RBI Updates NBFCs on FATF AML/CFT Jurisdiction Risks
Current · Source: Reserve Bank of India · RBI/2012-13/210 · issued 17 Sep 2012 · ~1 min read
Quick answerRBI directs NBFCs/RNBCs to review FATF's June 2012 statement on AML/CFT deficiencies in certain jurisdictions. Firms must consider these risks but can continue legitimate trade with those countries.
The rule, in the simplest words
Review FATF's June 2012 statement on high-risk jurisdictions and update your AML/CFT policies.
Ensure your compliance team monitors the FATF website for ongoing updates on non-cooperative jurisdictions.
Continue legitimate business with listed countries but apply enhanced due diligence where warranted.
Document your risk assessment process for dealing with these jurisdictions to demonstrate regulatory compliance.
How it plays out — a real example
A KYC & compliance officer in Indore, Mr. Kumar, reviews the latest FATF statement on high-risk jurisdictions to ensure his NBFC's compliance with AML/CFT standards. He updates the company's policies and procedures to reflect the new information, and continues to facilitate legitimate gold loans to customers from these countries while applying enhanced due diligence to mitigate potential risks.
What changed
RBI issued a circular on September 17, 2012, referencing an earlier April 2012 circular on AML/CFT risks. It communicated FATF's updated June 22, 2012 statement on high-risk and non-cooperative jurisdictions, advising NBFCs/RNBCs to factor this information into their compliance processes.
What it means for you
NBFCs and RNBCs must stay alert to evolving global AML/CFT standards and adjust their risk assessments accordingly. The circular does not ban transactions with listed jurisdictions but expects enhanced due diligence. Lenders should integrate FATF updates into their internal controls to avoid regulatory gaps.
What you must do
Review FATF's June 2012 statement on high-risk jurisdictions and update your AML/CFT policies accordingly.
Ensure your compliance team monitors the FATF website for ongoing updates on non-cooperative jurisdictions.
Continue legitimate business with listed countries but apply enhanced due diligence where warranted.
Document your risk assessment process for dealing with these jurisdictions to demonstrate regulatory compliance.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
❓ Common questions
Does this circular ban transactions with the listed jurisdictions?
No, the circular explicitly states it does not preclude legitimate trade and business transactions with those countries. However, NBFCs must consider the AML/CFT risks highlighted by FATF.
Where can I find the FATF statement referenced in the circular?
The circular provides URLs to FATF's website: http://www.fatf-gafi.org/documents/repository/fatfpublicstatement-22june2012.html and a related page on improving global AML/CFT compliance.
What was the previous circular on this topic?
RBI had issued DNBS(PD).CC.No.270/03.10.42/2011-12 dated April 4, 2012, which also addressed risks from AML/CFT deficiencies in certain jurisdictions.
📜 Read the original circular — full text as issued by RBI
RBI/2012-13/210
DNBS(PD).CC.No304/03.10.42/2012-13
September 17, 2012
All Non Banking Financial Companies /
Residuary Non Banking Companies
Dear Sir,
Anti-Money Laundering (AML)/Combating of Financing of Terrorism (CFT) - Standards
Please refer to DNBS(PD).CC.No.270/03.10.42/2011-12 dated April 4, 2012 on risks arising from the deficiencies in AML/CFT regime of certain jurisdictions.
2. Financial Action Task Force (FATF) has updated its Statement on June 22, 2012 on the subject ( copy enclosed ). The statement /document can be accessed from the following URL also:
http://www.fatf-gafi.org/documents/repository/fatfpublicstatement-22june2012.html and
http://www.fatf-gafi.org/topics/high-riskandnon-cooperativejurisdictions/documents/improvingglobalamlcftcomplianceon-goingprocess-22june2012.html
3. All NBFCs/RNBCs are accordingly advised to consider the information contained in the enclosed statement.
4. This, however, does not preclude financial institutions from legitimate trade and business transactions with these countries and jurisdictions.
Yours faithfully,
(Chandana Dasgupta)
Deputy General Manager
Encl: as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2012-13/210 · issued 17 Sep 2012. The plain-English explanation above is BankPulse’s own independent summary.
Example: if you are a Compliance officer at a bank this circular applies to (All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)), your first concrete step on “RBI Updates NBFCs on FATF AML/CFT Jurisdiction Risks” is: “Review FATF's June 2012 statement on high-risk jurisdictions and update your AML/CFT policies accordingly.” (RBI issued this 17 Sep 2012).
Action required: Review FATF's June 2012 statement on high-risk jurisdictions and update your AML/CFT policies accordingly.
Action required: Ensure your compliance team monitors the FATF website for ongoing updates on non-cooperative jurisdictions.
Action required: Continue legitimate business with listed countries but apply enhanced due diligence where warranted.
Action required: Document your risk assessment process for dealing with these jurisdictions to demonstrate regulatory compliance.
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=7572&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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