FATF AML/CFT Deficiencies: Updated Guidance for MTSS Agents
Current · Source: Reserve Bank of India · RBI/2010-11/537 · issued 20 May 2011 · ~1 min read
Quick answerRBI directs all Indian Agents under MTSS to consider the latest FATF statement on jurisdictions with strategic AML/CFT deficiencies, reinforcing compliance with PMLA and FEMA provisions.
The rule, in the simplest words
Indian Agents under MTSS must consider the latest FATF statement on jurisdictions with strategic AML/CFT deficiencies.
Agents must integrate the updated FATF list into their AML/CFT screening processes for cross-border inward remittances.
Non-compliance with these guidelines attracts penal provisions under FEMA and PMLA.
How it plays out — a real example
As a KYC & compliance officer in Indore, Rohan must ensure that he updates his AML/CFT risk assessment for cross-border inward remittances after receiving the latest FATF statement. He must communicate the updated requirements to all relevant constituents and customers, and align his transaction monitoring systems to flag remittances from the listed jurisdictions to prevent any penal provisions under FEMA and PMLA.
What changed
RBI has forwarded the February 25, 2011 FATF statement identifying jurisdictions with strategic AML/CFT deficiencies. This updates the earlier April 6, 2011 circular and requires agents to consider the new information in their operations.
What it means for you
Indian Agents under MTSS must integrate the updated FATF list into their AML/CFT screening processes for cross-border inward remittances. Non-compliance with these guidelines attracts penal provisions under FEMA and PMLA, making it critical to update internal controls.
What you must do
Review the enclosed FATF statement and update your AML/CFT risk assessment for cross-border inward remittances.
Ensure your Principal Officer acknowledges receipt of this circular.
Communicate the updated requirements to all relevant constituents and customers.
Align your transaction monitoring systems to flag remittances from the listed jurisdictions.
Who it affects
All Authorised Persons acting as Indian Agents under the Money Transfer Service Scheme, Principal Officers of these entities, Customers and constituents using MTSS for cross-border inward remittances
❓ Common questions
What is the key action required from Indian Agents under this circular?
Agents must consider the information in the enclosed FATF statement on jurisdictions with strategic AML/CFT deficiencies and apply it to their cross-border inward remittance operations.
What are the legal bases for these directions?
The circular is issued under Section 10(4) and Section 11(1) of FEMA, 1999, and under PMLA, 2002, as amended. Non-compliance attracts penal provisions under these Acts.
Does this circular replace the earlier April 6, 2011 circular?
No, it supplements it by forwarding the updated FATF statement from February 25, 2011, which agents must now consider.
📜 Read the original circular — full text as issued by RBI
RBI/2010-11/537
A.P. (DIR Series) Circular No. 66
May 20, 2011
To,
All Authorised Persons, who are Indian Agents under Money Transfer Service Scheme.
Madam/ Dear Sir,
Anti-Money Laundering (AML) standards/Combating the Financing of Terrorism (CFT) Standards - Cross Border Inward Remittance under Money Transfer Service Scheme
Please refer to our A.P.(DIR Series) Circular No.52 { A.P.(FL/RL Series) Circular No.14} dated April 6, 2011 forwarding the Financial Action Task Force (FATF) Statement identifying a list of jurisdictions which have strategic AML/CFT deficiencies.
2. Financial Action Task Force (FATF) has further issued a Statement on February 25, 2011 ( copy enclosed ) calling upon jurisdictions listed in the Statement to complete the implementation of their action plan within timeframe. The FATF, in the Statement has called upon its members to consider the information given in the Statement.
3. All Authorised Persons (Indian Agents) are accordingly advised to consider the information contained in the enclosed Statement.
4. Authorised Persons (Indian Agents) may bring the contents of this circular to the notice of their constituents and customers concerned.
5. Please advise your Principal Officer to acknowledge receipt of this circular letter.
6. The directions contained in this Circular have been issued under Section 10(4) and Section 11(1) of the Foreign Exchange Management Act, 1999 (42 of 1999)and also under the, Prevention of Money Laundering Act, (PMLA), 2002, as amended by Prevention of Money Laundering (Amendment) Act, 2009 and Prevention of Money-Laundering (Maintenance of Records of the Nature and Value of Transactions, the Procedure and Manner of Maintaining and Time for Furnishing Information and Verification and Maintenance of Records of the Identity of the Clients of the Banking Companies, Financial Institutions and Intermediaries) Rules, 2005 as amended from time to time. Non-compliance with the guidelines would attract penal provisions of the Acts concerned or Rules made there under.
Yours faithfully,
(Meena Hemchandra)
Chief General Manager-in-Charge
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2010-11/537 · issued 20 May 2011. The plain-English explanation above is BankPulse’s own independent summary.
Align your transaction monitoring systems to flag remittances from the listed jurisdictions.
📜 Compliance
Review the enclosed FATF statement and update your AML/CFT risk assessment for cross-border inward remittances.
Ensure your Principal Officer acknowledges receipt of this circular.
Communicate the updated requirements to all relevant constituents and customers.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template
Example: if you are a Compliance officer at a bank this circular applies to (All Authorised Persons acting as Indian Agents under the Money Transfer Service Scheme, Principal Officers of these entities, Customers and constituents using MTSS for cross-border inward remittances), your first concrete step on “FATF AML/CFT Deficiencies: Updated Guidance for MTSS Agents” is: “Review the enclosed FATF statement and update your AML/CFT risk assessment for cross-border inward remittances.” (RBI issued this 20 May 2011).
Action required: Review the enclosed FATF statement and update your AML/CFT risk assessment for cross-border inward remittances.
Action required: Ensure your Principal Officer acknowledges receipt of this circular.
Action required: Communicate the updated requirements to all relevant constituents and customers.
Action required: Align your transaction monitoring systems to flag remittances from the listed jurisdictions.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
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.
💬 Banker Discussion
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=6424&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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