FIU-IND published a list of NBFCs that hadn’t fulfilled their PMLA registration obligations as of June 2026 — and a formal FIU-IND–RBI information-sharing arrangement means gaps here no longer stay siloed from your RBI standing. CS Chetna Shoor handles the FINnet Gateway registration and ongoing reporting so your NBFC isn’t on that list.
Every RBI-registered NBFC is a “reporting entity” under the Prevention of Money Laundering Act, 2002, obligated to register itself and its Principal Officer with FIU-IND through the FINnet Gateway (FINGate 2.0) portal, and to intimate a Designated Director as well. Registration is only the starting point — NBFCs must then file Suspicious Transaction Reports, Cash Transaction Reports, and other prescribed reports on an ongoing basis, against statutory deadlines as tight as seven working days for suspicious activity.
This obligation is actively enforced, not a formality: FIU-IND’s own published list of non-compliant NBFCs, most recently updated as of June 30, 2026, is used by banks to apply enhanced scrutiny to those entities’ transactions. This page is for NBFCs setting up FIU-IND registration for the first time, or discovering — often during an acquisition or compliance audit — that registration was never completed or has lapsed. Chetna manages the entity and Principal Officer registration and sets up the ongoing reporting discipline both RBI and FIU-IND expect.
Is a "reporting entity" under PMLA, regardless of size or category
The mandatory online portal (FINGate 2.0) for entity and Principal Officer registration
Deadline to file a Suspicious Transaction Report from when suspicion is formed
Cash transaction threshold triggering a Cash Transaction Report, due by the 15th of the following month
Minimum record-retention period under PMLA
Legal basis, with active information-sharing between the two regulators
RBI rejects over 40% of NBFC applications on the first attempt. Here’s what actually causes it.
Completing entity and Principal Officer registration on FINnet is only step one. The ongoing STR/CTR/NTR filing cadence — with deadlines as tight as seven working days for suspicious activity and monthly deadlines for cash transaction reports — is where most compliance failures actually occur, well after registration itself is done.
FIU-IND now shares information with RBI under a formal coordination arrangement, and FIU-IND's own published non-compliant NBFC list is used by banks to apply enhanced due diligence to those entities. A gap here has consequences that reach beyond FIU-IND itself.
A Principal Officer or Designated Director change needs to be promptly updated with FIU-IND. NBFCs that update internal records but forget the FIU-IND intimation end up with a registration that's technically inaccurate — which surfaces exactly when a reporting deadline is missed and FIU-IND asks who was responsible.
Most founders default to assuming they need a generic “NBFC license” — but RBI’s framework has distinct categories, and applying under the wrong one is a common reason applications stall. We confirm the right category before filing, not after a rejection.
The highest-risk position — your NBFC is on record as failing a mandatory PMLA obligation the moment FIU-IND or RBI checks.
A common gap — entity registration was completed once, but STR/CTR filings have lapsed or were never properly operationalized day to day.
Lower risk, but still needs correcting — a Principal Officer or Designated Director change that was never intimated to FIU-IND.
For peer-to-peer lending platforms — a separate license category with its own fund-transfer and exposure-limit rules under RBI's P2P lending directions.
We confirm your current registration status, personnel records, and reporting history against what FIU-IND actually has on file.
Registration or correction completed on the FINnet Gateway portal.
Policy aligned to PMLA and RBI's KYC/AML Master Direction, drafted fresh or updated as needed.
Designated Director intimated to FIU-IND, and an internal reporting workflow established.
Reports filed within statutory deadlines, rather than tracked manually and at risk of slipping.
Direct handling of any FIU-IND queries or notices as they arise.
FIU-IND compliance is an ongoing discipline, not a registration you complete once and file away.
Ongoing STR/CTR/NTR filing discipline against statutory deadlines, not a one-time registration event.
Prompt intimation of any Principal Officer or Designated Director change.
Periodic internal review of AML/CFT policy against updated PMLA rules and RBI directions.
Coordination with your broader RBI compliance program, since RBI now has visibility into FIU-IND standing. See NBFC Annual RBI Compliance.
CS Chetna Shoor’s team replies within 4 hours on WhatsApp.
Yes. Every NBFC registered with RBI is a “reporting entity” under the Prevention of Money Laundering Act, 2002, and must register itself and its Principal Officer with FIU-IND through the FINnet Gateway portal, regardless of size or category. This applies equally to deposit-taking and non-deposit-taking NBFCs.
The Principal Officer is a senior management employee responsible for AML/CFT compliance, filing reports with FIU-IND, and acting as the primary point of contact for FIU-IND communications. The Designated Director is a separate, senior board-level appointment that NBFCs must also intimate to FIU-IND, adding an additional layer of accountability beyond the Principal Officer.
NBFCs file Suspicious Transaction Reports (STRs) within seven working days of forming suspicion, Cash Transaction Reports (CTRs) for cash transactions of ₹10 lakh or more by the 15th of the following month, and Non-Profit Organization Transaction Reports (NTRs) where applicable. Records supporting these reports must be retained for a minimum of five years.
Unregistered NBFCs are published on FIU-IND’s list of non-compliant entities, which banks use to apply enhanced due diligence to their transactions — creating operational friction well before any formal penalty is imposed. Non-compliance also risks direct enforcement action under PMLA and can affect the NBFC’s standing with RBI given the information-sharing arrangement between the two regulators.
Yes. FIU-IND and RBI have a formal information-sharing arrangement, and repeated or serious violations of FIU-IND reporting obligations can attract RBI scrutiny in its own right, separate from any FIU-IND enforcement action. Treating FIU-IND compliance as unrelated to your RBI standing is no longer a safe assumption.
Qualified Company Secretary · ICSI Member · Founder, Expertvuw Management Pvt Ltd
Chetna has guided NBFC promoters through RBI’s COR process end to end, with particular focus on structuring the Net Owned Fund and business plan so the application survives first-round RBI scrutiny rather than coming back with a query.