FIU-IND Registration for Reporting Entities
If your business is a reporting entity under the Prevention of Money-laundering Act, 2002, FIU-IND registration comes before your first report. You name a Principal Officer and a Designated Director, register on the FINnet portal, and then file cash and suspicious transaction reports on time. We prepare the papers and the AML policy, and guide the portal setup.
What it is
FIU-IND is the Financial Intelligence Unit of India. It receives, processes and analyses information about cash and suspicious transactions under the Prevention of Money-laundering Act, 2002 (PMLA). FIU-IND registration is how a reporting entity gets its login to the FINnet portal, the only channel for filing these reports online.
Section 12 of the PMLA sets your duties. You keep records of every transaction so each one can be reconstructed, you keep client identity records and account files, and you furnish information to the Director of FIU-IND within the prescribed time. Transaction records stay for five years from the transaction, and identity records for five years after the relationship ends.
Who it applies to
Financial businesses
Banks, NBFCs, housing finance companies, chit funds, payment system operators, brokers, mutual funds, insurers and forex dealers are all reporting entities. If a regulator licenses you, FIU-IND registration usually follows. Our NBFC compliance work covers this for lenders.
Virtual digital asset providers
The Central Government brought virtual digital asset service providers under the PMLA as reporting entities on 7 March 2023, and FIU-IND issued AML and CFT guidelines on 10 March 2023. Exchanges and custodians serving Indian customers register like any other entity.
Trust and company service providers
Notification S.O. 2135(E) of 9 May 2023 covers formation agents for companies and LLPs, nominee shareholders, trustees and those who provide a registered office. Employees acting within their job, and advocates or CAs filing incorporation declarations, are excluded.
Why it matters
You cannot file without it
Reports go through FINnet. No registration means no login. Then a missed STR or CTR is simply a default on your side.
A legal duty with a price tag
Section 13 lets the Director impose a penalty of ₹10,000 to ₹1 lakh for each failure to meet the Chapter IV obligations. The penalty is per failure, so repeated lapses add up.
Your regulator expects it
RBI’s KYC Directions for NBFCs require Designated Director and Principal Officer details to be given to FIU-IND as well as RBI. A clean FIU file helps at every inspection.
Documents required
Entity papers
- Certificate of incorporation or registration
- PAN of the entity
- Licence or registration from your regulator, where one applies
- Registered office address proof
Principal Officer and Designated Director
- Names, designations and official addresses
- PAN and ID proof of each person
- Official email ID and mobile number
- Board resolution naming both
Policy papers
- Board-approved AML and KYC policy
- Risk assessment and customer due diligence procedure
- Record-keeping and employee training plan
- Internal process to detect and report suspicious activity
How it works
Pick the right reporting entity category
Picking the wrong category on the portal is the most common slip. We read your licences and activities first, then match them to the category that applies.
Name your two officers
The Principal Officer furnishes information to the Director and keeps the records. The Designated Director’s name, designation and address go to FIU-IND. We draft the board resolution.
Register on the FINnet portal
We prepare the entity and officer details and guide the registration so the profile is complete at the first go.
Write the policy and fix the calendar
We prepare the AML policy and a reporting calendar for CTRs and STRs. Say you run a Faridabad finance business that takes cash collections: we mark the 15th of every month on that calendar, with a reminder a week earlier.
Update FIU-IND when people change
When an officer changes, FIU-IND must be told. We handle the update and refresh the policy once a year.
Reports you file after registration
These are the standard report types and their due dates under the FIU-IND reporting regime.
| Report | Threshold | Due date |
|---|---|---|
| STR (suspicious transaction) | No threshold | Within 7 working days of concluding the transaction is suspicious |
| CTR (cash transaction) | Above ₹10 lakh, or connected series above it | 15th of the next month |
| NTR (non-profit transaction) | ₹10 lakh | 15th of the next month |
| CBWTR (cross-border wire transfer) | ₹5 lakh | 15th of the next month |
| CCR (counterfeit currency) | No threshold | 15th of the next month |
| PTR (property transaction) | ₹50 lakh | 15th of the month after the quarter ends |
Timelines
Register before your first report is due
There is no waiting period in the law. Registration should be done as soon as you fall within a reporting entity category, and before your first CTR or STR falls due.
Seven working days for an STR
Count from the day you conclude a transaction is suspicious. FIU-IND’s FAQ says to report promptly and not later than seven working days.
Five years of records
Transaction records for five years from the transaction. Client identity and account records for five years after the relationship ends.
What happens if you miss it
Penalty for each failure
Under Section 13 of the PMLA the Director can impose ₹10,000 to ₹1 lakh for every failure to comply with Chapter IV obligations.
Warnings and directions
Before or alongside a penalty, the Director may issue a written warning, direct specific compliance, or call for periodic compliance reports.
Recovery of unpaid penalty
If a penalty stays unpaid for six months, it can be recovered through income tax recovery procedures. Your regulator may also act separately.
Frequently asked questions
What is FIU-IND registration?
It is the registration of a reporting entity on the FINnet portal run by the Financial Intelligence Unit-India. Registration lets you file STRs, CTRs and other reports online under the PMLA. You also name a Principal Officer and a Designated Director. Without it you have no way to file, so we complete it first and then build your reporting calendar.
Who must register with FIU-IND?
Every reporting entity under the PMLA must register. That includes banks, NBFCs, housing finance companies, chit funds, payment operators, brokers, mutual funds, insurers and forex dealers. Virtual digital asset providers joined on 7 March 2023, and trust and company service providers by notification on 9 May 2023. Unsure where you fall? We read your licences and tell you.
How soon must a suspicious transaction be reported?
You must file an STR promptly and not later than seven working days after concluding the transaction is suspicious. There is no minimum amount, so even a small transaction can qualify. Keep a short written note of why you decided it was suspicious. We set up that process with you.
What is the CTR threshold and due date?
A cash transaction report is due for cash transactions above ₹10 lakh, or a connected series that crosses it. It must be filed by the 15th of the following month. Take a ₹12 lakh cash receipt in September: the CTR is due by 15 October. We put every month on your calendar.
Who should be the Principal Officer?
The Principal Officer is the person who furnishes transaction information to the Director and maintains the records. Pick someone who knows your operations and can be reached by FIU-IND. Their details go on the portal. If they leave, FIU-IND must be told. We advise on the choice and draft the board resolution.
What is the penalty for not complying?
Section 13 of the PMLA allows a penalty of ₹10,000 to ₹1 lakh for each failure to meet your obligations. The Director can also warn you or direct compliance, and a penalty unpaid for six months is recoverable like income tax dues. We review your position and close any gaps.
Do virtual digital asset providers need FIU-IND registration?
Yes. Virtual digital asset service providers serving Indian customers became reporting entities on 7 March 2023, and FIU-IND issued AML and CFT guidelines three days later. They must register, appoint officers and report like other entities. Offshore providers serving Indian users are in scope too. We prepare the entity and officer details for the portal.
How long must I keep records?
Keep transaction records for five years from the date of the transaction. Keep client identity documents and account files for five years after the business relationship ends. The records must let you reconstruct individual transactions. We set up a simple record structure so retrieval takes minutes, not days.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
Government penalties arise only if obligations are missed: under Section 13 of the PMLA, ₹10,000 to ₹1 lakh for each failure.
Ready to begin?
Tell us your licences and activities. We will confirm your reporting entity category and register you on the portal.