RBI · RBI Enforcement Cases

ENF-05: KYC/AML penalty

Paragraph-level professional implementation page for RBI Enforcement Cases.

RBI Enforcement CasesENF-05BR Act/RBI Act/PSS Act/CICRA/SARFAESI according to contravention

Finin2min Summary — in 2 Minutes

ENF-05 — KYC/AML penalty. Trace the failed policy, onboarding, monitoring, reporting or periodic-update control.

Official source and legal ownership

Instrument ownerBR Act/RBI Act/PSS Act/CICRA/SARFAESI according to contravention

Source statusCURRENT OFFICIAL SOURCE GATEWAY

Review date2026-07-19

Primary sourceRBI enforcement and press-release repository

Paragraph-wise Finin2min interpretation

Legal trigger

Trace the failed policy, onboarding, monitoring, reporting or periodic-update control.

Control owner

Business identifies the event; Compliance confirms law; Operations/Technology executes; Independent review tests evidence.

Evidence

Official source snapshot, policy/SOP, system rule, customer/transaction record, maker-checker log, exception approval and regulatory acknowledgement.

Failure consequence

Customer harm, reporting defect, prudential misstatement, supervisory observation, monetary penalty, restriction or remediation.

Practical example

Scenario: An exception arises under KYC/AML penalty. The owner records the trigger, regulated entity, paragraph/reference ENF-05, affected customer or exposure, applicable threshold, approval and system evidence. Compliance then tests the result against the official source rather than relying on a generic policy statement.

Implementation and evidence controls

Freeze the applicable entity class, product, transaction date and official instrument version.
Map every control to its legal owner, enabling provision, responsible function, evidence and escalation route.
Retain Board/committee approval, policy version, system configuration, maker-checker evidence, exception approval and regulatory filing acknowledgement.
Re-test the control after an amendment, product change, outsourcing change, merger, customer-risk reclassification or supervisory observation.

Practical Q&A

What is the first test for KYC/AML penalty?

Confirm entity, product, event date, official paragraph and any stated exception.

Can a portal or system acceptance cure a legal defect?

No. Technical processing does not override the substantive Direction.

What should be retained for review?

The official source version, legal mapping, calculation or decision record, approvals, communications and filing evidence.