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AML in Non-Financial Businesses

Last Updated on Feb 12, 2026, 2k Views

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AML in Non-Financial Businesses

1️⃣ What is Money Laundering?

Money laundering is the process of making illegally obtained money appear legitimate. It usually happens in three stages:

  1. Placement – Introducing illegal money into the system

  2. Layering – Moving money through multiple transactions to hide its origin

  3. Integration – Reintroducing the money as “clean” funds

Non-financial businesses are often used in the placement and integration stages.


2️⃣ Which Non-Financial Businesses Are Covered Under AML?

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

3️⃣ AML Obligations for Non-Financial Businesses

Even if not a bank, businesses may be required to implement:
🔎 1. Customer Due Diligence (CDD)
  • Verify identity (KYC – Know Your Customer)
  • Understand nature of business relationship
  • Identify beneficial owners
📄 2. Record Keeping
  • Maintain customer records
  • Keep transaction documentation (usually 5–10 years)
🚨 3. Suspicious Transaction Reporting (STR)
  • Report suspicious activities to authorities (FIU – Financial Intelligence Unit)
⚖ 4. Risk-Based Approach
  • Conduct AML risk assessment
  • Apply enhanced due diligence for high-risk customers
📚 5. Internal Controls
  • Appoint AML compliance officer
  • Staff training
  • Written AML policies & procedures

4️⃣ Why AML Matters for Non-Financial Businesses

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

5️⃣ Common Red Flags in Non-Financial Businesses

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


6️⃣ Example Scenario

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

7️⃣ Global & Indian Context (if applicable)

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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