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FINnet Gateway Test Mode Reporting for Money Transfer Agents (Circular dated October 12, 2012)

Current · Source: Reserve Bank of India · RBI/2012-13/246 · issued 12 Oct 2012 · ~2 min read
Quick answerRBI, via circular dated October 12, 2012, directs all Authorised Persons (Indian Agents) under Money Transfer Service Scheme to start uploading Cash Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) in 'Test Mode' on the FINnet Gateway from August 31, 2012, while continuing existing CD submissions until FIU-IND announces go-live.
The rule, in the simplest words
How it plays out — a real example

A compliance officer at a bank in Mumbai, acting as an Indian Agent for money transfers, starts uploading CTRs and STRs in 'Test Mode' on the FINnet Gateway to test their electronic upload capability, while also continuing to submit reports in CD format as required. This ensures the bank's systems are ready for the upcoming mandatory shift to electronic reporting. The officer also contacts the FIU Help Desk for any technical assistance needed during the test phase.

What changed

FIU-IND, in a letter dated August 28, 2012, mandated that Authorised Persons (Indian Agents) begin submitting CTRs and STRs in 'Test Mode' on the FINnet Gateway from August 31, 2012, to test electronic upload capability. RBI's circular of October 12, 2012, communicates this directive. This test phase will continue until FIU-IND communicates the official go-live date, provisionally set for October 1, 2012. Existing CD-based submissions must continue in parallel until further notice.

What it means for you

Banks and other Authorised Persons acting as Indian Agents must now invest in XML-compliant reporting systems and test their ability to upload reports electronically via FINnet Gateway. This is a preparatory step before the mandatory shift from physical CD submissions to fully electronic reporting, which will streamline compliance but requires immediate technical readiness. Failure to test adequately could disrupt compliance when go-live is announced.

What you must do

Who it affects

All Authorised Persons (Indian Agents) under Money Transfer Service Scheme, Banks acting as Indian Agents for money transfers, Compliance and reporting teams handling CTRs and STRs

❓ Common questions

What is the purpose of the 'Test Mode' on FINnet Gateway?

It allows Authorised Persons to test their ability to upload CTRs and STRs electronically in XML format before the mandatory go-live, ensuring systems are ready for full electronic reporting.

Do we need to stop CD submissions during the test phase?

No, existing CD submissions must continue as before until FIU-IND announces the go-live date, after which the CD procedure will be discontinued.

What is the provisional go-live date mentioned in the circular?

The provisional go-live date is October 1, 2012, but this will be confirmed separately by FIU-IND. Until then, test mode submissions and CD submissions both remain in effect.

📜 Read the original circular — full text as issued by RBI
RBI/2012-13/246 A.P. (DIR Series) Circular No. 43 October 12, 2012 To, All Authorised Persons, who are Indian Agents under Money Transfer Service Scheme. Madam/ Dear Sir, Uploading of Reports in 'Test Mode' on FINnet Gateway Please refer to Annex- III to A.P.(DIR Series) Circular No.18 [A.P.(FL/RL Series) Circular No. 05] dated November 27, 2009, prescribing reporting formats for Authorised Persons (Indian Agents) as required under provisions of PML Rules  2005. In this connection, we invite your attention to FIU-IND's letter F.No.9-29/2011-FIU-IND dated March 31, 2011 advising Authorised Persons (Indian Agents) to go through reporting formats viz. Cash Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) and initiate urgent steps to develop capacity to generate reports compliant with the XML format specifications and be in readiness to implement the new format as and when advised by the FIU-IND. 2. FIU-IND have now advised vide their letter F.No.9-29/2011-FIU-IND dated August 28, 2012 (contents of the letter given in the Annex ), that all Authorised Persons (Indian Agents) should initiate submission of reports on the FINnet Gateway in 'Test Mode' from August 31, 2012 to test their ability to upload the report electronically. Such submission in 'Test Mode' would continue till FIU-IND informs the Authorised Persons (Indian Agents) about 'go-live' of the project. Authorised Persons (Indian Agents) are also required to continue to submit the existing reports in CD as presently required till further notice. All Authorised Persons (Indian Agents) are accordingly advised to take action as required by FIU-IND. 3. All other instructions issued vide A.P.(DIR Series) Circular No. 18 [ A.P.(FL/RL Series) Circular No. 05 ] dated November 27, 2009, as amended from time to time will remain unchanged. 4. Please advise your Principal Officer to acknowledge receipt of this circular. 5. 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 and are without prejudice to permission/approvals, if any, required under any other law. Yours faithfully, (Rudra Narayan Kar) Chief General Manager F.No.9-29/2011-FIU-IND Government of India Ministry of Finance Department of Revenue Financial Intelligence Unit-India 6th Floor, Hotel Samrat Chanakyapuri, New Delhi – 110 021 Date: August 28, 2012 OFFICE MEMORANDUM Subject:- Upload of Reports in 'Test Mode' on FINnet Gateway Kindly refer to OM of even no. dated 31st March, 2011 releasing the new reporting format under Project FINnet. The reporting entities were advised to initiate urgent steps to build capacity to generate reports, which are compliant with the XML format specifications. 2. You may kindly now advise the reporting entities to initiate submission of reports on the FINnet gateway in 'TEST MODE' from 31-08-2012 to test their ability to upload the report electronically. The reporting entities may contact FIU Help Desk at email or phone numbers 011-24109792/93 for any clarification or assistance. 3. The reporting entities may continue to submit the reports to FIU-IND in CD form as per earlier prescribed reporting format till go-live date (provisional go-live date is 1st October, 2012) after which the earlier procedure will be discontinued. The go-live date will be communicated to the reporting entities separately. 4. This issues with the approval of Director (FIU-IND). (Sanjeev Singh) Additional Director
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2012-13/246 · issued 12 Oct 2012. The plain-English explanation above is BankPulse’s own independent summary.
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Who does what — compliance checklist
💻 IT / Systems
  • Ensure your systems generate reports compliant with XML format specifications as per FIU-IND guidelines.
📜 Compliance
  • Initiate submission of CTRs and STRs in 'Test Mode' on FINnet Gateway immediately if not already started.
  • Continue submitting existing reports in CD format until FIU-IND announces the go-live date.
  • Contact FIU Help Desk at 011-24109792/93 for any technical assistance or clarifications.
  • Advise your Principal Officer to acknowledge receipt of this circular.
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 (Indian Agents) under Money Transfer Service Scheme, Banks acting as Indian Agents for money transfers, Compliance and reporting teams handling CTRs and STRs), your first concrete step on “FINnet Gateway Test Mode Reporting for Money Transfer Agents (Circular dated October 12, 2012)” is: “Initiate submission of CTRs and STRs in 'Test Mode' on FINnet Gateway immediately if not already started.” (RBI issued this 12 Oct 2012).

  1. Circular: RBI/2012-13/246 -- FINnet Gateway Test Mode Reporting for Money Transfer Agents (Circular dated October 12, 2012)
  2. Issued: 12 Oct 2012
  3. Action required: Initiate submission of CTRs and STRs in 'Test Mode' on FINnet Gateway immediately if not already started.
  4. Action required: Ensure your systems generate reports compliant with XML format specifications as per FIU-IND guidelines.
  5. Action required: Continue submitting existing reports in CD format until FIU-IND announces the go-live date.
  6. Action required: Contact FIU Help Desk at 011-24109792/93 for any technical assistance or clarifications.
  7. Action required: Advise your Principal Officer to acknowledge receipt of this circular.
  8. Owner: ____________ Target date: ____________
  9. Board/committee approval needed? Y / N
  10. 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.

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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=7621&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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