Punjab National Bank Vs Financial Intelligence Unit (Appellate Tribunal Under SAFEMA Delhi)
The Appellate Tribunal under SAFEMA/PMLA delivered its final order on Punjab National Bank’s challenge to the ₹15.62 crore penalty imposed by the Director, FIU–India for large-scale violations of reporting obligations under the PMLA & PML Rules, 2005. The review pertained to the period 01.04.2016 to 30.11.2017, during which FIU alleged extensive delays, incorrect filings & systemic failures in the Bank’s AML compliance framework.
PNB argued that its lapses were unintentional, caused largely by technical glitches on FIU’s reporting portal, workforce shortages, & the scale of reporting requirements. It contended that it had cooperated fully during inspections & that the FIU failed to justify imposing monetary penalty instead of lesser actions (warning or directions) u/s 13(2). The Bank further submitted that many Cash Transaction Reports (CTRs), Suspicious Transaction Reports (STRs) & Non-Profit Organisation (NTR) reports had been filed on time but were rejected due to system issues, & were subsequently accepted when re-uploaded.
After examining each head of alleged non-compliance, the Tribunal upheld FIU’s findings across major violations. It confirmed that the Bank had delayed 38 months’ worth of CTRs, filed 343 STRs with incomplete suspicion grounds, failed to report 14,577 NTR-reportable transactions, & filed 3,47,990 cross-border wire transaction entries with a cumulative delay of 270 months. The Tribunal held that PNB lacked an effective internal control mechanism to detect, classify & furnish reportable transactions in the time prescribed under Rules 3, 7 & 8.
