PMLA - Maintenace of Records

[Ethirajan Parthasarathy]

Rule 3 of PMLA (Maintenance of Records) Rule 2005 provides for maintenance of records of 7 types of transactions with threshold limit specified therein.

It follows only such transactions have to be reported by “Reporting Entities”

Recent notification has included reporting of certain transactions carried out by CAs on behalf of their client.

I presume CAs are required to report such specified transactions subject to threshold limit specified in Rule 3 above, that too only if transactions are done by cash and for & on behalf of “clients”.

View of experts are solicited

[DR.MARIAPPAN GOVINDARAJAN]

Your views are correct.

AI Summary

Reporting obligations under PMLA extend to chartered accountants for cash transactions carried out on behalf of clients. Rule 3 of the PMLA (Maintenance of Records) Rules, 2005 mandates that reporting entities maintain records and report seven specified transaction types exceeding prescribed thresholds. A recent notification includes certain transactions carried out by chartered accountants on behalf of clients; where those transactions fall within Rule 3 categories, exceed the thresholds and are in cash and executed for and on behalf of clients, the chartered accountant is required to report them as a reporting entity.