Guide

KYC/AML Policy Requirements for NBFCs: What RBI Actually Expects

KYC, AML and PMLA obligations for NBFCs — CDD/EDD, transaction monitoring, FIU-IND reporting and the policy framework RBI inspectors test.

RBI’s KYC Directions and the Prevention of Money Laundering Act (PMLA) make financial-crime controls mandatory for every NBFC — including digital lenders. Inspectors don’t just read your policy; they test whether it works. Here’s what the framework must contain.

  • RBI Master Direction on KYC — customer identification, risk categorisation, periodic updation
  • PMLA, 2002 — NBFCs are reporting entities: maintain records, report prescribed transactions to FIU-IND
  • Your board-approved KYC/AML policy — the document everything else hangs from

The five pillars

1. Customer Acceptance Policy

Who you onboard — and who you don’t. Defined customer types, documentation standards, and escalation for high-risk cases.

2. Customer Identification (CIP)

Verify identity and address through prescribed documents. For digital onboarding, RBI permits modes like video-based customer identification (V-CIP) with safeguards — choose deliberately and document the choice.

3. Risk categorisation & CDD/EDD

  • Customer Due Diligence (CDD): standard verification for all customers
  • Enhanced Due Diligence (EDD): deeper scrutiny for high-risk customers — PEPs, complex structures, high-risk geographies
  • Simplified measures where RBI permits for low-risk customers

4. Transaction monitoring

Ongoing monitoring with defined scenarios, thresholds and alert-handling SOPs. Monitoring must be risk-based, not a flat rule for everyone.

5. Reporting & record-keeping

Suspicious Transaction Reports (STRs) to FIU-IND, cash transaction reporting as prescribed, and records retained per PMLA timelines. Appoint a Principal Officer and Designated Director with documented charters.

What inspectors test

  • Sample customer files: is CDD complete and risk-graded correctly?
  • Alert handling: were monitoring alerts investigated and escalated on time?
  • STR discipline: are suspicious transactions identified and reported, not just filed away?
  • Training records: can front-line staff explain the policy?

Frequently asked questions

How often must KYC be updated? Periodically, based on risk categorisation — high, medium and low-risk customers at different intervals prescribed by RBI.

Does PMLA apply to small NBFCs too? Yes. There is no de minimis exemption for reporting entities.

Can we use Aadhaar-based e-KYC? Yes, within the prescribed modes and with customer consent — document your chosen modes in the policy. Our KYC/AML advisory designs the full framework.

Need help applying this? This guide is general information, not advice for your specific situation. WhatsApp our team or send an enquiry for a free initial consultation.
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