In plain words: professionals who handle clients' money and transactions now face real PMLA exposure — both compliance duties and the risk of being drawn in if they knowingly assist wrongdoing.
Two kinds of exposure
For professionals, PMLA risk comes in two forms: compliance obligations where they are treated as covered persons for certain activities, and criminal exposure if they knowingly help a client launder proceeds of crime.
When professionals are covered for compliance
Notifications have brought specified activities — such as carrying out certain financial transactions on behalf of clients (managing money, creating or managing entities, dealing with certain assets) — within PMLA obligations for professionals like CAs, CS and cost accountants. Where covered, the usual duties apply: client due diligence, record-keeping and reporting.
The criminal risk: 'knowingly assisting'
Separately, a professional who knows funds are tainted and helps structure, disguise or move them can attract Section 3 liability. The protection is genuine, arm's-length professional work — the danger is crossing into knowing facilitation.
How to protect yourself
- Do proper client due diligence — know your client and their source of funds.
- Keep clean records of your engagement and advice.
- Refuse suspicious instructions and do not lend your name or certifications to disguise anything.
- Comply with any reporting obligations that apply to your activities.
- Take advice if a client's affairs raise red flags.
Frequently asked questions
Are CAs now reporting entities? For certain notified activities on behalf of clients, professionals can be covered — check the current notifications.
Can I be prosecuted for a client's laundering? If you knowingly assisted — genuine professional work is different.
What is my best protection? Due diligence, clean records, and refusing suspicious instructions.
How Vakil Help Desk helps
Vakil Help Desk advises and defends clients at every stage of a PMLA matter — summons, attachment, arrest, bail and trial. If the ED has contacted you or you fear action, we can help you protect your position.
This article is for general legal awareness, not individual legal advice. PMLA proceedings move fast and the law is evolving through court rulings and notifications, so the right step depends on your facts and the current position. If you have received an ED notice or fear action, consult a lawyer immediately.