Executive Summary

The International Financial Services Centres Authority (IFSCA) issued Circular IFSCA-DAC/7/2024-AMLCFT, updating the IFSCA (AML, CFT and KYC) Guidelines, 2022. The modifications mandate electronic regulatory reporting through the FINgate 2.0 portal, clarify reporting for Cross-Border Wire Transfers, and enforce IP address geolocation verification during digital customer onboarding.

Regulatory Background

As GIFT City IFSC expands its footprint in international banking, capital markets, and asset management, regulatory oversight continues to align with Financial Action Task Force (FATF) standards. Digital onboarding of non-residents and NRIs requires robust technical controls to mitigate cross-jurisdictional compliance risks and restrict access from unauthorized territories.

What Has Changed?

IFSCA has aligned regulatory reporting (including CTRs and STRs) with the FINgate 2.0 portal architecture. Additionally, Regulated Entities (REs) must verify and record the IP address and geographical location of applicants during digital onboarding and video-based customer identification processes (V-CIP).

Key Changes Comparison

Who Will Be Affected?

• IFSC Banking Units (IBUs)
• Finance Companies and Finance Units in GIFT City
• Fund Management Entities (FMEs) and Broker-Dealers
• Insurance Intermediaries and Regulated Entities under IFSCA

Effective Date & Applicability

• Reference Circular: Circular F. No. IFSCA-DAC/7/2024-AMLCFT
• Applicability: All Regulated Entities operating under IFSCA jurisdiction.

Compliance Impact

• IT Infrastructure: Onboarding portals must incorporate automated IP-geolocation verification to detect mismatches between declared residency and connection origin.
• Portal Integration: Compliance teams must configure user credentials and transmission workflows for filing on FINgate 2.0.
• Internal Manuals: Update internal AML/CFT manuals to incorporate IP-verification protocols and cross-border transfer reporting guidelines.

KGS Practical Takeaway: GIFT City entities must integrate technical security parameters directly into their AML frameworks. Capturing verifiable IP geolocation logs provides an objective compliance trail during supervisory audits.

Source / Reference

• Authority: International Financial Services Centres Authority (IFSCA)
• Document: Circular
• Reference No.: IFSCA-DAC/7/2024-AMLCFT
• Official Source: IFSCA Official Website — Circulars Section