On the morning of 1 March 2024 FIU-IND published an order against Paytm Payments Bank imposing a monetary penalty of Rs 5,49,00,000. The order ran to several pages. It itemised specific failures in CDD, in STR filing timeliness, in beneficial-ownership identification and in internal AML governance. It named the sections of the Act and the specific sub-rules under PML Rules 2005 that had been breached. It was signed by the Director, FIU-IND. It was not an ED prosecution. Paytm Payments Bank was not accused of money laundering. It was penalised for failing to run its AML programme to the standard the Rules require.
Every Principal Officer must understand that distinction, because misreading it leads to one of two bad outcomes. The first bad outcome is thinking "we are not committing money laundering, so FIU-IND will not come". FIU-IND does not come looking for money launderers. It comes looking for Reporting Entities whose programmes have failed. The second bad outcome is thinking "a fine is a cost of doing business, we can pay and move on". The published order lives on the FIU-IND website in perpetuity, it becomes exhibit material in sectoral regulator proceedings, it is a reputational injury and it marks the entity as a priority inspection target.
Two agencies, two different jobs
FIU-IND is the Financial Intelligence Unit. It is constituted under the Ministry of Finance. Its primary job is to receive, process, analyse and disseminate information relating to suspicious financial transactions. It operates FINnet 2.0 as the collection and dissemination platform. It issues the AML/CFT Guidelines that interpret Rule 9 and Rule 3 for specific Reporting Entity cohorts. And it exercises the Section 13 PMLA [L4-C1] power to inquire into and penalise Reporting Entity compliance failures.
The Enforcement Directorate is the law-enforcement agency. It is also under the Ministry of Finance, but its remit is Section 3 and Section 4 PMLA [L4-C2], the actual offence of money laundering. It registers Enforcement Case Information Reports (ECIRs), it exercises the Section 5 provisional attachment power [L4-C3], it conducts Section 17 searches and Section 19 arrests, it summons under Section 50, and it files prosecution complaints before the Special Courts under Section 44.
Reporting Entities interact with FIU-IND primarily. They interact with the ED only when the ED comes asking for information about a specific suspect under Section 50, when a Reporting Entity\'s customer is subject to a Section 5 attachment order the entity must comply with, or when an ED investigation reveals that a Reporting Entity systemically facilitated proceeds-of-crime movement. In the ordinary course of operating an AML programme, your counterparty is FIU-IND.
The compliance order ladder of 2024-2025
Four orders from the FIU-IND Director\'s desk anchor the current enforcement reality. Every Principal Officer should read them in full on the FIU-IND website. Here is the shape of each.
Paytm Payments Bank, order dated 1 March 2024, Rs 5,49,00,000 [L4-C4]. The order found systemic failures in verification of identity, in beneficial-ownership identification for business accounts, in STR escalation and in the internal AML policy. The teaching lesson is that a technology-forward platform with scale does not automatically translate into a compliant AML programme. Technology without governance is a bigger exposure, not a smaller one.
KuCoin (Peken Global Limited), order dated 22 March 2024, Rs 34,50,000 [L4-C5]. A smaller order against an offshore VDA SP operating in India without registration. The teaching lesson is that FIU-IND will pursue offshore operators who have Indian customers. Offshore domicile is not protection.
Binance, order dated 19 June 2024, Rs 18,82,00,000 [L4-C6]. The flagship order of the year. The order followed the December 2023 show-cause notice to nine offshore VDA SPs and the MeitY URL blocks. Binance subsequently paid, registered with FIU-IND and resumed operations. The teaching lesson is that the system has teeth, that unregistered operation is finite, and that registration remains available after penalty.
Bybit, order dated 31 January 2025, Rs 9,27,00,000 [L4-C7]. A follow-on to the Binance pattern. Bybit paid and registered. The teaching lesson is that the ladder is predictable: show-cause, inquiry, penalty, registration, resumption. The exits are known.
Add to these the Union Bank of India Order 01/DIR/FIU-IND/2025 dated 8 April 2025, and the twin December 2025 orders against Gandhinagar Nagarik Co-operative Bank and Rajgurunagar Sahakari Bank. The co-op bank orders are important precisely because the co-op cohort has historically assumed lighter scrutiny. FIU-IND has signalled otherwise.
ED statistics for FY 2024-25, in Board-ready form
The ED Annual Report for FY 2024-25 is primary-source reading. The headline numbers are stark. 775 new PMLA investigations were registered in FY 2024-25, taking the cumulative ECIR count to 8,851 as of 31 March 2026. 461 provisional attachment orders were issued, attaching assets worth Rs 30,036 crore, a rise of 44 percent in number and 141 percent in value year on year. The cumulative value under provisional attachment reached Rs 1,54,594 crore as of 31 March 2025. 333 prosecution complaints were filed, taking the cumulative at-trial count to 1,739. And 56 of 60 trial-completed cases ended in conviction, yielding a 93.33 percent conviction rate.
If you brief a Board on enforcement trend, those are the numbers. The combination of a 93 percent conviction rate at the ED end and an active FIU penalty docket at the regulator end is why "AML is for banks" is no longer a credible internal talking point.
Reading an order like a Principal Officer
Every published FIU-IND order follows a pattern. The order recites the Reporting Entity\'s registration status, summarises the inquiry process, identifies the specific sub-provisions breached (which Rule 9 sub-paragraph, which Rule 3 category, which Rule 7 timeline), itemises the quantum of each failure under Section 13(2)(d), aggregates to the final penalty, and sets out directions for remedial action. Read in this frame, every order is a free training document for your own programme.
I keep an "enforcement reading log" that tracks each new order against a four-column template: date, Reporting Entity, specific sub-provisions breached, remedial action we have confirmed in our own programme. Reviewed monthly. The template is at the end of this lesson. By the time the next order lands, you will have internalised the pattern.
FATF 2024 is the slow-moving forcing function
In the background sits the FATF Mutual Evaluation Report on India [L4-C8], adopted at the Singapore Plenary of June 2024 and published on 19 September 2024. India was placed in "regular follow-up", the top tier, with Substantial effectiveness ratings on six Immediate Outcomes and Moderate on five. The first follow-up self-assessment is due in 2027. The Ministry of Finance will pre-empt that review with regulatory tightening on NPO supervision and on ML trial completion metrics. If you are planning your 2027 AML calendar, assume at least one Rule amendment and one FIU-IND guideline refresh driven by the FATF cycle.
Five failure modes practitioners repeat on enforcement
Treating an FIU penalty as "pay and move on". The order survives on the public record. Boards and sectoral regulators read it. Prepare for second-order consequences.
Confusing a Section 13 FIU inquiry with an ED ECIR. The two are different beasts. A Section 13 inquiry can be answered by the Principal Officer with documentation. An ED ECIR needs counsel from the first summons.
Underestimating offshore enforcement reach. Binance and Bybit disposed of that assumption.
Ignoring the FATF review cycle. The 2027 self-assessment will shape the 2026-27 Rules amendments. Build your tracker now.
Not reading published orders. Each order is a template of what not to do, written by the regulator itself. If you are not spending an hour on each new order within thirty days of publication, you are flying blind.
Your artifact from Lesson 4
Build the enforcement reading log with the four columns described above. Pre-populate it with the Paytm, KuCoin, Binance, Bybit, Union Bank, Gandhinagar and Rajgurunagar orders. Save it as Artifact 4 in your capstone workbook. Add a reminder in your calendar to open the FIU-IND compliance orders page on the first Monday of every month and log every new order published since the previous review.