Record maintenance and transaction reporting
Reporting entities must maintain prescribed transaction and identity records and furnish reports within rule-based time limits while maintaining confidenti
Finin2min summary
Reporting entities must maintain prescribed transaction and identity records and furnish reports within rule-based time limits while maintaining confidentiality.
Legal anchors
- Section 12
- Rules 3–8 and 10
- FIU reporting formats
How to analyse it
- Classify reportable transaction types.
- Build system rules and manual escalation.
- Retain data and supporting records for prescribed period.
- Protect STR confidentiality.
Practical illustration
Cash and integrally connected cash transactions may require monthly reporting, while an STR requires prompt filing after satisfaction of suspicion.
What can go wrong?
- Treating thresholds as substitutes for suspicion
- Tipping off customer
- Incomplete transaction linkage
Evidence pack
- Transaction data
- Alert disposition
- Report acknowledgement
- Retention log
Decision workflow
- Freeze the facts and effective date.
- Identify the controlling Act, rule, notification, circular and jurisdictional overlay.
- Prepare a calculation or exposure note.
- Collect the evidence pack before filing, payment, signing or response.
- Record reviewer conclusion and assumptions.
Quick Q&A
Is the result automatic?
No. Classify reportable transaction types.
What is the most important control?
Protect STR confidentiality.
What should be escalated?
Treating thresholds as substitutes for suspicion, especially where money, deadlines, enforcement, personal liability or irreversible transaction steps are involved.
Official source trail
- PMLA, 2002 — FIU-IND
- PMLA, 2002 PDF — FIU-IND
- PML Maintenance of Records Rules, 2005 — FIU-IND
- FIU-IND FAQs
Secondary commentary may help interpretation, but it is not the source of law.