121 FAQs on Imports of Goods and Services under FEMA, 1999″ provides a comprehensive overview of the legal and procedural framework governing imports into India. It outlines the roles of FEMA, RBI, and DGFT in regulating import transactions, emphasizing the responsibilities of Authorized Dealer (AD) Banks. These banks must ensure compliance with FEMA, FTP, KYC norms, and documentation requirements like BoEs and IDPMS filings. The FAQs clarify permissible payment methods, timelines for remittances, deferred payment arrangements, and third-party payments. It also covers sector-specific provisions for rough diamonds, aircraft, and BPO equipment, along with rules on guarantees, advance remittances, and currency importation. Importers are required to maintain documentary evidence and adhere to RBI’s prudential guidelines. Banks may allow certain flexibilities under prescribed conditions and must escalate high-value or time-sensitive cases to the RBI. Overall, the guidelines aim to balance regulatory control with trade facilitation and ensure proper tracking of foreign exchange transactions.
121 FAQs on Imports of Goods and Services under FEMA, 1999
(Source for compilation is Master direction no. 18 dated Jan 01, 2016 was 1st direction + also updated on Jan 06, 2022)
Chapter I – Introduction for IoGS
1. What is Legal status for IoGS?
(i) IoGS are permitted under section 5 of FEMA, 1999.
(ii) IoGS provisions are notified through notification G.S.R. 381(E) dated May 03, 2000 i.e. Foreign Exchange Management (Current Account Transaction) Rules, 2000.
(iii) IoGS provisions are amended from time to time for incorporating changes in regulatory frameworks + also published through several amendment notifications “both”.
2. What are RBI’s regulations for IoGS?
- RBI’s regulations are required to communicate through issue of directions to AD Category-I Banks (Banks) under section 11 of FEMA, 1999.
3. What are RBI’s directions for IoGS?
- RBI’s directions are required to prescribe modalities for foreign exchange businesses with Importers for implementing RBI’s regulations.
4. What are RBI’s Instructions for IoGS?
- RBI’s instructions are required to issue for IoGS through Master Direction (MD) with several circulars / notifications.
- Master Direction 18 dated Jan 01, 2016 was 1st direction issued for IoGS under FEMA + also “lastly” updated on Jan 06, 2022 “both”.
5. What are RBI’s directions for regulation’s changes?
- RBI is required to issue directions to Banks through A.P. (DIR Series) for changes in regulations + also directions “both” for transactions with importers.
6. What is DGFT’s role for IoGS?
- IoGS are required to regulate by Directorate General of Foreign Trade (DGFT) working under Ministry of Commerce and Industry, Government of India (Govt.) through Department of Commerce.
7. What are Bank’s roles for FTPs’ compliances?
- Banks are required to ensure that imports are in conformity with Foreign Trade Policy (FTP) + with Foreign Exchange Management (Current Account Transactions) Rules, 2000 + notified through Notification No. G.S.R.381 (E) dated May 3, 2000 + RBI’s directions issued under FEMA 1999 + also amended from time to time “all”.
8. What are Bank’s roles for UCPDC?
- Banks are required to follow “normal” banking procedures + provisions for Uniform Customs and Practices of Documentary Credits (UCPDC) + also etc. “all” for opening Letters of Credit (LC) for importers.
9. What are Bank’s roles for R&D Cess Act?
kBanks are required to ensure compliances with provisions for Research & Development (R&D) Cess Act, 1986 for imports of drawings + also designs “both”.
10. What are Bank’s roles for Income Tax + Companies Act?
- Banks are required to advise to importers for ensuring compliances with provisions of Income Tax Act (ITA) 1961 + also Companies Act (CA) 2013.
11. What are Bank’s roles for approaching to RBI?
- Banks are required to approach RBI’s Regional Office (RO) under Foreign Exchange Department situated in jurisdiction where Importers are residing / firms / companies are functioning when banks don’t have powers.
Chapter II – RBI’s “General” Guidelines for IoGS
12. What are RBI’s rules + regulations for IoGS?
- Banks are required to follow RBI’s rules + also regulations “both” when importers are making payments for imports of goods / services.
13. What is RBI’s normal trade practices for IoGS?
- Banks are required to follow “normal” trade practices when “specific” rules + also regulations “both” are not existed i.e. RBI’s Know Your Customer (KYC) regulations.
14. What are Bank’s roles for import’s remittances?
- Banks are required to ensure that 100% “requisite” details are available with importers + also remittances “both” for bona fide “trade” transactions in accordance with prevailing laws in India.
15. What are Bank’s roles for FTP’s licences?
- Banks are required to obtain FTP’s licences when import of goods / services are under FTP’s “negative” list.
16. What are Bank’s roles for opening LCs?
- Banks are required to open LCs for import of goods / services
17. What are Bank’s roles for preserving utilized licences?
- Banks are required to preserve “utilized” licence’s copies till these are verified by banks’ Internal Auditors / Statutory Auditors / inspectors.
18. What are Importers’ roles for acquiring foreign exchanges?
- Importers are required to use acquired foreign exchange as mentioned in their declaration filed to banks under section 10(5) of FEMA, 1999
19. What are Importers’ roles for furnishing evidences?
- Importers are required to furnish evidences for imports of goods / services like:
(i) Postal Appraisal Form (PAF)
(ii) Customs Assessment Certificate (CAC)
20. What are Importers’ duties for goods / services’ values?
- Importers are required to ensure that goods / services’ values are not lower than amount remitted for export of goods / services.
21. What are Importers’ duties for IDPMS’ uploading?
- Importers are required to ensure that 100% outstanding payments are uploaded in IDPMS on scheduled notified dates.
22. What are Importers’ rights for using international credit cards?
(i) Importers are permitted to make payments for imports of goods / services using “international” credit card issued in INR by “international” credit card / debit card issuing agencies / banks for making payments in foreign exchanges.
(ii) Importers are required to ensure that 100% payments using “international” credit card / debit card are in FTP’s conformity.
23. What are Importers’ rights for non-residents’ expenses?
- Importers are permitted to make payments for expenses in INR for non-residents visiting in India for importers’ works like:
(i) Boarding expenses
(ii) Lodging expenses
(iii) Other expenses
24. What are Importers’ rights for crossed cheques / bank drafts?
- Importers are permitted to make payments by “crossed” cheques / crossed bank drafts for golds / silvers’ purchased in accordance with Foreign Trade (Development and Regulations) Act, 1992 / under other laws / rules / regulations for time being in force
25. What are Importers’ rights for non-residents’ expenses in INR?
- Importers are permitted to make payments in INR to their non-resident non “whole-time” directors visiting in India for importers’ works + these directors are entitled for sitting fees + commissions + remunerations + travel expenses in accordance with company’s Memorandum of Association (MoA) + Articles of Association (AoA) + also resolutions passed by companies in their AGMs / EGMs / Board of Directors (BoDs) “all”.
26. What are Time Limits for normal payments?
(i) Importers are required to make 100% payments within maximum 6 months commencing from shipments’ date “before” July 31, 2020.
(ii) Importers are required to make 100% payments within maximum 12 months commencing from shipments’ date “after” July 31, 2020.
27. What are Importer’s rights for withholding payments?
- Importers are permitted for “withholding” payments for “performance” guarantees + disruptions due to outbreak i.e. COVID-19 + also etc. “all”
28. What are Bank’s roles for delay payments?
- Banks are permitted to make 100% payments within maximum 3 years when delays are due to disputes / financial difficulties + also etc. “both”
29. What are Bank’s roles for delay payments’ interest?
- Banks are not permitted to make payments for delay payments’ “interest” exceeding 3 years.
30. What are Time Limits for deferred payments?
- Banks are permitted to make 100% payments within maximum 5 years when payments are required under deferred payment arrangements / supplier credits / buyer credits
31. What are ECBs for deferred payments?
(i) Importers are required to treat External Commercial Borrowings (ECBs) + also trade credits “both” for deferred payment arrangements / supplier credits / buyer credits
(ii) Importers are required to obey RBI’s ECBs guidelines for deferred payment arrangements / supplier credits / buyer credits
32. What are Time Limits for books’ imports?
(i) Banks are permitted for remitting 100% outstandings against books’ imports “without” restrictions for number of years + also interest payments for 100% outstanding’s period “both”.
(ii) Banks are for not permitted for imposing restrictions e. 1 / 3 / 5 years for remitting 100% outstandings for books’ imports
(iii) Banks are not permitted for imposing restrictions for not to pay “interest” on outstanding exceeding 5 years for books’ imports
33. What are Time Limits for extensions?
(i) Banks are permitted to grant extensions for time limits for import’s payments not exceeding 6 months at 1 time.
(ii) Banks are permitted to grant extensions for time limits for import’s payments not exceeding 36 months at 6 times.
(iii) Hence banks are permitted to grant extensions for import’s payments not exceeding 36 months e. 6 months for 1st extension + 30 months for 5 “additional” extensions = 36 months
34. What are RBI’s guidelines for extensions?
- RBI has issued “sector wise specific” guidelines for time’s extension i.e. “separate” guidelines for rough + cut + also polished “all” diamonds.
35. What are Banks’ roles for extensions?
- Banks are required to satisfy criteria’s “before” granting extensions like:
(i) Banks are required to ensure that imports’ transactions are not under investigations by certain agencies like:
(a) Enforcement Directorate (ED)
(b) Central Bureau of Investigation (CBI)
(c) Other Investigating Agencies (OIAs)
(ii) (a) Banks are required to ensure that “total” outstandings are not exceeding USD 1 million / it’s equivalent
Or
(b) Not exceeding “average” 10% of imports remittances made in preceding 2 financial years whichever are lower when extensions are exceeding for 1 year
(iii) Banks are required to mark extension’s date in remarks’ column
(iv) Banks are not permitted to extend time limit beyond instructions or when periods are exceeding 3 years whichever are higher.
(v) Banks are required to approach to RBI’s RO for time’s extension beyond instructions or when periods are exceeding 3 years whichever are higher.
(vi) Banks are required to report in IDPMS for Bill of Entry (BoE) extension + also extended date “both”.
36. What are RBI’s guidelines for foreign currencies’ imports?
- RBI is not permitted to allow for importing “foreign” currencies + also “foreign” currencies’ cheques “both” in India.
37. What are RBI’s guidelines for foreign currencies by non-residents?
(i) Non-residents of India are permitted for bringing “foreign” currencies notes + also Travel Cheques (TCs) “both” on their arrival in India “after” submitting declaration to custom authorities at airport in Currency Declaration Form (CDF)
(ii) Non-residents of India are not required to submit CDF when “foreign” currencies notes + also TCs “both” are not exceeding USD 10,000 / it’s equivalent
(iii) Non-residents of India are not required to submit CDF when “foreign” currencies notes “only” are not exceeding USD 5,000 / it’s equivalent
38. What are RBI’s guidelines for Indian currency by residents?
(i) Residents of India are not permitted to bring INR exceeding 25,000 when they are returning back in India from “temporary” foreign visits.
(ii) Residents of India are permitted to bring INR exceeding 25,000 when they are returning back in India from “temporary” foreign visits from Nepal / Bhutan.
(iii) (a) Residents of India are not permitted to bring INR exceeding 25,000 when they are returning back in India from “temporary” foreign visits from Nepal / Bhutan in “denominations” exceeding INR 100.
(b) Residents of India are not permitted to bring INR exceeding 25,000 when they are returning back in India from “temporary” foreign visits from Nepal / Bhutan in “denominations” in INR 500
39. What are Banks’ roles for 3rd party payments?
- Banks are permitted to make payments to 3rd party for imports of goods / services “after” satisfaction of conditions like:
(i) Banks are required to ensure that importers are having firm irrevocable purchase orders / “tripartite” agreements.
(ii) Banks are not required to ensure that importers are having firm irrevocable purchase orders / “tripartite” agreements when “documentary” evidences are available for circumstances for 3rd party payments / 3rd party’s name “already” mentioned in firm irrevocable purchase orders / invoices produced by importers.
- Banks are required to satisfy for transactions’ bona fide + also for Financial Action Task Force (FATF) statement “before” handling 3rd party transactions.
- Banks are required to ensure that invoices are containing “narration” for payments to 3rd party “only”.
- Banks are required to ensure that BoEs are mentioning shipper’s name + also containing “narration” for payment to 3rd party “only”.
- Banks are required to ensure that importers have complied RBI’s instructions for imports + also advance payments “both”.
40. What are Banks’ roles for issuing guarantees?
- Banks are permitted to give guarantees against debts / obligations / other liabilities incurred by importers for imports of goods / services on deferred payment arrangements + also in accordance with RBI’s approval “both”.
41. What are Banks’ roles for different guarantees?
- Banks are permitted to give 2 types guarantees against debts / obligations / other liabilities incurred by importers for import of goods / services “after” satisfaction of RBI’s conditions like:
(i) Letter of Undertakings (LoUs)
(ii) Letter of Comforts (LoCs)
42. What are Banks’ roles for service’s import guarantees?
- Banks are permitted to give guarantees in favour of non-resident service providers for service’s imports “after” satisfaction of RBI’s conditions
43. What are Limits for non-PSUs services’ guarantees?
- Banks are not permitted to give guarantees for service’s imports when amounts are exceeding USD 500,000 / its equivalent.
44. What are Limits for PSUs services’ guarantees?
- Banks are not permitted to give guarantees for service’s imports by Public sector undertaking (PSUs) / Central govts.’ undertakings / State govts.’ undertakings when amounts are exceeding USD 100,000 / its equivalent “without” approval from Ministry of Finance (MoF) Govt. of India.
45. What are Banks’ roles for corporate guarantees?
- Banks are permitted to issue “corporate” guarantees for operating lease through import financings from foreign lessors in accordance with FTP + Foreign exchange Management (Current Account Transactions) Rules, 2000 notified through Notification No. G. S. R. 381 (E) dated May 3, 2000 + also RBI’s directions issued under FEMA Act, 1999 “all”.
Chapter III –RBI’s “Operational” Guidelines for IoGS
Banks’ roles for Advance remittances
46. What are Banks’ roles for advance remittances?
- Banks are permitted to send “advance” remittances for Imports of goods / services not exceeding USD 200,000 / its equivalent.
47. What are Limits for advance remittances?
- Banks are permitted to send “advance” remittances for Imports of goods / services exceeding USD 200,000 / it’s equivalent when supported with unconditional + also irrevocable Standby Letter of Credit (SLC) / guaranteed from reputed “international” banks located outside India / guaranteed from AD Category-I Banks located in India “both”.
48. What are Banks’ roles for remittances “without” guarantees?
(i) Banks are permitted to send “advance” remittances for Imports of goods / services not exceeding USD 500,000 / it’s equivalent when importers are unable to obtain bank guarantees from overseas’ suppliers
But
(ii) Banks are satisfied for track records + also bona fide “both” for importers
49. What are Banks’ roles for framing internal guidelines?
- Banks are permitted to frame their own internal guidelines for dealing with “advance” remittances based on “suitable” policies framed by bank’s BoDs
50. What are Banks’ roles for PSUs remittances “without” guarantees?
(i) Banks are permitted to send “advance” remittances exceeding USD 1,00,000 / it’s equivalent for PSUs / importers i.e. PSUs + departments / Undertaking of Central Government / State Government(s) when they are unable to obtain bank guarantees from reputed “international” banks
But
(ii) Importers are required to obtain “specific” waivers for bank guarantees from MoF of India
51. What are ORMs for advance remittances?
- Banks are permitted to send “advance” remittances for imports of goods / services “after” creating Outward Remittance Messages (ORMs) for 100% “advance” remittances + also to follow RBI’s guidelines for IDPMS “both”.
52. What are Banks’ roles for rough diamonds’ remittances?
- Banks are permitted to send “advance” remittances “without” monetary limit for bank guarantees / stand-by-LC for “rough” diamond’s imports subject to satisfaction of conditions
53. What are Banks’ duties for rough diamonds’ remittances?
(i) Banks are required to ensure that overseas “mining” entities are approved by Gem & Jewellery Export Promotion Council (GJEPC) in India.
(ii) Banks are required to ensure that Importers are “recognised” processors for “rough” diamonds + also having good track records “both”.
(iii) Banks are required to ensure based on their commercial judgments + also to satisfy for import transactions’ bona fide “both”.
(iv) Banks are required to ensure that “advance” remittances are made strictly in accordance with sale contracts’ conditions + also made directly to overseas supplier’s / ultimate beneficiaries accounts.
(v) Banks are required to ensure that “advance” remittances are not made through “numbered” accounts / otherwise
(vi) Banks are required to ensure that they have created ORM for 100% remittances in IDPMS.
(vii) Banks are required to take “proper” due cautions “before” remittances for “conflict” diamonds’ imports / “Kimberly” Certifications
(viii) Banks are required to obey RBI’s KYC guidelines + also to carry “proper” due diligence in accordance with RBI’s guidelines.
(ix) Banks are required to follow-up for submitting BoE / documents evidencing “rough” diamonds’ imports in accordance with conditions specified in FEMA, 1999 + FEMA’s rules + FEMA’s regulations + also RBI’s directions “all”
(x) Banks are required to obtain “waiver” letters from MoF, Govt. of India for imports by PSUs + govt.’s departments + Central govt.’s undertakings + also state govt.(s) undertakings “all” when “advance” remittances are exceeding USD 100,000 / it’s equivalent + also bank guarantees from overseas suppliers are not received “both”
(xi) Banks are required to download “BoE” issued by EDI ports from “BOE Master” in IDPMS based on EDI Ports’ declarations filed by importers
(xi) Banks are required to upload “BoE” data in IDPMS based on message format “Manual BoE reporting” on daily basis “after” receiving BoE from customers / custom offices.
(xii) Banks are required to enter “BoE” details + also to mark “off ORMs” based on message format for BoE settlements.
(xiii) Banks are required to send “advance” remittances “after” receiving BoE + also ORMs’ generations based on message format “both” for BoE settlements.
54. What are Banks’ roles for Aircrafts’ remittances?
- Banks are permitted to send “advance” remittances “without” bank guarantees / irrevocable stand-by-LC for imports of Aircrafts + Helicopters + Aviation + used / 2nd hand aircrafts / helicopters when amounts are not exceeding USD 50 million / it’s equivalent where operators are permitted for operating by Directorate General of Civil Aviation (DGCA)
55. What are Banks’ duties for Aircrafts’ remittances?
(i) Banks are required to undertake transactions based on commercial judgments + “after” satisfaction for transactions’ bona fide + KYC guidelines + due diligence exercises against Indian importers + also overseas manufacturers “all”.
(ii) Banks are required to send “advance” remittances based on strictly sale contract’s terms + also directly to overseas manufacturers’ accounts “only”.
(iii) Banks are required to frame own internal guidelines for dealing with “advance” remittance cases “after” obtaining approval from BoDs.
(iv) Banks are required to ensure that bank guarantees’ requirements are waived by MoF, Govt. of India for “advance” remittances when amounts are exceeding USD 100,000 / it’s equivalent + importers are PSUs + Govt. Department + also Undertaking of Central / State Government(s) “all”.
(v) Banks are required to ensure that “physical” imports for non-“capital” goods are made within 6 months + also for “capital” goods within 3 years from remittances’
(vi) Banks are required to ensure that importers have given undertakings for furnishing “documentary” evidences within 15 days from closures’
(vii) Banks are required to ensure that “principal” approvals are obtained by importers from Ministry of Civil Aviation for Scheduled Air Service Operations
(viii) Banks are required to ensure that “principal” approvals are obtained by importers from DGCA / other agencies in accordance with FTP in India.
(ix) Banks are required to ensure that amounts for “advance” remittances are immediately repatriated to India when imports for aircraft / aviation sector related items are cancelled.
(x) Banks are required to ensure for obtaining approvals from RBI’s RO for deviation(s) from abovementioned stipulations “if any”.
(xi) Banks are required to generate ORMs + BoE entries + also BoE settlements “all” with ORMs in accordance with RBI’s guidelines for IDPMS.
56. What are Banks’ roles for services’ remittances?
- Banks are permitted to send “advance” remittances “without” monetary limits for bank guarantees / stand-by-LC for services’ imports subject to satisfaction of conditions
57. What are Banks’ duties for services’ remittances?
(i) Banks are required to obtain guarantees from reputed “international” banks located outside India / from banks located in India when “advance” remittances are exceeding USD 500,000 / it’s equivalent
(ii) Banks are required to take approval from MoF, Govt. of India for “advance” remittances for services’ imports “without” bank guarantee when “advance” remittances are exceeding USD 100,000 / it’s equivalent + importers are PSUs + Govt. Department + also Undertaking of Central / State Government(s) “all”
(iii) Banks are required to follow-ups for ensuring that ultimate beneficiaries for “advance” remittances are fulfilling their obligations under contracts / agreements with importers otherwise overseas suppliers are required immediately to repatriate to India.
(iv) Banks are required to ensure that ORMs generated + also marked off in IDPMS are in accordance with RBI’s guidelines for IDPMS.
58. What are Banks’ roles for outstanding bills’ interests?
- Banks are permitted to allow payments for interests on outstanding “usance” bills / “overdue” interest on delayed payments for period not exceeding 3 years from shipments’ date at interest rate prescribed by RBI for trade credits.
59. What are Banks’ roles for bills’ prepayments?
(i) Banks are permitted for “usance” bills’ prepayments + also remittances “after” deducting “proportionate” interest for “unexpired usance” bills’ time at interest rate claimed / LIBOR of invoices whichever are applicable
(ii) Banks are permitted for remittances when interest are not “separately” claimed / “expressly” indicated “after” deducting “proportionate” interest for “unexpired usance” bills’ time at LIBOR of invoices.
60. What are Banks’ roles for ORM mark in IDPMS / etc.?
- Banks are required to ensure that “proper” remarks / indicators are entered for ORM mark in IDPMS / etc. for changes in values in accordance with RBI’s guidelines for IDPMS.
61. What are Banks’ roles for lost-in-transit?
(i) Banks are required to ensure that remittances are received in India when goods are lost-in-transit / short-supplied / damaged / short-landed.
(ii) Banks are required to obtain copies for exchange control of imports “licences” utilised for covering LC’s opening against “original” goods.
(iii) Banks are required to obtain “original” endorsement in “proportions” to lost-in-transit + also to have “fresh” remittances “both” for imports’ replacement “without” referring to RBI “after” ensuring that insurance claims for lost-in-transit are settled in importers’ favour.
(iv) Banks are required to ensure that replacement’s shipments are within licenses’ “validity” periods + also made “proper” remarks / indicators entered for ORM marks off / bills’ closure in IDPMS / etc. in accordance with RBI’s guidelines for IDPMS.
62. What are Banks’ roles for issuing replacements’ guarantees?
(i) Banks are permitted to issue “fresh” guarantees for importing goods against “defected” goods’ replacements.
(ii) Banks are required to ensure that “original” defected goods are replaced.
63. What are Banks’ roles for BPOs’ equipment imports?
- Banks are required to allow remittances for importing equipment by Business Process Outsourcing (BPO) companies working in India for installing at “overseas” sites for setting their International Call Centres (ICCs)
64. What are Banks’ duties for BPOs’ equipment imports?
(i) Banks are required to ensure that BPO’s companies have obtained “necessary” approvals from Ministry of Communications and Information Technology, Govt. of India + also “other” authorities concerned “both” for ICC’s setting in India.
(ii) Banks are required to ensure that commercial judgments + also transactions’ bona fide are strictly in accordance with conditions specified in contracts between importers and exporters “both”.
(iii) Banks are required to send “direct” remittances to overseas suppliers’ bank accounts.
(iv) Banks are required to obtain certificates for imports’ evidences from Chief Executive Officer (CEO) / Statutory Auditor of importer’s companies that goods are “actually” imported + also installed at “overseas” sites “both”.
(v) Banks are required to ensure that IDPMS’ compliances are fulfilled in accordance with RBI’s guidelines for IDPMS.
65. What are Banks’ roles for ORMs’ generations?
- Banks are required to ensure for ORMs’ generation + BoE entries + also BoE settlements “all” with ORMs in accordance with RBI’s guidelines for IDPMS.
66. What are Banks’ duties for ORMs’ generations?
- Banks are required to ensure that imports’ documents + also bills “both” be received “directly” from overseas’ bankers for overseas’ suppliers
67. What are Exemptions for ORMs’ generations?
- Banks are permitted to make remittances without “directly” receiving imports’ documents + also bills “both” from overseas’ bankers for overseas’ suppliers in “specific” circumstances like:
(i) When imports’ bills are not exceeding USD 300,000 / it’s equivalent.
(ii) When imports’ bills are received by wholly-owned “Indian” subsidiaries from holding “foreign” company.
(iii) When imports’ bills are received by Status Holder Exporters “defined” in FTP + 100% Export Oriented Units (EOUs) / Units in Special Economic Zones (SEZs) + also PSUs “all”.
(iv) When import’ bills are received by public limited companies + “deemed” public limited companies + also “private” limited companies “all”.
68. What are Banks’ roles for diamonds imports’ remittances?
- Banks are permitted to allow remittances for imports by diamonds’ importers when imports are not exceeding USD 300,000 / it’s equivalent + also, for items’ imports i.e. rough diamonds + rough precious stones + also semi-precious stones “all”.
69. What are Banks’ duties for diamonds imports’ remittances?
(i) Banks are required to ensure that documents received “directly” from overseas’ suppliers + also “documentary” evidences “both” for imports are submitted by importers at remittances’ time.
(ii) Banks are required to ensure that imports should be for “rough” diamonds + “rough” precious stones + also “semi-precious” stones “all” without monetary limit “after” satisfaction of conditions like:
(a) When imports are in accordance with FTP.
(b) When transactions are based on commercial judgments + also satisfied with bona fide “both”.
(c) When banks have completed KYC exercises + due diligence exercises + 100% satisfied for importers’ financial standings + status + also track records “before” extending facilities.
70. What are Banks’ roles for receiving documents directly?
(i) Banks are permitted to receive bills “directly” from overseas’ suppliers “after” receiving requests from importers when banks are 100% satisfied for importers’ financial standings + also track records “both”.
(ii) Banks are required to obtain reports for “each” overseas’ suppliers from overseas’ bankers / reputed overseas credit agencies.
(iii) Banks are not required to obtain reports for “each” overseas’ supplier from overseas’ bankers / reputed overseas credit agencies when invoices’ values are not exceeding USD 300,000 / it’s equivalent + satisfied with transactions’ bona fide + also importers’ track records “all”.
71. What are Documentary evidences for physical imports?
- Banks are required to ensure that 100% documents are submitted by importers for goods’ “physical” imports like:
(i) BoE number + port code + also shipment’s date “all” for marking imports’ evidences under IDPMS.
(ii) CAC / PAF declared by importers to Customs Authorities when imports are made by post / courier by couriers’ companies to Customs Authorities for goods “physical” imports through couriers.
(iii) Exchange Control Copy (ECC) for Ex-Bond BoE / BoE issued by Customs Authorities for goods “physically” imported + also stored “both” in Free Trade Warehousing Zone (FTWZ) / SEZ Unit warehouses / Customs bonded warehouses / etc.
72. What are Banks’ roles for imports on acceptance basis?
(i) Banks are required to verify imports’ evidences from IDPMS “before” remittances for imports on delivery against acceptance basis
(ii) Banks are permitted to allow remittances when importers are failed to produce “documentary” evidences due to “genuine” consignments’ non-arrival / delay delivery / delay in consignments’ custom clearings / etc. where banks are satisfied with request’s “genuineness”
(iii) Banks are permitted to allow “advance” remittances maximum for 3 months from remittances’ date for reasons mentioned under FAQ 72 (ii) for submitting imports’ evidences.
73. What are Banks’ roles for creating ORMs?
- Banks are required to create ORMs for 100% remittances + also to perform “subsequent” activities “both” in accordance with RBI’s IDPMS guidelines like:
(i) Documents’ submissions
(ii) Outward remittance data
(iii) Matching with ORMs
(iv) Transactions’ closings
(v) etc.
74. What are Banks’ roles for documents in Lieu of BoE?
- Banks are permitted to accept certificates from Chief Executive Officer (CEO) / Statutory Auditor in lieu of BoE’s ECC for home consumptions + also goods were imported “after” satisfaction of conditions “both”.
75. What are Conditions for documents in Lieu of BoE?
(i) When foreign exchanges’ amounts remitted are not exceeding USD 1,000,000 / it’s equivalent.
(ii) When importers’ companies are listed on stock exchanges in India + also having net worth exceeding INR 100 crore as on last audited balance sheet’s date “both”.
(iii) When importers are PSUs / undertakings / departments of Govt.
76. What are Banks’ rights for documents in Lieu of BoE?
(i) Banks are permitted to extend this facility to autonomous bodies e. scientific bodies + academic institutions “both” i.e. Indian Institute of Science / Indian Institute of Technology / etc.
(ii) Banks are permitted to extend this facility when accounts are audited by Comptroller and Auditor General of India (CAG)
(iii) Banks are permitted to obtain declarations from Statutory Auditor / CEO of institutions that their accounts are audited by CAG
(iv) Banks are permitted to created ORM + also to download BoE Master in IDPMS
(v) Banks are permitted to accept “duplicate” copies / “certified” custom duties “paid” copies + also to obtain RBI’s waivers “both”
77. What are Banks’ roles for intangibles’ imports?
(i) Banks are required to obtain certificates from Chartered Accountants (CAs) that software’s / data’s / drawings / designs are received by importers when imports are made in non “physical” form i.e. software’s / data through internet + drawings + also designs through e-mail “all”.
(ii) Banks are required to ensure that importers have informed to Customs Authorities for non “physical” form’s imports.
78. What are Banks’ roles for documents not submitted?
- Banks are required to create ORM for 100% outward remittances for imports’ payments when “prescribed” documents for evidences are not submitted by importers.
79. What are Banks’ roles for settling ORMs?
(i) Banks are required to download BoE issued by EDI ports from BOE Master in IDPMS
(ii) Banks are required to submit “hard” copies for imports’ evidences documentse. BoE + also ECC “both”
(iii) Banks are required to enter BoE’s details like:
(a) BoE number
(b) Port code
(c) ORM’s date associated with “advance” payments for imports transactions in accordance with message format under BoE’s settlements.
(iv) Banks are required to generate ORM for imports’ payments made by importers in accordance with message format under BoE’s settlements.
(v) Banks are permitted to settle “multiple” ORMs for “multiple” BoE
80. What are Documents for settling ORMs?
- Banks are required to settle ORM with imports’ evidences + also to issue acknowledgement slips to importers containing followings particulars:
(i) Importer’s full names + also addresses with code numbers “both”
(ii) BoE’s numbers + BoE’s dates + also imports’ amounts “all”
(iii) Recap advices for BoE’s numbers + BoE’s amounts + also ORM “all” when not settled for importers.
81. What are Importers’ roles for settling ORMs?
- Importers are required to preserve “printed” importers copies for BoEs as import’s evidences + also acknowledgement slips “both” for future use.
82. What are Banks’ roles for time’s extension?
(i) Banks are required to give time’s extension for BoE’s submission beyond “prescribed” period in accordance with RBI’s guidelines.
(ii)Banks are required to report in IDPMS in accordance with message for BoE’s extension + also extensions’ dates “both” in extension date’s column
83. What are Banks’ roles for write offs?
(i) Banks are required to consider BoEs / ORM’s closure in IDPMS when write- offs are not exceeding 5% for invoice’s values
(ii) Banks are required to satisfy with “operational” reason(s) submitted by importers when amount declared in BoE is different from “actual” remittances.
(iii) Banks are required to consider BoE’s closure for imports’ transactions when write-offs are on following reasons:
(a) Write-offs due to poor quality
(b) Write-offs due to short shipments
(c) Write-offs due to goods’ destruction by ports / customs / health authorities in accordance with RBI’s guidelines
(iv) Banks are required to settle + also to close ORM / BoE with “appropriate” Adjustment Indicator (AI) in IDPMS
(v) Banks are required to create + to upload in form of BoE data in accordance with BoEs’ message “format” manual reporting in IDPMS when imports’ evidence are accepted in lieu of BoE based on RBI’s instructions + also RBI’s guidelines “all”
84. What are Importers’ roles for write offs?
- Importers are required to submit “satisfactory” documentations beside amount’s quantum
85. What are Conditions for write offs?
(i) When case is not pending in civil / criminal suit in India + also outside India “both”
(ii) When importers are not in ED / CBI / OIAs “adverse” notices
(iii) When “internal” inspectors / “Statutory” Auditors / “external” Auditors have carried “random” samples check / percentage check for imports bills’ write-offs
86. What are RBI’s roles for write offs?
- RBI’s ROs are permitted to give “necessary” approvals for extensions + write offs when banks have referred for extensions / write offs where extensions + also write offs “all” are not covered under RBI’s guidelines
87. What are Banks’ roles for continuing follow-ups?
(i) Banks are required to continue follow-ups against “outward” remittances made for imports i.e. “unsettled” ORM in accordance with RBI’s guidelines.
(ii) Banks are required to continue follow-ups with importers for submitting “necessary” imports’ documents when imports’ evidences data are not available in IDPMS “after” ORM’s “due” date.
88. What are Banks’ roles for document’s verifications?
(i) Banks are required to carry verifications + IS audit + BoE’s assurance settlement process in IDPMS through “Internal” inspectors + “Statutory” Auditors + also “external” Auditors “all”
(ii) Banks are required to process data for BoE’s settlement + also data’s preservation in accordance with RBI’s guidelines under Cyber Security Framework (CSF) in banks.
(iii) Banks are required to carry document’s verifications for evidencing imports“other than” available in IDPMS e. ECC of PAFs / CACs /etc. through “Internal” inspectors / “Statutory” Auditors / “external” Auditors
89. What are Banks’ roles for document’s preservations?
(i) Banks are required to preserve documents “evidencing” imports for minimum 1 year from verification’s
(ii) Banks are required to preserve documents “evidencing” imports “after” obtaining clearances from investigating agencies when cases are under investigations by investigating agencies e. CBI / ED / OIAs.
90. What are Banks’ roles for evidences’ follow-ups?
(i) Banks are required to follow-ups with importers for obtaining “necessary” “documentary” evidences for imports within maximum 3 months from remittances’
(ii) Banks are required to follow-ups with importers for obtaining “necessary” “documentary” evidences for imports within “next” 3 months from 1st expiry “after” 3 months + also “minimum” 1 communication with importers through registered letter “both”.
91. What are Banks’ roles for reporting to RBI’s RO?
(i) Banks are required to report to concerned RBI’s RO for 100% outstanding cases when import’s remittances are pending without “physical” These are commonly known imports are not completed
(ii) Banks are required to submit “separate” BEF statement to concerned RBI’s RO for half year ending e. June 30th + also Dec 31st “both”
92. What is ’s roles for imports’ 20:80 scheme?
(i) Govt. of India has withdrawn imports’ 20:80 scheme on Nov 28, 2014 for importing gold
(ii) Importers are required to export against golds imported under 20:80 scheme “before” Nov 28, 2014
93. What are Banks’ roles for golds’ imports?
(i) “Nominated” banks + also nominated agencies “both” notified by DGFT are permitted for “importing” golds on “consignment” basis for “qualified” jewellers notified by International Financial Services Centres Authority (IFSCA) under specific ITC (HS) Codes through India International Bullion Exchange IFSC Limited (IIBX).
(ii) 100% gold’s sales are required to made for “upfront” payments by “Nominated” banks + also nominated agencies “both” to “qualified” jewellers
(iii) Nominated banks are permitted to grant “gold” metal loans to “authorized” importers
94. What are Banks’s roles for star holder exporters’ imports?
(i) Star holder exporters are permitted to imports golds in accordance with RBI’s guidelines issued under FTP + also amended from time to time. “both”
(ii) Star holder exporters are permitted to imports golds “coins” medallions
95. What are Banks’ roles for gold coins’ imports?
(i) “Nominated” banks are permitted to imports golds “coins” medallions
(ii)Nominated banks are not permitted to sale gold “coins” medallions “without” RBI’s approvals.
96. What are Banks’ roles for golds imports’ loans?
(i) Banks are permitted to allow “suppliers” credits + “buyers” credits + also “usance” period’s LC “all” for importing golds like:
(i) Gold’s jewelleries
(ii) Precious metal’s jewelleries
(iii) Diamond’s jewelleries
(iv) Semi-precious stone’s jewelleries
(v) Precious stone’s jewelleries
(ii) Banks are not permitted to allow “suppliers” credits + “buyers” credits + also “usance” period’s LC “all” for exceeding 90 days from shipment’s date.
97. What are Banks’ roles for precious metals’ imports?
(i) Banks are permitted to allow “suppliers” credits + “buyers” credits + also “usance” period’s LC “all” for importing “precious” metals like:
(a) Platinum metals
(b) Palladium metals
(c) Rhodium metals
(d) Silver metals
(e) Rough diamonds
(f) Cut diamonds
(g) Polished diamonds
(h) Precious stones
(i) Semi-precious stones
(ii) Banks are not permitted to allow “suppliers” credits + “buyers” credits + also “usance” period’s LC “all” for exceeding 90 days from shipment’s date.
98. What are Banks’ roles for 180 days clean credits?
- Banks are permitted to allow “clean” credits i.e. credits given by “foreign” suppliers “without” LCs + LoUs + Fixed Deposits (FDs) from “Indian” financial institutions for not exceeding 180 days from shipments’ date for importing “precious” metals like:
(i) Platinum metals
(ii) Palladium metals
(iii) Rhodium metals
(iv) Silver metals
(v) Rough diamonds
(vi) Cut diamonds
(vii) Polished diamonds
(viii) Precious stones
(ix) Semi-precious stones
99. What are Banks’ roles for 360 days clean credits?
- Banks are permitted to allow “clean” credits i.e. credits given by “foreign” suppliers “without” LCs + LoUs + FDs from “Indian” financial institutions with 180 days “extensions”. Hence permitted for not exceeding 360 days from shipments’ date for importing “precious” metals like:
(i) Platinum metals
(ii) Palladium metals
(iii) Rhodium metals
(iv) Silver metals
(v) Rough diamonds
(vi) Cut diamonds
(vii) Polished diamonds
(viii) Precious stones
(ix) Semi-precious stones
100. What are Banks’ roles for “more than” 360 days clean credits?
- Banks are required to refer to concerned RBI’s RO for extensions beyond period exceeding 360 days
101. What are Banks’ duties for metals / diamonds’ imports?
(i) Banks are required to ensure compliances for RBI’s due diligences + RBI’s KYC norms + Anti-Money Laundering (AML) guidelines for importing “precious” metals + “rough” diamonds + “cut” diamonds + also “polished” diamonds “all”.
(ii) Banks are required to monitor “closely” for large + abnormal “increases” in business’s volumes + bona fide’s transactions + also not intended for interest / currency arbitrages “all”
102. What are Banks’ roles for platinum + silvers’ imports?
(i) Nominated” banks + nominated agencies are permitted to imports platinum + also silver “all” based on “outright” purchases “after” satisfaction that imports’ “ownerships” are required to pass at imports’ time
(ii) Prices for platinum’s purchases + silver’s purchases are required to fix at sell’s time to actual users / ultimate consumers by nominated banks + nominated agencies “all”.
103. What are Banks’ roles for factoring services?
(i) Banks are permitted to enter in arrangements with reputed “international” factoring services companies + also members of “International” Factors Chains “both”
(ii) Banks are permitted to enter in these arrangements “without” RBI’s approval.
(iii) Banks are required to ensure compliances in accordance with RBI’s guidelines under FTP for imports.
Merchanting Trade Transactions (MTTs
104. What are Banks’ roles for MTTs?
- Banks are permitted to handle MTTs “after” satisfaction of conditions in accordance with RBI’s guidelines.
105. What are Banks’ duties for MTTs?
(i) Banks are required to classify MTTs + also to acquire goods from outside Domestic Tariff Area (DTA) “both”.
(ii) Banks are required to satisfy with “documentary” evidences + transactions’ bona fides when goods are imported for “specific” processing’s value additions + also transformations “all”.
(iii) Banks are required to allow exports / imports under FTP’s guidelines on shipments’ date.
(iv) Banks are required to ensure compliances for 100% RBI’s rules + RBI’s regulations + RBI’s directions for exports except Export Declaration Form (EDF) + for imports except BoE are compiled e. exports leg + also imports leg respectively “all”.
(v) Banks are required to ensure that transactions’ bona fides + KYC guidelines + also AML guidelines “all” are “seriously” obeyed in transactions’ handlings.
(vi) Banks are required to verify 100% documents like:
(a) Invoices
(b) Packing lists
(c) Transport’s documents
(d) Insurance’s documents
(vii) Banks are required to satisfy for trade’s genuineness + also to rely on “online” verifications for Bill of Lading (BoL) / Airway Bill on website of International Maritime Bureau (IMB) / Airline’s “web check” facilities
(viii) Bank are required to ensure that “requisite” details are available / retrievable at time of transactions’ Inspections / Audits / investigations.
(ix) Banks are required to ensure that 100% MTTs are completed within 9 months + also foreign exchanges’ outlay are not permitted “after” 4 months from 100% MTTs completions’
(x) Banks are permitted to provide credits for MTTs through “short term” credits e. supplier’s credits / buyer’s credits with backing through 100% “advance” payments for exports leg + also exports leg’s discounting by banks for imports’ transactions.
(xi) Banks are not permitted to issue LoU / LC for supplier’s / buyer’s credits
(xii) Banks are required to ensure that exports leg’s receipts are parked in Exchange Earners Foreign Currency (EEFC) / in interest “bearing” INR accounts in India till imports leg liabilities arises “before” payments for imports
(xiii) Banks are required to ensure for earmarking / lien-marking for imports leg’s payments + for imports leg’s liabilities when arises + also to extinguish from these funds “without” delay.
(xiv) Banks are required to ensure that receipts are kept in interest “bearing” INR accounts in India.
(xv) Banks are required to release credits in Importers’ accounts in accordance with RBI’s guidelines.
(xvi) Banks are not permitted for funds based / non-funds based facilities against balances in accounts in India.
(xvii) Banks are permitted for payments against imports leg from EEFC accounts of Merchant Traders (MTs) in India.
(xviii) Banks are permitted to allow “advance” payments for imports leg based on demands made by overseas’ suppliers when “inward” remittances from overseas’ buyers are not received before “outward” remittances to overseas’ suppliers.
(xix) Banks are required to handle transactions based on commercial judgements + also to ensure for “advance” payments made against imports legs “both”.
(xx) Banks are not permitted to make “advance” payments “without” bank guarantees / unconditional / irrevocable standby LC from reputed “international” banks when amounts are exceeding USD 500,000 / it’s equivalent per transaction.
(xxi) Banks are required to ensure “prudential” limits for “advance” payments “before” allowing “advance” payments by Importers.
(xxii) Banks are permitted to issue LCs to suppliers for imports legs against “confirmed” exports orders + keeping in view “final” foreign exchange outlay for 4 months + MTTs’ completions within 9 months “after” satisfaction of conditions in accordance with RBI’s guidelines for guarantees + also Co-acceptances “all”.
(xxiii) Bank are required to match 1-to-1 for “each” MTT + to report defaults “if any” in exports legs / imports legs by Merchanting Traders to concerned RBI’s RO on half yearly basis within 15 days from half yearly’s closing e. up to July 15th + also Jan 15th “all”
(xxiv) Banks are required to ensure that Merchanting traders are “genuinely” trading of goods + not working as “financial” intermediaries + also having “confirmed” orders “all” for exports from overseas’ buyers against imports
(xxv) Banks are required to satisfy for Merchanting traders’ capabilities for “performing” obligations under exports’ orders + Merchanting trades to generate “profits” only “after” deducting imports’ payments + also other related expenses “all”.
106. What are Importers’ roles for MTTs?
(i) Importers are required to route 100% MTTs through “same” bank.
(ii) Importers are required to provide non “negotiable” copies to banks when “original” documents are not available
(iii) Importers are required to compute MTTs’ “commencement” dates from shipments’ dates / “exports” leg receipts / “imports” leg payments whichever are earlier.
(iv) Importers are required to compute MTTs’ “completion” dates from shipments’ dates / “exports” leg receipts / “imports” leg payments whichever are later.
107. What are RBI’s roles for MTTs?
- RBI is required to put MTs’ names in caution lists prepared for “annual” exports earnings’ reports when MTs’ outstanding are exceeding 5% of “annual” export earnings.
108. What are Banks’ roles for unrealized MTT’s write-offs?
- Banks are permitted to write-off “unrealized” amounts for exports leg “without” monetary limits based on request made by MTs “after” satisfaction of conditions.
109. What are Banks’ duties for unrealized MTT’s write-offs?
(i) Banks are required to ensure that MTTs buyers are declared insolvent + also obtained certificates from official liquidators “specifying” that no possibilities for recovery of exports proceeds “both”.
(ii) Banks are required to ensure that exported goods are auctioned / destroyed by Ports / Customs / Health authorities in “importing” countries + also received certificates for same “both”.
(iii) Banks are required to ensure that “unrealized” amounts for exports legs are representing “balance” outstanding amounts as settled through interventions by “Indian” Embassies / “Foreign” Chambers of Commerce / “similar” Organizations.
(iv) Banks are required to ensure that MTTs have obeyed 100% “other” provisions except delays in timelines for outlay / MTTs completion’s
(v) Banks are required to satisfy for transactions’ bona fides + KYC + also AML concerns “all”.
(vi) Banks are required to ensure that transactions are not in investigations under FEMA, 1999 by investigating agencies.
(vii) Banks are required to ensure that counterparties to MTs are not from countries / jurisdictions listed in FATF Public Statement as High Risk + also non-co-operative Jurisdictions “both” when FATF has “already” asked for counter measures.
110. What are Banks’ roles for MTT’s payments to 3rd party?
- Banks are not permitted for 3rd party payments for MTTs’ imports leg
111. What are Banks’ roles for MTT’s agency commissions?
- Banks are not permitted for making payments for MTTs’ agency commissions.
112. What are Banks’ duties for MTT’s agency commissions?
- Banks are permitted for making payments for “reasonable” agency commissions amounts through outward remittances “after” satisfaction of conditions like:
(i) When MTTs are 100% completed
(ii) When agency commission’s payments are not leading to losses in MTTs.
(iii) When MTs are making “specific” requests for making payments for agency commissions.
113. What are RBI’s roles for MTT’s regularizations?
- RBI’s ROs are permitted to regularize MTTs matters based on banks’ requests when MTs have deviated from RBI’s guidelines where banks are not permitted to close MTTs “without” RBI’s RO approvals
114. What are Banks’ roles for MTT’s reporting?
- Banks are required to report to concerned RBI’s RO under FETERS based on gross for following codes:
| S.No | Trades | Code under FETERS | Descriptions |
| (i) | Exports | P0108 | Goods “sold” under merchanting / receipt for MTs’ exports leg |
| (ii) | Imports | S0108 | Goods “purchased” under merchanting / receipt for MTs’ imports leg |
115. What are Banks’ roles for MTTs with Nepal/Bhutan?
- Banks are permitted for MTTs with Nepal / Bhutan subject to satisfaction of conditions.
116. What are Banks’ duties for MTTs with Nepal/Bhutan?
(i) Banks are required to ensure that MTTs with Nepal/Bhutan are under Custom Transit Declarations (CTDs) in accordance with RBI’s guidelines when goods are imported from 3rd country by Nepal/Bhutan’s importers
(ii) Banks are required to ensure that goods’ transit “treaties” between India and Nepal / Bhutan are existed + also goods in accordance with Indo-Nepal treaty + also Indo-Bhutan treaty “both” for goods’ transit
(iii) Banks are required to ensure that goods are consigned to Nepal/Bhutan’s importers from 3rd country for considering MTTs
Payments through Online Payment Gateway Service Providers (OPGSPs)
117. What are Banks’ roles for OPGSPs?
- Banks are permitted to offer payment’s facility for imports of goods / services / software’s when values are not exceeding USD 2,000 / it’s equivalent through entering in standing arrangements with OPGSPs “after” satisfaction of conditions
118. What are Banks’ duties for OPGSPs?
(i) Banks are required to remit to overseas exporter’s accounts for balances available in importers “collection” accounts based on funds received from importers + also to send within maximum 2 days from credits’ dates in collection accounts in India.
(ii) Banks are required to obtain invoices’ copies + airway bills from OPGSP “containing” names + beneficiaries’ addresses as imports’ evidences + also to report transactions in R-Return under foreign currency payments head “all”.
(iii) Banks are required to allow credits in OPGSP’s Importers “Collection” accounts for “online” purchases from overseas exporters “electronically” through credit cards / debit cards / net banking + also to charge back from overseas exporters “both”.
119. What are Permissible debits for OPGSPs?
(i) Permitted for debiting against payments to “foreign” exporters in permissible foreign currencies
(ii) Permitted for debiting against payments to “Indian” importers for returns + also refunds “both”
(iii) Permitted for debiting against payments for commission based on rates / frequencies defined under contract for OPGSP’s current accounts.
(iv) Permitted for debiting against bank charges
120. What are Banks’ roles for imports’ settlements?
(i) Banks are required to facilitate imports’ settlements when invoices are made in Freely Convertible Foreign Currencies (FCFCs).
(ii) Banks are required to settle imports’ payments in beneficiaries’ currencies when “direct” exchange rates are not available.
121. What are Banks’ duties for imports’ settlements?
- Banks are required to settle imports’ transactions except those are put through ACU mechanism “after” satisfaction of conditions like:
(i) When importers are banks’ customers
(ii) When signed contracts / invoices are in FCFCs.
(iii) When beneficiaries are required to receive payments in beneficiaries’ currencies instead “original” invoices’ FCFCs / contracts / LCs as full and final settlements.
(iv) When banks are satisfied with transactions’ bona fides.
(v) When counterparties to importers are not from countries / jurisdictions listed in FATF Public Statement on High Risk + also non-co-operative Jurisdictions “both” where FATF has “already” issued instructions for counter measures.
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(Author can be reached at email address satishagarwal307@yahoo.com or on Mobile No. 9811081957)
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