Category: Anti-Money Laundering

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, […]

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 […]

Preface: A Problem Hiding in Plain Sight There is a peculiar quality to the mule account threat that makes it so difficult to tackle: the account looks entirely normal. The account holder is real. The KYC documents seem genuine. The account was opened through a legitimate branch or a verified digital onboarding channel. The first […]

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.

There is a foundational assumption embedded in every AML programme in India – one so basic that it is rarely examined: that the compliance function knows what it is looking for. Transaction monitoring rules are built around typologies. STR narratives are structured around suspicion. Risk ratings are calibrated around customer profiles. But all of it […]