Home › Circulars › RBI/2009-10/229

FATF-flagged countries: Enhanced AML/CFT risk monitoring

No longer current — withdrawn, no replacement on file yet
Source: Reserve Bank of India · RBI/2009-10/229 · issued 20 Nov 2009 · ~1 min read
Quick answerRBI directs banks to factor in AML/CFT deficiencies of Iran, Uzbekistan, Pakistan, Turkmenistan, and Sao Tome and Principe, per FATF's statement dated October 16, 2009. Enhanced due diligence and risk assessment are required for transactions linked to these jurisdictions.

What changed

RBI updated its earlier October 1, 2009 advisory by incorporating FATF's latest statement dated October 16, 2009. The list of high-risk jurisdictions remains the same: Iran, Uzbekistan, Pakistan, Turkmenistan, and Sao Tome and Principe. Banks must now explicitly account for risks from these countries' AML/CFT regime gaps.

What it means for you

Banks and financial institutions must treat transactions involving these five countries with heightened scrutiny. This reinforces existing KYC/AML obligations and may require additional documentation or transaction monitoring. Non-compliance could expose banks to regulatory action and reputational risk.

Historical instruction — do not use for current compliance. This is what was required at the time; it no longer reflects current RBI requirements. If no replacement rule is linked above, that only means none is recorded on our register yet — it does not prove no later applicable rule exists. Confirm on the official RBI source below.

What banks were required to do at the time

Who it affects

All Scheduled Commercial Banks (excluding RRBs), Local Area Banks, Financial Institutions

❓ Common questions

Regulatory timeline

Built from our lineage records — each fact carries its provenance; missing history simply is not shown (never guessed).

Which countries are flagged in this circular?

Iran, Uzbekistan, Pakistan, Turkmenistan, and Sao Tome and Principe are identified as having deficiencies in their AML/CFT regimes.

What action does RBI expect from banks?

Banks must factor in the risks from these deficiencies in their KYC/AML procedures and apply enhanced due diligence for related transactions.

Does this replace the earlier October 2009 circular?

No, it supplements it. The earlier circular (dated October 1, 2009) is referenced, and this one adds FATF's latest statement as of October 16, 2009.

📜 This document’s life story (1 recorded event, each backed by RBI’s own words)
Repealed by RBI/2025-26/100 — Consolidation of Regulations — Withdrawal of circulars (28 Nov 2025)
RBI’s words: “Official withdrawal register entry #1781: DBOD.AML.No.8923/14.01.032/2009-10 — "Know Your Customer (KYC) Norms / Anti - Money Laundering (AML) Standards / Combating of Financing of Terrorism (CFT)" da”
📜 Read the original circular — full text as issued by RBI
RBI/2009-10/229 DBOD. AML. No. 8923 /14.01.032 /2009-10 November 20, 2009 The Chairman/ CEOs of all Scheduled Commercial Banks(Excluding RRBs)/ Local Area Banks / Financial Institutions Dear Sir, Know Your Customer (KYC) Norms/ Anti- Money Laundering (AML) Standards/ Combating of Financing of Terrorism (CFT) Please refer to our letter DBOD. AML.No.5852/14.01.029/2008-09 dated October 1, 2009 on risks arising from the deficiencies in AML/CFT regime of Uzbekistan, Iran, Pakistan, Turkmenistan, Sao Tome and Principe. 2. Financial Action Task Force (FATF) has issued a further Statement on October 16, 2009 on the subject ( copy enclosed ). All banks and financial institutions are accordingly advised to take into account risks arising from the deficiencies in AML/CFT regime of Iran, Uzbekistan, Pakistan, Turkmenistan and Sao Tome and Principe. 3. Please advise Principal Officer of your bank to acknowledge receipt of this circular letter. Yours faithfully, (Vinay Baijal) Chief General Manager Encl: As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2009-10/229 · issued 20 Nov 2009. The plain-English explanation above is BankPulse’s own independent summary.
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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=5377&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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