AML Policies

✅ Core AML Requirements for Credit Card Issuers

1️⃣ Customer Due Diligence (CDD)

Before issuing a card, banks must verify:

✔ Identity (PAN mandatory)
✔ Address proof
✔ Income source
✔ Risk profile of customer

This happens through full KYC verification.


2️⃣ Risk Categorization of Customers

Banks classify customers into:

🟢 Low risk → salaried individuals
🟡 Medium risk → business owners
🔴 High risk → politically exposed persons, high cash activity

High-risk customers face stricter monitoring.


3️⃣ Transaction Monitoring

Banks track unusual credit card behavior such as:

⚠ Very high spending suddenly
⚠ Repeated refunds or reversals
⚠ International transactions without pattern
⚠ Large payments followed by cash withdrawal
⚠ Multiple cards used for same merchant

If detected → bank may block the card temporarily.


4️⃣ Reporting Suspicious Transactions

Banks must report suspicious activity to:

👉 Financial Intelligence Unit (FIU-IND)

Examples reported:

  • Fake merchant payments
  • Structuring transactions to avoid detection
  • Identity misuse

5️⃣ Record Maintenance

Banks must keep records of:

✔ Customer identity documents
✔ Transaction history
✔ Card usage data

These records must be stored for at least 5 years after account closure.


6️⃣ Limits on Cash-like Transactions

To reduce laundering risk, banks control:

  • Cash withdrawals from credit card
  • Wallet loading using credit card
  • Gambling or high-risk merchant payments

Some transactions may be blocked automatically.

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