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
- Initiate submission of CTRs and STRs in 'Test Mode' on FINnet Gateway immediately if not already started.
- Ensure your systems generate reports compliant with XML format specifications as per FIU-IND guidelines.
- 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.
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
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.