML Team — Today

If you have received an ED summons, a provisional attachment order, or a notice from the FIU — do not wait. AML matters move fast and the first steps taken determine the outcome. GP reviews every AML matter the same day it is received. If your situation is urgent, call us directly.

Same-day response on urgent ED / PMLA matters
First consultation — 30 minutes, no obligation
Complete confidentiality — attorney-client privilege applies
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