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Video-based Customer Identification Process (V-CIP) has fundamentally transformed customer onboarding in India’s banking and financial services industry. Introduced by the Reserve Bank of India (RBI) and subsequently adopted by other financial sector regulators, V-CIP enables regulated entities to establish customer identity remotely while providing a level of assurance comparable to face-to-face onboarding, provided prescribed controls […]

A note on terminology The FATF canon describes three stages of money laundering: placement, layering and integration. Structuring is not a fourth stage. It is the dominant technique by which placement is executed, and in a digitised economy it has largely displaced the suitcase of cash. Treating structuring as the operational face of placement is […]

India’s AML/CFT regulators, especially the Reserve Bank of India (RBI), the Securities and Exchange Board of India (SEBI), and the Insurance Regulatory and Development Authority of India (IRDAI) – all define “Politically Exposed Persons” by reference to individuals entrusted with prominent public functions by a foreign country. This is the statutory scope of “PEP” under […]

Why this guidance deserves more than a compliance memo When the Reserve Bank of India released its Internal Risk Assessment Guidance for Money Laundering/Terrorist Financing Risks on 10 October 2024, the immediate reaction across the industry was predictable: law firms issued client alerts, consulting firms published two-page summaries, and compliance heads circulated the PDF with […]

Every AML programme is, at bottom, a theory about where risk comes from and how it announces itself. For the better part of two decades, that theory has rested on a quiet assumption: that risk, when it exists, eventually gets formalized – codified into a sanctions list, a PEP database, a regulatory enforcement order and […]

A Practitioner’s Perspective on India’s BFSI Sector, coupled with Global Best Practices 1.  Introduction: A System Crying Wolf In the world of Anti-Money Laundering (AML), the transaction monitoring system is the frontline sentinel – a rules based or mode -driven engine designed to flag suspicious financial activity for human review. Yet across Indian banks, NBFCs, […]