Category: AML & CFT

You know that feeling when something seems a little off, but you’re unsure if it’s worth bringing up? 

For example, a small business in India gets a substantial payment from a new customer. They don’t think much of it, but down the road, it turns out to be a red flag for something bigger.

This happens more often than you’d think, and that’s why FIU-IND reporting exists. 

It’s about keeping things transparent, not just for big corporations but for every business involved in financial transactions. 

Reporting to FIU-IND isn’t complicated, and with the right steps, it’s just part of the process. In this guide, we’ll unpack everything you need to know: who needs to report, what transactions to flag, and how easy it can be once you know the basics.

But first, let’s start with nuts and bolts.

What is FIU Reporting in India?

FIU Reporting in India is when businesses, mainly in the financial space, report certain transactions to the Financial Intelligence Unit – India (FIU-IND). 

FIU-IND is the government agency responsible for collecting and disseminating information related to suspicious financial transactions. Its main goal is to combat financial crimes by tracking suspicious activities across the financial system. 

If there’s a transaction that stands out, like a large cash deposit, a significant cross-border transfer, or just something that feels off, it needs to be flagged.

It’s all part of India’s efforts under the Prevention of Money Laundering Act (PMLA), 2002. So, banks, insurance companies, and NBFCs (basically anyone working in financial services) must report these transactions to FIU-IND. FIU-IND takes these reports and then passes the info along to law enforcement if something needs deeper investigation. 

In short, it’s a way for businesses to keep the financial system clean. If something doesn’t feel right, it’s on them to report it. 

Who Needs to Report to FIU in India?

FIU-IND’s reporting obligations apply specifically to entities that handle transactions where the risk of money laundering or terrorism financing is higher. 

These entities are required to submit reports on any suspicious or large transactions.

Entities falling under this umbrella include:

1. Banks (Public & Private Sector, Cooperative Banks, etc.)
2. Non-Banking Financial Companies
3. Insurance Companies
4. Securities Market Intermediaries (Stock Brokers, Mutual Funds, etc.)
5. Payment Service Providers (Digital Wallets, Payment Gateways, UPI Services, etc.)
6. Cryptocurrency Exchanges
7. Foreign Exchange Dealers

Essentially, if your business deals with financial transactions that could be used for money laundering or terrorism financing, you’re on the hook to report them to FIU-IND.

What Are the Key Reporting Obligations?

Now that we know what FIU Reporting is and who is obliged, let’s take a look at those key reporting obligations to understand what needs to be flagged.

1. Cash Transaction Reports (CTR)

If there’s a cash transaction that exceeds ₹10 lakh, it has to be reported. 

This also applies to any series of connected transactions within a month, even if individually they don’t cross the threshold, but together they do. Banks and other financial institutions are particularly responsible for keeping an eye on these high-value cash transactions. 

The goal here is to catch any potential layering of illicit funds, where cash is being moved in and out in ways that might not make sense on the surface.

2. Suspicious Transaction Reports (STR)

Any transaction that raises suspicion (whether it’s due to its complexity, the amount, or the nature of the person involved) needs to be flagged as an STR. 

For instance, if a large amount of money is being deposited into an account without a clear source of income or if there are frequent international money transfers with no legitimate business reason, these should be reported. 

3. Non-Profit Organization Transaction Reports (NTR)

For Non-Profit Organizations (NPOs), any donation or fund transfer of more than ₹10 lakh needs to be reported. NPOs can sometimes be used as a channel to funnel illicit funds, so it’s crucial that financial institutions monitor these large transactions. Any red flags here could point to abuse of charitable giving for unlawful purposes.

4. Cross-Border Wire Transfer Reports (CBWTR)

Any cross-border wire transfer greater than ₹5 lakh (or its foreign currency equivalent) also must be reported. 

These reports are especially important because large international money transfers can be used to move illicit money across borders, which could potentially fund terrorism or other criminal activities. This is why any such transfers, whether inbound or outbound, need to be carefully monitored and reported.

5. Counterfeit Currency Reports (CCR)

If any counterfeit currency is detected during a transaction, it must be reported immediately. If someone tries to deposit or exchange fake currency, that’s a red flag. Financial institutions must report these transactions to help authorities track down the source of the counterfeit money and prevent it from entering circulation.

With these key obligations in mind, let’s explore what happens if you don’t report as required.

What Happens If You Don’t Report?

Under the Prevention of Money Laundering Act (PMLA), 2002, non-compliance can lead to hefty fines, legal action, and even criminal charges. Penalties for failing to report can be significant, including fines that can reach up to ₹1 lakh per unreported transaction.

Beyond the financial penalties, failing to report can severely damage your business’s reputation. Financial institutions that are caught neglecting their reporting obligations risk losing trust with regulators, customers, and business partners. 

Step-by-Step FIU Reporting Process

To ensure compliance with FIU-IND reporting obligations, businesses in the financial sector need to follow a structured process. 

Here’s how the FIU reporting process typically works, broken down into clear steps:

• Step 1 – Identify Reportable Transactions: These include large cash deposits, cross-border transfers, suspicious activity, or counterfeit currency. If any transaction meets the criteria set by FIU-IND (e.g., over ₹10 lakh in cash or transactions that seem suspicious), it must be flagged.
• Step 2 – Gather Transaction Details: Gather details like transaction amount, involved parties, and any supporting documentation. The more complete the information, the easier it will be for FIU-IND to process and analyze the report.
• Step 3 – Log into the FINGate 2.0 Portal: All reports must be submitted through the FIU-IND’s FINGate 2.0 portal. Before submitting, ensure you are registered with the portal and have your Reporting Entity Identification Number (REID).
• Step 4 – Fill Out the Required Forms: FIU-IND has specific forms for different types of reports, like Cash Transaction Reports (CTR), Suspicious Transaction Reports (STR), etc. Each form must be filled out with the necessary transaction details. 
• Step 5 – Submit the Report: Submit the report through the FINGate 2.0 portal. Once validated, the report is officially submitted and logged in FIU-IND’s database.
• Step 6 – Monitor and Follow Up: FIU-IND might contact the business for additional information or clarification if needed.
• Step 7 – Maintain Records: These records should be retained for at least 5 years, as mandated by the PMLA, in case they are needed for future reference or audits.

This process ensures you are staying compliant with FIU-IND regulations, helping to safeguard India’s financial system from misuse. 

How Regulated Entities Can Stay FIU-Compliant

So, we’ve walked through all the nuts and bolts; let’s now understand how businesses can stay FIU-compliant and avoid any potential issues moving forward.

1. Stay Updated on Reporting Requirements

Regulations change, and it’s important to stay on top of them. Make it a habit to regularly check for updates from FIU-IND so your business doesn’t miss any shifts in reporting guidelines. It helps you stay proactive and prepared for any changes.

2. Implement Transaction Monitoring Systems

Having a solid transaction monitoring system is essential. You need to be able to spot large or suspicious transactions quickly, and a sound system will help you do that in real-time. The faster you catch something that doesn’t look right, the easier it is to report it.

3. Maintain Detailed and Accurate Records

Record-keeping might seem like a chore, but it’s an essential part of staying compliant. Keeping detailed, accurate records of all transactions not only makes reporting easier but also ensures that you have everything you need if regulators come knocking.

4. Streamline the Reporting Process

Manual reporting can be a pain, and it leaves room for errors. Automating the process helps streamline things, making it faster, more accurate, and less stressful. The last thing you want is a missed deadline or an incomplete report.

And that’s where Signzy can help. We offer API-based solutions that make FIU compliance simpler and more efficient. Our KYC and transaction monitoring APIs help regulated entities make sure everything is flagged correctly without the usual hassle.

If you’re managing contracts manually, your cycle probably looks like:

• Chasing after signatures and approvals, and somehow always losing track of who’s signed and who hasn’t.
• Digging through stacks of paper or scrolling endlessly through folders, just to find that one contract you need.
• Juggling multiple stakeholders, each with their own priorities and timelines, makes everything take longer and feel more chaotic.
• Trying to keep up with compliance deadlines but missing some along the way due to manual tracking.
• Constantly re-entering data and updating documents because everything is still being handled on paper or in different systems.

Sound familiar? These inefficiencies are already costing you time and money. In fact, a survey confirmed this. On average, a company loses 9% of its annual turnover just from contract mismanagement (source: WorldCC). 

But the good news is, it doesn’t have to be this way. Grab your cuppa coffee, and let’s dive into how you can rethink contract management for better efficiency and less risk.

What is Contract Management?

When we talk about contract management, we’re referring to the structured process of overseeing every stage of a contract’s lifecycle. 

From its creation to execution, monitoring, and eventual renewal, contract management is a critical function that ensures all parties involved are held accountable to their commitments. 

In simple terms, it’s about managing the agreements your business enters into while making sure risks are minimized and opportunities are maximized.

Why is Contract Management Necessary for KYC and AML?

For industries like fintech, payment processing, and crypto, the ability to manage contracts effectively can make the difference between staying compliant and facing penalties.

• Clearly Defined Compliance Obligations

Contracts can specify the procedures for identity verification, due diligence checks, and the documentation required. By defining these obligations in the contract, businesses set clear expectations for both parties from the start, ensuring compliance is built into the process.

• Tracking KYC and AML Requirements

Contracts can outline the need for periodic updates, document revalidation, and reporting. With a well-managed contract, businesses ensure these regular obligations are not overlooked, helping maintain continuous compliance.

• Mitigating Risks with Clear Roles and Responsibilities

Contract management helps by defining who is responsible for carrying out KYC and AML checks, reducing the chances of oversight. Clear assignment of roles ensures that compliance duties are consistently fulfilled and helps avoid the risk of non-compliance, which can lead to financial penalties or reputational damage.

• Easier Audit Trails

Financial institutions are often subject to audits. 

Well-managed contracts ensure there is a clear, accessible record of compliance actions taken at every stage. This audit trail makes it easier to demonstrate that KYC and AML procedures were followed, ensuring transparency and accountability.

Now that we’ve defined what contract management is and why it’s necessary, let’s dive into the key stages that make up the contract lifecycle.

Key Stages of Contract Management

The contract management lifecycle consists of five key stages. Let’s walk through these stages, from identifying the need to successfully closing out and renewing the agreement.

1. Identification of Need and Requirements

The first step in contract management is identifying the need for a contract and defining its scope. Whether you’re onboarding a new client, forming a partnership, or signing with a vendor, this stage is about setting clear, measurable objectives. 

Key actions at this stage include:

• Assessing business needs and understanding the type of agreement required (e.g., service agreement, partnership, vendor contract)
• Gathering input from key stakeholders (legal, compliance, procurement)
• Defining clear goals, deliverables, and timelines

This stage is vital for ensuring that contracts comply with KYC/AML regulations and align with business objectives.

2. Drafting, Negotiation, and Legal Review

Once the need for a contract is identified, it’s time to draft the agreement and enter negotiations. This stage focuses on aligning both parties’ interests, refining terms, and ensuring the contract meets legal and regulatory standards. The process includes:

• Drafting the contract with agreed terms and conditions
• Negotiating deliverables, payment terms, and timelines
• Involving legal teams to review terms and ensure compliance with laws such as KYC, AML, and other regulatory frameworks
• Redlining and revising the document to meet both parties’ expectations

For financial businesses, this is a critical stage to ensure that all legal compliance requirements are addressed, particularly concerning data security, privacy, and regulatory frameworks.

3. Onboarding

After the contract is signed, the next step is putting the terms into action. This phase involves setting up the necessary systems, tools, and processes to ensure everything runs smoothly.

At this point, businesses need to ensure all teams are aligned, systems are in place to track progress, and compliance requirements, like KYC and AML checks, are implemented right from the start.

4. Close-out 

The final stage of the contract lifecycle is the close-out phase. This is when the contract has been fulfilled, and all obligations have been completed. The contract is formally closed, and all records are archived for future reference.

5. Renewal

As the contract’s term nears its end, the renewal phase kicks in. This is an important stage, as it often presents an opportunity for renegotiation. Businesses can assess whether they are getting the value they expected from the contract, or whether it’s time to update terms.

As we’ve discussed, contract management spans 5 stages. However, to make this process more efficient and secure, the way contracts are managed becomes just as important. 

Now, let’s take a look at how manual and digital contract management compare, especially in the context of financial services and compliance.

Manual vs Digital Contract Management

 

Aspect	Manual Contract Management	Digital Contract Management
Speed and Efficiency	Slow and time-consuming due to manual processes and paperwork.	Faster, with automated workflows and quick access to documents.
Error Rate	High, due to human errors in tracking, filing, and updating.	Low, with automated checks, real-time updates, and version control.
Compliance	Difficulty tracking compliance obligations and deadlines manually.	Easier to ensure compliance with automated reminders, audits, and tracking features.
Visibility and Access	Limited visibility, with contracts stored in physical files or in different locations.	Centralized digital storage allows easy access and real-time visibility.
Security	Risk of document loss or unauthorized access, especially with physical storage.	Enhanced security features like encryption and access control for digital contracts.
Scalability	Challenging to scale as the business grows and contract volume increases.	Highly scalable, able to handle large volumes of contracts without compromising efficiency.

From differences, digital contract management clearly comes out as a winner. Even reports back this. Businesses incur an estimated cost of $122 for every hour an in-house lawyer spends reviewing contracts.

To avoid these inefficiencies, businesses can turn to digital solutions. For example, a digital contracting API can automate the signing process and eliminate the need for in-person meetings. The best part is that these solutions can streamline all this while enhancing security and providing an audit trail.

We are not sure about others, but Signzy’s Digital Contracting API is designed to do just that. Take a demo to learn more.

And that wraps up today’s discussion! Don’t forget to check out our other blogs for more expert advice on topics like KYC, AML, and digital transformation in the financial industry. 

Stay ahead of the curve and keep learning with us 🙂

$4.35 billion.

That’s the total amount of penalties paid by just five companies for data breaches and non-compliance with data privacy laws. Even the likes of Facebook and Amazon, with their massive cybersecurity teams, weren’t spared.

And those are just the most significant fines. There’s much more happening behind the scenes. 

Now, when it comes to the UAE, things are even more critical. A data breach here can result in legal action and significant penalties. And it goes without saying, a setback in a market as competitive and high-stakes as the UAE can have long-lasting consequences for your business.

Luckily, you don’t need to navigate this alone. There are tools, practices, and platforms to help you stay compliant and secure, giving you more time to focus on growing your business.

But first, if you are looking to cover all the basics, this blog has a lot of information for you. 

Let’s start right away. 

What Are the Data Privacy Laws in the UAE?

The UAE has really stepped it up when it comes to data privacy. They introduced the Personal Data Protection Law (PDPL) under Federal Decree-Law No. 45 of 2021, and it officially kicked in January 2022. 

Put simply, the law is about making sure personal data is handled properly, transparently, and with respect. 

So, what does this mean for your business? 

If you’re handling personal data in the UAE or dealing with data from UAE residents, you need to get up to speed with these regulations. 

This is the first comprehensive data protection law the UAE has rolled out, and it’s a big deal because it brings the country’s approach to personal data in line with global standards like the EU’s GDPR.

What Data Privacy Rules Do Companies Need to Follow?

The Personal Data Protection Law (PDPL) mandates that businesses comply with strict rules when it comes to processing personal data. Some of the most important rules are listed below.

• Obtain Clear Consent (Article 6)

Companies must obtain clear, explicit consent from individuals before processing their personal data. Consent should be unambiguous and recorded, ensuring the data subject knows exactly what data is being collected and for what purpose. It’s essential that businesses demonstrate they have obtained consent, as consent can be withdrawn at any time by the data subject.

• Limit Data Collection (Article 5)

The data collected must be sufficient, relevant, and not excessive for the specified purpose. Businesses are prohibited from collecting more data than necessary. This means that organizations need to carefully assess what data is essential to meet business needs and ensure that they aren’t over-collecting.

• Purpose Limitation (Article 5)

Personal data must be collected for specific, legitimate purposes, and must not be processed in a way that’s incompatible with those purposes. If the business intends to use the data for a different purpose later, fresh consent must be obtained.

• Accuracy of Data (Article 7)

Businesses are required to ensure that the data they process is accurate and up to date. If any data held is inaccurate or incomplete, it must be rectified without delay. This is crucial to avoid making decisions based on incorrect or outdated information.

• Data Security (Article 20)

Companies must implement technical and organizational measures to ensure personal data is secure. This includes protecting data against unauthorized access, accidental loss, or damage. The law mandates encryption, pseudonymization, and other security protocols to safeguard data in line with best international practices.

• Transparency (Article 8)

Businesses must inform individuals about how their data will be processed, the purpose of the collection, and any third parties with whom the data may be shared. This ensures transparency and helps businesses build trust with data subjects. Additionally, companies must provide a way for data subjects to easily exercise their rights, such as the right to access and correct their data.

• Data Subject Rights (Articles 13-18)

Data subjects are granted several rights, which businesses must respect:

• Right to Access (Article 13): Data subjects can request access to their personal data.
• Right to Rectification (Article 15): Data subjects can correct inaccurate data.
• Right to Erasure (Article 15): In specific circumstances, data subjects can request their data to be erased.
• Right to Restrict Processing (Article 16): Data subjects can restrict how their data is processed.
• Right to Object (Article 17): Data subjects can object to processing for direct marketing or other specific cases.

•  Data Breach Notification (Article 9)

If a data breach occurs, businesses must notify the UAE Data Office immediately and, in some instances, inform the affected data subjects. The breach report must include details of the nature of the breach, corrective actions taken, and the likely consequences of the breach.

• Cross-Border Data Transfers (Articles 22-23)

Personal data can be transferred outside of the UAE, but only to countries that have adequate data protection laws in place. If the destination country doesn’t provide sufficient protection, businesses must implement additional safeguards, such as contracts or agreements, to ensure that data is protected.

• Appointment of a Data Protection Officer (Article 10)

If your business handles large volumes of sensitive personal data or if automated decision-making (such as profiling) is involved, a Data Protection Officer (DPO) must be appointed. The DPO’s role is to monitor compliance, provide guidance on data protection, and act as a liaison with the UAE Data Office.

By following these rules, businesses can ensure that they are compliant with the PDPL, which is essential for maintaining trust and avoiding penalties.

Who Needs to Follow These Laws?

So, who exactly needs to be on top of the UAE’s Personal Data Protection Law? The answer is simple: pretty much anyone dealing with personal data in the UAE, regardless of whether you’re based here or operating internationally. 

• Businesses processing personal data in the UAE
• International businesses processing personal data of UAE residents
• Data controllers determining data processing purposes
• Data processors handling data on behalf of others
• Free zone entities (DIFC, ADGM, DHCC)

As you can see, it’s a responsibility that spans across sectors and borders, so make sure you’re on top of it.

Risks of Non-Compliance in the UAE

Non-compliance with UAE data privacy laws not only affects your business operations but can also lead to severe financial and reputational consequences.

While specific penalties are yet to be fully defined in the PDPL, businesses can face severe fines if they violate key provisions of the law. These can be specified by the UAE Data Office once the executive regulations are issued.

Unauthorized disclosure of personal data can result in criminal charges, including fines of at least AED 20,000 and potential imprisonment for up to one year.

Choosing the Right Privacy Compliance Solution

When selecting a privacy compliance solution, businesses need to ensure that the technology they adopt not only meets regulatory standards but also integrates seamlessly with their existing infrastructure. There should be two main priorities:

1. Security: A privacy compliance solution must ensure that data is protected at all stages: during transit, at rest, and during processing. It should include robust encryption, real-time monitoring, and thorough testing to safeguard against vulnerabilities. 
2. Scalability: As your business grows, so will the volume of data you need to manage. A scalable solution allows you to handle an increasing amount of data and users without sacrificing performance or security. 

 

Finding a solution that covers all these aspects without juggling multiple tools can be overwhelming. This is where Signzy makes a difference.

Signzy offers end-to-end suites while ensuring complete compliance with data privacy laws. No more scrambling around for multiple APIs from different vendors. With Signzy, you get everything you need. Built-in encryption, automated consent management, and continuous security testing through our DevSecOps cycle, all packed in one solution.

Anything that moves fast needs checks to stay stable. 

Financial systems are no different. Without built-in friction, bad money flows just as easily as good money. 

That’s what AML registration solves. It slows things down just enough to make illegal activity harder and accountability easier.

In the UAE, this isn’t optional for certain businesses. If you operate in sectors like real estate, precious metals, crypto, or professional services, you’re expected to register, report, and stay alert. 

If you want to do AML registration in UAE, grab a cuppa coffee, and let’s go through the entire process, step-by-step.

Understanding AML Registration

AML registration is basically your business getting on record with the UAE government to say you’re following anti-money laundering rules. 

In the UAE, AML registration is overseen by the Financial Intelligence Unit (FIU), which runs the goAML platform. Depending on your business type, you might also deal with other authorities like the Central Bank, Ministry of Economy, or Dubai Financial Services Authority. 

These bodies make sure you’re not just registered but also actually doing what’s required, like appointing a compliance officer, setting up internal checks, and staying alert to suspicious activity.

Who Must Register for AML in the UAE?

Not every business needs to go through AML registration, but if you deal with money, high-value assets, or client trust, there’s a good chance you’re on the list. 

The UAE has clearly defined which sectors are considered high-risk for money laundering or terrorism financing, and these are the ones that need to register on the goAML portal and follow AML rules.

Category	Examples
Financial Institutions (FIs)	Banks, insurance companies, exchange houses
Real Estate Sector	Brokers, developers, and agents involved in property transactions
Dealers in Precious Metals and Stones (DPMS)	Jewelry businesses, gold, and diamond dealers
Virtual Asset Service Providers (VASPs)	Crypto exchanges, digital wallet providers
Corporate Service Providers	Businesses offering company formation, nominee director services
Legal Professionals	Law firms, notaries (if engaged in financial or asset transactions)
Accounting and Audit Firms	Accountants, auditors, tax advisors

Even if your business doesn’t handle cash directly, offering services that can be used to hide or move money puts you on the radar. If you’re in doubt, it’s safer to assume registration is needed and verify with a compliance expert.

Step-by-Step Guide to the AML Registration Process

Whether you’re setting this up for the first time or helping someone else do it, here’s exactly how it unfolds. The typical AML registration process has seven steps:

Step 1 – Confirm if Registration Applies to Your Business: Start by checking if your company falls under any of the regulated categories from the above table (double-check with a compliance officer). If yes, registration isn’t optional.

Step 2 – Appoint a Compliance Officer and Gather Documents: You’ll need to assign someone as your AML point of contact. Their documents (e.g., passport, visa, Emirates ID, and authorization letter) will be part of the registration file. Also, get your trade license and business ownership info ready.

Step 3 – Complete Pre-Registration via SACM: Before anything goes into the goAML system, you need access. That starts with registering on the SACM (Service Access Control Manager) portal. This step gives you login credentials and sets up your Google Authenticator access for secure sign-in.

Step 4 – Log into goAML and Set Up Your Entity Profile: Once you’re through SACM, head to the goAML portal. Log in using the credentials and two-factor code. Then, complete your organization’s profile, enter business details and compliance officer info, and assign the correct regulatory authority.

Step 5 – Wait for Approval and Receive Org ID: After submission, your application is reviewed by the relevant authority. Once approved, you’ll receive your official goAML Organization ID. This is what links your business to the system for reporting.

Step 6 – Have Your Internal AML Controls Ready: This isn’t something you do after getting approved. You’re expected to already have your AML policy in place (customer checks, transaction monitoring, risk assessments). If regulators ask for it during the process, you should be ready.

Step 7  – Start Reporting: Once fully registered, you can begin reporting suspicious transactions, high-risk dealings, or flagged clients through the goAML portal. You’re officially live and accountable from this point forward.

Every step builds on the last, so skipping ahead or missing a detail can delay your approval. Do it clean, do it right the first time, and your business stays on the right side of UAE compliance. 

Key Documents and Information Required for Registration

Before you dive into AML registration, make sure your paperwork’s tight. The authorities won’t even look at your application if basic documents are missing or unclear. 

Most of what’s required is standard business documents, but there are a few AML-specific additions you’ll need to prepare upfront.

Here’s what typically needs to be submitted:

• Trade License: A valid commercial or professional license for your business
• Compliance Officer Documents: Copy of passport, Emirates ID, and residence visa of the appointed AML compliance officer
• Authorization Letter: Signed letter authorizing the compliance officer to act on behalf of the company for AML matters
• Organizational Structure: Basic outline of ownership, partners, and business activities
• Contact Details: Accurate email and phone number for official communication
• Google Authenticator Setup: You’ll need to install the app on the compliance officer’s phone for 2FA during goAML access
• Additional Licenses (if applicable): Any sector-specific permits or approvals depending on your business activity

Some authorities may ask for extra stuff depending on your business type, so it’s wise to check before you hit submit. 

Now that you ‘shave working knowledge of what’s AML registration in UAE, it process, document requirements, let’s see what can happen if you don’t comply. 

Consequences of Non-Compliance

The UAE has zero tolerance for businesses that ignore AML laws, and the penalties aren’t light warnings. They hit hard, both financially and reputationally. Here’s a quick snapshot:

Violation	Penalty
Failure to register on goAML	AED 50,000 to AED 5,000,000
Not appointing a Compliance Officer	Heavy fines + possible business review
Delayed or missing STR/SAR submissions	Financial penalty + regulatory scrutiny
Incomplete or incorrect documentation	Application rejection or delays
Not implementing internal AML controls	License suspension or revocation
Repeat or willful violations	Criminal investigation or prosecution

As you can see, whether it’s missing registration deadlines or failing to report suspicious activity, the fines stack up fast and can even lead to criminal charges.

Ongoing compliance is where most businesses slip, not because they ignore the rules but because manual checks can’t keep up with evolving risks.

That’s where smarter infrastructure helps. Tools that handle KYC verification, PEP screening, and UBO checks in real-time reduce the load without cutting corners. Signzy’s API stack fits right into that layer. It’s built to support compliance teams who want faster onboarding, cleaner records, and fewer gaps in their process.

If staying compliant is a priority, your tech should reflect that.

Every fast-moving finance business runs on one simple mechanism: decisions, actions, and consequences.

• Who approved that payout?
• Why was that vendor cleared?
• Was that onboarding flow compliant? 

These questions don’t come up when things go right. 

…But they define everything when things don’t.

That’s where GRC steps in. 

Not as a cost center, not as a corporate ritual, but as a system that ensures critical decisions don’t rely on memory, mood, or muscle memory.

If you want to know how to structure it, run it, and make it part of your operations without slowing down what matters, this guide has everything you need to know and take-home trackers. 

Let’s start with nuts and bolts first.

Governance, Risk, Compliance (GRC), Explained

If you’re building in fintech, crypto, or anything that touches money, you can’t afford loose ends.

Not just in code or design but in how your company works behind the scenes. Who’s making decisions? What happens when things break? Whether you’re following the rules that apply to you.

That’s GRC. Governance, Risk, Compliance. It’s more like the spine that keeps everything straight as you grow.

• Governance → Defines who has the authority to make decisions, approve changes, sign contracts, manage funds, and access sensitive systems. Prevents overlap, confusion, and unauthorized actions.
• Risk → It detects threats like fraud, regulatory action, system downtime, and third-party failure and sets up controls to reduce or respond to them.
• Compliance → Tracks which laws, regulations, and standards apply (like RBI, SEBI, FATF, GDPR) and ensures internal processes, documentation, and product features meet those requirements. Includes audit readiness.

GRC is built so your team doesn’t get stuck fixing preventable problems. It’s what lets you move fast without crossing lines you didn’t even know existed.

Without GRC, you fix things when they break. With GRC, you avoid most breaks to begin with. Especially as you grow, it keeps operations stable while everything else scales. It is not a visible feature, but it keeps the engine clean.

How to Implement GRC in an Organization?

You do not need to over-architect the system, but it has to be deliberate. GRC is not something that happens in the background. It is something you set up intentionally. 

Here’s a comprehensive 6-step process to get running.

Step 1: Assign Clear Ownership

GRC does not work unless each component has a responsible owner. 

• Governance is typically handled by senior leadership, such as the COO or board members since it involves decision-making rules, oversight mechanisms, and accountability. 
• Risk should be owned by operations or a product-risk team, depending on the business model. 
• Compliance usually falls under legal or finance, especially in regulated sectors. 

These roles should be fixed, documented, and visible to the entire leadership team.

Step 2: Build a Live Compliance Inventory

The first tactical step is building a compliance inventory. This is a single document that lists every regulatory, legal, and operational requirement your company must follow. It should include authorities like RBI, SEBI, FIU-IND, income tax, and any self-imposed obligations like contractual requirements from partners or investors. 

For each item, document the frequency, responsible owner, due date, and status. This should be reviewed every month and updated as rules evolve.

Look at this tracker, for example:

You can get this tracker template – HERE. Please read the disclaimer carefully before using it.

Step 3: Maintain a Risk Register

This register is a working document that makes your leadership aware of what could go wrong, how prepared you are, and where you need to act next.

In this, create a structured register of risks across the business. Include legal, operational, financial, cybersecurity, vendor, and reputational risks. Each risk entry should include a short description, its likelihood and impact rating, an owner, and the mitigation plan. Refer the example below for better idea.

Grab tracker – HERE (check second sheet). Once again, please read the disclaimer carefully before using it.

If a risk materializes, the register should also track the incident history and recovery steps.

Step 4: Apply Access and Change Controls

Every tool or system that handles data, money, or sensitive workflows must have permission layers. 

No one should get admin access without documented approval, and no access should go unmonitored. 

You should be able to review logs showing who accessed what and when. For workflows that involve financial decisions, refunds, reconciliations, or reporting, enforce a maker-checker system. One person performs, and another person verifies. 

This prevents internal fraud, misuse, and unintentional errors from going unnoticed.

Step 5: Define Protocols for Incidents

You need a basic response plan for the most common categories like: data breaches, financial errors, system outages, regulatory notices, or internal fraud. These plans should define who is responsible, what steps are taken immediately, who is informed, and whether reporting to regulators or partners is required.

This can be stored in a simple internal document. Everyone involved in operations, tech, or compliance should be trained on it once per quarter. The aim is to avoid delays and miscommunication during high-pressure events.

Step 6: Conduct Internal Reviews Quarterly

Set a fixed schedule to review GRC functioning across departments. 

Each quarter, review the compliance tracker, governance logs, risk register, and access controls. 

• Check what was missed, what got delayed, and what changed. 
• Document the gaps. Assign fix owners. 
• Set a 30-day resolution period for anything that affects compliance or customer trust.

These reviews don’t need to be formal audits. But they need to be routine, structured and followed through. GRC stays strong only when it’s maintained, such as in infrastructure.

Best Practices to Implement GRC

A structured GRC system is good. But what keeps it working week after week is operational hygiene. Beyond the core setup, there are specific habits and decisions that make the difference between a GRC program that exists on paper and one that actually holds up under pressure.

Read these four best practices we’ve compiled. 

1. Regulations should live close to your product, not just in legal docs: Maintain a product-to-regulation mapping. For every customer-facing flow (like onboarding, lending, payments), clearly link the governing rule, circular, or internal policy. Update this during every major release cycle. This avoids accidental non-compliance with product updates.
2. Regulatory updates should be treated as version changes, not alerts. Set a fixed monthly slot to review new circulars, enforcement trends, and legal shifts. Assign a team member to summarize what changed, what’s relevant, and what needs action. Tag affected workflows and assign follow-ups.
3. Compliance tasks need to show up where work happens, not in static files: Use task management tools like ClickUp, Notion, or Trello to assign and track compliance activities. Each task must have an owner, deadline, and proof-of-work link. Reminders and missed-task visibility should be built in by default.
4. Vendor risks should be logged and monitored like internal ones: For every third-party tool, partner, or contractor with access to sensitive data or systems, maintain a basic vendor risk profile. Note compliance clauses, data handling risks, and SLA violations. Review high-risk vendors quarterly. Keep contracts easily retrievable.

The tighter your internal processes get, the more your external systems need to keep pace. When workflows like onboarding, Video KYC, and risk checks become routine, they should not rely on manual checks or scattered tools. That’s where APIs step in for consistency and control.

Whether it’s checking if your information is compromised in data breaches or verifying identities during onboarding, these compliance checks are foundational steps in how trust is built, and risk is managed.

Signzy’s suite of APIs is designed to support that shift. Quietly, in the background, where structure matters most.