Anti-Money Laundering & Counter-Terrorist Financing Policy

1. Regulatory Framework and Statement of Intent

1.1 Governance Standard

Indian Attorneys Ltd ("the Company," "IA UK") is committed to the highest standards of financial integrity. This policy ensures adherence to:

• United Kingdom: The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017; The Proceeds of Crime Act 2002 (POCA); and the Economic Crime and Corporate Transparency Act 2023.
• India: The Prevention of Money Laundering Act (PMLA) 2002 and its 2023 Amendments.

1.2 Zero Tolerance

IA UK maintains a zero-tolerance mandate regarding the facilitation of financial crime. We operate a proactive "Detect, Deter, and Disclose" framework to ensure our platform is not used for illicit capital movement.

2. Institutional Scope

This policy is binding upon all internal and external stakeholders:

• Corporate Officers: Directors, employees, and consultants of IA UK.
• The Network: All Advocates and law firms onboarded via the IA UK platform.
• The Clientele: All users engaging in cross-border consultations, particularly those involving asset transfers, real estate, or estate settlements.

3. Risk-Based Approach (RBA) and Taxonomy

3.1 Dynamic Risk Assessment

IA UK categorises engagements into Low, Medium, and High-Risk profiles based on:

• Geographic Risk: Transactions involving jurisdictions under increased FATF monitoring.
• Service Risk: Scrutiny for high-value assets, including property acquisition and corporate restructuring.
• Delivery Risk: Non-face-to-face onboarding is mitigated through biometric liveness checks and digital identity verification.

4. Customer Due Diligence (CDD) & Biometric KYC

4.1 Identification & Verification (ID&V)

Before any instruction is facilitated, IA UK performs mandatory CDD:

• For Natural Persons (NRIs): Valid Passport/OCI card, proof of tax residency, and AI-powered biometric liveness verification.
• For Legal Entities: Certificate of Incorporation and identification of Ultimate Beneficial Owners (UBO) holding >10% interest.
• For Advocates: Bar Council of India certification, professional indemnity status, and a clean disciplinary record check.

4.2 Source of Wealth (SoW) and Source of Funds (SoF)

5. Enhanced Due Diligence (EDD) Protocols

5.1 Politically Exposed Persons (PEPs)

IA UK performs automated screening against global PEP databases. Any match triggers immediate EDD and requires manual sign-off by the Money Laundering Reporting Officer (MLRO).

5.2 High-Value Litigation

Cases involving significant financial claims are subject to continuous monitoring of fund movements.

6. The Integrated Escrow & Financial Monitoring

6.1 Payment Vigilance

All professional fees processed through the IA UK Secure Payment Facilitation System are monitored for "Structuring" (layering small payments) and "Third-Party Payments".

6.2 Prohibited Methods

IA UK does not accept cash, untraceable money orders, or high-risk crypto-assets for the settlement of legal fees.

7. Suspicious Activity Reporting (SAR)

7.1 Mandatory Reporting

In accordance with the UK POCA, any transaction deemed suspicious will be documented by the MLRO.

7.2 Anti-Tipping Off

IA UK employees are strictly prohibited from "tipping off" a client that a SAR has been filed. Breach of this provision is a criminal offence.

7.3 External Filing

SARs will be submitted to the National Crime Agency (NCA) in the UK or the Financial Intelligence Unit (FIU-IND) in India.

8. Data Retention and Archival

8.1 Record Integrity

All KYC/CDD/EDD records and transaction logs are retained for six (6) years post-termination of the business relationship.

8.2 Digital Security

AML records are stored in a partitioned, high-security environment within the IA UK cloud, accessible only by the Compliance Department.