GIFT City · IFSCA

v1.0.0Effective 1/1/2024 · Last reviewed 1/1/2024

IFSCA AML/CFT & KYC rulebook (GIFT City)

Omnified's GIFT City rulebook models the IFSCA AML/CFT & KYC Guidelines applied by IFSC-based entities: banking units, fund management entities, capital-markets intermediaries, IFSC insurance offices, finance companies, PSPs, and fintech sandbox entities. The client base is predominantly non-resident, so the identity rails and V-CIP conditions differ materially from a domestic Indian onboarding.

Operational interpretation — not legal advice

This rulebook is a structured operational interpretation of public regulatory guidance to help configure Omnified. Verify every threshold, list, and requirement with qualified compliance counsel before relying on it. Thresholds and lists change — see version notes.

IFSC entity-type matrix

Entity type	Regulated as	Notes
IFSC Banking Unit (IBU)	IFSCA (Banking) Regulations	Branch of an Indian or foreign bank operating in IFSC
Fund Management Entity (FME)	IFSCA (FME) Regulations	Authorised, Registered, or Retail FME
Capital Markets Intermediary	IFSCA (Capital Markets Intermediaries) Regulations	Broker-dealers, custodians, clearing members
IFSC Insurance Office (IIO)	IFSCA (Insurance) Regulations	Reinsurers, direct insurers, intermediaries
Finance Company	IFSCA (Finance Company) Regulations	Global-treasury and factoring flows
Payment Service Provider	IFSCA PSP framework	Cross-border payments in IFSC
Fintech sandbox entity	IFSCA Fintech Framework	Time-boxed pilots — subject to sandbox conditions

Requirements by category

Identification

IFSCA-CDD-001IFSCA AML/CFT & KYC Guidelines Ch. 5 — Customer Identificationverify with counsel

Collect full name, date of birth, nationality, and residential address for every individual customer. For non-resident customers, a valid passport is the primary ID document.

Evidence: passport_or_national_idaddress_proof

IFSCA-CDD-003IFSCA Guidelines Ch. 5 — Legal Personsverify with counsel

Collect entity name, registration number, legal form, registered address, and directors/partners/trustees. For foreign entities, request certified translations where documents are not in English.

Evidence: certificate_of_incorporationregister_of_directors

Verification

IFSCA-CDD-002IFSCA Guidelines Ch. 5 — Non-Resident Identity Railsverify with counsel

Non-resident individuals: verify identity via passport (MRZ machine-read where possible) plus overseas address proof. Foreign government eID equivalents accepted where scoped in policy.

Evidence: passport_scanmrz_extractionoverseas_address_proof

IFSCA-IND-001IFSCA Guidelines Ch. 5 — India-Linked Customers (PMLA aligned)verify with counsel

India-linked customers (Indian passport / OCI / PIO / Indian-resident): apply PMLA-aligned rails — DigiLocker/Aadhaar-based verification, PAN validation, and CKYC registry lookup where applicable.

Evidence: digilocker_pullpan_validationckyc_receipt

Non face to face

IFSCA-VCIP-001IFSCA Guidelines Ch. 6 — V-CIP Conditionsverify with counsel

Video-based Customer Identification Process (V-CIP) is an accepted non-face-to-face route provided the session is live, geotagged where required, conducted by a trained official, and the recording retained.

Evidence: vcip_recordinggeotag_logofficer_certification

Beneficial ownership

IFSCA-BO-COMPANYIFSCA Guidelines Ch. 5 — BO (PMLA-aligned, companies)verify with counsel

Identify beneficial owners of companies — natural persons who ultimately own or control ≥10% (PMLA-aligned) with a cascading control test if no individual meets the threshold. THRESHOLD IS DATA — verify current value with counsel.

Evidence: bo_registerownership_chart

IFSCA-BO-PARTNERSHIPIFSCA Guidelines Ch. 5 — BO (partnerships)verify with counsel

Identify beneficial owners of partnerships — natural persons who ultimately own or control ≥10% (PMLA-aligned) of capital/profits. THRESHOLD IS DATA.

Evidence: partnership_deedbo_register

IFSCA-BO-TRUSTIFSCA Guidelines Ch. 5 — BO (trusts)verify with counsel

For trusts, identify the settlor, trustees, protector (if any), beneficiaries or class of beneficiaries, and any other natural person exercising ultimate effective control.

Evidence: trust_deedbeneficiary_register

Enhanced dd

IFSCA-EDD-PEPIFSCA Guidelines Ch. 7 — PEPs & EDDverify with counsel

PEPs require senior-management approval, source-of-wealth/source-of-funds, and enhanced ongoing monitoring — mandatory for foreign PEPs; risk-based for domestic and international-organisation PEPs.

Evidence: sow_documentationsof_documentationsenior_approval_memo

IFSCA-EDD-FATFIFSCA Guidelines Ch. 7 — FATF High-Risk Jurisdictionsverify with counsel

Customers from FATF-identified higher-risk jurisdictions trigger mandatory EDD, expanded screening, and enhanced ongoing monitoring.

Evidence: country_risk_assessment

Screening

IFSCA-SCR-001IFSCA Guidelines Ch. 8 — Screeningverify with counsel

Screen against UN sanctions and MHA India Section 51-A designations. Add PEP and adverse-media screening for standard and enhanced tiers.

Evidence: screening_report

Risk tier

IFSCA-SCDD-001IFSCA Guidelines Ch. 5 — Simplified CDDverify with counsel

Simplified CDD requires a documented low-risk rationale and is disqualified by any ML/TF suspicion.

Evidence: low_risk_rationale_memo

Ongoing monitoring

IFSCA-OM-001IFSCA Guidelines Ch. 8 — Ongoing Monitoringverify with counsel

Periodic review of customer information: high-risk annually, medium-risk every 2 years (seed values — counsel-verify against firm policy).

Evidence: periodic_review_schedule

Record keeping

IFSCA-RK-001IFSCA Guidelines Ch. 10 — Record Retentionverify with counsel

Retain CDD, transaction, and STR-related records for at least 5 years after the end of the relationship or the occasional transaction (counsel-verify).

Evidence: retention_policy

Governance

IFSCA-DPO-001IFSCA Guidelines Ch. 3 — Designated Personnelverify with counsel

Every IFSC entity must designate a Principal Officer and a Designated Director for AML/CFT and communicate these designations to IFSCA.

Evidence: appointment_lettersifsca_intimation

Reliance

IFSCA-REL-001IFSCA Guidelines Ch. 9 — Group Reliance & Outsourcingverify with counsel

Group-entity reliance and outsourcing: parent-group CDD may be relied on where the group applies equivalent AML/CFT standards and the underlying documentation is made available on request.

Evidence: group_policyreliance_agreement

Scenario library

a) NRI in Dubai — GIFT City USD fund subscription

Problem: A non-resident Indian living in the UAE subscribes to an FME's USD-denominated fund in GIFT City.
Requirements: IFSCA-CDD-001IFSCA-CDD-002IFSCA-VCIP-001IFSCA-IND-001IFSCA-SCR-001
Omnified routes: Passport MRZ + overseas address proof → V-CIP session (live, geotagged, retained) → PAN validation + CKYC lookup → UN + MHA screening.
Expected outcome: compliant when V-CIP conditions (geotag, trained officer, recording) are all met; not_met on IFSCA-VCIP-001 otherwise.

b) Foreign corporate investing via an FME

Problem: A Cayman feeder fund invests in an IFSC master fund managed by an FME.
Requirements: IFSCA-CDD-003IFSCA-BO-COMPANYIFSCA-EDD-FATFIFSCA-SCR-001
Omnified routes: Corporate identity + BO cascade at the 10% PMLA-aligned threshold, cross-referenced against FATF country lists.
Expected outcome: gaps_found if BO cascade doesn't identify a ≥10% individual or a control-test person; blocked outcomes never fire from this path.

c) Indian-resident director of a foreign entity

Problem: A director on the board of a foreign corporate customer is an Indian resident with PAN + Aadhaar.
Requirements: IFSCA-IND-001IFSCA-CDD-003IFSCA-BO-COMPANY
Omnified routes: For the director's own KYC, DigiLocker/PAN rails apply. The corporate customer is still assessed under IFSCA-CDD-003 + BO cascade.
Expected outcome: compliant if the director's identity is captured through DigiLocker (or CKYC / Aadhaar offline) alongside the entity documents.

d) Trust with foreign settlor and Indian beneficiaries

Problem: A private-wealth trust set up in a foreign jurisdiction, with an Indian-resident class of beneficiaries.
Requirements: IFSCA-CDD-003IFSCA-BO-TRUST
Omnified routes: Identify settlor + trustees + beneficiaries (or class thereof) + any person exercising ultimate control. Foreign settlor gets non-resident rails; Indian beneficiaries may need PAN/CKYC evidence [counsel-verify per fund/product].
Expected outcome: not_met until trust_settlor, trust_trustees, and trust_beneficiaries fields are all populated.

e) Branch of a foreign bank relying on parent-group CDD

Problem: An IBU wants to rely on identity work performed by the parent bank's group compliance team for a shared client.
Requirements: IFSCA-CDD-001IFSCA-REL-001
Omnified routes: Group-reliance rule fires only when equivalent-standards + documentation-available flags are both set; otherwise the IBU must re-perform CDD.
Expected outcome: compliant when the reliance flags are set and a reliance agreement is on file; gaps_found otherwise.

f) High-risk-country investor triggering EDD + monitoring cadence

Problem: An investor ordinarily resident in a FATF-listed country subscribing to an IFSC product.
Requirements: IFSCA-EDD-FATFIFSCA-OM-001IFSCA-SCR-001
Omnified routes: Country flag triggers enhanced monitoring + adverse-media screening. Periodic-review cadence pinned to high-risk (seed: annual).
Expected outcome: gaps_found until enhanced monitoring and adverse-media flags are set; compliant otherwise.

Identity-rail decision tree


  ┌─ India-linked customer? ────── yes ──▶ DigiLocker / Aadhaar-offline / CKYC + PAN
  │                                 no
  │
  ├─ non-resident individual? ──── yes ──┬─ face-to-face? ─▶ passport + overseas address proof
  │                                       └─ non-face-to-face? ─▶ passport + V-CIP (geotag + trained officer + recording retained)
  │
  └─ corporate / trust / partnership ──▶ entity docs + BO cascade at 10% (PMLA-aligned) + control test

Changelog

v1.0.0 — Initial baseline modeled on the IFSCA AML/CFT & KYC Guidelines for IBUs, FMEs, CMIs, IIOs, finance companies, PSPs, and fintech sandbox entities. Cross-references PMLA-aligned BO thresholds and V-CIP conditions. All thresholds live in machine_rule.params.