What changed
The amendment adds three new record-keeping requirements for Indian Agents under MTSS: (1) series of cash transactions below ₹10 lakh each but aggregating over ₹10 lakh (the series must occur within a month) must be recorded; (2) all receipts by non-profit organisations exceeding ₹10 lakh or equivalent in foreign currency must be recorded; (3) all cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine and where any forgery of a valuable security or a document has taken place facilitating the transaction must be recorded.
What it means for you
Indian Agents must expand their transaction monitoring systems to capture connected cash series and non-profit receipts above the threshold, increasing compliance burden. The inclusion of forged currency/document transactions signals heightened anti-money laundering vigilance. Non-compliance risks penal action under FEMA and PMLA.
What you must do
- Update internal KYC/AML policies and transaction monitoring systems to include the three new record categories.
- Train staff to identify and record series of cash transactions aggregating over ₹10 lakh in a month.
- Implement a process to flag and record all receipts from non-profit organisations exceeding ₹10 lakh.
- Establish a mechanism to detect and record cash transactions involving forged currency or documents.
- Communicate the amended instructions to all relevant constituents and customers.
Who it affects
All Authorised Persons acting as Indian Agents under Money Transfer Service Scheme (MTSS), Compliance and AML teams of MTSS agents, Non-profit organisations receiving cross-border inward remittances via MTSS
What is the new threshold for recording series of cash transactions?
Previously, series of cash transactions integrally connected to each other valued below ₹10 lakh each within a month needed recording. Now, such series must be recorded if their aggregate value exceeds ₹10 lakh.
Are non-profit organisations specifically targeted by this circular?
Yes. The amendment adds a new requirement to record all transactions involving receipts by non-profit organisations of value more than ₹10 lakh or equivalent in foreign currency, referencing a Government of India Notification dated November 12, 2009.