The International Financial Services Centres Authority (“IFSCA”), in exercise of the powers conferred under Section 12 read with Section 13 of the International Financial Services Centres Authority Act, 2019 and Rule 9(14) of the Prevention of Money-laundering (Maintenance of Records) Rules, 2000 (“PML Rules”), vide Circular No. F. No. IFSCA-DAC/7/2024-AMLCFT/01,[1] dated June 05, 2025, issued certain modifications to the International Financial Services Centres Authority (Anti Money Laundering, Counter-Terrorist Financing and Know Your Customer) Guidelines, 2022 (hereinafter referred as “Guidelines”), in line with the revised PML Rules, as notified on July 19, 2024
The IFSCA has announced several amendments, which are intended to align the Guidelines with recent updates to the PML Rules, and to enhance the robustness of customer due diligence and record-keeping practices.
Key Amendments to the Guidelines
- Clarification in Clause 1.3.30 of the Guidelines – Proof of Address Documents: The reference to ‘city council tax receipts’ has been removed as an acceptable proof of address under limited KYC scenarios.
- Revision to Guidance Note after Clause 5.4.3 of the Guidelines: When a customer submits documents such as bank or foreign bank statements (other than a Post Office or Indian bank statement) as proof of address, they shall also be required to furnish an updated Officially Valid Document (“OVD”) or its electronic equivalent with the current address within 3 (three) months. These documents shall only be treated as OVDs where simplified due diligence measures are applicable.
- Substitution of Sub-clause (b) to Clause 11.6 of the Guidelines – Know Your Customer (“KYC”) Record Retrieval and Use of CKYCR: Regulated Entities must retrieve KYC records using the KYC Identifier from the Central KYC Records Registry (“CKYCR”) instead of re-obtaining documents from customers. Exceptions to this mandate are allowed in the following cases:
- Customer information has changed;
- Retrieved records are incomplete or non-compliant;
- Validity of documents has lapsed;
- Further verification or enhanced due diligence is necessary.
- Insertion of Additional Sub-clauses to Clause 11.6 of the Guidelines
- Sub-clause (c): Any updated or additional KYC information collected must be uploaded to CKYCR within 7 (seven) days or as notified by the Central Government.
- Sub-clause (d): Upon update, CKYCR will notify all Regulated Entities who have dealt with the customer, who in turn must retrieve and update their records accordingly.
- Sub-clause (e): These requirements are now applicable to a broad category of entities, including but not limited to:
- Payment service providers
- IFSC Banking Units
- Finance companies (core)
- Broker-dealers
- Bullion traders
- Insurance companies (both life and general)
- Fund managers
- Clearing members, depository participants, and investment advisors
- Revised Guidance Note to Clause 11.6 of the Guidelines
- Indian nationals are required to have their KYC records submitted to CKYCR.
- For foreign nationals, this is not mandatory, but if a Regulated Entity chooses to submit such records:
- Documents issued by foreign government authorities or foreign embassies in India can be accepted as proof of current address.
- For identity and address, one of the following must be obtained: Passport; Driving License; or Voter ID card
[1]https://ifsca.gov.in/Viewer?Path=Document%2FLegal%2Fcircular-modification-of-ifsca-aml-ctf-kyc-guidelines-202205062025070603.pdf&Title=Modifications%20under%20the%20International%20Financial%20Services%20Centres%20Authority%20%28Anti%20Money%20Laundering%2C%20Counter-Terrorist%20Financing%20and%20Know%20Your%20Customer%29%20Guidelines%2C%202022&Date=05%2F06%2F2025