APPELLATE TRIBUNAL UNDER SAFEMA AT NEW DELHI Vikramaditya Nagrik Sahakari Bank Maryadit … Appellant Versus The Financial Intelligent Unit, Delhi … Respondent Advocates/Authorized Representatives who appeared For the Appellant : Mr. Kavindra Solanki, Adv.

Ms. Khushi Sharma, Adv.

For the Respondent : Mr. Satish Aggarwal, Adv.

CORAM JUSTICE MUNISHWAR NATH BHANDARI : CHAIRMAN SHRI G. C. MISHRA : MEMBER

FINAL ORDER

05.02.2026 By this appeal, a challenge has been made to the order dated

09.11.2022 passed by the Directorate FIU imposing a penalty of Rs. 1 lakh, finding failure of the appellant to put in place an effective internal mechanism to deduct and report suspicious transactions reportable as STRs, in violation of Section 12 of the PMLA Act, 2002 read with Rule

7(3) of the PMLA Rules, 2005.

Another penalty of rupees one lakh has been imposed for violation

5(2) and 7(3) of the Rules of 2005. The third penalty of rupees one lakh was imposed for failure of the appellant to identify the ultimate beneficial owner of the trust, legal entities, and similar other customers in violation PMLA Rules, 2005 and Section 12 (1) (d) of the 2002 read with Rules 9 (1) (a) (ii) and 9 (3) of the PMLA Rules, 2