Money launderingCriminal enforcement
Which government entities enforce your jurisdiction’s money laundering laws?
The Directorate of Enforcement (ED), which is under the administrative control of the Department of Revenue, the Ministry of Finance, the Indian government and the director of the Financial Intelligence Unit (FIU) under the Department of Revenue of the Ministry of Finance have been appointed to exercise exclusive powers under specific sections of the Prevention of Money Laundering Act 2002 (the PML Act).
Additionally, section 54 of the PML Act provides that certain officers are empowered and required to assist authorities under the Act with enforcement, including:
- officers of the Customs and Central Excise Departments;
- officers appointed in terms of certain provisions of the Narcotic Drugs and Psychotropic Substances Act 1985;
- members and officers of recognised stock exchanges under the Securities Contracts (Regulation) Act 1956;
- income tax authorities under the Income Tax Act 1961;
- officers of the Reserve Bank of India (RBI);
- officers of the police;
- officers of enforcement appointed under the Foreign Exchange Management Act 1999;
- officers of the Securities and Exchange Board of India (SEBI);
- officers of the Insurance Regulatory and Development Authority;
- officers of the Forward Markets Commission;
- officers and members of associations recognised under the Forward Contracts (Regulation) Act, 1952;
- officers of the Pension Fund Regulatory and Development Authority;
- officers of the Department of Posts in the Indian government;
- registrars and sub-registrars appointed by state governments under the Registration Act 1908;
- registering authorities empowered to register motor vehicles under the Motor Vehicles Act 1988;
- officers and members of the Institute of Chartered Accountants of India, the Institute of Cost and Works Accountants of India and the Institute of Company Secretaries of India;
- officers of any other body corporate that is established under a state or central legislation; and
- such other officers of the central government, state government, local authorities or reporting entities (ie, banks, financial institutions, persons carrying out a designated business or profession (designated persons) and intermediaries) who may be notified by a special order of the central government.
The PML Act specifically mandates assistance and cooperation between the above-mentioned authorities since an essential element for the commission of the offence of money laundering is being involved in a process or activity connected with the ‘proceeds of crime’ (including its concealment, possession, acquisition or use), and projecting or claiming those proceeds of crime as untainted property.
The PML Act defines ‘proceeds of crime’ to mean any property (or the value of any property) derived or obtained, directly or indirectly, by any person as a result of any offence under the Indian penal statutes set out in the Schedule to the PML Act (scheduled offences); or where such property is taken or held outside the country, the property equivalent in value held within the country or abroad. It has been clarified in an explanation that ‘proceeds of crime’ include not only property that is derived or obtained from scheduled offences but also any property that may directly or indirectly be derived or obtained as a result of any criminal activity that is relatable to a scheduled offence.
Part XIV of the Finance Act 2018, which came into effect on 19 April 2018, amended the definition of ‘proceeds of crime’ such that the right of attachment also extends to property (equivalent to the proceeds of crime) held outside India. Scheduled offences are the predicate offences for the commission of the offence of money laundering. Accordingly, if any transaction is not linked to a scheduled offence, the funds relating to those transactions would not constitute proceeds of crime, and, therefore, dealing in those funds would not amount to money laundering. The investigation of the offence of money laundering is, therefore, inextricably linked to the investigation of the scheduled offence, and it is on account of this that various investigative agencies have been directed in terms of the PML Act to coordinate and cooperate with the ED.
Scheduled offences and the offence of money laundering are proposed to be tried together by a special court constituted by the PML Act that has jurisdiction over the area in which the offence has been committed. Section 43 of the Act provides that the central government may, in consultation with the Chief Justice of the relevant High Court, designate one or more sessions courts as a special court. Accordingly, the commission of a scheduled offence must be alleged before the special court that is trying the offence of money laundering under the PML Act, and evidence and material relating to the scheduled offence must be placed before the special court to enable it to frame a charge in respect of the offence and try it (see Hasan Ali Khan v Union of India (2012 BomCR (Cri) 807)).
The Finance Act 2015 introduced certain amendments to the PML Act, including the replacement of the Adjudicating Authority with a special court, which will be authorised to adjudicate on and finalise an order of attachment of property. Additionally, a provision was also included in the PML Act that permits the special court to direct that any property that stands confiscated to the central government be restored to a claimant with a legitimate interest in the property who, acting in good faith, may have suffered a quantifiable loss as a result of the offence of money laundering, despite having taken all reasonable precautions. The special court has been empowered to consider the claim for restoration of such a claimant during the trial of the offence.
Pursuant to amendments made to the PML Act by the Finance Act 2016, the appellate tribunal constituted under the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act 1976 has been deemed to be the appellate tribunal for hearing appeals against the orders of the Adjudicating Authority and the director of FIU under the PML Act.Defendants
Can both natural and legal persons be prosecuted for money laundering?
Under the PML Act, both natural and legal persons can be prosecuted for money laundering.
The term ‘person’ under the PML Act has been defined to include individuals, companies, firms, associations of persons (whether incorporated or not), artificial juridical persons and agencies, offices and branches owned or controlled by any such natural or legal person. The PML Act provides for a wide range of penal actions that may be taken against persons in possession of proceeds of crime who have committed scheduled offences.
Under section 70 of the PML Act, if a body corporate (including a firm or association of individuals) contravenes any of the provisions of the PML Act, the persons in charge of the body corporate (and responsible to the body corporate for the conduct of its business) at the time of commission of the offence by the body corporate and the body corporate itself will be deemed to be guilty of the contravention of the provisions of the PML Act.
However, section 70 of the PML Act provides that persons in charge of the company will not be liable for the contravention if they are able to prove that the contravention of the PML Act by the body corporate took place without their knowledge or that they exercised all due diligence to prevent the commission of such an offence by the body corporate.
Further, where a contravention by a body corporate is attributable to any particular director, officer, secretary or manager (either on account of his or her consent, connivance or negligence), the director, officer, secretary or manager may also be prosecuted separately under the PML Act for the contravention committed by the body corporate.The offence of money laundering
What constitutes money laundering?Offence of money laundering
Money laundering is defined in the PML Act as direct or indirect attempts to indulge in, knowingly assist or knowingly become a party to, or having actual involvement in, the process or activity connected with the proceeds of crime (including its concealment, possession, acquisition or use) and projecting or claiming such property as untainted property. Under section 3 of the PML Act, the following actions are tantamount to the offence of money laundering:
- a direct or indirect attempt to indulge in any process or activity that is connected with the proceeds of crime (including its concealment, possession, acquisition or use), with the intention of projecting or claiming those proceeds of crime as untainted property;
- any direct or indirect assistance in any process or activity connected with the proceeds of crime (including its concealment, possession, acquisition or use) and projecting or claiming those proceeds of crime as untainted property, provided that assistance is knowingly given; and
- being, directly or indirectly, a knowing party to or being involved in any process or activity connected with the proceeds of crime (including its concealment, possession, acquisition or use) and projecting or claiming those proceeds of crime as untainted property.
Further, in the case of Hasan Ali Khan v Union of India, the Bombay High Court held that an offence is committed under the PML Act only when an attempt is made to demonstrate a legitimate source of earning with respect to a tainted property, namely with respect to proceeds of crime. In terms of section 24 of the Act, where there are any proceedings relating to proceeds of crime under the PML Act, in the case of a person involved in the offence of money laundering, unless the contrary is proved, it is presumed that the proceeds of crime are involved in the offence of money laundering.
The PML Act sets out certain specific offences that are referred to as ‘scheduled offences’ under the PML Act. These scheduled offences are further sub-divided into three categories, namely Part A, Part B and Part C offences. The commission of any offence mentioned in Part A of the Schedule to the PML Act (Part A offence) or Part C of the Schedule to the PML Act (Part C offence) constitutes a scheduled offence. Part C offences are those that have cross-border implications and are Part A offences, offences against property under Chapter XVII of the Penal Code 1860 (PC) or offences of wilful attempts to evade any tax, penalty or interest referred to in section 51 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act 2015 (the Black Money Act). The commission of an offence mentioned in Part B of the Schedule to the PMLA (Part B offence) constitutes a scheduled offence only if the total value involved in the offence is equal to or greater than 10 million rupees.
To constitute an offence of money laundering under section 3 of the PML Act, a person must knowingly assist or knowingly be a party to any process or activity connected with the proceeds of crime and in the projection or claiming of such proceeds of crime as untainted property, or be involved in concealing, acquiring or using such proceeds of crime. Therefore, the element of knowledge is an important constituent for the offence of money laundering in India; thus, a strict liability standard may not be applicable in India in the context of an offence of money laundering. The term ‘knowledge’ was specifically inserted into section 3 of the PML Act after deliberations over the draft bill in parliament prior to the passing of the PML Act. Therefore, the legislative intent of the parliament in this regard seems quite clear.
Banks, financial institutions, persons carrying out a designated business or profession (designated persons) and intermediaries (collectively, reporting entities) can be prosecuted or pursued for money laundering offences committed by their clients if it can be demonstrated that they were aware of the commission of a scheduled offence, knowingly became recipients of the proceeds of crime and projected the proceeds as untainted property. The obligations cast on the reporting entities in terms of the PML Act, the Prevention of Money Laundering (Maintenance of Records) Rules 2005, as amended from time to time (the PML Rules), the Reserve Bank of India (Know Your Customer (KYC)) Directions 2016 (the RBI KYC Master Directions) and the Master Circular on Guidelines on Anti-Money Laundering (AML) Standards/Combating Financing of Terrorism (CFT)/Obligations of Intermediaries under the Prevention of Money Laundering Act 2002 and the rules framed thereunder (the SEBI AML Guidelines) are to exercise due diligence in their dealings with clients and to maintain and supply records of certain prescribed dealings with clients. Accordingly, although the exercise of diligence on the part of the reporting entities does not constitute a defence under the PML Act and the PML Rules, it may be used as a factor in demonstrating the lack of knowledge of the commission of money laundering by their clients.Qualifying assets and transactions
Is there any limitation on the types of assets or transactions that can form the basis of a money laundering offence?
Determination of the commission of a scheduled offence is required to ascertain whether the offence of money laundering has been committed. For such a determination, a monetary threshold has been prescribed for certain scheduled offences (namely, Part B offences). Part B offences include offences of false declarations and false documents under section 132 of the Customs Act 1962, for which a monetary threshold of 10 million rupees has been prescribed. Accordingly, only if the total value involved in the commission of such a Part B offence exceeds 10 million rupees would the other elements of the offence of money laundering be satisfied.
In the context of a Part A offence and an offence of cross-border implications, however, the above monetary threshold do not apply.Predicate offences
Generally, what constitute predicate offences?
The Schedule to the PML Act sets out a list of offences (ie, scheduled offences), the commission of which are a prerequisite to determine whether the offence of money laundering has been committed. These include certain identified offences under the IPC (including, inter alia, criminal conspiracy, counterfeiting, kidnapping, extortion, robbery, receiving stolen property and fraud), the Arms Act 1959 (relating to, inter alia, the manufacturing and selling of arms and ammunition in contravention of the Arms Act), the Prevention of Corruption Act 1988 (PCA), the Wildlife (Protection) Act 1972, the Immoral Traffic (Prevention) Act 1956 and the Narcotic Drugs and Psychotropic Substance Act 1985 (the NDPS Act). Further, if the offence of a deliberate attempt to evade tax under section 51 of the Black Money Act has cross-border implications, then it is a scheduled offence under the PML Act.
Under the Black Money Act, wilful non-filing of returns or non-declaration of foreign incomes or assets in the periodic income tax returns is punishable by rigorous imprisonment for a period between six months and seven years. However, a declarant who has made a declaration under section 59 of the Black Money Act is immune from the PML Act to the extent of the scheduled offence of wilful attempt to evade tax, in respect of those declared assets.
The Finance Act 2018, which came into effect on 1 April 2018, also incorporated corporate fraud under the Companies Act 2013 in the list of scheduled offences under the PML Act. Further, through certain amendments to the PCA, with effect from 26 July 2018, the ambit of certain offences thereunder was widened, and certain additional offences were also added. Consequential amendments have also been made to the list of scheduled offences in the PML Act. As a result, the updated list of scheduled offences under the PML Act also includes, inter alia, offences such as bribing a public servant by a commercial organisation and taking an undue advantage to influence a public servant by corrupt or illegal means or by exercising personal influence as well as punishment for habitual offenders.
If vast sums of money arise from criminal acts that are not scheduled offences, even if attempts have been made to project these as legitimate earnings, the offence of money laundering could not have occurred since the predicate offence would not have been committed (Hasan Ali Khan v Union of India). The jurisdiction of the PML Act applies where an offence is committed by a person outside India and the offence would also constitute a scheduled offence (had it been committed in India), and any part of the proceeds of the offence have been remitted to India. Further, the jurisdiction of the PML Act also extends to situations where the scheduled offences have been committed within India, and all or part of the proceeds of crime have been remitted outside India.Defences
Are there any codified or common law defences to charges of money laundering?
There are no codified defences to the charge of money laundering other than demonstrating a lack of knowledge.Resolutions and sanctions
What is the range of outcomes in criminal money laundering cases?
An offence of money laundering is punishable by imprisonment for a term of between three years and seven years and, additionally, a fine. The maximum term of imprisonment may extend to 10 years in the event that the proceeds of crime relate to an offence under the NDPS Act (which deals with crimes relating to narcotics). Plea bargaining is available in terms of the Code of Criminal Procedure 1973 (CrPC), although not for:
- offences that have been notified by the government as affecting the ‘socio-economic condition of the country’; or
- offences where the punishment prescribed by law is:
- life imprisonment; or
- imprisonment for a term in excess of seven years.
The offence of money laundering has not yet been notified as affecting the ‘socio-economic condition of the country’ and is, accordingly, not precluded from being eligible for plea bargaining. Further, given that the maximum punishment is seven years’ imprisonment (except in the case of proceeds of crime arising out of an offence under the NDPS Act), plea bargaining should be available for the offence of money laundering. In this regard, if the courts in India consider the PML Act as a socio-economic statute like the corruption laws and other statutes, then plea bargaining may not be available.
The process for plea bargaining involves the accused making an application to the court and, upon the court being satisfied that the application was made voluntarily, making an order for the accused to work out a mutually satisfactory disposition of the case that may include the accused giving to the victim the compensation and other expenses during the case and thereafter.
Under the PML Act, fines ranging from 10,000 rupees to 100,000 rupees for each failure can be imposed on a reporting entity if it has failed to maintain records or supply information in the manner prescribed under the PML Act and the PML Rules.
In addition, although the PML Act and PML Rules do not provide for the revocation of licences of reporting entities, this may be possible based on the circulars relating to KYC and AML, issued by the regulators of the reporting entities. The RBI KYC Master Directions were issued by the RBI under section 35A of the Banking Regulation Act 1949 (the BR Act) (which empowers the RBI to issue such general or specific directions ‘as it may deem fit’), as well as under the PML Rules. Section 35A of the BR Act, read with section 22, provides that if a banking company does not comply with a direction validly issued by the RBI, then the RBI has the power to revoke the banking licence of the banking company. Accordingly, in the event that a banking company fails to comply with the provisions of the RBI KYC Master Directions, the RBI may be empowered to revoke the licence of the banking company.
Similarly, sections 45K and 45L read with section 45 IA(6) of the Reserve Bank of India Act 1934 provide that if an NBFC fails to comply with the provisions of a direction issued by the RBI, including, for instance, the RBI KYC Master Directions, the RBI is empowered to cancel the registration of the NBFC.
Section 11B of the SEBI Act 1992, inter alia, empowers the SEBI to regulate the securities market by any measures as it thinks fit and to cancel the licence of an intermediary for non-compliance with the directions issued by the SEBI, including, for instance, the SEBI AML Guidelines.Forfeiture
Describe any related asset freezing, forfeiture, disgorgement and victim compensation laws.Provisional attachment
The PML Act provides for the provisional attachment of any property that is the proceeds of crime, pending a final confirmation by the Adjudicating Authority under the PML Act. The term ‘property’ has been defined very broadly to mean any property or assets of every description, whether corporeal or incorporeal, movable or immovable and tangible or intangible, and it includes deeds and instruments evidencing title to, or interest in, such property or assets wherever located. Further, the term ‘property’ includes property of any kind used in the commission of an offence under the PMLA Act; or any scheduled offence.
The amendment to the definition of ‘proceeds of crime’ under the PML Act by the Finance Act 2015 enables the attachment and confiscation of equivalent assets in India where the proceeds of crime have been taken or held outside India. Further, the Finance Act 2018 amended the definition of ‘proceeds of crime’ such that such right of attachment also extends to property (equivalent to the proceeds of crime) held outside India.
In terms of section 5 of the PML Act, if the ED, based on the materials in its possession, has reason to believe that a person is in possession of proceeds of crime and those proceeds are likely to be concealed, transferred or dealt with in any manner that may result in frustrating any proceedings relating to the confiscation of those proceeds, then the ED, by an order in writing, may provisionally attach such property for a period of 180 days from the date of the order or until a confirming order is passed by the Adjudicating Authority under section 8(2) of the PML Act, whichever is earlier. An order of provisional attachment can be made only after a report has been forwarded to a magistrate under section 173 of the CrPC in relation to a scheduled offence or a complaint has been filed before a magistrate for taking cognisance of the scheduled offence. The Finance Act, 2018 has clarified that in computing the 180-day period for provisional attachment of the property, the period during which the proceedings are stayed by the relevant High Court is excluded, and a further period not exceeding 30 days from the date of order of vacation of the stay order is counted.
The PML Act does not define or explain the term ‘reason to believe’. However, the construction of the phrase may be aided by the definition of the term in section 26 of the PC, wherein it is provided that a person may have reason to believe something if there is sufficient cause to believe it, but not otherwise. The courts have held that ‘reason to believe’ does not mean a purely subjective satisfaction, and the belief must be held in good faith. It is open for the courts to examine the reasons for a belief and to ascertain whether these reasons are relevant and not extraneous to the matter in question.
It has been held by the courts (albeit not in the context of the PML Act, but in the context of other statutes) that a mere doubt or suspicion cannot be a reason to believe. Following provisional attachment under section 5 of the PML Act, the ED, or an officer authorised in this regard, is required to forward the material in its possession along with the provisional attachment order in a sealed envelope to the Adjudicating Authority in accordance with the procedure prescribed in the Prevention of Money Laundering (the Manner of forwarding a Copy of the Order of Provisional Attachment of Property along with the Material, and Copy of the Reasons along with the Material in respect of Survey, to the Adjudicating Authority and its Period of Retention) Rules 2005. The PML Act specifically permits a person interested in the ‘enjoyment’ of immovable property to enjoy the immovable property that has been attached.
In the judgment of B Rama Raju v Union of India (2011 164 CompCas 149(AP)), the Andhra Pradesh High Court held that for the purposes of attachment and confiscation (which are civil and economic consequences and not penal sanctions and are distinct from the process for prosecution under the PML Act) neither mens rea nor knowledge that a property has a lineage of criminality has been statutorily prescribed as a prerequisite. Therefore, even where a person has not been charged with the predicate offence or the offence of money laundering, the authorities may, nevertheless, attach (and confiscate) property in the possession of the person if the property constitutes the proceeds of crime.Limitation periods on money laundering prosecutions
What are the limitation periods governing money laundering prosecutions?
The PML Act does not specifically provide for a limitation period in relation to the offence of money laundering. However, section 468 of the CrPC specifies the limitation periods of various categories of offences in India. Under section 468, for an offence punishable with imprisonment for a term greater than three years, there is no limitation period. The CrPC defines the term ‘offence’ to mean ‘any act or omission made punishable by any law for the time being in force’. Consequently, the offence of money laundering under the PML Act constitutes an ‘offence’ within the meaning of the CrPC. Given that the offence of money laundering is punishable with imprisonment from three to 10 years, in accordance with the provisions of section 468 of the CrPC, there is no limitation period for the offence of money laundering.
Further, under section 468 of the CrPC, if two or more offences are being tried together, then the limitation period for each offence will be determined with reference to the offence that is punishable with the most severe punishment. Thus, if a person is prosecuted simultaneously for a scheduled offence punishable by imprisonment for a term of less than three years together with the offence of money laundering under the PML Act (which is punishable with imprisonment for three or more years), then even if the limitation period for the underlying scheduled offence may have expired when considered independently, the accused person may still be tried for the scheduled offence in light of section 468 of the CrPC, given that the limitation period in such a scenario for both offences would be determined based on the offence of money laundering and not the scheduled offence.Extraterritorial reach of money laundering law
Do your jurisdiction’s money laundering laws have extraterritorial reach?
The PML Act applies to the whole of India; however, its application is not restricted to property situated in India. The term ‘property’ is defined under the PML Act to include any property or assets, wherever located, so long as it is derived from, arises out of or is related to any of the scheduled offences. The amendment to the definition of ‘proceeds of crime’ under the PML Act, by the Finance Act 2015, enables the attachment and confiscation of equivalent assets in India where the proceeds of crime have been taken or held outside India. Further, the Finance Act 2018 has amended the definition of ‘proceeds of crime’ such that this right of attachment also extends to property (equivalent to the proceeds of crime) held outside India.
To give effect to this limited extraterritorial application in the context of certain specified offences that may be committed abroad (which also constitute scheduled offences if committed in India) but the proceeds of which may have been remitted to India, or where the scheduled offence may have been committed in India but the proceeds of the crime are remitted abroad, section 56 of the PML Act empowers the central government to enter into reciprocal arrangements with the government of any country outside India for enforcing the provisions of the PML Act and for the exchange of information for the prevention of any offence under the PML Act or under the corresponding law in force in that country, or for investigation under the PML Act.
On 1 August 2018, the government notified the Fugitive Economic Offenders Act 2018 (the Economic Offenders Act), effective retrospectively from 21 April 2018, to deter fugitive economic offenders from evading the process of law by staying outside the jurisdiction of Indian courts. For operationalising the Economic Offenders Act, the Fugitive Economic Offenders (Procedure for Conducting Search and Seizure) Rules 2018 have also been notified with effect from 24 August 2018. Some of the key provisions of the Economic Offenders Act are set out below:
- a ‘fugitive economic offender’ is defined as an individual against whom an arrest warrant has been issued for committing any prescribed offence (where the value exceeds 1 billion rupees), and has left the country to avoid facing prosecution or has refused to return to face prosecution;
- if any person against whom an application has been filed fails to appear (in person or through counsel) after a notice issued by the special court, then the person may be declared a ‘fugitive economic offender’;
- any property of the fugitive economic offender can be attached for 180 days unless further extended by the special court. The properties will be released if the person is not found to be a fugitive economic offender at the conclusion of proceedings; and
- the special court is entitled to confiscate properties, free of encumbrances, of any person declared as a ‘fugitive economic offender’ that are proceeds of a crime in India or abroad, benami properties in India or abroad or any other property in India or abroad. However, the special court is empowered to exempt from confiscation, any property in which a third party has a bona fide interest, without knowledge of the fact that the property is a proceed of crime.
The PML Act also contemplates ‘offences of cross-border implications’, which are:
- offences committed or related to conduct outside India that constitute an offence in that jurisdiction and are scheduled offences under the PML Act, and a part of or all the proceeds of crime arising from such conduct are remitted to India; or
- scheduled offences committed in India, and part of or all the proceeds of crime have been transferred or have been attempted to be transferred from India to a place outside India.
Offences with cross-border implications are scheduled offences under the PML Act and, accordingly, the PML Act may be applicable to those offences. In addition to this, the Black Money Act provided for a three-month window from 1 July 2015 to 30 September 2015 within which a person could make a declaration in respect of his or her undisclosed assets located outside India, and pay the prescribed rate of tax and penalty on those foreign assets on or before 31 December 2015, failing which those individuals would be subject to all the provisions of the Black Money Act, including penalties and prosecutions. The offence of wilful attempt to evade tax under section 51 of the Black Money Act has also been included in the list of scheduled offences under the PML Act, and accordingly, the PML Act may be applicable to those offences.
Further, the UN Security Council Resolution 1373 obliges countries to freeze without delay the funds or other assets of:
- persons who commit, or attempt to commit, terrorist acts, or participate in or facilitate the commission of terrorist acts;
- entities owned or controlled directly or indirectly by (1); and
- persons and entities acting on behalf of, or at the direction of, (1) or (2), including funds or other assets derived or generated from property owned or controlled, directly or indirectly, by those persons and associated persons and entities.
Each country has the authority to designate the persons and entities that should have their funds or other assets frozen. Additionally, to ensure that effective cooperation is developed among countries, countries should examine and give effect to, if appropriate, the actions initiated under the freezing mechanisms of other countries. To give effect to the requests of foreign countries under UN Security Council Resolution 1373, the Ministry of External Affairs will examine the requests made by foreign countries and forward it electronically, with their comments, to a designated officer for the freezing of funds or other assets. Freezing orders take place without prior notice to the designated persons involved.
Law stated dateCorrect on
Give the date on which the above information is accurate
20 April 2020.