Financial Intelligence Unit What is FIU Registration? Section 12 of PMLA, 2002 and rules there under require every reporting entity to check and verify and maintain the records of the identity of all its clients including beneficial owners. For verification and maintenance of records of the identity of clients are prescribed under Rules 9 and 10 of PMLA Rules. Who are Reporting Entity? FIU-IND has identified following entity to be registered under FIU-IND and providing report of transaction to following entity are as follow: Banking CompanyFinancial InstitutionIntermediaryChit Fund CompanyCo-operative BankHousing Finance InstitutionNon-Banking Financial Company Verification of identity On transaction of an amount equal to or exceeding Rs. 50,000/- whether conducted as a single transaction or several transactions that appear to be connected or any international money transfer operations Documents for Identity of Client Individual One certified copy of an officially valid document containing details of identity and address One recent photograph and Such other documents including in respect of nature of business and financial status of the client as may be required by the reporting entity Company Certificate of Incorporation (COI)/MOA & AOA of Company Resolution from BOD and POA granted to its managers, officers or employees to transact on its behalf and Officially valid document in respect of managers, officers or employees holding an attorney to transact on its behalf. Partnership Firm Registration Certificate Partnership Deed An officially valid document in respect of the person holding an attorney to transact on its behalf Trust Registration Certificate Trust Deed An officially valid document in respect of the person holding an attorney to transact on its behalf UIB/BOI Resolution of Managing body of such association or body of individuals POA granted to him to transact on its behalf An officially valid document in respect of the person holding an attorney to transact on its behalf Such information as may be required by reporting entity to collectively establish the legal existence of such association or Body of Individual (BOI) *Note: Officially valid Document means passport, driving license, PAN, Voter Identity Card as per Section 2(d) of PMLA Rules, 2005. Suspicious Transaction means a transaction whether or not made in cash which, to a person acting in good faith- Give rise to a reasonable ground of suspicion that it may involve the proceeds of crime; orAppears to be made in circumstances of unusual or unjustified complexity; orAppears to have no economic rationale or bonafide purpose (As per Definition is given u/s 2(g) of PMLA Rules, 2005) The records of the identity of clients and its beneficial owners shall be maintained for a period of 5 years after the business relationship between a client and reporting entity has ended or the account has been closed, whichever is later. [Section 12(4) of PMLA Act, 2002] Maintenance of Records of Transaction Transaction to be a record of are:- All cash transaction of the value more than Rs. 10 lakhs or its equivalent in foreign currencyAll series of cash transaction integrally connected to each other which have been valued below Rs. 10 lakhs or its equivalent in foreign currency where such series of transaction have taken place within monthsAll transaction involving receipts by a non-profit organization of value more than Rs. 10 lakhs or its equivalent in foreign currencyAll cash transaction where forged or counterfeit currency notes or bank notes have been used as genuine or where any forgery of valuable security or a document has taken place facilitating the transactionSuspicious transaction whether in cash or notAll cross-border wire transfer of the value of more than Rs. 5 lakhs or its equivalent in foreign currency where either the origin or destination of fund is in IndiaAll purchase and sale by any person of immovable property valued at Rs. 50 lakhs or more that is registered by the reporting entity. And of course, this transaction to be furnished by every reporting entity to FIU-IND on prescribed format and as per regulation there under. Records should contain following information Nature of transaction Amount of transaction and currency in which it was denominated Date on which transaction was conducted and Parties to the transaction Over and above of regular maintenance of records of transaction. Such records to be maintained for a period of 10 years from the date of cessation of transaction as per Rule 6 of PMLA, 2005. Reports to be submitted There are 5 types of reporting format i.e. Cash Transaction Report (CTR), Suspicious Transaction Report (STR), Counterfeit Currency Report (CCR), Cross-Border Wire Transfer Report (CBWTR) and Report on sale/purchase of immovable property (IPR). The method of filing is electronic over secure gateway. S.NoReportDescriptionDue Date1CTRRs. 10 lakh or more15th day of succeeding month2CCRForged or Counterfeit currency15th day of succeeding month3NTRAll transaction involving receipts by NPO of value more than Rs. 10 lakhs or more15th day of succeeding month4CBWTRCross-Border Transfer Rs. 5 lakhs or more15th day of succeeding month5IPRSale purchase of Immovable property value exceeding Rs. 50 lakh or more15th day of the month succeeding the quarter6STRAll suspicious transaction whether or not made in cashNot later than 7 working days on being satisfied that the transaction is suspicious *For NBFC: CTR for each month should be submitted to FIU-IND by 15th of the succeeding month. While filing CTR, individual transaction below Rs. 50K may not be included. Principal Officer (PO) will be responsible for timely submission of CTR and STR to FIU-IND. All branches to be consolidated and file at one report electronically. The NBFCs are required to report information relating to cash (CTR) and suspicious transaction (STR) to Director, Financial Intelligence Unit India, 6th Floor, Hotel Samrat, Chanakyapuri. New Delhi-110021. [Based on Notification No. RBI-2005-06/352 DNBS(PD). CC 68/03.10.042/2005-06 dated 5th April 2006] How to get reporting format? The format of reporting transaction is available in the “Downloads” section of the FIU-IND website. The same need to first generate and validate in another stage then XML file be uploaded after duly log in to the site. Registration of Reporting Entity It is most to know the registration is of two-person i.e. first entity itself and second is registration of principal officer. To register both the following things are required to do:- Go to http://finnet.gov.in/ and Click on new user on the login page. Click on register new reporting entity. Fill the basic details of reporting entity such as reporting entity name, category and details of user and submit the form. After that, the message displayed saying the details of reporting entity have been submitted to FIU-IND which provides a reporting entity registration request number. Click on registration request number to take print out and send a copy or hard copy to FIU. Scan copy should be emailed to ctrcell@fiuindia.gov.in. Paper/hard copy may be posted to Director, FIU-India, 6th Floor, Hotel Mandatory documents: Scope of the Quality Management System (QMS) (clause 4.3)Quality policy (clause 5.2)Quality objectives (clause 6.2)Criteria for evaluation and selection of suppliers (clause 8.4.1) Please note that records marked with * as mentioned below, are only mandatory in cases when the relevant clause is not excluded from the scope of the QMS: Mandatory records: Monitoring and measuring equipment calibration records* (clause 7.1.5.1)Records of training, skills, experience and qualifications (clause 7.2)Product/service requirements review records (clause 8.2.3.2)Record about design and development outputs review* (clause 8.3.2)Records about design and development inputs* (clause 8.3.3)Records of design and development controls* (clause 8.3.4)Records of design and development outputs *(clause 8.3.5)Design and development changes records* (clause 8.3.6)Characteristics of product to be produced and service to be provided (clause 8.5.1)Records about customer property (clause 8.5.3)Production/service provision change control records (clause 8.5.6)Record of conformity of product/service with acceptance criteria (clause 8.6)Record of nonconforming outputs (clause 8.7.2)Monitoring and measurement results (clause 9.1.1)Internal audit program (clause 9.2)Results of internal audits (clause 9.2)Results of the management review (clause 9.3)Results of corrective actions (clause 10.1) Non-mandatory documents: There are many non-mandatory documents that may be used for ISO 9001 implementation as the list is exhaustive. However, there is a general consensus among ISO consultants at Mumbai & various quality interpreters across the globe, that following non-mandatory documents are most commonly used: Procedure for determining context of the organization and interested parties (clauses 4.1 and 4.2)Procedure for addressing risks and opportunities (clause 6.1)Procedure for competence, training and awareness (clauses 7.1.2, 7.2 and 7.3)Procedure for equipment maintenance and measuring equipment (clause 7.1.5)Procedure for document and record control (clause 7.5)Sales procedure (clause 8.2)Procedure for design and development (clause 8.3)Procedure for production and service provision (clause 8.5)Warehousing procedure (clause 8.5.4)Procedure for management of non conformity and corrective actions (clauses 8.7 and 10.2)Procedure for monitoring customer satisfaction (clause 9.1.2)Procedure for internal audit (clause 9.2)Procedure for management review (clause 9.3) , New Delhi-110021. Envelope containing registration request should be superscripted as “New Registration Request. On approval, The FIUREID (unique identity number of an organization registered with FIU-IND) will be communicated to the email ID provided. The process to register the Principal Officer is as like registration of Reporting Entity but it will be enabled only after Entity registration on the FIU-IND portal. Both registration process is just to fill up the basic credentials of Reporting The Entity and Principal Officer, no need to upload any documents. Checklist for Registration For Entity: Registration Number granted by RegulatorName of User, Contact Number (11 digits) & Email Id For Principal Officer: Aadhar Card of Principal OfficerTelephone Number of Officer is mandatoryMobile No. & Email Id (Preferably organization email-id) book mark this link