NBFCs: Enhanced KYC/AML for High-Risk Jurisdictions
No longer current — withdrawn, no replacement on file yet
Source: Reserve Bank of India · RBI/2010-11/161 · issued 01 Jul 2010 · ~1 min read
Quick answerRBI directs NBFCs to use public info beyond FATF statements to identify countries with weak AML/CFT regimes, and scrutinize transactions from those jurisdictions more closely.
What changed
RBI expanded the scope of high-risk jurisdictions NBFCs must monitor. Previously, NBFCs relied solely on FATF Statements circulated by RBI. Now they must also use publicly available information to identify countries that do not or insufficiently apply FATF recommendations. Additionally, ongoing monitoring must include examining the background and purpose of transactions from such jurisdictions, and retaining written findings for authorities.
What it means for you
NBFCs must broaden their AML/CFT due diligence beyond official FATF lists, using open-source intelligence to flag risky jurisdictions. This increases compliance burden but strengthens India's anti-money laundering framework. Lenders need to update their KYC policies and transaction monitoring systems to capture these additional risk factors.
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
Update your KYC/AML policy to include publicly available information for identifying high-risk jurisdictions.
Enhance transaction monitoring systems to flag transactions from countries that insufficiently apply FATF recommendations.
Train staff on examining background and purpose of transactions from such jurisdictions and documenting findings.
Ensure written findings and documents are retained and available for RBI or other authorities on request.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
❓ Common questions
Regulatory timeline
Decoded by BankPulse2026-06-19 04:39 IST
repealed_by — Consolidation of Regulations — Withdrawal of circulars (28 Nov 2025)
Status change: withdrawn03 Aug 2026, 04:00 IST
Built from our lineage records — each fact carries its provenance; missing history simply is not shown (never guessed).
What sources should we use beyond FATF statements?
Use publicly available information such as reports from international bodies, government advisories, and credible news sources to identify countries with weak AML/CFT regimes.
What documentation is required for transactions from high-risk jurisdictions?
You must examine the background and purpose of such transactions, document written findings, and retain all related documents. These must be made available to RBI or other authorities on request.
📜 This document’s life story (1 recorded event, each backed by RBI’s own words)
Repealed byRBI/2025-26/100 — Consolidation of Regulations — Withdrawal of circulars (28 Nov 2025)
📜 Read the original circular — full text as issued by RBI
RBI/2010-11/161
DNBS. (PD) CC No 194/03.10.42/2010-11
August 09 , 2010
Dear Sir,
All Non-Banking Financial Companies,
Residuary Non-Banking Companies
Dear Sir,
Know Your Customer (KYC) norms/Anti-Money Laundering (AML) standards
Please refer to the Master Circular No. 184 dated July 01, 2010 on the captioned subject. All NBFCs (including RNBCs) are advised to take note of modifications to the above circular as under:
Countries which do not or insufficiently apply the FATF recommendations.
2. Reference has been invited to para 16 of the Master Circular No 184 dated July 1, 2010. NBFCs 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 NBFCs should, in addition to FATF Statements circulated by Reserve Bank of India from time to time, also consider publicly available information for identifying such countries, which do not or insufficiently apply the FATF Recommendations. NBFCs should give special attention to business relationships and transactions with persons (including legal persons and other financial institutions) from or in these countries.
3. In terms of paragraph 4 of Annex-VI of the Master Circular No 184 dated July 1, 2010, ongoing monitoring is an essential element of effective KYC procedures. It is advised that NBFCs 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 be retained and made available to Reserve Bank/other relevant authorities, on request.
4. These guidelines are issued under Section 45K and 45L of the Reserve Bank of India Act, 1934 and any contravention thereof or non-compliance shall attract penalties under RBI Act.
Yours sincerely,
(Uma Subramaniam)
Chief General Manager-in-Charge
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2010-11/161 · issued 01 Jul 2010. The plain-English explanation above is BankPulse’s own independent summary.
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=5934&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.
Help us keep this accurate
Found an inaccuracy or have an improvement? Tell us. Every report is reviewed by our team before any change is made — nothing goes live unverified.
Public beta — plain-English informational summaries. Always verify against the official RBI source (circular number cited on every page) before making compliance, credit, treasury, audit, or operational decisions. · Join our WhatsApp channel ↗
BANKPULSE · FREE DAILY BRIEF
Get RBI updates for your role
Every important RBI update, decoded in plain English — for your career, exams & financial awareness.
We collect only your email, name and role, used solely to send your brief — never sold or shared. Withdraw anytime via the unsubscribe link in any email. Independent platform, not affiliated with the RBI. Information, not legal advice.
REPORT AN ERROR · BETA
Spotted an error? Earn 500 BankPulse Credits
Help us stay accurate. If your correction is verified true and approved by our founder, you earn 500 BankPulse Credits — redeemable when the platform monetises.
Reviewed by a human before any credit is awarded. We never change the site from crowd input without verification.
WANT A NEW FEATURE · BETA
What would make BankPulse more useful for you?
Tell us what to build next — a tool, a data view, a role page, anything. We read every suggestion.
Thank you — your ideas directly shape what we build.