Executive Summary:
This circular from the Reserve Bank of India (RBI) extends the Centralized KYC Registry (CKYCR) to Legal Entities (LEs). It mandates Regulated Entities (REs) to upload KYC data of LE accounts opened on or after April 1, 2021, onto CKYCR. The circular also updates guidelines for uploading existing individual KYC records and using KYC identifiers. The updated Master Direction on KYC takes immediate effect.
Key Points / Main Content:
* **Extension of CKYCR to Legal Entities:**
* REs must upload KYC data for LE accounts opened on or after April 1, 2021, to CKYCR as per PML Rules.
* Legal Entity (LE) Template and Annex are provided (Annex A and Annex B).
* For LE accounts opened before April 1, 2021, KYC records should be uploaded during periodic updation or when updated KYC information is received.
* During periodic updation, LE KYC details must be migrated to current Customer Due Diligence (CDD) standards.
* **Individual KYC Record Updates:**
* REs must upload KYC data for individual accounts opened before January 1, 2017, during periodic updation or when updated KYC information is received.
* During periodic updation, individual KYC details must be migrated to current CDD standards.
* **KYC Identifier Usage:**
* If a customer submits a KYC Identifier with consent to download records from CKYCR, the RE should retrieve KYC records online.
* The customer should not be required to submit the same KYC records unless:
* There is a change in the customer's information.
* The current address needs verification.
* The RE needs to verify identity/address, perform enhanced due diligence, or build a risk profile.
* REs must communicate the KYC Identifier generated by CKYCR to the individual/legal entity.
* **Master Direction Update:**
* The Master Direction on KYC dated February 25, 2016, is updated to reflect these changes, effective immediately.
Impact Analysis:
* **Regulated Entities (REs):**
* *Impact:* REs need to modify their KYC processes to accommodate uploading LE data to CKYCR and handle KYC identifiers. REs also need to update existing individual KYC records.
* *Action Required:* REs must update systems to use the LE Template, upload KYC data for new and existing LE accounts, ensure migration to current CDD standards during updates, retrieve KYC records using identifiers when available, and communicate KYC identifiers to customers.
* **Legal Entities (LEs):**
* *Impact:* LEs will have their KYC data uploaded to CKYCR for easier verification by REs.
* *Action Required:* LEs should be prepared to provide KYC information in the format required by the LE Template and use the KYC identifier provided by the RE for future interactions.
* **Individual Customers:**
* *Impact:* Individuals may experience a streamlined KYC process if they provide their KYC identifier.
* *Action Required:* Individuals should provide their KYC identifier to REs when opening new accounts, if available, and inform REs of any changes to their KYC information.
Key Entities Referenced
Reserve Bank: Refers to the Reserve Bank of India (RBI), the central bank of India, which is responsible for regulating the banking sector and issuing guidelines on KYC and AML.
CKYCR: Centralized KYC Registry, a central repository for KYC data of customers, maintained by CERSAI. The document discusses extending CKYCR to Legal Entities.
CERSAI: Central Registry of Securitisation Asset Reconstruction and Security Interest of India, which maintains and releases the Legal Entity Template for CKYCR.
Legal Entities: Refers to non-individual entities like companies, partnerships, etc. The notification discusses extending CKYCR requirements to these entities.
Prevention of Money Laundering Maintenance of Records Rules, 2005: The legal framework under which regulated entities are required to upload KYC data to CKYCR.
KYC: Know Your Customer, refers to the process of identifying and verifying the identity of customers, including individuals and legal entities.
Master Direction on KYC dated February 25, 2016: A comprehensive guideline issued by the RBI regarding KYC norms and procedures for Regulated Entities.
Mumbai, Maharashtra: Location of the Central Office of the Department of Regulation, Reserve Bank of India.
RBI/2020-21/80
DOR.AML.BC.No.31/14.01.001/2020-21 December 18, 2020
The Chairpersons/ CEOs of all the Regulated Entities
Dear Sir/Madam,
Amendment to Master Direction (MD) on KYC – Centralized KYC Registry – Roll
out of Legal Entity Template & other changes
Regulated Entities (REs) have been uploading the KYC data pertaining to all individual
accounts opened on or after January 1, 2017 on to CKYCR in terms of the provisions of
the Prevention of Money Laundering (Maintenance of Records) Rules, 2005. Changes to
the template, as and when required are released by CERSAI after consulting the Reserve
Bank.
2. As the CKYCR is now fully operational for individual customers, it has been decided to
extend the CKYCR to Legal Entities (LEs). Accordingly, REs shall upload the KYC data
pertaining to accounts of LEs opened on or after April 1, 2021, on to CKYCR in terms of
Rule 9 (1A) of the PML Rules. The LE Template and the Annex thereof are attached as
Annex “A” and Annex “B” respectively to this circular. The LE Template would be released
by CERSAI well in advance so that REs start using it from the notified date. REs shall
also ensure that in case of accounts of LEs opened prior to April 1, 2021, the KYC records
are uploaded on to CKYCR during the process of periodic updation as specified in Section
38 of the Master Direction, or earlier when the updated KYC information is
obtained/received from the customer in certain cases. REs shall ensure that during
periodic updation, the customers’ KYC details are migrated to current Customer Due
Diligence (CDD) standards.
3. In order to ensure that all existing KYC records of individual customers are
incrementally uploaded on to CKYCR, REs shall upload the KYC data pertaining to
accounts of individuals opened prior to January 01, 2017, at the time of periodic updation
as specified in Section 38 of the Master Direction, or earlier when the updated KYC
information is obtained/received from the customer in certain cases. REs shall ensure that
during periodic updation, the customers’ KYC details are migrated to current CDD
standard.
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फोन फैक्स ईमेल वेबसाइट
, , , 13 , , – 400 001
: 022-22701203, : 022-22701239, - : cgmaml@rbi.org.in, : www.rbi.org.in
Department of Regulation, Central Office, Central Office Building, 13th Floor, Shahid Bhagat Singh Marg, Fort, Mumbai – 400 001
Phone : 022-22701203, Fax : 022-22701239, E-mail : cgmaml@rbi.org.in, Website : www.rbi.org.in
"Caution: RBI never sends mails, SMSs or makes calls asking for personal information like bank account details, passwords, etc. It never keeps or offers funds to anyone. Please do not respond in
any manner to such offers."2
4. Where a customer, for the purpose of establishing an account based relationship,
submits a KYC Identifier to a RE, with an explicit consent to download records from
CKYCR, then such RE shall retrieve the KYC records online from CKYCR using the KYC
Identifier and the customer shall not be required to submit the same KYC records or
information or any other additional identification documents or details, unless –
(i) there is a change in the information of the customer as existing in the records of
CKYCR;
(ii) the current address of the customer is required to be verified;
(iii) the RE considers it necessary in order to verify the identity or address of the
customer, or to perform enhanced due diligence or to build an appropriate risk
profile of the client.
5. Once KYC Identifier is generated by CKYCR, the REs shall ensure that the same is
communicated to the individual/legal entity as the case may be.
6. The Master Direction on KYC dated February 25, 2016, is hereby updated to reflect the
changes effected by the above amendment and shall come into force with immediate
effect.
Yours faithfully,
(Thomas Mathew)
Chief General Manager
Encl: As above