Background

A comprehensive KYC-AML framework is a bulwark to prevent the financial system from being used for money laundering and other unlawful activities. Payment Aggregators (PAs) must adhere to strict KYC/AML/CFT framework which are strictly in compliance with the extant regulatory and legal requirements. The key challenges involve conducting thorough background checks on merchants, tiered onboarding (small, medium, high-risk), physical verification, and mandatory PCI-DSS compliance. Real time transaction monitoring is crucial to detect money laundering. A sound and robust KYC framework coupled with effective AML measures constitutes one of the key components of Regulated Entities (REs) business strategy and its governance structure. The Board of PAs is responsible for their organisation’s business strategy, effective governance structure & practices, risk management & compliance obligations.

Objective

This program seeks to sensitize the senior and middle level officers of PAs about the risk and strategic issues surrounding KYC framework and AML measures which they are required to put in place. The program will also dwell on the need for a robust governance architecture in the regulated PAs. Most importantly, the program seeks to discuss the nuances, challenges and complexities in respect of compliance and interpretation of the regulations.

Program Highlights

The program will deal with the following topics:

• Regulatory framework for Payment Aggregators – Overview, Governance expectations, interlinkages with AML/CFT obligations, role of Board and Senior Management
• Governance architecture and risk management – Board oversight and committees of the Board, risk management framework, Internal audit and compliance function expectations, MIS
• KYC framework for merchant onboarding
• AML/CFT obligations and transaction monitoring – STR, RFIs, rule-based vs AI/ML approaches, coordination with FIU
• Emerging risks and supervisory expectations – fraud typologies, misuse of PAs for illicit flows