What changed
The circular extends the existing reporting obligation under PML Rules to include cross border wire transfers exceeding Rs. 5 lakh (or equivalent in foreign currency) where either the origin or destination is India. It specifies that the Transaction Based Reporting Format already used for CTRs, STRs, and NTRs must now be used for these wire transfers, with submission via the FIN-Net module.
What it means for you
Banks and other authorised persons acting as Indian Agents under MTSS must now systematically track and report all cross border wire transfers above the threshold. This tightens anti-money laundering compliance and requires integration of wire transfer data into existing FIU-IND reporting workflows. Non-compliance could attract penalties under FEMA and PMLA.
What you must do
- Update your internal systems to capture all cross border wire transfers of Rs. 5 lakh or more (or foreign currency equivalent) with India as origin or destination.
- Ensure your reporting team uses the Transaction Based Reporting Format available on the FIU-IND website for these transactions.
- Submit the reports electronically via the FIN-Net module to FIU-IND by the 15th of the month following the transaction month.
- Train relevant staff on the new reporting requirement and the use of the TRF format for cross border wire transfers.
Who it affects
All Authorised Persons who are Indian Agents under the Money Transfer Service Scheme (MTSS), Banks handling cross border wire transfers, Compliance and AML reporting teams
What is the threshold for reporting cross border wire transfers under this circular?
The threshold is Rs. 5 lakh or its equivalent in foreign currency, where either the origin or destination of the funds is in India.
By when must the report be submitted to FIU-IND?
The report must be furnished to the Director, FIU-IND by the 15th of the month succeeding the transaction month.
Which format should be used for reporting these wire transfers?
The existing Transaction Based Reporting Format (TRF) already used for Cash Transaction Reports, Suspicious Transaction Reports, and Non-Profit Organization Transaction Reports should be used.