AML / KYC & PMLA Compliance Officer — India Practitioner

The onboarding rule book, read as a working document and not an academic index. The three CDD tiers of Rule 9. The officially valid documents list. V-CIP standards under RBI MD KYC Para 18 and when Aadhaar face authentication became an acceptable mode after the Second Amendment of 14 August 2025. The CKYCR push-and-pull obligation under Rule 9(1C) added by GSR 419(E) of 19 July 2024 and the stale-KYC trap it closed. Rule 9A and the Section 11A Aadhaar authentication framework. The deliverable is a KYC intake form with three-tier branching that your onboarding team can run on day one.

1. 1. Rule 9 and the three CDD tiers. When simplified, when regular, when enhanced 12 min
2. 2. Officially valid documents and V-CIP under RBI MD Para 18 13 min
3. 3. The CKYCR push-and-pull flow under Rule 9(1C), as GSR 419(E) rewrote it 12 min
4. 4. Rule 9A, Section 11A PMLA and the two Aadhaar paths 12 min
5. 5. The RBI KYC Second Amendment of 14 August 2025, provision by provision 13 min

Where the theory of Rule 9 meets the practice of a Monday morning onboarding desk. The onboarding workflow and risk scoring. Beneficial-ownership tracing at the post-2023 thresholds of more than 10 percent of capital or profits for a company and more than 15 percent for partnerships and trusts (any template still carrying 25 percent is stale). PEP identification covering foreign PEPs, domestic PEPs, family members and close associates. Source of funds and source of wealth as two different documents. The FATF black and grey lists, UNSC 1267, UAPA Section 51A. One fully-worked beneficial-ownership tracing on a case-study customer.

1. 1. The onboarding workflow and Day 1 risk scoring, built around a Pashupati Finserv gold-loan customer 12 min
2. 2. Beneficial-ownership tracing at the post-2023 thresholds, with a worked four-level corporate structure 13 min
3. 3. PEP identification: foreign PEPs, domestic PEPs, family members and close associates, without the common-name false positives 12 min
4. 4. Source of funds and source of wealth, as two separate documents on three distinct pieces of evidence 12 min
5. 5. High-risk jurisdictions and sanctions screening: FATF lists, UNSC 1267, MHA UAPA Section 51A, and the Day 1 scoring call 13 min

The lesson that produces most of your work and most of your false positives. Scenario design and the red-flag typology library. Alert triage and the twenty-eighty rule. FIU-IND published typologies and how to read them in a Monday morning review. Twenty case-study red flags drawn from FIU-IND published orders and ED prosecutions, each with the structural pattern, the trigger values and the next step. The handoff from alert to STR escalation.

1. 1. Scenario design that is tied to Rule 3 reporting categories, not to vendor presets 13 min
2. 2. Alert triage, the 20-80 rule, and how to document closed alerts for the Section 70 defence 13 min
3. 3. How to read FIU-IND typologies and feed them back into scenario design 13 min
4. 4. Twenty case-study red flags drawn from FIU-IND published orders and ED prosecutions 15 min
5. 5. The handoff from alert to STR, and how to preserve the Rule 7 satisfaction clock 13 min

The reports that actually leave your building. CTR for cash above Rs 10 lakh (single or integrally connected in a month). NTR for non-profit receipts above Rs 10 lakh. CBWTR for cross-border wire transfers of Rs 5 lakh or more in foreign currency. CCR for counterfeit currency. STR for reason-to-believe. The Rule 7 window of promptly and not later than seven working days from the Principal Officer being satisfied (not from the transaction, the most-mistaught fact in Indian AML training). FINnet 2.0 form-wise walk-through. Three worked STR narratives for a cash-structuring pattern, a trade-based pattern and a mule-account pattern.

1. 1. The five reports in Rule 3, and what each one is actually asking you to say 12 min
2. 2. The STR filing window under Rule 7. Satisfaction is the clock, not the transaction 14 min
3. 3. CTR, NTR, CBWTR and CCR mechanics. Thresholds, traps and the integrally-connected rule 13 min
4. 4. FINnet 2.0 end to end. FINGate collection, FINCore processing, FINex dissemination 12 min
5. 5. The STR narrative drill. Three worked examples a Principal Officer should be able to write in his sleep 14 min

The role itself. The appointment resolution that your Board must pass. The FIU-IND registration walk-through on FINnet 2.0. The internal AML policy with its twelve non-negotiable clauses. The Board reporting cadence of monthly, quarterly, half-yearly and annual touchpoints. The personal liability framework under Section 13(2) and Section 70 PMLA, and the senior-management defence that comes from documented decisions, not oral assurances.

1. 1. The eleven-paragraph Board resolution appointing your Principal Officer, paragraph by paragraph 13 min
2. 2. FIU-IND registration on FINnet 2.0, step by step, and how to keep it current when the Principal Officer changes 12 min
3. 3. The internal AML policy, twelve non-negotiable clauses with specimen language 14 min
4. 4. Board reporting cadence, the KPIs that matter and the six-slide deck template 12 min
5. 5. The personal liability shield. Section 13(2), Section 70 and the senior-management due-diligence defence 13 min

The paperwork that keeps the Principal Officer out of a Section 63 proceeding. Section 12 obligations on record-keeping and verification of identity. The five-year rule from Section 12 and Rule 10. Electronic storage, data residency, encryption and access logs. Inspection-readiness and the three questions an FIU-IND inspector will open with. The retention schedule as a layered artifact: PMLA floor, RBI MD KYC overlay, SEBI MC AML overlay, IRDAI AML MG overlay, Companies Act Section 128 overlay. Reconstructing a customer file in under thirty minutes.

1. 1. Section 12 obligations and the five-year rule, from first touch to final deletion 12 min
2. 2. Electronic storage, data residency and the audit trail that an inspector will actually trust 12 min
3. 3. Inspection readiness, or the three questions an FIU-IND inspector opens with 12 min
4. 4. The layered retention schedule across PMLA, RBI, SEBI, IRDAI and Companies Act 13 min
5. 5. Reconstructing a customer file in under thirty minutes using an indexed record store 12 min

The compliance function that creates the loudest false positives and the most consequential true positives. UNSC 1267 and MHA UAPA Section 51A on mandatory screening and freezing. The OFAC overlap and extraterritorial exposure for Indian REs with USD correspondent relationships. The screening SOP across onboarding, periodic and event-driven triggers. Name-match heuristics covering fuzzy matching, transliteration and the common-name false-positive patterns that eat analyst time. The three-step remediation of a true hit: freeze, report, close.

1. 1. UNSC 1267 as the base list, and UAPA Section 51A as the Indian freezing power that actually bites 12 min
2. 2. OFAC overlap, the correspondent-banking fault line, and the extraterritorial exposure every Indian reporting entity now carries 12 min
3. 3. The screening SOP across three triggers: onboarding, periodic, event-driven 12 min
4. 4. Fuzzy matching, transliteration, and the tuning problem of catching Mohammed Ali without freezing every Mohammed Ali in Pune 13 min
5. 5. Remediation of a true hit. Freeze under UAPA 51A, report under Rule 7, close under regulator direction 13 min

One lesson for each of the five sectors every Indian AML practitioner must be literate in. Banks and NBFCs under the RBI KYC MD Second Amendment of 14 August 2025 and the February 2026 non-compliant NBFC list of 3,910 base-layer and 102 middle-layer entities. Securities intermediaries under the SEBI AML Master Circular with the October 2025 draft refresh in consultation. Insurance under the IRDAI AML Master Guidelines 2022 and the August 2024 CKYCR port. Fintech, Payment Aggregators and PPIs with the Paytm Payments Bank Rs 5.49 crore order of 1 March 2024 as taught case law. VDA Service Providers with 54 registered as of July 2026, the October 2025 fresh notices to 25 offshore SPs, and the Travel Rule for VDA transfers above Rs 50,000.

1. 1. Banks and NBFCs after the RBI KYC Second Amendment of 14 August 2025, with the February 2026 non-compliant NBFC list on the Board table 13 min
2. 2. Securities intermediaries under the SEBI AML Master Circular, with the October 2025 draft refresh on the horizon 13 min
3. 3. Insurance under the IRDAI AML/CFT Master Guidelines 2022, with the 12 August 2024 CKYCR port in your calendar 13 min
4. 4. Fintech, Payment Aggregators and PPIs, with the Paytm Payments Bank order of 1 March 2024 taught as case law 14 min
5. 5. VDA Service Providers after S.O. 1072(E) of 7 March 2023, with Binance, Bybit and the October 2025 offshore notices on the record 14 min

The lesson that converts fear into focus. ED powers across attachment, prosecution and the Section 45 bail bar. Section 63 and Section 13(2)(d) penalty slabs from Rs 1 lakh to Rs 1 crore per failure. The Supreme Court position after Vijay Madanlal Choudhary 2022 and what the pending review will clarify. Four live FIU penalty orders dissected lesson by lesson: Paytm Rs 5.49 crore (1 March 2024), KuCoin Rs 34.5 lakh (22 March 2024), Binance Rs 18.82 crore (19 June 2024) and Bybit Rs 9.27 crore (31 January 2025). ED statistics for FY 2024-25: 775 new ECIRs, Rs 30,036 crore attached in 461 provisional attachment orders, cumulative Rs 1,54,594 crore under attachment, 93.33 percent conviction rate on trial-completed cases.

1. 1. ED powers under PMLA, and the Section 45 bail bar every Principal Officer must understand before the first summons 13 min
2. 2. Section 63 PMLA and the Section 13(2)(d) penalty slabs, with a worked penalty computation for a mid-size NBFC 12 min
3. 3. Vijay Madanlal Choudhary 2022, Pavana Dibbur 2023 and the Ganpati Dealcom recall. What the Supreme Court actually did to PMLA 13 min
4. 4. Four live FIU-IND compliance orders dissected: Paytm, KuCoin, Binance, Bybit 15 min
5. 5. ED statistics FY 2024-25, the FATF 2027 forcing function, and the Board-ready briefing format every Principal Officer must master 12 min

The newer and lighter-infrastructure cohort of Reporting Entities. The May 2023 Ministry of Finance notification S.O. 2036(E) bringing in Chartered Accountants, Company Secretaries and Cost Accountants, and the five activities that trigger reporting-entity status. The pending Delhi High Court writ with interim relief declined. The FIU-IND registration walk-through for a professional firm and the ICSI, ICAI and ICMAI member guides. Real-estate agents and developers under the March 2023 notification with risk-based rather than threshold-based compliance. Multi-State Co-operative Societies under the FIU guidelines effective 11 October 2024. The Prevention of Corruption Act 2018 Section 10 adequate-procedures defence for commercial organisations as the India-equivalent of the UK Bribery Act Section 7.

1. 1. S.O. 2036(E) of 3 May 2023. How a CA, CS or CMA firm became a Reporting Entity overnight 12 min
2. 2. FIU-IND registration for a CA, CS or CMA firm. The walkthrough nobody wrote 13 min
3. 3. Real-estate agents and developers under S.O. 1073(E). Why there is no threshold and what a Rs 15 crore Mumbai deal looks like in file form 12 min
4. 4. Multi-State Co-operative Societies under the 11 October 2024 FIU-IND Guidelines. Gandhinagar Nagarik and Rajgurunagar Sahakari as teaching cases 13 min
5. 5. Prevention of Corruption Act Section 10. Building the adequate-procedures defence and why PCA Sections 7, 8 and 13 are PMLA scheduled offences 14 min

The capstone walks you through a complete ten-week AML programme on Pashupati Finserv, a fictional Pune NBFC with a Rs 1,200 crore gold-loan and personal-loan book across 48 branches. You produce every artifact from Modules 1-11 on this one entity and submit a complete programme file. The final exam is 45 questions drawn from a 70-item pool, covering every module, with each question anchored to a specific Section, Rule, Gazette notification, Master Direction, Master Circular, FIU-IND guideline or compliance order cited in the course.

1. 1. Build your ten-week AML programme. The scope document and the stakeholder map 11 min
2. 2. Weeks 1-10 Gantt and the twelve artifacts of the capstone workbook 11 min
3. 3. The Board briefing deck and the year-1 operating calendar 11 min
4. 4. The 25-anchor exam reference card 10 min
5. 5. The final exam. 45 questions from a 70-item pool, 90 minutes, 75 percent pass 10 min