Category: Anti-Money Laundering

Sanctions screening sits at the intersection of international security policy and everyday financial services. Banks must identify prohibited relationships and payments while processing legitimate business. Excessive alerts consume investigation capacity; missed matches can allow restricted funds to move. The UK Financial Conduct Authority’s review of firms’ response to Russia sanctions documented both problems: overly sensitive […]

Ask a compliance officer at an Indian bank or NBFC which sanctions lists they screen against, and the answer is almost always “all of them” — UN, OFAC, EU, and usually a handful of others besides. Ask the same officer which of those lists they are legally obligated to screen against under Indian law, and […]

There is a sentence buried in every AML policy manual in the country that reads, in some form or another: “Enhanced Due Diligence shall be applied to customers classified as high risk.” It is one line. It sounds procedural, almost administrative. And it perhaps conceals one of the widest implementation gaps in Indian financial compliance. […]

Digital customer onboarding was supposed to be the part of financial services that got easier as technology matured. In many respects it has:- the branch visit that is no longer mandatory, identity documents that can be verified remotely, and a customer who can be onboarded in minutes under the right conditions. Yet for every institution […]

Guarding the Two Gates Every Market Abuser Must Pass Through What SEBI actually requires, what three years of enforcement reveal about how the system gets abused, and what brokers and DPs should be doing about risk assessment, internal controls, governance, and technology 1. Why Brokers and DPs Are the Two Gates Everyone Must Pass Through […]

A practitioner’s guide to the regulatory architecture, the scale-based regulation overlay and the enforcement reality NBFCs;  from the smallest base layer lender to upper Layer now operate under : Has Your AML Programme Caught Up? 1. Why NBFCs Can No Longer Treat AML as a Bank Problem Non-Banking Financial Companies used to sit at the […]

On 28 November 2025 the Reserve Bank repealed the KYC Master Direction of 2016 and issued ten entity-specific instruments. NBFCs now read one written for them. Here is what it requires, how it meshes with the RBI’s Internal Risk Assessment guidance, and what the first enforcement cycle is saying. The instrument is the Reserve Bank […]

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 […]