Policy

AML Policy Drafting

Regulatory-grade AML/CFT policy documents tailored to your business model

Overview

A well-drafted AML policy is the cornerstone of PMLA compliance. Estabizz drafts, reviews and updates AML/CFT policy documents that are regulator-ready, operationally practical and calibrated to your specific business model — whether you are an NBFC, payment aggregator, insurance entity, stockbroker or fintech platform.

What We Offer

✓Board-approved KYC/AML Policy compliant with PMLA Rules 2005
✓Customer Acceptance Policy (CAP) and Risk Categorisation framework
✓Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) SOP
✓Combating Financing of Terrorism (CFT) procedures
✓STR/CTR escalation and filing procedure
✓Record Retention Policy (5-year PMLA requirement)
✓Politically Exposed Persons (PEP) and adverse media screening procedures

How It Works

1

Business Model Review

Understand your products, customer segments, geographies and distribution channels to calibrate the policy.

2

Regulatory Mapping

Map applicable PMLA Rules, sector-specific master directions (RBI/SEBI/IRDAI) and FATF guidance.

3

Draft & Review

Prepare first draft, share with your compliance/legal team, incorporate feedback and produce a final Board-ready version.

4

Board Adoption Support

Prepare Board note and resolution language; update policy schedule with version control.

Documents Required

  • Business model overview (products, geographies, customer types)
  • Existing AML policy (if being revised)
  • Organisational chart — compliance and senior management
  • Regulator-specific licence/registration details

Frequently Asked Questions

Is a separate CFT policy required or can it be part of the AML policy?+

Both approaches are acceptable. A combined AML/CFT policy is common and acceptable to regulators; some large entities maintain a separate CFT annex.

Does the Board need to formally approve the AML policy?+

Yes. Under PMLA Rules and most sector-specific directions, the AML/KYC policy must be approved and periodically reviewed by the Board.

Can the same policy apply to multiple regulated entities in a group?+

A group-level policy can set minimum standards, but each regulated entity typically needs its own adopted version reflecting its specific licence and customer base.

AML Policy Drafting — Start Today

Regulatory-grade AML/CFT policy documents tailored to your business model

Book a Free Consultation →