What changed
RBI reiterated that NBFCs must use software to flag transactions inconsistent with customer risk profiles. It clarified that integrally connected cash transactions are determined by aggregating all cash debits or credits in a calendar month exceeding ₹10 lakh, with individual transactions below ₹50,000 excluded from CTR. Electronic filing of CTR/STR is mandatory, and branches not yet computerized must manually feed data into electronic utilities.
What it means for you
NBFCs face tighter scrutiny on cash transaction monitoring and reporting. The ₹10 lakh threshold for integrally connected transactions requires monthly aggregation, increasing compliance burden. Non-electronic filing is no longer acceptable, pushing even non-computerized branches to digitize reporting. This raises operational costs but reduces money laundering risks.
What you must do
- Deploy or upgrade software to generate alerts for transactions inconsistent with customer risk profiles.
- Ensure monthly CTR filing to FIU-IND by the 15th of the succeeding month, with branches reporting monthly (not fortnightly).
- Aggregate all cash debits and credits per account monthly; report only those where total debits or credits exceed ₹10 lakh, excluding transactions below ₹50,000.
- File electronic CTR/STR; for non-computerized branches, use FIU-IND's editable utilities to feed data.
- Report counterfeit currency or forged document transactions immediately via CCR format (Annex II, III, and IV).
Who it affects
All Non-Banking Financial Companies (NBFCs), Miscellaneous Non-Banking Companies (MNBCs), Residuary Non-Banking Companies (RNBCs), Principal Officers of NBFCs, Compliance and IT teams at NBFCs
What is the new rule for integrally connected cash transactions?
NBFCs must aggregate all individual cash transactions in an account per calendar month. If total debits or credits exceed ₹10 lakh, report them as integrally connected, but omit transactions below ₹50,000 from CTR.
Can NBFCs still file CTR manually?
No. Electronic filing is mandatory. For non-computerized branches, the Principal Officer must extract transaction details and use FIU-IND's editable electronic utilities to create and submit electronic files.
What is the deadline for monthly CTR submission?
CTR for each month must be submitted to FIU-IND by the 15th of the following month. Branches must report to the Principal Officer on a monthly basis, not fortnightly.