Q.38: 1. We are registered with NDML KRA. However, one of our client KYC was not available on NDML and it (NDML) says verify with CVLKRA then how to go about it as we are not registered with CVLKRA. As per the knowledge I have, we have to get registered with only one KRA. Please let us know way forward for KYC compliance.

We have received our registration with FIU and we can successfully log-in now. We are sole proprietory concern.

• We dont have any suspicious transactions as of now so do we have to do NIL reporting?
• Is there any other reporting required and what is the frequency?

Response:

Response to Sub-Query-1:

Generally, if KYC is done with any KRA, it will be visible in the public domain itself. So, if it is already appearing as KYC “done” in any of the KRAs then, no further action is required.

If such client is not having status of “KYC” done in any of the KRAs then, proceed to upload the KYC records with your KRA (where you registered as RIA / Intermediary).

Note: Why there is no mention of CKYC verification of such client. That is most important and mandatory today. So, please check with CKYC portal also and then proceed accordingly. Hope you registered with CKYC as an RIA / Intermediary.

Response to Sub-Query-2:

Hope you have done both registrations – Reporting Entity and also Principal Officer.

1. There is no requirement to do NIL reporting with FIU-IND.
2. Reportings with FIU-IND include the following, if applicable.
   1. – Requirement-basis STR (Suspicious Transaction Report)
   2. – Monthly NTR (Non-Profit Organization Transaction Report)
   3. – Monthly CTR (Cash Transaction Report)