The Reserve Bank of India outlines detailed responsibilities for banks under the Know Your Customer (KYC) guidelines to ensure compliance, security, and effective customer management. Here’s a closer look:


1. Regular Updates of Customer Records

Banks must:

  • Maintain accurate and up-to-date information about all customers, including periodic KYC updates.
  • Categorize customers as low, medium, or high-risk, and monitor accounts more frequently if they are deemed higher risk.
  • Ensure adherence to timelines for KYC updates:
  • High-risk: Every 2 years.
  • Medium-risk: Every 8 years.
  • Low-risk: Every 10 years.

2. Monitoring Transactions

  • Implement systems to monitor customer transactions regularly, ensuring activities align with the customer’s known profile.
  • Identify transactions that:
  • Are unusually large or inconsistent with the customer’s regular behavior.
  • Could be suspicious, such as frequent small deposits just below reporting thresholds.
  • Submit Suspicious Transaction Reports (STRs) to the Financial Intelligence Unit of India (FIU-IND) promptly when necessary.

3. Due Diligence

  • Conduct detailed Customer Due Diligence (CDD) procedures for specific entities, including individuals, partnerships, companies, trusts, sole proprietorships, etc. This includes verifying identities using government-issued documents such as Aadhaar, PAN cards, or passports.
  • Apply Enhanced Due Diligence (EDD) for accounts involving Politically Exposed Persons (PEPs) or for high-risk accounts. For example:
  • Verify the source of funds or wealth for such customers.
  • Obtain senior management approval before onboarding PEPs or continuing relationships with existing PEPs.

4. Reporting and Compliance

  • File reports regarding large cash transactions, suspicious activities, and international transfers exceeding certain limits.
  • Respond to queries from law enforcement and regulatory authorities swiftly by making transaction records available upon request.
  • Comply with international agreements and sanctions lists. For example:
  • Ensure no accounts are held or opened for entities on terrorist or money-laundering sanction lists.
  • Implement freezing or restricting actions on accounts as directed by government orders.

5. Technological and Procedural Safeguards

  • Use advanced systems capable of flagging anomalies in transactions.
  • Employ measures like Video-based Customer Identification Process (V-CIP) or digital KYC to verify customers remotely.
  • Ensure end-to-end encryption when handling sensitive customer data during KYC processes.

6. Staff Training and Accountability

  • Train employees, especially frontline staff, on KYC and Anti-Money Laundering (AML) requirements to ensure robust compliance.
  • Appoint a Principal Officer and Designated Director responsible for overseeing KYC compliance and ensuring all regulatory obligations are met.
  • Conduct audits to verify compliance with KYC guidelines and report findings to higher authorities regularly.

7. Record-Keeping

  • Maintain transaction and identification records for a minimum of five years, even after an account is closed.
  • Ensure quick retrieval of these records whenever required for investigation or audits.

Banks play a vital role in maintaining the integrity of the financial system by preventing fraud, money laundering, and other illicit activities.

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