Decoding the implications of ‘Prevention of Money Laundering (Maintenance of Records) Third Amendment Rules, 2019’

To eliminate all ambiguities surrounding ‘Digital KYC’, the Department of Revenue working under the aegis of the Union Government of India’s Ministry of Finance recently released a notification on 19th August 2019 titled ‘Prevention of Money Laundering (Maintenance of Records) Third Amendment Rules, 2019.’

Here is our humble attempt to decode the various nuances of these amendments and shed some light on their business implications for Reporting Entities (REs).

Part I – Date of Publication and Enforcement Date:

  • Publication Date of Official Gazette: 19th August 2019.
  • Enforcement Date: From the same day i.e. 19th August 2019.

Part II: Key Amendments:

1. Inclusion of the definition of ‘Digital KYC.’

2. Inclusion of the definition of ‘Equivalent e-Document’

3. Clarifications on ‘Capturing of Aadhaar Number’ by Reporting Entities (REs).

4. Elaboration of the high-level process flow for performing Digital KYC transactions where Aadhaar Offline KYC is not used.

Below is a quick primer on the above-mentioned amendments and their business implications:

1. Inclusion of the definition of ‘Digital KYC’:

1

2. Inclusion of the definition of ‘Equivalent e-Document’:

2

3. Clarifications on ‘Capturing of Aadhaar Number’ by Reporting Entities (REs):

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4. Elaboration of the Process Flow of Digital KYC transactions where Aadhaar Offline KYC is not used:

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As India’s leading KYC Solutions company, we are happy to inform you that our robust, highly scalable Full Stack ‘Digi CAF’ solution not only adheres to all the above-mentioned mandates but also facilitates faster and economical Digital KYC.

Below are a few notable features of our ‘Digi CAF’ solution:

1. Supports Digital KYC through following OVDs:

  • Offline KYC XML
  • eAadhaar
  • Driving License
  • Cersai Central KYC
  • Voter ID
  • MNREGA
  • KYC OVDs extracted from the Digi Locker

2. Capturing the live photo of an individual along with a ‘liveness check’ and automated conversion of the photograph in a white background. This photograph is then embedded in Digi CAF as mandated by the regulator.

3. Supports Facial Authentication transactions to enable REs to match the live photo with the photo of the person retrieved from the original OVD.

4. Capturing the GPS Coordinates (LAT- LONG).

5. Generation of the Digital CAF Form with watermark containing the following transactional data:

  • Employee Name and Employee Code
  • Date and Time Stamp
  • LAT-LONG Coordinates

6. OCR of the photograph of the original OVD to facilitate extraction of the demographic data from the original OVD.

7. Real-time API data fetch for all the above-mentioned OVDs (KYC data is fetched dynamically from the issuer of the OVD).

8. Cohesive Data Matching feature that facilitates the matching of OCR data with the data received from the issuer of the OVD.

9. Pre-integrated with Digi Locker to facilitate quick extraction of the original OVDs that are digitally-certified and signed by Digi Locker.

10. Dynamic auto-population of the demographic data and photograph in the CAF Form.

11. OTP validation of the end-user/agent.

12. Affixing the digital signature of the RE on the Digi CAF Form without any manual intervention.

13. Integration with the Offline KYC-based eSign service to enable the end-user to digitally sign the Digi CAF Form.

14. Auto email of the signed Digi CAF to the email ID of the end-user.

Feel free to get in touch with our colleague Amit Joshi on 9820875525 / 7208155528, or email him at amit@eastcs.com if you would like to know more about our Digi CAF solution.

Regards

Team ECS.

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