What changed
The 2009 amendment to PMLA Rules introduces a definition for 'non-profit organization' and requires banks to maintain records of NPO receipts exceeding ₹10 lakh. It also mandates identity verification for non-account-based (walk-in) customers for transactions of ₹50,000 or more, and removes the earlier proviso allowing delayed verification after account opening.
What it means for you
RRBs now have enhanced compliance obligations: they must track and report large NPO inflows monthly, and verify walk-in customers for high-value transactions. The deletion of the delayed verification proviso tightens KYC timelines. Structuring transactions below ₹50,000 to avoid detection must be treated as suspicious and reported.
What you must do
- Set up systems to identify and record all NPO receipts above ₹10 lakh, and file monthly reports to FIU-IND by the 15th of the succeeding month.
- Verify identity and address for any walk-in customer transaction of ₹50,000 or more, including connected transactions.
- Monitor for intentional structuring below ₹50,000 and file STRs to FIU-IND when suspected.
- Ensure confidentiality of suspicious transaction reporting as per amended Rule 8(3).
Who it affects
All Regional Rural Banks (RRBs), Compliance and AML teams at RRBs, Branch staff handling cash and walk-in transactions
What is the reporting deadline for NPO transactions over ₹10 lakh?
RRBs must forward a report to FIU-IND every month by the 15th of the succeeding month.
Do we need to verify identity for a walk-in customer doing multiple small transactions that add up to ₹50,000?
Yes, if the transactions appear connected, you must verify identity and address. If you suspect intentional structuring, also file a suspicious transaction report.