HomeCirculars › RBI/2010-11/126

RRBs: Enhanced KYC/AML Checks for High-Risk Jurisdictions

Current · Source: Reserve Bank of India · RBI/2010-11/126 · issued 22 Jul 2010 · ~2 min read
Quick answerRBI directs RRBs to scrutinize transactions from countries with weak AML/CFT regimes, including those flagged by FATF. Banks must also avoid dealings with shell banks and verify foreign correspondent institutions. Non-compliance invites penalties under the Banking Regulation Act.
The rule, in the simplest words
How it plays out — a real example

A KYC & compliance officer in a rural RRB branch in Bihar sees a large transfer from a country on the FATF grey list. She pauses the transaction, asks the customer for the business purpose, and documents her findings in a file, knowing she must keep it for RBI inspection.

What changed

RBI clarified that RRBs must use publicly available information, in addition to FATF statements, to identify jurisdictions with deficient AML/CFT application. Banks are now explicitly required to examine the background and purpose of transactions from such countries, especially those lacking economic or lawful purpose. The circular also reinforces the prohibition on relationships with shell banks and mandates due diligence on foreign correspondent institutions.

What it means for you

RRBs must tighten their KYC/AML monitoring for cross-border transactions, particularly those involving high-risk jurisdictions. This increases operational burden but reduces money laundering and terrorism financing risks. Non-compliance could lead to regulatory penalties, so banks need to update their internal policies and training programs accordingly.

What you must do

Who it affects

All Regional Rural Banks (RRBs), Compliance and AML/KYC teams at RRBs, Correspondent banking relationships of RRBs

❓ Common questions

What are FATF Statements and how should RRBs use them?

FATF Statements identify jurisdictions with weak AML/CFT regimes. RRBs must use these statements, plus publicly available information, to flag high-risk countries and scrutinize related transactions.

What is a shell bank and why can't RRBs deal with them?

A shell bank has no physical presence or meaningful regulation. RBI prohibits RRBs from any relationship with shell banks and requires verification that foreign correspondents don't allow their accounts to be used by shell banks.

What happens if an RRB fails to comply with these guidelines?

Non-compliance attracts penalties under Section 35A of the Banking Regulation Act, 1949. This could include fines or other regulatory actions.

📜 Read the original circular — full text as issued by RBI
RBI/2010-11/126 RPCD.CO RRB.AML.BC.No.13/03.05.33(E)/2010-11 July 22, 2010 The Chairman All Regional Rural Banks (RRBs) Dear Sir, Know Your Customer (KYC) norms/Anti-Money Laundering (AML) standards/Combating of Financing of Terrorism (CFT)/Obligation of banks under Prevention of Money Laundering Act (PMLA), 2002. Please refer to our circular RPCD.CO.RRB.NO.13611/03.05.28-A/2008-09 dated June 18, 2009 and circular RPCD.RRB.BC.NO. 81/03.05.33(E)/2004-05 dated February 18, 2005 on Know Your Customer (KYC) norms/Anti-Money Laundering (AML) standards / Combating of Financing of Terrorism (CFT)/Obligation of banks under Prevention of Money Laundering Act (PMLA), 2002. Countries which do not or insufficiently apply the FATF recommendations. 2. In paragraph 3 of the circular RPCD.CO.RRB.NO.13611/03.05.28-A/2008-09 dated June 18, 2009, RRBs have been advised to take into account risks arising from the deficiencies in AML/CFT regime of the jurisdictions included in the FATF Statement.  It is further advised that banks should, in addition to FATF Statements circulated by Reserve Bank of India from time to time, also consider publicly available information for identifying countries, which do not or insufficiently apply the FATF Recommendations. It is clarified that banks should also give special attention to business relationships and transactions with persons (including legal persons and other financial institutions) from or in countries that do not or insufficiently apply the FATF Recommendations and jurisdictions included in FATF Statements. 3. In terms of paragraph 4 of the Guidelines on 'Know Your Customer' Norms and Anti-Money Laundering Measures enclosed with our circular RPCD.RRB.BC.NO. 81/03.05.33(E)/2004-05 dated February 18, 2005, ongoing monitoring is an essential element of effective KYC procedures. It is advised that RRBs should examine the background and purpose of transactions with persons (including legal persons and other financial institutions) from jurisdictions included in FATF Statements and countries that do not or insufficiently apply the FATF Recommendations. Further, if the transactions have no apparent economic or visible lawful purpose, the background and purpose of such transactions should, as far as possible be examined, and written findings together with all documents should be retained and made available to Reserve Bank/other relevant authorities, on request. Shell Banks 4. In terms of instructions contained in Annex 1 to the Guidelines on 'Know Your Customer' Norms and Anti-Money Laundering Measures enclosed with our circular dated February 18, 2005, referred to above, banks should guard against establishing relationships with respondent foreign financial institutions that permit their accounts to be used by shell banks. It is clarified that banks should not enter into relationship with shell banks and before establishing correspondent relationship with any foreign institution, banks should take appropriate measures to satisfy themselves that the foreign respondent institution does not permit its accounts to be used by shell banks. 5. These guidelines are issued under Section 35A of the Banking Regulation Act, 1949. Any contravention thereof or non-compliance shall attract penalties under Banking Regulation Act. Yours faithfully, (B.P.Vijayendra) Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2010-11/126 · issued 22 Jul 2010. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Worked example & action-note template

Example: if you are a Compliance officer at a bank this circular applies to (All Regional Rural Banks (RRBs), Compliance and AML/KYC teams at RRBs, Correspondent banking relationships of RRBs), your first concrete step on “RRBs: Enhanced KYC/AML Checks for High-Risk Jurisdictions” is: “Update KYC/AML policies to include monitoring of transactions from FATF-listed and other deficient jurisdictions.” (RBI issued this 22 Jul 2010).

  1. Circular: RBI/2010-11/126 -- RRBs: Enhanced KYC/AML Checks for High-Risk Jurisdictions
  2. Issued: 22 Jul 2010
  3. Action required: Update KYC/AML policies to include monitoring of transactions from FATF-listed and other deficient jurisdictions.
  4. Action required: Train staff to identify and document transactions with no apparent economic or lawful purpose from high-risk countries.
  5. Action required: Ensure no correspondent relationship is established with shell banks; verify foreign institutions' policies on shell banks.
  6. Action required: Maintain written findings and documents for suspicious transactions and make them available to RBI/authorities on request.
  7. Owner: ____________ Target date: ____________
  8. Board/committee approval needed? Y / N
  9. Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=5887&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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