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Reporting entities and governance

Banks, financial institutions, intermediaries and persons carrying on designated business or profession have governance, CDD, record, reporting and coopera

Finin2min summary

Banks, financial institutions, intermediaries and persons carrying on designated business or profession have governance, CDD, record, reporting and cooperation obligations.

Source review date: 4 July 2026. Read with the official text and the facts of the transaction.

Legal anchors

  • Sections 11A–15
  • PML Maintenance of Records Rules, 2005
  • Sector regulator directions

How to analyse it

  1. Confirm reporting-entity status.
  2. Appoint designated director and principal officer.
  3. Approve AML policy and risk assessment.
  4. Register and maintain FIU reporting capability.

Practical illustration

A newly notified professional activity may bring a firm into the reporting-entity regime even if it has no traditional financial licence.

What can go wrong?

  • No applicability review
  • Roles appointed only on paper
  • No board oversight

Evidence pack

  • Applicability memo
  • Appointments
  • AML policy
  • FIU registration

Decision workflow

  1. Freeze the facts and effective date.
  2. Identify the controlling Act, rule, notification, circular and jurisdictional overlay.
  3. Prepare a calculation or exposure note.
  4. Collect the evidence pack before filing, payment, signing or response.
  5. Record reviewer conclusion and assumptions.

Quick Q&A

Is the result automatic?

No. Confirm reporting-entity status.

What is the most important control?

Register and maintain FIU reporting capability.

What should be escalated?

No applicability review, especially where money, deadlines, enforcement, personal liability or irreversible transaction steps are involved.

Official source trail

Secondary commentary may help interpretation, but it is not the source of law.

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