Sanctions Screening in India: What the Law Actually Requires and Who It Applies To

Compliance officers in India’s financial sector are familiar with the idea of screening customers against lists. What is less consistently understood is that not all screening obligations carry the same legal weight – and that confusing a risk-based due diligence requirement with an absolute statutory prohibition can quietly undermine how an institution designs, resources and […]

Reporting Entities Obligation with Foreign PEPs in India

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 […]

A Practitioner’s Guide to RBI’s IRA Mandate: Weighing Risk, Not Just Recording It

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 […]

The Alert Fatigue Crisis in AML Transaction Monitoring And How to Solve It

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, […]

The Risk of Unknown Unknowns in KYC

In the context of risk management; the infamous epistemology of uncertainty – “there are known knowns, known unknowns, and unknown unknowns” is well understood. This maps seamlessly with the unsettling precision onto the world of Know Your Customer (KYC) compliance in Indian financial services. The known knowns are the KYC documents we collect. The known […]

Perilous Gaps Between Prescribed and Actual AML Compliance

Risk-Based in Name, Rule-Based in Practice India’s anti-money laundering framework has undergone a visible transformation over the past decade. Regulatory expectations have expanded, reporting obligations have intensified, and financial institutions today operate within a significantly more mature AML/CFT environment than they did even a few years ago. This evolution was reflected in India’s recent Mutual […]

The Cost of Looking Away – Risks, Reasons, and Remedies of AML Non-Compliance in India

India’s anti-money laundering framework is no longer the patchwork it once was. The Prevention of Money Laundering Act, 2002 (PMLA), as reinforced by the PML Rules 2005 and a dense web of regulatory directions from the Reserve Bank of India (RBI), the Securities and Exchange Board of India (SEBI), the Insurance Regulatory and Development Authority of India (IRDAI), the International Financial Services Centres Authority (IFSCA), and the Pension Fund Regulatory and Development Authority (PFRDA), has created one of the more comprehensive anti-money laundering and counter-financing of terrorism AML/CFT) architectures in the world.