What changed
RBI reiterated that banks must maintain transaction records in both hard and soft copies and report all Rule 3 transactions to FIU-IND. It clarified that integrally connected cash transactions exceeding ₹10 lakh in a month must be reported, but individual transactions below ₹50,000 can be omitted from CTR. Banks must now use editable electronic utilities from FIU-IND for non-computerized branches and submit CTRs monthly (not fortnightly).
What it means for you
UCBs face tighter anti-money laundering scrutiny with mandatory electronic reporting and robust transaction monitoring software. The ₹10 lakh threshold for integrally connected cash transactions requires banks to aggregate all debits and credits per account monthly. Non-compliance with electronic filing may attract regulatory action, increasing operational costs for banks with manual branches.
What you must do
- Ensure all branches submit cash transaction details to the Principal Officer monthly, not fortnightly.
- Deploy software that generates alerts for transactions inconsistent with customer risk profiles and updated profiles.
- File CTR and STR electronically to FIU-IND by the 15th of each month; use FIU-IND's editable utilities for non-computerized branches.
- Report counterfeit currency transactions immediately to FIU-IND using the CCR format in Annex II/III.
- Review and update customer risk categorization periodically as per February 2008 circular.
Who it affects
All Primary (Urban) Co-operative Banks, Principal Officers of UCBs, Compliance and AML teams, Branch managers handling cash transactions
What is the threshold for reporting integrally connected cash transactions?
Banks must report all cash transactions in an account where either total debits or total credits exceed ₹10 lakh in a calendar month. Individual transactions below ₹50,000 can be excluded from the CTR.
How should non-computerized branches file reports?
The Principal Officer must manually extract transaction details from non-computerized branches and feed them into an electronic file using the editable CTR/STR utilities available on the FIU-IND website.
What is the deadline for submitting CTR to FIU-IND?
CTR for each month must be submitted by the 15th of the following month. Branches must send their data to the Principal Officer on a monthly basis, not fortnightly.