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Renewed focus on Liberty - Delhi High Court upholds Constitutional Safeguards on Bail under PMLA

Securing bail under the Prevention of Money Laundering Act, 2002 (“PMLA“), is challenging due to the high threshold for bail stipulated by the Act. Section 45 of the PMLA stipulates that bail may be granted to an accused in a money laundering case only if two conditions are met: first, the Public Prosecutor must be given the opportunity to oppose the bail application; second, there must be prima facie satisfaction that the accused has not committed the offence and is not likely to commit any offence while on bail. It is frequently contended that these twin conditions pose a significant challenge to the prevailing legal principle in criminal jurisprudence that “bail is the rule and jail is the exception”. The Hon’ble Supreme Court has observed that the twin conditions challenge an accused’s right to liberty under Article 21 of the Constitution[1].

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The Prevention of Money Laundering Act, 2002 (“PMLA”), is a comprehensive law, dealing with aspects of money-laundering, attachment of proceeds of crime, adjudication, and confiscation thereof. The “proceeds of crime” is the fulcrum of the offence of money-laundering under the PMLA and all actions taken by the Enforcement Directorate (“ED”) under the PMLA invariably revolve around it. Accordingly, the definition of proceeds of crime under Section 2(1)(u) of the PMLA is of immense relevance. In terms of Section 2(1)(u) of the PMLA, “any property derived or obtained… by any person as a result of criminal activity relating to a scheduled offence…” is regarded as proceeds of crime. As held by the Hon’ble Supreme Court in Vijay Madanlal Choudhary & Ors. v. Union of India & Ors.[1] (“Vijay Madanlal”), the expression “derived or obtained” is indicative of a criminal activity, relating to a scheduled offence, already accomplished. The commission of a scheduled offense, whether registered with the jurisdictional police or under review by a competent forum through a complaint, constitutes the legal basis for any investigation conducted under the PMLA.

Continue Reading Shifting Paradigms in PMLA Jurisprudence: Madras High Court reopens settled principles of Automatic Quashing of PMLA Proceedings
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Introduction

Section 9 of the Arbitration and Conciliation Act 1996 (“Arbitration Act”)[1] deals with the powers of courts to grant interim reliefs, before or during arbitral proceedings or at any time after the making of the arbitral award but before it is enforced, to parties in order to safeguard the subject matter of the arbitration. Once a court has passed an order under Section 9(1)(ii), i.e., an order of “any interim measure of protection”, then arbitral proceedings[2] must be commenced within ninety (90) days “from the date of such order” or “within such further time as the court may determine” as provided under Section 9(2). The bar on the civil court’s jurisdiction under Section 9(3) is applicable to instances where the arbitral tribunal has already been constituted. In this article, we have restricted our analysis to examining the scope and ambit of Section 9(2) of the Arbitration Act and adherence to the timeline.

The Arbitration and Conciliation (Amendment) Act 2015 inserted Subsections (2) and (3) to Section 9 of the Arbitration Act. Before the amendment and inclusion of the timeline under Section 9(2), the Supreme Court (“SC”), in its 1999 judgment reported in Sundaram Finance v. NEPC India Pvt. Ltd., had adjudicated on the timeline to commence arbitral proceedings vis-à-vis Section 9 of the Arbitration Act. The SC ruled that when a party seeks interim measures of protection under Section 9, it implicitly accepts that a final and binding arbitration agreement exists and that a dispute referable to the arbitral tribunal has arisen.[3] Thus, when a Section 9 petition is filed before the commencement of arbitral proceedings, the applicant must demonstrate manifest intention to take effective steps in commencing the impending arbitral proceedings. A notice under Section 21 of the Arbitration Act may be sufficient to establish the manifest intention to have the dispute referred to an arbitral tribunal.

However, for a scenario where a party seeks relief under Section 9 even prior to issuing a notice of arbitration, the SC held that the relevant court would have to be satisfied about the existence of a valid arbitration agreement and the applicant’s intention to take the dispute to arbitration. The court may also pass a conditional order under Section 9 directing the applicant to such terms as it deems fit with a view to ensure that the applicant takes effective steps for commencing the arbitral proceedings.

Ambiguity about date of commencement of 90-day period under Section 9(2) of the Arbitration Act

The twin requirements – (i) manifest intention to arbitrate and (ii) effective steps being taken to commence arbitral proceedings after receiving “any interim measure of protection” under Section 9 Arbitration Act – must be fulfilled; however, ambiguity exists about (i) whether “any interim measure of protection” under Section 9(1)(ii) includes both ad interim and interim orders and (ii) whether the 90-day period under Section 9(2) commences from the date of the ad interim or the final interim order. The wordings of Section 9(2) of the Arbitration Act do not distinguish between interim or ad interim orders and broadly state that “(2) Where, before the commencement of the arbitral proceedings, a Court passes an order for any interim measure of protection under sub-section (1), the arbitral proceedings shall be commenced within a period of ninety days from the date of such order or within such further time as the Court may determine.”

In Information TV Private Limited v. Jitendra Dahyabhai Patel 2024 SCC OnLine Del 810, the Delhi High Court (“DHC”) adjudicated upon a petition under Section 11(6) of the Arbitration Act for the appointment of an arbitrator. The Respondent, among other things,alleged that since 2021 the Petitioner was sitting on an interim order the Court had granted in a Section 9 petition the Petitioner had sought and had chosen to invoke arbitration only in 2023. Thus, the Petitioner was barred from approaching the Court under Section 9(2) of the Arbitration Act for not demonstrating a clear and manifest intention to arbitrate. The DHC, relying on Sundaram Finance held the following: “…The Question as to when arbitral proceedings have to be commenced after filing a section 9 petition is no longer res integra and has been decided way back in 1999 by the Supreme Court in Sundaram Finance…12. In terms of the said judgment, there are only two components that need to be looked at, firstly that there has been an intention to arbitrate the disputes and secondly, effective steps have to be taken to commence the arbitral proceedings.”[4] 

The DHC held that the petition was not barred for other reasons pertaining to the timelines under Section 11(6) of the Arbitration Act. However, with regard to the order passed under Section 9, it held that such order (i) continues even if a Section 21 notice is issued and (ii) remains in effect until the conclusion of the arbitral proceedings.[5]

In Ezen Aviation Limited v. Big Charter 2021 SCC OnLine Del 5369, the DHC adjudicated on two appeals Ezen sought challenging two interim orders the Single Judge under Section 9 of the Arbitration Act had passed in favour of Big Charter on the ground that Big Charter had failed to initiate arbitral proceedings within the statutory period as stipulated under Section 9(2). The Court observed that “… the respondent is yet to take steps to have its claims adjudicated through arbitration…Section 9(2) of the Act requires that where a Court passes an order for any interim measure or protection, the arbitral proceedings shall be commenced within a period of ninety days from the date of such order or within such time as the Court may determine. This sub-Section was introduced by the Arbitration and Conciliation (Amendment Act), 2015. In Sundaram Finance Ltd. (Supra), the Supreme Court, while holding that an application under Section 9 of the Act may be filed before the commencement of the arbitral proceedings, observed that the party invoking such jurisdiction must satisfy the Court that it intends to take the disputes to arbitration. While passing such an order and in order to ensure that effective steps are taken for commencement of arbitral proceedings, the Court can pass a conditional order to put the applicant to such terms, as it may deem fit with a view to see that effective steps have been taken by the applicant for commencing the arbitral proceedings.” [6] Thus, the Court allowed the appeal sought by Ezen and held that the interim orders passed under Section 9 of the Arbitration Act were set aside as the statutory period for initiation of arbitral proceedings had expired[7] and Big Charter had taken no action under Section 9(2).

On the other hand, the Bombay High Court in the case of Aditya Birla Finance v. Airen Metals, COMM. ARB.PET. (L) No. 6754 of 2021 sought to distinguish between ad interim and interim orders qua the applicability of the 90-day timeline under Section 9(2) Arbitration Act. The Court observed the following: “This submission is made on the strength of section 9(2) of the Arbitration Act. I find this argument also to be without any merit. What has been granted by this Court on 1st April, 2021 are not interim reliefs but ad-interim reliefs. This petition was thereafter kept for further reliefs and has not been disposed of. In such circumstances, I do not think that Section 9(2) of the Arbitration Act would be of any assistance to the Respondent No.1 – Company…”[8] On the contrary, in the case of Borivali Anamika Niwas Coop Hsg Soc Ltd. v. Aditya Developers and Ors. 2019 SCC OnLine Bom 10718, the Bombay High Court held that “Section 9(2) Arbitration Act requires that after an interim order is made, arbitral proceedings must commence within 90 days from the date of such order or within further time as the Court may permit. No application for any enlargement of time was ever made. It was for this reason that on 4th November 2019 I vacated the ad-interim relief previously granted in favour of the society.”[9]. 

Additionally, along the lines of the Bombay High Court order in Borivali Anamika, in the case of Manosh Elias Constructions Pvt. Ltd. v. Manual John 2018 SCC OnLine Ker 6383, the Kerala High Court adjudicated on the applicability of Section 9(2) timelines to ad interim orders and held “that the limitations stipulated under sub-section (2) of Section 9 will squarely apply even with respect to an ad-interim order passed in an original petition filed under Section 9(1)”.[10]

Consequence of non-initiation of arbitration within the statutory 90-day period

The wordings of Section 9(2) of the Arbitration Act reflect no express statutory consequences and/or penalties on the failure to initiate arbitration within the 90-day period. This is also on account of the words, “within such further time as the court may determine”. Thus, while an automatic vacation of an interim order of protection under Section 9(1) cannot be presumed, the courts have set aside such orders on a case-to-case basis. In fact, failure to initiate arbitration within the 90-day period/taking of effective steps could demonstrate the applicant’s lack of intent to arbitrate. This, too, after securing an interim measure of protection in its favour and indicating inequitable conduct.

In Shanti Dey v. Suvodeep Saha, 2016 SCC OnLine Cal 6251,[11] the Calcutta High Court held that the use of the words“or within such further time as the Court may determine”makes it clear that the time stipulation of ninety (90) days is directory and, accordingly, the Court might extend the time for commencement of arbitral proceedings. Further, it also held that there is no penalty for default in the commencement of arbitral proceedings within ninety (90) days. However, Section 9(2) cannot be interpretated in a manner that expands any situation not legislatively contemplated.[12]

Conclusion

Before the amendment to Section 9(2) of the Arbitration Act in 2015 and the insertion of the 90-day timeline, a party armed with an interim order of protection under Section 9(1) of the Arbitration Act had to (i) demonstrate a manifest intention to arbitrate and (ii) take effective steps to commence arbitral proceedings (such as a notice under Section 21 of the Arbitration Act). However, some judgments made after the amendment suggest that parties are required to adhere to the 90-day timeline from the date of grant of any interim order (both ad interim and interim orders) and that courts may vacate such interim orders granted if parties do not adhere to the timeline. Different high courts seem to have taken different stances, depending on the facts and circumstances of each case and on the nature (directory/mandatory) of the timeline under Section (2). It would be interesting to see if the issue travels to the SC and how it deals with the same. Nonetheless, in our view, keeping in mind the aim and intent of arbitration, the 90-day period should be made mandatory, and a party that has received any interim order/protection must take effective steps to initiate arbitration within the stipulated time frame.

[1] 9. Interim measures, etc., by Court. —

(2) Where, before the commencement of the arbitral proceedings, a Court passes an order for any interim measure of protection under sub-section (1), the arbitral proceedings shall be commenced within a period of ninety days from the date of such order or within such further time as the Court may determine.

[2] In accordance with Section 21 of the Arbitration Act, arbitral proceedings commence upon the issuance of a notice of arbitration.

[3] Sundaram Finance v. NEPC India Pvt. Ltd. (1999) 2 SCC 479, Para 19

[4] Information TV Private Limited v. Jitendra Dahyabhai Patel 2024 SCC OnLine Del 810, para 11 and 12

[5] Unless otherwise stated by the courts in its order.

[6] Ezen Aviation Limited v. Big Charter 2021 SCC OnLine Del 5369, para 8, 9, 10

[7] See also, SIPL Lifestyle Private Limited v. Vama Apparels (India) Private Limited and Another. (2020) 267 DLT 467. The DHC @para 27 held that while previously no limitation was fixed for commencement of arbitration after seeking interim reliefs under S.9. In the amended S.9, the arbitral proceedings must begin within 90 days after interim order is passed.

[8] Aditya Birla Finance v. Airen Metals, COMM. ARB.PET. (L) No. 6754 of 2021, para 22

[9] Borivali Anamika Niwas Coop Hsg Soc Ltd. v. Aditya Developers and Ors. 2019 SCC OnLine Bom 10718, para 5

[10] Manosh Elias Constructions Pvt. Ltd. v. Manual John 2018 SCC OnLine Ker 6383, para 7

[11] Shanti Dey v. Suvodeep Saha, 2016 SCC OnLine Cal 6251

[12] Chaudhary Avadhesh Kumar v. Volleyball Federation of India 2017 SCC OnLine Mad 19117, para 41

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Introduction

The Supreme Court of India (“SC”) in its landmark decision in Arif Azim Co. Ltd. v. Micromax Informatics FZE[1] (“Arif Azim”)[2] has once again reiterated the distinction between ‘seat’ and ‘venue’ in an arbitration agreement and its jurisdictional implication. The judgment addresses the contentious issue of whether a location designated in an arbitration agreement serves merely as ‘venue’ (a place where proceedings may occur) or as juridical ‘seat’ (which grants a court jurisdictional oversight). This distinction has immense implications, especially for cross-border commercial agreements, where different interpretations can lead to divergent legal outcomes.

Continue Reading Decoding Supreme Court’s Landmark Decision on ‘Seat’ vs. ‘Venue’ in Arbitration
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From Harbour to Hardships? Understanding the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 – Part IV

Introduction

This is in continuation to the series on the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“2021 Rules”). This article examines the Rule[1] that proposed the creation of a fact-checking unit (“FCU”) and the subsequent legal challenge before the Bombay High Court, which has led to this specific rule being declared unconstitutional.

Continue Reading From Harbour to Hardships? Understanding the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 – Part IV
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Revisiting Unilateral Arbitrator Appointments: The Supreme Court’s New Stance on Fairness and Equality

Introduction

Party autonomy is undoubtedly a cornerstone of arbitration proceedings, allowing parties substantial freedom to shape the contours of their dispute resolution process. This freedom extends to choosing arbitrators and defining procedural rules, reflecting a central appeal of arbitration over litigation. However, this autonomy has limits, particularly where it intersects with the mandatory provisions of the Arbitration and Conciliation Act, 1996 (“Arbitration Act / Act”), designed to uphold fairness, impartiality and transparency.

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Ripple Effect of Sanctions: How US Measures against Russia affect Indian Businesses

Background

The ongoing tensions surrounding the Russia-Ukraine conflict have led to significant geopolitical shifts, particularly in the realm of international sanctions. In response to Russia’s military invasion of Ukraine, the United States (U.S.) had implemented a series of sanctions to curtail Russian influence and capabilities. A pivotal moment in this effort was the issuance of Executive Order 14024 (“EO 14024”) on April 15, 2021, by President Joe Biden.

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Is mere possession of proceeds of crime sufficient for trigerring PMLA?

Introduction:

A recent decision rendered by the Madras High Court in S. Srinivasan v. The Assistant Director, Directorate of Enforcement, Chennai[1], has held that being in possession of the proceeds of crime and claiming it to be untainted property can independently be perceived as money laundering under Section 3 of the Prevention of Money Laundering Act, 2002 (“PMLA”).

Although the said decision is in line with the principles previously enunciated by various courts while interpreting the PMLA provisions, such a simple interpretation may possibly lead to unintended situations. The primary reason being that anyone who is merely in possession of proceeds of crime without any genuine knowledge or any involvement therein can be prosecuted under PMLA. This perspective may prove to be counterproductive to the principle of presumption of innocence in criminal law.

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Navigating the Crypto Maze: Delhi HC expands scope of predicate offences under PMLA

Introduction

A single judge bench of the Hon’ble High Court of Delhi delivered a significant ruling in the matter of Adnan Nisar v. Directorate of Enforcement and other connected matters[1], on September 17, 2024, holding that an offence committed in a foreign country can be classified as Predicate Offence, under the Prevention of Money Laundering Act, 2002, provided it has cross-border crime implications and the proceeds have travelled back to the Indian territory. 

Factual Background

Three bail applications were filed before the Court under Section 439 of the Code of Criminal Procedure, 1973 (“CrPC”), and Section 45 of the Prevention of Money Laundering Act, 2002 (“PMLA”), for grant of regular bail. Charges were registered under Section 3 and 4 of the PMLA. The petitioners (collectively referred to as the “Co-accused”), were implicated in a cryptocurrency fraud, which was uncovered following a complaint by a victim in the United States of America (“USA”), who reported significant financial losses to the measure of $527,615.45.

The victim had reported that certain cryptocurrencies were fraudulently transferred from their ‘Ledger Hardware’ wallet in August 2022. Investigations revealed that these transactions traced back to Vishal Moral’s WazirX trading account, uncovering a network of individuals, inter alia the other two accused, involved in orchestrating the fraud. Following a Mutual Legal Assistance Request (“MLAR”) from the US Department of Justice, detailing accusations of wire fraud and money laundering against Mr. Moral, the Enforcement Directorate (“ED”) commenced its investigations.

During searches conducted at Mr. Moral’s residence under Section 17 of the PMLA, the ED seized electronic devices and cash amounting to INR 25,60,000. It was also discovered that he had used malware to compromise the victim’s wallets, while engaging in schemes to convert the stolen cryptocurrencies into cash for creation of immoveable assets. Accordingly, the ED concluded that the offenses investigated by the US Department of Justice corresponded with Section 75 of the Information Technology Act, 2000 (“IT Act”), as well as Sections 420 and 424 of the Indian Penal Code, 1860 (“IPC”), leading to the arrest of the accused, under Section 19 of the PMLA.

Contention of the parties

On behalf of one of the petitioners, it was contended that the proceedings initiated by the ED under Sections 3 and 4 of the PMLA were contrary to law and that the Special Court had taken mechanical cognizance of the complaint filed by the ED without knowledge of either the victim’s identity or the MLAR. It was further asserted that the scope of the MLAR was limited to ensuring that the WazirX accounts mentioned therein were seized and frozen; however, the ED had overreached by initiating a separate investigation based on an offense committed abroad. Reliance was placed on judgments such as Vijay Madanlal Choudhary v. Union of India[2] (“Vijay Madanlal”) and P. Chidambaram v. Directorate of Enforcement[3] to argue that prosecution under the PMLA necessitates clear establishment of a scheduled offense within Indian jurisdiction; otherwise, charges cannot be sustained. Counsel for Co-accused supported these submissions, arguing further that the proceedings initiated under Sections 3 and 4 of the PMLA were flawed and that the ED had exceeded its authority by investigating an offense that had occurred outside India.

Conversely, on behalf of the ED, it was asserted that a scheduled offence was evident in this case because the investigated offence corresponded to offences under the IT Act and the IPC. The counsels for ED provided proof by way of blockchain analysis to demonstrate that the stolen cryptocurrency had in fact been transferred into Mr. Moral’s accounts. ED stressed upon the elaborate roles played by the other Co-accused in orchestrating such a fraud and Mr. Moral’s statements during interrogation under Section 50 of the PMLA were inconsistent.

ED’s arguments in detail

Firstly, counsels for the ED relied on both the MLAR and the “Treaty Between the Government of India and the US on Mutual Legal Assistance in Criminal Matters” (“Treaty”) to contend that an investigation across borders is a necessary corollary to filing a complaint, thereby triggering relevant provisions under the PMLA. Secondly, reliance was placed on the judgement of Vijay Madanlal to assert that PMLA is a sui generis legislation against money laundering; thus, it may be activated when an offense has been committed in a contracting state and its proceeds have crossed into India. Thirdly, an arrest is an inherent power during investigations, aimed at collecting evidence[4]. Lastly, addressing claims of jurisdictional overreach, it was argued that since proceeds had entered Indian jurisdiction, money laundering would be deemed to have been committed in India, according to Section 2(2) of PMLA, which allows for interpretation of corresponding laws to be inclusive of foreign law[5]. In conclusion, it was emphasised that the ED was solely investigating money laundering offenses within its jurisdiction rather than any predicate offense.

Observations of the Court  –

Offence under foreign law as scheduled offence

    While the PMLA confers extraterritorial jurisdiction to the Directorate of Enforcement where the offence has cross-border implications, the Delhi High Court in this judgement clarified that for the ED to take action, there must be a corresponding scheduled offence recognised under Indian law, even if it were committed in foreign territories. The Court opined that crimes committed outside India can be prosecuted under the PMLA if such offence corresponds to those under Part C of the Schedule to PMLA (“Schedule”). An offence is classified as having ‘cross border implications’ under Section 2(1) (ra) of the PMLA if: (i) it was committed outside India and would constitute an offence under Part A-C of the Schedule and the proceeds have been transferred to India; or (ii) if the scheduled offence occurred in India and the proceeds travelled to a place outside. On a conjoint reading of Part C of the Schedule with Sections 2(1)(ia), 2(1)(ra) and 2(2) of the PMLA, the Court concluded that offences in Part C of the Schedule may be treated as predicate offences, if they have any cross-border implications. The Court noted that the definition of ‘corresponding law’ had been inserted by way of a 2013 amendment to the PMLA, which clarifies that it would mean any law of any foreign country dealing with such offences that may correspond to scheduled offences under the PMLA.

    Basis the present facts, the Court noted that while a predicate offence can only be tried as per the corresponding US Laws and Section 44(1)(c) of the PMLA would have no bearing on the situation, there was a movement of proceeds of crime into India, which established significant links to the offence committed in the US and therefore the ED must be permitted to investigate and prosecute the standalone offence under the PMLA.

    MLAR and Powers of the Authority under the Act

    The Court examined the intent behind the incorporation of Chapter IX of the PMLA, relying on Article 1 of the Treaty, which binds Contracting Parties to provide mutual assistance in various forms to the ‘widest measure’, including (i) taking testimony; (ii) providing records; (iii) executing search and seizure requests; and (iv) assisting in forfeiture proceedings. The Court specifically observed that the MLAR issued in the present matter referenced the Treaty, while seeking assistance to obtain evidence on criminal investigations. Upon reviewing Section 60 of the PMLA, the Court concluded that while a contracting state may limit its request to attachment or freezing properties in India, executing such requests necessitates inquiry or investigation. The Court upheld that arrest is part of investigatory procedures and that the ED can arrest an accused once a case is lodged under Sections 3 and 4 of the PMLA. Most importantly, if the ED is satisfied that an investigated offence corresponds to scheduled offences under the PMLA and the proceeds have entered India, it can register an offence under Sections 3 and 4 without needing an MLAR. The Court also observed that although the predicate offence occurred in the US, the proceeds travelled to India, making it a standalone offence under the PMLA, thus requiring no sanction mandated by the proviso to Section 188 of the CrPC.

    Concluding, the Court noted the lack of any material on record to establish even prima facie that the alleged predicate offence corresponds to the offences mentioned in the Schedule to the PMLA.  It observed that in the absence of reasonable grounds to believe that the Accused were not guilty, as per Section 45 of the PMLA, the petitioners had made out a sufficient case for the grant of regular bail and disposed off the applications accordingly.

    Conclusion

    This judgement of the Delhi High Court is a significant step in the development of PMLA jurisprudence. Firstly, it reaffirms Vijay Madanlal to clarify that for the prosecution of any offence under the PMLA, a scheduled offence corresponding to the Indian law must be established, despite the jurisdiction of their commission. If the proceeds of crime to such offence have made their way to India, the ED shall be empowered to investigate under the PMLA, including making arrests and/ or seizing arrests during the course of its investigation, while also strengthening the authority bestowed onto the ED to act on cases where the proceeds of crime have entered India, inspite of the commission of a foreign offence. Lastly, the judgement reinforces the need for and importance of international cooperation in combatting financial offences/ crimes. The decentralised and borderless nature of cryptocurrencies highlights the necessity for more robust international collaboration. In light of the same, the present judgement may precedentially influence how assistance is extended to foreign investigatory bodies in similar scenarios of prosecution.

    [1] Bail Application No. 3056/2023; Bail Application No. 3168/2023; and Bail Application No. 3529/2023.

    [2] 2022 SCC OnLine SC 929.

    [3] (2019) 9 SCC 24.

    [4] H.N. v. State (Delhi Administration), 1954 2 SCC 934.

    [5] Ahsan Ahmad Mirza & Ors. v. Enforcement Directorate & Anr., 2019 SCC OnLine J&K 1026.

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    Time to harmonize AML control systems for global, commercial Indian companies

    Introduction

    For many global organisations, finding the right balance between having global, unified compliance programs, and the need to address local legal and compliance risks, is a challenge. In this blog, we will address the challenge that money laundering and related issues presents to Indian companies operating in Europe.

    Continue Reading Time to harmonize AML control systems for global, commercial Indian companies