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<h1>Banks under PMLA can impose short suspicion-based debit freezes, but indefinite holds without action breach Article 300A</h1> Kerala High Court held that banks, as PMLA 'reporting entities' regulated by RBI's KYC/AML framework, possess a limited implied power to impose immediate, suspicion-based debit freezes on accounts without prior notice when reasonable grounds indicate cyber fraud, money laundering, or illegal activity. Such power derives from 'appropriate action' and enhanced monitoring obligations, despite no express statutory freezing provision. However, indefinite freezing without law enforcement action violates Article 300A. The Court judicially prescribed a time-bound protocol: prompt notice to the customer, mandatory intimation to cyber police/authorities, consideration of the customer's explanation, a maximum three-month freeze absent statutory orders, and compulsory de-freezing thereafter. RBI was directed to frame a formal SOP.
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