COMPLIANCE

Anti-Money Laundering & Counter-Terrorist Financing Policy

Our commitment to financial integrity and regulatory compliance

Effective Date: 26 March 2026

Registered Entity: Indian Attorneys Ltd (Trading as "Indian Attorneys UK")

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 is engineered to ensure strict adherence to:

United Kingdom

  • The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)
  • The Proceeds of Crime Act 2002 (POCA)
  • The Economic Crime and Corporate Transparency Act 2023

India

  • The Prevention of Money Laundering Act (PMLA), 2002, and the 2023 Amendments therein

1.2 Zero Tolerance

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

2. Institutional Scope

This Policy is binding upon all internal and external stakeholders, including:

3. Risk-Based Approach (RBA) and Taxonomy

3.1 Dynamic Risk Assessment

IA UK does not apply a "one-size-fits-all" approach. We categorise engagements into Low, Medium, and High-Risk profiles based on:

Geographic Risk

Transactions involving jurisdictions identified by the FATF as high-risk or under increased monitoring.

Service Risk

High-intensity scrutiny for services involving "High-Value Assets," including property acquisition, corporate restructuring, and repatriating ancestral funds.

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 legal 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 to prevent deepfake or synthetic identity fraud.

For Legal Entities

Certificate of Incorporation, Memorandum of Association (MoA), and identification of the Ultimate Beneficial Owner (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)

For all transactions exceeding £5,000 (or the INR equivalent), IA UK requires documentary evidence of the origin of capital to ensure it is derived from legitimate economic activity.

5. Enhanced Due Diligence (EDD) Protocols

5.1 Politically Exposed Persons (PEPs)

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

5.2 High-Value Litigation

Cases involving significant financial claims (e.g., recovery of large ancestral estates) are subject to continuous monitoring of fund movements.

6. The Integrated Escrow & Financial Monitoring

6.1 Escrow Vigilance

All professional fees processed through the IA UK Escrow Facility are monitored for "Structuring" (breaking large payments into small amounts) and "Third-Party Payments" (where the payer is not the contracted client).

6.2 Prohibited Payment 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 Proceeds of Crime Act, any transaction or behaviour deemed "suspicious" will be documented by the MLRO.

7.2 Tipping-Off

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

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, as the jurisdiction dictates.

8. Data Retention and Archival

8.1 Record Integrity

All KYC/CDD/EDD records, transaction logs, and internal compliance memos are retained for a period of 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.

9. Appointment of Compliance Officers

9.1 MLRO

The Board of Indian Attorneys Ltd designates a Money Laundering Reporting Officer (MLRO) with sufficient seniority and authority to challenge business decisions on compliance grounds.

9.2 Training

All staff must complete an annual AML/CTF certification module focused on "Red Flag" identification in the UK-India legal corridor.

10. Audit and Review

10.1 Independent Testing

IA UK shall subject its AML framework to an independent compliance audit every 18 months to ensure the efficacy of our AI screening tools and manual controls.

Key Regulatory References

Money Laundering Regulations 2017 (MLR 2017)

Proceeds of Crime Act 2002 (POCA)

Economic Crime and Corporate Transparency Act 2023

Prevention of Money Laundering Act 2002 (PMLA) - India

FATF Recommendations & Grey List Monitoring

UK National Crime Agency (NCA) SAR Regime