India · PMLA compliance
PMLA CTR trigger checker for jewellers
Check reporting-entity status, this month’s ₹10 lakh cash thresholds, and the filing rhythm owed to FIU-IND.
Statutory basis: PMLA 2002, s.2(1)(sa)(vi); S.O. 4713(E), 28-Dec-2020; PML (Maintenance of Records) Rules, 2005.
Confirm the notified business
S.O. 4713(E) designates persons carrying on specified businesses or professions, including dealers in precious metals and precious stones, as Reporting Entities.
How PMLA CTR and STR reporting works
1. Reporting-entity status comes first
PMLA s.2(1)(sa)(vi) permits the Central Government to notify additional reporting entities. S.O. 4713(E), dated 28-Dec-2020, includes dealers in precious metals and precious stones. The ₹10 lakh test determines CTR reporting; it does not erase the underlying reporting-entity designation.
2. A CTR covers single and connected cash transactions
Rule 3(1)(A) covers a cash transaction of ₹10 lakh or more and integrally connected cash transactions that together reach ₹10 lakh or more within a month. A buyer paying ₹5 lakh twice can therefore create a CTR trigger even though neither receipt alone reaches ₹10 lakh. File a triggered CTR within 15 days after the month ends.
3. An STR is based on suspicion, not merely value
Rule 3(1)(D) covers suspicious transactions, including attempted or structured activity where the facts support suspicion. Customer resistance to identification or deliberate payment splitting may require review. Under Rule 8, report promptly and no later than 7 working days after reaching the conclusion that the transaction is suspicious.
4. Registration, governance, KYC and records continue
Register with FIU-IND, nominate a Principal Officer and Designated Director, apply Rule 9 customer-identification measures, and preserve transaction records for 5 years. These Chapter IV duties are separate from whether this month produces a CTR.
Statutory FAQs
Common PMLA questions from jewellers
My ITR filer says PMLA does not apply. Correct?
No. S.O. 4713(E), dated 28 December 2020, designates dealers in precious metals and precious stones as Reporting Entities under PMLA s.2(1)(sa)(vi). The designation is separate from income-tax return filing and does not begin only after a ₹10 lakh cash transaction.
I have never received cash above ₹10 lakh in a single sale. Do I still have an obligation?
Yes. Reporting-entity registration, nomination of a Principal Officer and Designated Director, recordkeeping, KYC and monthly transaction review still apply. Rule 3(1)(A) also aggregates connected cash transactions reaching ₹10 lakh or more within one month.
What are a Principal Officer and Designated Director?
They are PMLA compliance roles contemplated by the Prevention of Money-laundering (Maintenance of Records) Rules, 2005. The appropriate appointees depend on the legal form of the business and are typically the proprietor, a senior partner, a director or another sufficiently senior person. The roles should be formally appointed and notified through FIU-IND.
Is FIU-IND registration a one-time thing?
Yes. Registration and initial onboarding are generally one-time steps, although profile and officer details must remain current. Ongoing CTR and STR filings depend on the transactions and facts reviewed in each reporting period.
What is FINnet 2.0?
FINnet 2.0 is FIU-IND’s online reporting portal for reporting-entity registration, profile administration and submission of prescribed reports such as CTRs and STRs.
Where is the penalty for non-registration?
PMLA s.13 empowers the Director, FIU-IND, to inquire into reporting-entity failures and impose sanctions. Adjudicating Authority and FIU-IND orders should also be checked. Monetary consequences may extend up to ₹1 lakh for each instance of failure under the applicable framework; verify the current provision, rule text and quantum before relying on that figure.
Primary statutory references: Prevention of Money-laundering Act, 2002, ss.2(1)(sa)(vi), 12 and 13; Ministry of Finance, Department of Revenue, S.O. 4713(E), dated 28-Dec-2020; Prevention of Money-laundering (Maintenance of Records) Rules, 2005, including Rules 3, 7, 8 and 9. Verify amendments, current FIU-IND specifications and applicable orders before taking legal action.