HomeCirculars › RBI/2011-12/416

RBI Tightens KYC/AML for Cross-Border Remittances Under MTSS

Live · in forceNo withdrawal recorded as of 20 Jun 2026. Reviewed by Vikram Jain; always verify against the official RBI source below.
Issued by RBI: 29 Feb 2012  ·  Decoded by BankPulse: 20 Jun 2026, 04:44 IST
⏱ ~2 min read
📄 Official RBI source ↗
Quick answerRBI mandates Indian Agents under MTSS to identify and assess money laundering/terror financing risks for customers, countries, products, and delivery channels. Enhanced due diligence is required for medium or high-risk customers. Board-approved policies and risk-based transaction monitoring are now compulsory.

What changed

RBI now requires APs (Indian Agents) under MTSS to formally identify and assess ML/TF risks across customers, geographies, products, services, and delivery channels. This goes beyond earlier guidelines that only required customer profiling and enhanced due diligence for high-risk customers. Agents must have board-approved policies and controls to manage these risks using a risk-based approach.

What it means for you

Banks acting as Indian Agents under MTSS must now implement a comprehensive risk assessment framework covering all aspects of their cross-border remittance business. This means more rigorous KYC/AML checks, especially for medium and high-risk customers, and the need to design risk parameters for transaction monitoring. Sub-agents must also comply, with the Indian Agent bearing full responsibility.

What you must do

Who it affects

Indian Agents under Money Transfer Service Scheme (MTSS), Sub-agents of Indian Agents under MTSS, Banks and authorized persons handling cross-border inward remittances

What is the key change from the earlier 2009 circular?

The 2009 circular required customer profiling and enhanced due diligence for high-risk customers. This 2012 circular expands that to a full risk assessment covering customers, countries, products, services, and delivery channels, with board-approved policies and risk-based transaction monitoring.

Do sub-agents need to follow these guidelines?

Yes, these guidelines apply mutatis mutandis to all sub-agents. The Indian Agent is solely responsible for ensuring sub-agents comply.

What happens if we don't comply?

Non-compliance could lead to regulatory action under FEMA and PMLA. The circular emphasizes a risk-based approach, so failure to assess and mitigate risks may attract penalties.

Track this rule
⏳ How this rule evolved — History Map →Full RBI rulebook crosswalk →
AI-drafted · 3-model AI consensus fact-check · under the editorial review of Vikram Jain · decoded & published by BankPulse · 20 Jun 2026, 04:44 IST
Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=7029&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by Vikram Jain. Independent platform, not affiliated with the Reserve Bank of India; never reproduces RBI text verbatim.