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Money laundering is the process of making illegally obtained money appear legitimate. It usually happens in three stages:
Placement – Introducing illegal money into the system
Layering – Moving money through multiple transactions to hide its origin
Integration – Reintroducing the money as “clean” funds
Non-financial businesses are often used in the placement and integration stages.
These are often called DNFBPs (Designated Non-Financial Businesses and Professions):
✔ Real Estate Agents
Property purchases are commonly used to launder large amounts of money.
✔ Lawyers & Notaries
Especially when handling:
Client funds
Company formation
Property transactions
✔ Accountants
Can unknowingly help structure transactions to hide funds.
✔ Company Formation Agents
Used to create shell companies.
✔ Casinos & Gaming Businesses
Cash-heavy operations are high risk.
✔ Dealers in High-Value Goods
Luxury cars
Jewelry
Art
Precious metals
High-end electronics
✔ Trust & Company Service Providers
Failure to comply can result in:
Heavy fines
Criminal penalties
Business license suspension
Reputational damage
Regulators globally (FATF guidelines) require countries to monitor non-financial sectors due to increasing misuse.www
Examples include:
Customers insisting on large cash payments
Use of complex company structures without clear purpose
Transactions inconsistent with client profile
Reluctance to provide identification
Rapid resale of property at unusual prices
A real estate agent receives ₹2 crore in cash for a property purchase.
If the buyer refuses to disclose source of funds, the agent must:
Conduct enhanced due diligence
Verify identity and source of funds
File a Suspicious Transaction Report if needed
In India, AML is governed by:
Prevention of Money Laundering Act (PMLA), 2002
Regulated by:
FIU-IND
RBI (for financial entities)
Other sector regulators
Certain non-financial businesses fall under reporting obligations under PMLA.
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