Appellate Authority under PMLA 2002

 

An adjudicating authority is an entity that has the power to make decisions or orders under a specific act. The role of an adjudicating authority can vary depending on the act, and may include: 

Money laundering

The Adjudicating Authority has the power to confirm the attachment of property, or the retention of property or records, if it determines that the property is involved in money laundering. 

Insolvency

The Debt Recovery Tribunal is the adjudicating authority for insolvency matters involving individuals and firms. The National Company Law Tribunal is the adjudicating authority for insolvency matters involving corporate persons. 

GST

The Adjudicating Authority is any authority that has the power to make decisions or orders under the GST Act. 

Department of Revenue

The Adjudicating Authority is a body within the Department of Revenue of the Central Government's Ministry of Finance. It is made up of three members, one each from the fields of law, administration, and finance or accountancy.

The Prevention of Money Laundering Act, 2002 (PMLA)

The PMLA envisages a two-fold measure against the offence of money laundering. First, is the attachment proceedings, wherein properties suspected to be proceeds of crime are attached in terms of Section 5 and 8 of the PMLA, and second, the prosecution of the accused through a special court, with the intended goal of punishment.

 With respect to the former, when an empowered authority (Director or any other officer not below the rank of Deputy Director authorised by Director) under Section 5 of PMLA passes a provisional attachment order, the same is required to be confirmed under Section 8 by the Adjudicating Authority established under Section 6 of the PMLA. Section 25 provides for the establishment of an Appellate Tribunal, which is vested with power to hear appeals against orders passed by the Adjudicating Authority.

Section 5(3) provides that a provisional attachment order shall cease to have effect after the expiry of 180 days from the date of the order unless otherwise confirmed in terms of Section 8(3). Under Section 5(5), the Director or officer who provisionally attached the property is required, within a period of 30 days of the provisional attachment order, to file a complaint stating the facts of such attachment before the Adjudicating Authority.  

 

However, an anomaly occurs when the Adjudicating Authority, which is seized of the original complaint seeking confirmation of the provisional attachment order, fails to adjudicate within the period of 180 days. Resultantly, the proceedings before the Adjudicating Authority become infructuous, since the very basis of proceeding i.e., provisional attachment order, ceased to exist.



Because the initial attachment is provisional, the accused can continue to enjoy the property until the adjudicating authority confirms the attachment, after which the ED has the power to claim possession



In such a situation, the accused has two options either (i)  to file an application before the Adjudicating Authority itself on the ground that proceedings have become infructuous, and any order passed therein would be subject to appeal before the Appellate Tribunal u/s 26 and thereafter before the High Court u/s 42 of PMLA, or (ii) to file a petition under Article 226 read with 227 of Constitution.    

 

Section 6 of the PMLA before the 2009 amendment stated that the Central government shall appoint one or more Adjudicating Authorities to exercise jurisdiction, powers and authority conferred by or under the Act. Through the 2009 amendment, the words and phrases “one or more Adjudicating Authorities” were substituted by “an Adjudicating Authority”. Hence, the Adjudicating Authority at New Delhi exercises pan-India jurisdiction.


The Prevention of Money Laundering Act, 2002 (PMLA) establishes the PMLA Appellate Tribunal in section 25, which functions under the Ministry of Finance's Department of Revenue. The Tribunal's purpose is to hear appeals against orders made by the PMLA's Adjudicating Authority.

Constitution of Appellate Authority

The Tribunal is made up of a Chairperson and at least two members, who are appointed by the Central Government. Members are usually retired High Court judges or people with expertise in law or finance.

The Appellate Tribunal under the Prevention of Money Laundering Act, 2002 (PMLA) was brought into force w.e.f. 1st July, 2005. The Tribunal comprises a Chairman (who is or has been a Judge of the High Court or Supreme Court) and two members. One of the Members is an Accountant Member, who has been in the practice of accountancy as a Chartered Accountant for at least ten years and the other Member is a person who is or has been a judge of a High Court or who is a member of India Revenue Service and has held the post of Commissioner/Joint Secretary or equivalent post in Indian Legal Service, Income Tax, Indian Economic Service, Indian Customs and Central Excise Service or Indian Audit and Accounts Service in that service for at least three years.

They are appointed for a term of five years or till the age of 65 years, whichever is earlier.

The Delhi High Court has directed the Union Government (28 Feb 2023) to take expeditious steps for appointing Chairperson and other members of the Appellate Authority under Prevention of Money Laundering Act, 2002 (PMLA) within eight weeks. Taking judicial notice of the fact that there are a “large volume of cases” pending under PMLA

The Tribunal adjudicates appeals and allied petitions filed against the attachment/forfeiture orders passed by the Adjudicating Authority for attachment/forfeiture of properties involved in money laundering under PMLA. It also adjudicates appeals filed against the orders imposing fine passed by the Director- Financial Intelligence Unit India (FIU India). The Benches of the Appellate Tribunal sit at New Delhi without any benches elsewhere in the country.

 The appeals and allied petitions are disposed off by the Benches as constituted by the Chairperson with one or two Members as the Chairperson may deem fit.

 The Tribunal must deal with appeals as quickly as possible (Section 26) and aim to dispose of them within six months of filing. It sends copies of all orders to the parties involved in the appeal and to the relevant Adjudicating Authority or Director

The Delhi High court noted (25 March 23) that the Authority, at least in relation to portions relevant to compliance under Sections 5(1) and 8(1) of PMLA, 2002, was using identical paragraphs in a number of orders. Use of identical templated paragraphs could reflect as non-application of mind by the Authority concerned, said the court



 Happy Reading



Those who read this, also read:


1. Adminstration & Adjudication under PMLA 2002

 

Comments

Popular posts from this blog

National Risk Assessment (NRA): India

Customer Due Diligence(CDD) : Individuals

Periodic Updation of Customer Risk Profile