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FIU-IND, ED and the compliance order ladder from Paytm to Binance to Bybit

FIU-IND and the Enforcement Directorate are not the same agency and they do not do the same work. One imposes civil penalties on Reporting Entities for AML programme failures. The other prosecutes individuals under the Act for money laundering. This lesson walks you through what each does, how they relate, and dissects the five live compliance orders of 2024-2025 that every Principal Officer must read.

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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.

Every claim in this lesson is cited. Yellow markers like [L1-C1] are clickable. Click any to see the verbatim text of the Section, Rule or judgment we're relying on. Learn how we verify content ›

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Citations
PMLA Act 2002, Section 13 (Powers of Director to impose fine) L4-C1
The Director may, after inquiry, impose a fine on a reporting entity, its designated director on the Board or any of its employees, which shall not be less than ten thousand rupees but may extend to one lakh rupees for each failure.
PMLA Act 2002, Section 3 (Offence of money-laundering) L4-C2
Whosoever directly or indirectly attempts to indulge or knowingly assists or is a party to or is actually involved in any process or activity connected with the proceeds of crime, is guilty of the offence of money-laundering.
PMLA Act 2002, Section 5 (Attachment of property involved in money-laundering) L4-C3
The Director or an authorised officer not below the rank of Deputy Director may, by order in writing, provisionally attach such property for a period not exceeding 180 days.
FIU-IND Compliance Orders, FIU-IND Order Paytm Payments Bank (1 March 2024, Rs 5.49 crore) (Paytm Payments Bank penalty) L4-C4
FIU-IND imposed Rs 5,49,00,000 on Paytm Payments Bank by order dated 1 March 2024 for AML violations.
FIU-IND Compliance Orders, FIU-IND Order KuCoin PGL_08_2024 (22 March 2024, Rs 34.5 lakh) (KuCoin penalty) L4-C5
FIU-IND imposed Rs 34,50,000 on Peken Global Limited (KuCoin) by order dated 22 March 2024.
FIU-IND Compliance Orders, FIU-IND Order Binance 10/2024 (19 June 2024, Rs 18.82 crore) (Binance penalty) L4-C6
FIU-IND imposed Rs 18,82,00,000 on Binance by order dated 19 June 2024. Binance subsequently registered with FIU-IND.
FIU-IND Compliance Orders, FIU-IND Order Bybit (31 January 2025, Rs 9.27 crore) (Bybit penalty) L4-C7
FIU-IND imposed Rs 9,27,00,000 on Bybit by order dated 31 January 2025. Bybit subsequently registered with FIU-IND.
FATF, FATF Mutual Evaluation Report India 2024 (FATF MER India 2024) L4-C8
Adopted at Singapore Plenary June 2024, published 19 September 2024. India placed in regular follow-up, the top tier, with Substantial effectiveness ratings on IO1, IO2, IO5, IO6, IO8, IO11 and Moderate on IO3, IO4, IO7, IO9, IO10.
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Reading Module 1. Enrol to unlock the rest of the course.
Module 1: The PMLA Universe and Why You Are Reading This
Module 2: Know Your Customer, The Rule Book
  • Rule 9 and the three CDD tiers. When simplified, when regular, when enhanced
  • Officially valid documents and V-CIP under RBI MD Para 18
  • The CKYCR push-and-pull flow under Rule 9(1C), as GSR 419(E) rewrote it
  • Rule 9A, Section 11A PMLA and the two Aadhaar paths
  • The RBI KYC Second Amendment of 14 August 2025, provision by provision
Module 3: Customer Due Diligence in Practice
  • The onboarding workflow and Day 1 risk scoring, built around a Pashupati Finserv gold-loan customer
  • Beneficial-ownership tracing at the post-2023 thresholds, with a worked four-level corporate structure
  • PEP identification: foreign PEPs, domestic PEPs, family members and close associates, without the common-name false positives
  • Source of funds and source of wealth, as two separate documents on three distinct pieces of evidence
  • High-risk jurisdictions and sanctions screening: FATF lists, UNSC 1267, MHA UAPA Section 51A, and the Day 1 scoring call
Module 4: Transaction Monitoring and Red Flags
  • Scenario design that is tied to Rule 3 reporting categories, not to vendor presets
  • Alert triage, the 20-80 rule, and how to document closed alerts for the Section 70 defence
  • How to read FIU-IND typologies and feed them back into scenario design
  • Twenty case-study red flags drawn from FIU-IND published orders and ED prosecutions
  • The handoff from alert to STR, and how to preserve the Rule 7 satisfaction clock
Module 5: Reporting Obligations: STR, CTR, NTR, CBWTR, CCR
  • The five reports in Rule 3, and what each one is actually asking you to say
  • The STR filing window under Rule 7. Satisfaction is the clock, not the transaction
  • CTR, NTR, CBWTR and CCR mechanics. Thresholds, traps and the integrally-connected rule
  • FINnet 2.0 end to end. FINGate collection, FINCore processing, FINex dissemination
  • The STR narrative drill. Three worked examples a Principal Officer should be able to write in his sleep
Module 6: The Principal Officer's Playbook
  • The eleven-paragraph Board resolution appointing your Principal Officer, paragraph by paragraph
  • FIU-IND registration on FINnet 2.0, step by step, and how to keep it current when the Principal Officer changes
  • The internal AML policy, twelve non-negotiable clauses with specimen language
  • Board reporting cadence, the KPIs that matter and the six-slide deck template
  • The personal liability shield. Section 13(2), Section 70 and the senior-management due-diligence defence
Module 7: Record-Keeping, Retention and Audit Trail
  • Section 12 obligations and the five-year rule, from first touch to final deletion
  • Electronic storage, data residency and the audit trail that an inspector will actually trust
  • Inspection readiness, or the three questions an FIU-IND inspector opens with
  • The layered retention schedule across PMLA, RBI, SEBI, IRDAI and Companies Act
  • Reconstructing a customer file in under thirty minutes using an indexed record store
Module 8: Sanctions and Watchlist Screening
  • UNSC 1267 as the base list, and UAPA Section 51A as the Indian freezing power that actually bites
  • OFAC overlap, the correspondent-banking fault line, and the extraterritorial exposure every Indian reporting entity now carries
  • The screening SOP across three triggers: onboarding, periodic, event-driven
  • Fuzzy matching, transliteration, and the tuning problem of catching Mohammed Ali without freezing every Mohammed Ali in Pune
  • Remediation of a true hit. Freeze under UAPA 51A, report under Rule 7, close under regulator direction
Module 9: Sector Deep-Dives: Banks, Securities, Insurance, Fintech and VDA SPs
  • Banks and NBFCs after the RBI KYC Second Amendment of 14 August 2025, with the February 2026 non-compliant NBFC list on the Board table
  • Securities intermediaries under the SEBI AML Master Circular, with the October 2025 draft refresh on the horizon
  • Insurance under the IRDAI AML/CFT Master Guidelines 2022, with the 12 August 2024 CKYCR port in your calendar
  • Fintech, Payment Aggregators and PPIs, with the Paytm Payments Bank order of 1 March 2024 taught as case law
  • VDA Service Providers after S.O. 1072(E) of 7 March 2023, with Binance, Bybit and the October 2025 offshore notices on the record
Module 10: Enforcement, Penalties and Case Studies
  • ED powers under PMLA, and the Section 45 bail bar every Principal Officer must understand before the first summons
  • Section 63 PMLA and the Section 13(2)(d) penalty slabs, with a worked penalty computation for a mid-size NBFC
  • Vijay Madanlal Choudhary 2022, Pavana Dibbur 2023 and the Ganpati Dealcom recall. What the Supreme Court actually did to PMLA
  • Four live FIU-IND compliance orders dissected: Paytm, KuCoin, Binance, Bybit
  • ED statistics FY 2024-25, the FATF 2027 forcing function, and the Board-ready briefing format every Principal Officer must master
Module 11: AML for Non-Traditional Reporting Entities
  • S.O. 2036(E) of 3 May 2023. How a CA, CS or CMA firm became a Reporting Entity overnight
  • FIU-IND registration for a CA, CS or CMA firm. The walkthrough nobody wrote
  • Real-estate agents and developers under S.O. 1073(E). Why there is no threshold and what a Rs 15 crore Mumbai deal looks like in file form
  • Multi-State Co-operative Societies under the 11 October 2024 FIU-IND Guidelines. Gandhinagar Nagarik and Rajgurunagar Sahakari as teaching cases
  • Prevention of Corruption Act Section 10. Building the adequate-procedures defence and why PCA Sections 7, 8 and 13 are PMLA scheduled offences
Module 12: Capstone, Programme Build and Final Exam
  • Build your ten-week AML programme. The scope document and the stakeholder map
  • Weeks 1-10 Gantt and the twelve artifacts of the capstone workbook
  • The Board briefing deck and the year-1 operating calendar
  • The 25-anchor exam reference card
  • The final exam. 45 questions from a 70-item pool, 90 minutes, 75 percent pass