indianattorneys.uk@gmail.com
+44 7307 301473
Book a Consultation

Anti-Money Laundering Policy

Indian Attorneys (IA)
Effective Date: 01/04/2025

1. Introduction

Indian Attorneys (IA) is committed to conducting business in accordance with all applicable laws and regulations related to Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) in the jurisdictions in which it operates primarily in the United Kingdom and India. IA recognises the global threat posed by money laundering and is determined to take all responsible steps to prevent its services from being misused for illicit purposes.

This policy sets out the principles and practices to ensure that IA complies with:

  • 1.1 The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 in the United Kingdom
  • 1.2 The Prevention of Money Laundering Act (PMLA), 2002 in India
  • 1.3 Guidance from the Financial Conduct Authority (FCA), HMRC and other relevant regulatory authorities

2. Scope and Applicability

This policy applies to all stakeholders associated with IA, including but not limited to:

  • 2.1 Employees and contractors based in the UK
  • 2.2 Freelance legal consultants
  • 2.3 Verified Indian law firms and individual practitioners listed on the IA platform
  • 2.4 Clients using the platform to access legal services related to Indian jurisdictions

It encompasses all services offered via IA's digital platform, including lawyer-client matching, document submission, communication tools, and legal advisory functions.

3. AML Commitment and Objectives

  • 3.1 Prevent the platform from being used to facilitate money laundering or the financing of terrorism
  • 3.2 Identify and verify all clients and service providers before establishing a relationship (KYC/CDD)
  • 3.3 Apply enhanced due diligence (EDD) to high-risk individuals or transactions
  • 3.4 Maintain appropriate records of all AML-related processes and transactions
  • 3.5 Report suspicious activities in a timely and lawful manner
  • 3.6 Educate relevant personnel and ensure continuous compliance through training and audits

4. Know Your Customer (KYC) & Customer Due Diligence (CDD)

Before onboarding a client or legal service provider, IA will conduct a detailed KYC process. This includes:

4.1 For NRI Clients:

  • 4.1.1 Government-issued identification (e.g., passport)
  • 4.1.2 Proof of residential address (e.g., utility bills, bank statement within last 3 months)
  • 4.1.3 Source of funds(for transactions exceeding £5,000 or as determined under risk-based screening)

4.2 For Lawyers / Law Firms:

  • 4.2.1 Bare Council ID or license to practice in India
  • 4.2.2 Government issued photo identification
  • 4.2.3 Proof of business registration or Income Tax Returns (ITR) where applicable
  • 4.2.4 KYC of designated point of contact, if law firm

Where necessary, IA may rely on reputable third-party service providers to carry out identity verification under written agreements and oversight.

5. Enhanced Due Diligence (EDD)

EDD measures will be applied in the following scenarios:

  • 5.1 Clients or lawyers from high-risk jurisdictions
  • 5.2 Politically Exposed Persons (PEPs) or individuals with known affiliations to high-risk entities
  • 5.3 Complex or unusually structured transactions
  • 5.4 Use of third-party remittances or non-traditional payment systems (e.g., crypto assets)

EDD procedures include but are not limited to additional identity verification, source of wealth documentation, and senior management approval prior to onboarding or proceeding with transactions.

6. Risk-Based Approach

IA adopts a risk-based approach to AML compliance, tailoring its controls based on:

  • 6.1 Geographic risk – prioritising scrutiny in high-risk countries or regions
  • 6.2 Client risk – evaluating client type, background, and historical behaviour
  • 6.3 Service risk – assessing vulnerability of specific legal services to abuse (e.g., property transactions or inheritance settlements)
  • 6.4 Transaction risk – examining frequency, size, and structure of financial transactions

Risk categories (Low, Medium, High) guide the level of diligence and monitoring required.

7. Ongoing Monitoring

IA will monitor:

  • 7.1 All client-lawyer interactions and payment behaviours
  • 7.2 Repeat use of high-risk legal services
  • 7.3 Updates to client identification documents or regulatory status
  • 7.4 Adverse media or regulatory notices affecting users or law firms

Automated alerts and manual reviews will be conducted periodically to ensure risk controls remain effective.

8. Suspicious Activity Reporting (SAR)

IA maintains a zero-tolerance policy for suspicious or fraudulent activities. Any employee or partner who identifies suspicious behaviour must promptly report it to the appointed Money Laundering Reporting Officer (MLRO).

The MLRO is responsible for:

  • 8.1 Investigating internally and maintaining full records
  • 8.2 Making a formal Suspicious Activity Report (SAR) to the UK National Crime Agency (NCA) or relevant Indian authority
  • 8.3 Deciding on appropriate action (e.g., account freeze, lawyer delisting)

All SARs and supporting documents will be handled confidentially and stored securely.

9. Record Keeping

IA will retain all AML-related documents and records for a minimum of five (5) years after the end of a client or lawyer relationship, including:

  • 9.1 Copies of identity verification documents
  • 9.2 Communication and transaction records
  • 9.3 Internal decisions and SARs
  • 9.4 Risk assessments and compliance logs

These records will be securely stored in compliance with the UK Data Protection Act 2018 and UK GDPR.

10. Training and Awareness

IA provides regular training to all relevant personnel, including:

  • 10.1 AML principles and responsibilities
  • 10.2 Client and transaction risk indicators
  • 10.3 Proper use of IA's verification systems and compliance workflows
  • 10.4 Reporting obligations and escalation procedures

Training will be updated annually or as regulations change.

11. Appointment of MLRO (Money Laundering Reporting Officer)

IA designates an MLRO responsible for the implementation and oversight of this AML policy. The MLRO acts as the central point for reporting and liaising with external authorities.
Reporting Line: Directly to the Founder / Board

12. Policy Breaches and Disciplinary Action

Any employee or contractor found in breach of this AML policy may face disciplinary action, including termination. Serious breaches may be reported to law enforcement and regulatory bodies for prosecution.

Lawyers or law firms engaged in suspicious or non-compliant activity may be permanently removed from the platform.

13. Policy Review

This AML Policy will be reviewed at least once annually, or earlier if:

  • 13.1 There is a change in UK or Indian AML regulations
  • 13.2 New service models or payment systems are introduced
  • 13.3 Significant changes occur in the company's operational risk profile