NBFC

Detailed Overview of FIU-IND Reporting

FIU-IND Reporting

The Government of India has set up Financial Intelligence Unit – India which is known as the Central National Agency. FIU-IND is responsible for receiving, processing, analyzing and disseminating information relating to the financial transactions which are suspicious. It is an independent body which directly reports to the Economic Intelligence Council headed by the finance Minister. In this article, we will discuss more about FIU-IND reporting.

What is FIU-IND Reporting?

To prevent the money laundering Act, every reporting entity i.e. Financial Institution, NBFCs, banking companies and their intermediaries are required to furnish to FIU-IND reporting in the form of CTRs (Cash reporting transaction), STRs (Suspicious Transaction Reporting), Counterfeit Reporting Transactions and NTRs (Non-profit transaction reports).

ARF Format ARF Format for reporting of account-based transaction which can be cash transaction, suspicious transaction and counterfeit transaction).
TRF Format TRF Format for reporting of Transaction-based transaction which can be cash transaction, suspicious transaction and counterfeit transaction).
CCR Format CCR Reporting for reporting of Counterfeit currency reporting

What are the FIU-IND Reporting Entities?

Reporting Entities are banking company, Financial Institution, Intermediary, chit fund company, Co-operative Bank, Housing Finance Company and Non-Banking Financial Company (NBFC) who are regulated by the respective authority to perform their business activity.

FIU-IND Reporting

What are the functions performed by the FIU-IND?

The major function performed by the FIU-IND team is to analyze received information and to uncover the patterns of transaction suggesting suspicion of money laundering as it acts as the central reception point for receiving the CTRs, STRs and reports on purchase or sale of immovable property.

  • To assist the reporting entities, FIU-IND[1] has developed a Report Generation Utility and Report validation utility in the preparation of the prescribed reports.
  • Reporting entities are encouraged to shift to fixed width data structure before generating XML reports at their end.
  • To assist the reporting entities who have technical capabilities to generate XML reporting from their system.
  • Advise the reporting entities to go through the reporting formats carefully and to initiate urgent steps to build capacity to generate reports in compliance with the XML Format specifications.
  • Inform the reporting entities about the date of transition from the old reporting format to the new reporting format.
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All the instructions are issued with the approval of director (FIU-IND).

What are the obligations of reporting entity under FIU-IND Reporting?

  • Every reporting entity is required to report and verify and maintain the records of the identity of all the clients in such a manner and process as prescribed under the section of Prevention of Money Laundering Act, 2002.
  • Every reporting company shall at the time of commencement its business activity-

Identify and verify the information of the clients and the nature of business relationship, and where the transaction of an amount is equal to or exceeds Rs 50,000 by the means of single transaction or several transactions or any international money transfer transaction.

Exception – When there is account based transaction and the regulator is of the view that money laundering and terrorist financing risks are effectively managed, in that case it is not essential to conduct the client due diligence by interrupting the normal conduct of business. The reporting authority will allow completing the verification as soon as reasonably practicable following the establishment of the relationship

  • To follow the KYC (Know your customer) guidelines.
  • To focus on Client identification a risk assessment program as the reporting companies are not allowed opening any anonymous or fictitious account whose identity has not been disclosed and cannot be verified.
  • To mitigate the risk factor, the reporting entity shall carry out risk assessment to identify and take measures to mitigate the activities relating to money laundering and terrorist financing risks.
  • Implementation of Client Due Diligence program by including policies and procedures to mitigate the risk.
  • Maintenance of records of all transactions by the reporting entity and submitting it to the director at such intervals as prescribed under prevention of Money Laundering Act.
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Method of Filing Reports

Electronic filing over secure gateway is only available for filing reporting.

Note – Manual filing and electronic filing on CD is not available for filing FIU-IND reporting.

Multiple data files reporting format is being replaced by a single XML file format.

Note – FIU-IND will process received financial information and implement actionable intelligence in appropriate cases. It is not a regulatory authority but has a prime responsibility to gather and share financial transaction.

What are due dates for filing Reports to FIU-IND?

The due dates for filing reports are –

  • CTR

All the cash transaction reporting whose value is more than 10 lakh rupees or the transactions integrally related to each other whose value is less than 10 lakh rupees and a series of transactions have taken place within a month have to file CTR Reporting on the 15th day of the succeeding month.

Note – Transaction equivalent in foreign currency is covered under the same due date report filing compliance.

All transactions where counterfeit currency notes have been used also have to file CCR Reporting on the 15th day of the

  • NTR

ALL transactions involving receipts by non-profit organizations of value more than Rs.10 Lakh or, its equivalent in foreign currency have to file NTR Reporting on the 15th day of the succeeding month.

FIU-IND and NBFC

NBFC is required to get the FIU-IND registration by following the below mentioned steps –

  • Go to https://finnet.gov.in/
  • Click Register New User on login page to go to Search Reporting Entity page.
  • Click on Register new Reporting Entity, ‘Click Here’
  • Enter basic details of the reporting entity such as reporting entity name, reporting entity category and details of the user. Click Submit.
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It displays the following message: “The following registration details of the reporting entity have been submitted to FIU-IND. Your Reporting Entity registration request number is: ________.

  • Click on the registration request number to take the printout and send a scan copy or a hard copy to FIU.
  • Scan copy should be emailed to ctrcell@fiuindia.gov.in
  • Paper/ hard copy may be posted to Director, Financial Intelligence Unit.
  • Envelope containing the Registration request should be super scribed as “New Registration Request”

On approval, the FIUREID (the unique identity number of your organization registered with FIU-IND) will be communicated at the email ID provided.

For more details, please contact us at Enterclice.com

Read our article: Financial Intelligence Unit of India

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