KYC, AML & PMLA Obligations
KYC, AML and PMLA compliance for NBFCs: customer due diligence, transaction monitoring, KYC/AML policy drafting and PMLA reporting frameworks that stand up to RBI scrutiny.
RBI's KYC Directions and the Prevention of Money Laundering Act make customer due diligence, transaction monitoring and suspicious-transaction reporting non-negotiable for every NBFC — including digital lenders onboarding customers remotely.
We design and implement your financial-crime control framework: board-approved KYC/AML policies, risk-based CDD and EDD workflows, transaction-monitoring rules, and the reporting discipline (FIU-IND) that regulators expect.
What's included
Policy framework
- Board-approved KYC policy and AML policy drafted to RBI KYC Directions
- Customer acceptance, risk categorisation and due-diligence matrices
- PMLA compliance manual covering record-keeping and reporting duties
- Periodic policy review calendar aligned to regulatory changes
Due diligence & monitoring
- Customer due diligence (CDD) workflows for onboarding and periodic review
- Enhanced due diligence (EDD) triggers for high-risk customers and PEPs
- Transaction monitoring scenarios, thresholds and alert-handling SOPs
- Suspicious transaction identification, escalation and FIU-IND reporting discipline
Implementation & training
- Role-based AML training for front-line, operations and compliance teams
- Principal Officer / Designated Director appointment guidance
- Mock file reviews to test whether your controls work in practice
How we work
- Risk assessment. Enterprise-wide ML/TF risk assessment of your products, channels and customer base.
- Policy drafting. KYC/AML/PMLA policies tailored to your risk profile, not generic templates.
- Workflow design. CDD/EDD and monitoring workflows mapped to your systems.
- Training. Team training with case-based scenarios from NBFC practice.
- Testing. Sample-file testing and a remediation list before RBI looks.
What you receive
- Board-approved KYC policy, AML policy and PMLA manual
- CDD/EDD workflow documents and monitoring rulebook
- Training decks and attendance records
- ML/TF risk assessment report
KYC / AML / PMLA — FAQs
Yes. NBFCs are reporting entities under PMLA and must maintain records and report prescribed transactions to FIU-IND, alongside RBI KYC Direction compliance.
Customer Due Diligence is the standard verification for all customers; Enhanced Due Diligence applies extra scrutiny to higher-risk customers such as PEPs or complex structures. Your policy must define both triggers.
RBI permits several digital onboarding modes including video-based customer identification (V-CIP) with prescribed safeguards. We help you choose and document a compliant mode.
A senior management functionary designated to the role with FIU-IND reporting responsibility. We advise on appointment, role charter and succession.
RBI prescribes periodic updation based on risk categorisation — high, medium and low risk at different intervals. Your system must track and trigger reviews.
Need help with kyc / aml / pmla?
Free initial consultation — tell us your situation and we'll scope a fixed-fee engagement.