What changed
RBI issued a circular on September 4, 2013, referencing FATF's updated June 21, 2013 statement on AML/CFT compliance. It advises Authorised Persons (Indian Agents) under the Money Transfer Service Scheme to factor in the new FATF information. The circular also extends these guidelines to sub-agents, with Indian Agents responsible for their adherence.
What it means for you
Indian banks acting as MTSS agents must update their AML/CFT risk assessments based on FATF's latest list of high-risk jurisdictions. This does not ban transactions but requires enhanced due diligence. Banks must also ensure their sub-agents comply, shifting compliance responsibility upstream.
What you must do
- Review FATF's June 2013 statement and compliance document from the provided URLs.
- Update internal AML/CFT policies for cross-border inward remittances under MTSS.
- Ensure sub-agents are informed and adhere to the updated guidelines.
- Have your Principal Officer acknowledge receipt of this circular to RBI.
Who it affects
Authorised Persons (Indian Agents) under MTSS, Sub-agents of Indian Agents under MTSS, Banks handling cross-border inward remittances
Does this circular ban transactions with listed jurisdictions?
No, it explicitly states that legitimate transactions with these countries and jurisdictions are not precluded.
Who is responsible for sub-agent compliance?
Indian Agents (Authorised Persons) bear sole responsibility for ensuring their sub-agents adhere to these AML/CFT guidelines.