3rd National Chapter Meeting
Summary of Proceedings

Minutes of the 3rd ARIFAC Meeting held at Citibank’s Mumbai Office on July 24, 2024

1. The third ARIFAC meeting was organized & hosted by the Citibank NA India (CBNA India) at their BKC office in Mumbai on July 24, 2024 from 11.00 am to 3.30pm, which was attended by 61 participants of 52 Reporting Entities apart from the RBI and FIU-IND delegates. List of all participants attached separately for reference.

2. The meeting was moderated by Mr. Nihal Shah, Principal Officer, CBNA India. He thanked delegates from the FIU-IND and RBI and all other participants for attending 3rd ARIFAC meeting. He briefly apprised the participants about the agenda for the meeting.

3. In the opening welcome remarks, Mr. Siddharth Mehta, Chief Compliance Officer, CBNA India and Designated Director welcomed all the participants and highlighted the importance of having ARIFAC meeting which is Private-Private Partnership framework for information sharing on emerging trends relevant to AML/CFT compliance. He also welcomed and thanked the delegates of Financial Intelligence Unit (FIU-IND) and Reserve Bank of India (RBI) for their gracious participation.

4. During the first session, Mr. Nihal Shah, Principal Officer, CBNA India presented on “Payment Intermediaries and PA-CB, Industry wide Models & Challenges”. He highlighted PAs not in scope of Payment Intermediation definition, best practice on due diligence of PI / PA-CB, Indicative models for PA-CB and potential industry challenges around the same along with potential challenges on transactions monitoring. 

5. During the second session, Ms. Vasud Torsekar, Joint Director, FIU-India first provided background of ARIFAC initiative and its importance as strategic forum for long term perspective. She also presented a deck on the topic of “Need for Re-look at Risk understanding” covering various risks like product risk, customer risk etc. and other risk indicators to consider like I4C alerts. She emphasized on the need of CDD/EDD before filing an STR, customer risk to be upgraded post filing STR, deeper analysis on customer and its profile through valid open source etc. She also updated that FIU-IND is in the process of sharing some sort of guidance around filing defensive STRs.

6. During the third session, Maj Gaurav Chaturvedi (Retd)- Principal Officer, NPCI provided presentation on “Brief on AI/ML Modules Introduced by NPCI”. He explained how each modules work to trigger transaction-based alerts, how NPCI officers shares the same to respective Reporting Entities on daily basis.

7. During the fourth session, Mr. Hemang Sheth - Principal Officer, JPMorgan Chase Bank NA shared their experience on “KYC challenges for clients having foreign Authorised Signatories & Beneficial Owners”.

8. During the fifth session, Mr. Praveen Mohan Dayal - Principal Officer, HSBC shared “Case Studies - Service Based Money Laundering” typology with red flags on shell companies during monitoring of trade related FX remittances.

9. Any other agenda: Ms. Vasud Torsekar, Joint Director, FIU-India highlighted the need and encouraged REs to nominate sector wise “Training Lead” for providing sector specific trainings to all members across various sectors. It was also discussed that a steering committee needs to be formed for ARIFAC and the RE’s to volunteer for the same. Mr. Anmol Chopra AGM DOR KYC/AML Cell also addressed questions from participants on the KYC Master Direction.

10. Mr. Shirish Pathak from Fintelekt informed the members that ARIFAC website www.arifac.com has been created and will be leveraged for i) RE volunteers to nominate trainers, ii) ARIFAC member registration and iii) training topic requests. Ms. Jyothi N M (IndiaIdeas.com Limited - BillDesk) and Mr. Amit Madhusudan Retharekar (Karad Urban Co-Op Bank Ltd.) are leading the training initiatives for ARIFAC. 

11.  As proposed by FIU-IND, ARIFAC members could leverage on social media to promote the events of ARIFAC group to ensure large number of members get benefit of the same and increase participation. Accordingly, update of 3rd ARIFAC meeting with some photos would be posted on LinkedIn by Citibank. Any members having an objection of uploading their photos on LinkedIn, please reach out to nihal.shah@citi.com and pratik.doshi@citi.com by August 8, 2024.

12. The meeting was concluded with the closing remarks from Mr. V. Ilancheliyan, Joint Director, FIU-India.

13. All the presented topics were discussed and responded positively by the participants. FIU-IND and RBI officials have well appreciated, the agenda of the meeting, the participation from the member entities and overall organization & hospitality of the meeting by Citibank NA India.