Banks as Gatekeepers: A Critical Analysis of Anti-Money Laundering Obligations and Liabilities of Financial Institutions in India

  • Unique Paper ID: 197929
  • Volume: 12
  • Issue: 11
  • PageNo: 10495-10503
  • Abstract:
  • Money laundering is a systemic challenge to the financial integrity, economic stability and national security of India. Frontline frontline gatekeepers in the anti-money laundering (AML) architecture of India are banks and other financial institutions under the Prevention of Money Laundering Act, 2002 (PMLA). This article looks critically at the statutory requirements that banking firms, non-banking financial firms (NBFCs), securities mediators, and insurance firms have under the PMLA and the 20092023 amendments along with guidelines of the Reserve Bank of India (RBI), Securities and Exchange Board of India (SEBI) and Insurance Regulatory and Development Authority of India (IRDAI). It examines civil and criminal penalties of non-compliance, enforcement authorities of the Enforcement Directorate (ED) and Financial Intelligence Unit-India (FIU-IND), court interpretations of landmark cases, such as Vijay Madanlal Choudhary v. Union of India (2022) and Nikesh Tarachand Shah v. Union of India (2018), and emergent threats of fin The article uses a comparative and doctrinal examination of the critically missing links between procedural and substantive enforcement and suggests specific changes to enhance the AML system in India, which corresponds to the recommendations of the Financial Action Task Force (FATF).

Copyright & License

Copyright © 2026 Authors retain the copyright of this article. This article is an open access article distributed under the Creative Commons Attribution License which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.

BibTeX

@article{197929,
        author = {Anshika Vikram Singh and Dr.Rekha Verma},
        title = {Banks as Gatekeepers: A Critical Analysis of Anti-Money Laundering Obligations and Liabilities of Financial Institutions in India},
        journal = {International Journal of Innovative Research in Technology},
        year = {2026},
        volume = {12},
        number = {11},
        pages = {10495-10503},
        issn = {2349-6002},
        url = {https://ijirt.org/article?manuscript=197929},
        abstract = {Money laundering is a systemic challenge to the financial integrity, economic stability and national security of India. Frontline frontline gatekeepers in the anti-money laundering (AML) architecture of India are banks and other financial institutions under the Prevention of Money Laundering Act, 2002 (PMLA). This article looks critically at the statutory requirements that banking firms, non-banking financial firms (NBFCs), securities mediators, and insurance firms have under the PMLA and the 20092023 amendments along with guidelines of the Reserve Bank of India (RBI), Securities and Exchange Board of India (SEBI) and Insurance Regulatory and Development Authority of India (IRDAI). It examines civil and criminal penalties of non-compliance, enforcement authorities of the Enforcement Directorate (ED) and Financial Intelligence Unit-India (FIU-IND), court interpretations of landmark cases, such as Vijay Madanlal Choudhary v. Union of India (2022) and Nikesh Tarachand Shah v. Union of India (2018), and emergent threats of fin The article uses a comparative and doctrinal examination of the critically missing links between procedural and substantive enforcement and suggests specific changes to enhance the AML system in India, which corresponds to the recommendations of the Financial Action Task Force (FATF).},
        keywords = {Anti-Money Laundering, Customer Due Diligence, Enforcement Directorate, FATF, Gatekeeper Theory, Know Your Customer, PMLA 2002, Reporting Entities, Suspicious Transaction Report, Virtual Digital Assets},
        month = {April},
        }

Cite This Article

Singh, A. V., & Verma, D. (2026). Banks as Gatekeepers: A Critical Analysis of Anti-Money Laundering Obligations and Liabilities of Financial Institutions in India. International Journal of Innovative Research in Technology (IJIRT), 12(11), 10495–10503.

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