Last Updated on: 21st August 2026 | Last Reviewed on: 21st August 2026
Key takeaways at a glance
- Who is covered: the intermediaries in the National Pension System registered with the PFRDA, including points of presence, aggregators, central recordkeeping agencies, pension funds, the trustee bank, the custodian and retirement advisers, as reporting entities under the PMLA.
- Why they are covered: an intermediary registered by the PFRDA is expressly named in section 2(1)(n) of the PMLA, so it is a reporting entity under section 2(1)(wa).
- Governing laws: the PMLA, 2002 and the PML (Maintenance of Records) Rules, 2005; the PFRDA Master Circular on KYC, AML and CFT and its allied circulars; the PFRDA Act, 2013; the UAPA 1967 (Section 51A) and the WMD Act, 2005 (Section 12A).
- Supervisor: The Pension Fund Regulatory and Development Authority (PFRDA). Reports go to the Financial Intelligence Unit – India (FIU-IND); the Enforcement Directorate (ED) enforces the PMLA.
- Core duties: internal risk assessment, subscriber due diligence and KYC, beneficial owner identification, monitoring, prescribed transaction reporting, five-year record-keeping and sanctions screening.
This guide is general information on Indian law, not legal advice. For your firm’s specific position, speak to a qualified AML professional.
Pension intermediaries regulated by the Pension Fund Regulatory and Development Authority are reporting entities under the Prevention of Money Laundering Act, 2002. These are the intermediaries that operate the National Pension System, from the points of presence and aggregators that onboard subscribers to the central recordkeeping agencies, pension funds, the trustee bank and the custodian. Their AML, CFT and CPF duties flow from the PMLA, the PML (Maintenance of Records) Rules, 2005, the PFRDA Master Circular on KYC, AML and CFT, Section 51A of the UAPA, Section 12A of the WMD Act, and the FIU-IND reporting framework. The PFRDA supervises pension intermediaries, and reports are filed with FIU-IND. This guide sits within the wider set of guides for securities and pension market intermediaries.
The core instruments at a glance
Instrument | What it does for a pension intermediary |
PMLA, 2002 | The parent Act. Names the PFRDA-registered intermediary among the intermediaries and creates the duties of subscriber due diligence, record-keeping and reporting. |
PML (Maintenance of Records) Rules, 2005 | Set out what to report and when, how subscribers and beneficial owners are identified, and the duty to appoint officers. |
PFRDA KYC/AML/CFT Master Circular (25 September 2025) | The consolidated AML rulebook for pension intermediaries, into which the PMLA duties are read for the NPS. |
PFRDA Act, 2013 | The statute that establishes the PFRDA and its power to register and regulate the pension intermediaries. |
UAPA Section 51A and WMD Act Section 12A | Impose targeted financial sanctions for terrorism and proliferation financing. |
FATF Recommendations | The international preventive measure standards for financial institutions that India’s framework is built to meet. |
What counts as a pension intermediary in India?
Pension intermediaries are entities and individuals registered with the Pension Fund Regulatory and Development Authority under the PFRDA Act, 2013, to perform specified functions within the National Pension System (NPS). The ecosystem includes points of presence and aggregators that onboard subscribers, the central recordkeeping agencies that maintain subscriber records and accounts, the pension funds that manage contributions, the trustee bank that processes fund flows, the custodian that holds securities, and the retirement advisers who provide investment-related advice. Together, these intermediaries support a long-term, contribution-based retirement savings system, rather than a trading or lending business.
The money laundering risk of a pension intermediary is centred on subscriber onboarding, contributions and withdrawals, shaped by the long-term and restricted nature of the pension product. Risks arise from high-volume onboarding through points of presence and digital channels, verification of identity and beneficial ownership for non-individual, NRI and OCI subscribers, large or unusual contributions, and the identity of nominees and claimants at exit. Effective controls therefore require reliable subscriber KYC, beneficial owner verification, sanctions screening, and monitoring of contributions and withdrawals.
Are pension intermediaries reporting entities under the PMLA?
Yes. Pension intermediaries fall within the reporting entity framework under the PMLA. Section 2(1)(wa) includes an intermediary within the definition of reporting entity, while section 2(1)(n) expressly covers an intermediary registered with the Pension Fund Regulatory and Development Authority (PFRDA). Accordingly, a PFRDA-registered pension intermediary is a reporting entity by virtue of its registration.
This places a pension intermediary in the same broad category of reporting entities that file with FIU-IND as banks and securities intermediaries, and within the wider AML laws and regulations for intermediaries in India. The obligations are calibrated to the pension business, but the reporting-entity status is not optional.
Supervisory authority for pension intermediaries in India
The Pension Fund Regulatory and Development Authority (PFRDA) is the sectoral regulator and supervisor for pension intermediaries. It registers and regulates intermediaries under the PFRDA Act, 2013, and prescribes and supervises their AML, KYC and CFT requirements. The principal AML instrument is the PFRDA master circular on KYC< AML and CFT guidelines, updated on 25 September 2025, read with the applicable KYC requirements for NRI and OCI subscribers, officially valid document requirements and PFRDA FQs. Together, these instruments translate the PMLA obligations into the subscriber due diligence, monitoring, record-keeping and reporting requirements applicable within the NPS framework.
The Financial Intelligence Unit of India receives, analyses and disseminates the reports a pension intermediary files, and the Enforcement Directorate investigates and prosecutes the offence of money laundering under the PMLA. In short, the PFRDA sets and inspects the rules, FIU-IND receives the intelligence, and the ED enforces the criminal law.
AML Regulatory Requirements for Pension Intermediaries in India
The law that governs a pension intermediary does not sit in one place. It is a layered framework, and it helps to see it grouped as the core legislation, the overarching obligations, the sectoral regulator and its instruments, the miscellaneous official reports, the international standards, and the allied laws.
Core Legislation
The primary statutes and rules that create the AML, CFT and CPF obligations, grouped into three subsets.
AML Legislation
Prevention of Money Laundering Act, 2002 (PMLA)
The parent anti-money laundering law. It creates the offence of money laundering and the core duties on reporting entities, including client due diligence under Section 11A and record-keeping under Section 12. A pension intermediary is a reporting entity by virtue of the intermediary definition in section 2(1)(n), so the Act applies to a pension intermediary in the same shape as to a bank, scaled to the business.
The PML (Maintenance of Records) Rules, 2005 (PMLR)
The rules made under the PMLA. They set what to report and when (Rule 3 and Rule 8), how to identify clients and beneficial owners (Rule 9), and the duty to appoint officers (Rule 7). For a pension intermediary, the relevant Regulator named in Rule 2(1)(fa) is the PFRDA.
The PMLR has been amended through 31 Gazette notifications and orders, set out below as a legal-history timeline.
The 31 PMLR amendment notifications, in date order:
Gazette notification and date | Key change or rule touched |
G.S.R. 389(E), 24 May 2007 | The initial amendment to the 2005 Rules, expanded the Rule 2 definition of a suspicious transaction to reach dealings lacking economic rationale or a bona fide purpose as well as those indicating terrorism financing. It also revised Rule 3 concerning cash transactions involving forged or counterfeit currency, substituted Rule 8 on furnishing information to the Director, and reduced the requirement under Rule 9 from three certified copies to one of the required documents. |
G.S.R. 816(E), 12 November 2009 | It introduced the definitions of non-profit organisation and Regulator under Rule 2, revised the definition of a suspicious transaction, and required reporting of NPO receipts exceeding Rupees 10 lakh. Rule 6 prescribed a ten-year record retention period, while Rule 9 was substantially revised to require beneficial owner identification, ongoing due diligence, prohibition of anonymous accounts and a Client Identification Programme. |
G.S.R. 76(E), 12 February 2010 | Amended Rules 3, 4, 5, 7 and 9 to sharpen the record-keeping and the reporting references. most importantly inserted the first Explanation under Rule 9(1A), which treats the beneficial owner as the natural person who ultimately owns or controls a client or on whose behalf a transaction is carried out. |
G.S.R. 508(E), 16 June 2010 | Revised Rules 2, 9 and 10, covering definitions, customer due diligence and record-keeping, revised the requirements for customer identification and maintenance of records as part of the broader strengthening of the CDD and record-keeping framework. |
G.S.R. 980(E), 16 December 2010 | It provided the definition of the Designated Officer and the small account under Rule 2 and acceptance of the NREGA job card and the Aadhaar letter into the officially valid documents. and also added Rule 9(2A) on the opening and monitoring of such an account. |
G.S.R. 481(E), 24 June 2011 | Introduced the short title, amending Rule 1 to condense the long 2005 name into the Prevention of Money Laundering (Maintenance of Records) Rules, the PMLR shorthand used since. |
G.S.R. 576(E), 27 August 2013 | Amended Rules 2 and 3 and inserted provisions after Rule 10, addressing definitions, the cash and suspicious transaction reporting duties and the record framework so they matched the reporting obligations. |
G.S.R. 288(E), 15 April 2015 | Reworked the definitions under Rule 2, expanding and clarifying the terms that determine the scope of the operative provisions and setting the foundation for a series of further amendments in 2015. |
G.S.R. 544(E), 7 July 2015 | Amended Rules 2, 9, 10 and inserted Rule 9A on definitions, customer due diligence and record-keeping, revising how a reporting entity identifies customers and the records it holds. |
G.S.R. 730(E), 22 September 2015 | Inserted an explanation under Rule 2 clarifying that a marriage certificate can be used as a supporting document for a subsequent change of name in an officially valid document. |
G.S.R. 882(E), 18 November 2015 | Extended the timeline under Rule 9A for the Central Government to establish the Central KYC Records Registry from 90 days to 180 days from the commencement of the PML Amendment Rules. |
G.S.R. 347(E), 12 April 2017 | Amended Rule 2 and inserted Rule 9B, drawing the Central KYC Records Registry into the Rules, creating the duty for reporting entities to file customer KYC records centrally and the basis to reuse them, the structural addition behind today’s CKYCR. |
G.S.R. 538(E), 1 June 2017 | Revised Rules 2 and 9 to incorporate Aadhaar into customer due diligence, prescribing Aadhaar-based identification and authentication for KYC, an approach the Supreme Court’s Aadhaar ruling later reshaped. |
G.S.R. 1038(E), 21 August 2017 | Amended definitions under Rule 2 for the operative rules to be relevant with the changing principal, one of the most important amendments amongst several other definition changes in 2017. |
G.S.R. 1318(E), 23 October 2017 | A later 2017 amendment of the Rule 2 definitions, holding the defined terms current as the framework moved on. |
G.S.R. 456(E), 16 May 2018 | Inserted a clause in Rule 9 requiring reporting entities to align their customer due diligence programmes with applicable sector-specific guidelines and setting out what those guidelines should provide for reporting entities. |
G.S.R. 1078(E), 31 October 2018 | Amended Rule 9 to extend the timeline for filing a customer’s electronic CDD records from 3 days to 10 days. |
G.S.R. 108(E), 13 February 2019 | Revised Rules 2 and 9 on definitions and customer due diligence, after the legislative changes to Aadhaar use, revising the ways identification could be conducted. |
G.S.R. 381(E), 28 May 2019 | Revised Rule 9 the identification and verification process and the routes to confirm a customer’s identity, part of the post-Aadhaar reshaping of CDD. |
G.S.R. 582(E), 19 August 2019 | Amended Rules 2 and 9 and inserted provisions after Rule 11, involving definitions, customer due diligence and the supporting provisions on information and records maintenance. |
G.S.R. 669(E), 18 September 2019 | Further revised Rules 2 and 9 to update key definitions and reinforce the customer due diligence requirements applicable to depository receipts. |
G.S.R. 840(E), 13 November 2019 | Amended Rule 9 with further changes to the identification and verification requirements. |
G.S.R. 228(E), 31 March 2020 | Extended the validity of small accounts for the year of 2020 and any subsequent period notified by the Central Government. |
G.S.R. 251(E), 13 April 2020 | Amended Rule 8, which governs the submission of transaction reports to FIU-IND, by revising the prescribed reporting timeline. |
G.S.R. 254(E), 16 April 2020 | A follow-up amendment to Rule 8, issued shortly after the preceding change, further modified the transaction reporting timeline for a specific quarter. |
G.S.R. 798(E), 28 December 2020 | A significant expansion of the regime beyond the financial sector. Read alongside G.S.R. 799(E) and 800(E) issued on the same day, it brought real estate agents and dealers in precious metals and stones within the framework and designated their regulator, extending the regime to non-financial businesses. |
G.S.R. 575(E), 13 July 2022 | Introduced the definition of International Financial Services Centre (IFSC), along with a specific beneficial-owner provision for IFSC entities and added an IFSC proviso to Rule 9A on the CKYCR, aligning the Rules with the GIFT City framework and relevant to pension flows linked to an IFSC. |
S.O. 1074(E), 7 March 2023 | A major amendment that introduced definitions for politically exposed persons, non-profit organisations and groups, along with a new Rule 3A requiring group-wide AML policies. It also lowered the beneficial ownership threshold for companies from 25% to 10%, with a corresponding amendment to Rule 9(3)(e), directly affecting how pension intermediaries identify beneficial owners behind corporate or other non-individual subscribers. |
G.S.R. 652(E), 4 September 2023 | It placed the Principal Officer at management level, cut the partnership beneficial ownership threshold from 15 to 10 per cent, inserted an Explanation of control, required trustees to disclose their status, and added the results of any Rule 3 and Rule 9 analysis to the records kept, all of which bear on identifying who controls a non-individual NPS subscriber. |
G.S.R. 745(E), 17 October 2023 | Amended Rules 2, 3, 8 and 9 covering definitions, the reporting duties and customer due diligence, adjusting several operative provisions together to close the 2023 changes. |
G.S.R. 419(E), 19 July 2024 | Revised Rule 9(1C) on the KYC Identifier and set a deadline to update a CKYCR record after any change within seven days, added a duty to fetch the updated record, and overhauled Rule 9A(2)(g) on filing, retrieving and using registry records, sharpening how current central KYC data is kept. |
The PML (Manner of Receiving the Records Authenticated Outside India) Rules, 2005
Rules for accepting client records authenticated outside India, relevant where a pension intermediary onboards a non-resident client or a foreign portfolio investor and must rely on documents executed abroad.
CFT Legislation
The Unlawful Activities (Prevention) Act, 1967 (UAPA)
The counter terrorism law. Its Section 51A requires a pension intermediary to screen clients against the designated lists and to freeze, without delay, the funds and securities of listed persons and entities. The duty binds every pension intermediary, whatever its size.
Procedure for implementation of Section 51A of the UAPA (order dated 2 February 2021; corrigendum dated 15 March 2023 and 29 August 2023)
The official procedure a pension intermediary follows to apply Section 51A, including how to act on a designated list match. The PFRDA guidelines fold these steps into the pension intermediary to an issue’s screening and freezing controls.
CPF Legislation
The Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act, 2005 (WMD Act)
The proliferation financing law. Its Section 12A provides the legal basis for targeted financial sanctions relating to the financing of weapons of mass destruction and applies to pension intermediaries alongside banks and financial institutions.
Procedure for implementation of Section 12A of the WMD Act (dated 1 September 2023)
The official procedure for applying Section 12A mirrors the screening and freezing steps that Section 51A sets for terrorism financing.
The WMD and their Delivery Systems (Prohibition of Unlawful Activities) Implementation Rules, 2016
Rules implementing the WMD Act and supporting the proliferation financing controls a pension intermediary must operate.
Overarching Obligations
The cross-cutting systems and procedures that sit above any single regulator and carry an intermediary’s KYC data and reports.
CERSAI Central KYC Records Registry (CKYCR) Operating Guidelines, 2025
These guidelines govern the central KYC records registry and the handling of KYC records by reporting entities. A pension intermediary uploads and updates subscriber KYC records as required and may retrieve an existing record for identification and due diligence, reducing duplication and promoting consistent KYC information across the financial system.
FINnet 2.0 reporting formats (2024) and the FINGate 2.0 user manuals
These instruments define the electronic formats and the gateway through which a pension intermediary files its cash, suspicious and other prescribed reports to FIU-IND, in the current FINnet 2.0 and FINGate 2.0 environment.
Section 11A Aadhaar authentication procedure for reporting entities
The Section 11A procedure lets a pension intermediary use Aadhaar-based verification for subscribers within the statutory and Supreme Court limits, giving a lawful digital onboarding route.
Sectoral Guidelines
The market regulator and the instruments it issues. This is the sector-specific layer, and the PFRDA KYC, AML and CFT Master Circular is the instrument a pension intermediary works from most closely.
Pension Fund Regulatory and Development Authority (PFRDA)
PFRDA Master Circular on KYC, AML and CFT Guidelines (25 September 2025)
The principal sector-specific AML, CFT and CPF framework for PFRDA- regulated intermediaries. Updated on 25 September 2025, the master circular translates the broader PMLA requirements into the NPS framework, covering subscriber due diligence, risk categorisation, beneficial ownership identification, ongoing monitoring, record-keeping, reporting and sanctions screening. It is the primary reference for pension intermediaries when applying requirements to subscriber onboarding and ongoing servicing.
PFRDA amendment on KYC for NRI and OCI onboarding to the NPS
The PFRDA amendment that strengthens the KYC requirements for onboarding non-resident Indian and overseas citizen of India subscribers to the National Pension System, a higher-risk category that calls for enhanced identification and documentation.
PFRDA Officially Valid Documents circular and FAQs
The PFRDA circular on officially valid documents for proof of address, and the frequently asked questions on the KYC, AML and CFT guidelines, give a pension intermediary practical guidance on subscriber identification and record-keeping.
Miscellaneous
Official reports and guidance that are not binding rules but shape how a pension intermediary reads its risk and the wider enforcement picture.
FIU-IND Annual Report 2024-25
The Financial Intelligence Unit’s yearly account of reporting volumes, typologies and enforcement trends, useful for a pension intermediary calibrating what unusual client or trading activity looks like across the market.
Directorate of Enforcement Annual Report 2025-26
The ED’s annual report. It summarises PMLA investigations, attachments and prosecution outcomes, providing an overview of how the criminal enforcement side of the AML regime operates.
FIU-IND and its Core Functions and FAQs
FIU-IND’s explanation of its own role and a set of frequently asked questions, a plain-language reference on registration and reporting expectations.
MHA National Counter Terrorism Policy and Strategy
The Ministry of Home Affairs statement of national counter terrorism policy, background that frames the UAPA sanctions obligations a pension intermediary must apply.
International Standards
The global standards India’s framework is built to meet, and against which an intermediary’s controls are ultimately judged.
FATF Recommendations
The global standards that serve as a baseline for India’s AML, CFT and CPF framework. For pension intermediaries, recommendations 9-23 are particularly relevant, as they establish preventive measures for financial institutions, including CDD, reporting and targeted financial sanctions. The recommendations were last updated in June 2026, including an update to recommendation 6 on targeted financial sanctions.
FATF Mutual Evaluation Report on India, 2024 (and Executive Summary)
The peer assessment of India’s AML and CFT regime. It assesses the effectiveness and technical compliance of India’s AML, CFT and CPF framework. Its findings identified areas of strong compliance as well as areas requiring improvement, helping shape the continued development and supervision of pension intermediaries and other financial- sector entities.
IOPS Principles of Private Pension Supervision
The International Organisation of Pension Supervisors’ principles of private pension supervision provide an international benchmark for effective pension supervision and inform the development of PFRDA’s regulatory and supervisory framework for pension intermediaries, including its conduct and risk-management expectations.
Basel Committee, Sound Management of Risks Related to Money Laundering and Financing of Terrorism (2020)
The Basel Committee’s sound-management guidance provides a supervisory benchmark for embedding AML risk management and governance within financial institutions. Although developed primarily for banks, its principles can inform the risk-management frameworks of pension intermediaries.
Allied Laws
The wider body of law that defines the securities statutes and the predicate offences and enforcement machinery around money laundering. A pension intermediary operates under the securities statutes, while the predicate and enforcement Acts shape the risk it must assess and the conduct it may need to report.
The allied law framework consists of statutes that support pension regulation or address the underlying money laundering, terrorist financing, corruption, foreign exchange and asset forfeiture risks that may arise in the pension sector.
The Pension Fund Regulatory and Development Authority Act, 2013, The principal sectoral statute. It establishes PFRDA and provides the regulatory framework for pension schemes and intermediaries, including their registration, supervision and conduct.
The Indian Trusts Act, 1882, is relevant to the MPS trust, particularly its legal and fiduciary framework for holding and administering pension assets.
The Companies Act, 2013, relevant where a pension intermediary is incorporated as a company, including its corporate governance, ownership and beneficial ownership framework.
The Foreign Exchange Management Act, 1999, applies to foreign exchange transactions and cross-border flows undertaken by pension intermediaries within the scope of applicable FEMA rules and regulations.
The Bharatiya Nyaya Sanhita, 2023 and the Bharatiya Nagarik Suraksha Sanhita, 2023, provide a general criminal law and procedural framework relevant to offences that may generate or involve illicit proceeds.
The Benami Transactions (Prohibition) Act, 1988, addresses property held benami and is relevant where pension-related assets or transactions may involve concealed beneficial ownership.
The Prevention of Corruption Act, 1988, the Fugitive Economic Offenders Act, 2018, the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015, the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974, the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976, and the Central Vigilance Commission Act, 2003, these laws address fraud, cheating, forgery, corruption, concealed ownership, economic offences, smugglings and forfeiture of illicit property. They are relevant to identify predicate offences and other financial crime risks affecting the source, ownership or legitimacy of assets handled by pension intermediaries.
The Narcotic Drugs and Psychotropic Substances Act, 1985, the Foreign Contribution (Regulation) Act, 2010, the Arms Act, 1959, and the Chemical Weapons Convention Act, 2000, these laws regulate activities involving unlawful arms, chemical weapons and restricted foreign contributions, making them relevant to proliferation financing and financial crime risks.
Core AML/CFT/CPF Obligations for Pension Intermediaries in India
Across that framework, the regulations require a pension intermediary to do the following. This article keeps each at the level required by law; a compliance requirements guide explains how to do each.
- Register with FIU-IND. Enrol on the FINnet 2.0 / FINGate 2.0 portal so the pension intermediary can file its reports.
- Appoint officers. Appoint a Designated Director and a management-level Principal Officer under Rule 7 of the PMLR and the PFRDA guidelines. The same person cannot hold both roles, and both are to be informed to FIU-IND and the PFRDA.
- Conduct the internal risk assessment. Run an ML and TF risk assessment across subscribers, products, channels and geographies, document it, and take its outcome to the board, as the PFRDA guidelines require.
- Document AML policy, controls and procedures. Adopt a board-approved policy that turns the risk assessment into the pension intermediary’s operating procedures.
- Subscriber identification and CDD. Identify and verify every subscriber and, for a non-individual subscriber, the beneficial owner (a controlling interest of more than 10 per cent for a company or partnership, and more than 15 per cent for an unincorporated association or body of individuals, with the separate trust test), with enhanced due diligence for politically exposed persons, NRI and OCI subscribers and other higher-risk cases, under Section 11A of the PMLA, Rule 9 of the PMLR and the PFRDA KYC guidelines. Given the pension business, reliable subscriber identification at volume and scrutiny of the source of large or irregular contributions are central.
- Ongoing monitoring and periodic updation. Monitor contributions, withdrawals and account changes on an ongoing basis, and refresh KYC at least once every 2, 8 and 10 years for high, medium and low-risk subscribers. Review each subscriber’s risk categorisation periodically.
- Sanctions screening. Screen subscribers and beneficial owners against the designated lists under Section 51A of the UAPA and Section 12A of the WMD Act, and freeze and report any match, verifying the relevant UNSC and domestic lists daily.
- Regulatory reporting. File cash transaction reports for cash above Rupees 10 lakh, suspicious transaction reports of any value, non-profit organisation receipt reports and counterfeit currency reports under Rule 3 and Rule 8 of the PMLR. Cash and related reports are filed monthly, by the 15th day of the succeeding month; suspicious transaction reports are filed promptly once the Principal Officer is satisfied, through FINnet 2.0.
- Record management, CKYCR and FINnet 2.0. Keep transaction records for five years from the date of the transaction, and identity records, account files and correspondence for five years after the relationship ends, under Section 12 of the PMLA. Upload subscriber KYC records to the CKYCR under Rule 9A, and file all prescribed reports through FINnet 2.0.
- Training and awareness. Train staff and points of presence by role to apply the controls and recognise red flags in the NPS, such as identity mismatches at onboarding, large or irregular contributions inconsistent with a subscriber’s profile, third-party funding of contributions, and suspicious nominee or claimant details at exit.
- Independent testing and audit. Test the programme through internal audit, compliance assurance or independent review, and close every finding.
- Run group-wide controls. Where the pension intermediary is part of a group, apply AML and CFT programmes at group level, including for branches and majority-owned subsidiaries, as the PFRDA guidelines require.
What this article does not cover
This article explains the laws and regulatory instruments that apply to pension intermediaries. Neither does it provide a control-by-control compliance manual, nor does it restate the PFRDA Act or the NPS operating rules except where they bear on the AML duties. For implementation, a pension intermediary separately documents subscriber and beneficial-owner due diligence, KYC and CDD procedures, source-of-contribution checks, sanctions screening, monitoring, suspicious-transaction escalation, staff training, audit testing and board reporting. Those controls are the subject of the companion compliance guide.
To see how the pension intermediary framework fits within the sector, see AML laws and regulations for intermediaries in India, and to place it within the national picture, see AML laws and regulations in India.
From regulation to compliance: your next step
Knowing the law is only the starting point. For a pension intermediary, effective compliance requires a risk-based programme covering risk assessment, policies and procedures, subscriber due diligence, monitoring, screening, reporting, training and independent review. Particular attention should be given to subscriber KYC, source-of-contribution scrutiny and sanctions screening are the controls that matter most. Understanding the stages of money laundering and how the sanctions screening process works is a useful foundation for building these controls.
Frequently Asked Questions
An entity registered with the Pension Fund Regulatory and Development Authority under the PFRDA Act, 2013, to perform a role in the National Pension System, such as a point of presence, aggregator, central recordkeeping agency, pension fund, trustee bank, custodian or retirement adviser. A PFRDA-registered intermediary is a reporting entity under the PMLA.
Yes. An intermediary registered by the PFRDA is expressly named in section 2(1)(n) of the PMLA, so it is a reporting entity under section 2(1)(wa). No separate designation notification is needed; a pension intermediary is within the regime by virtue of its PFRDA registration.
The PFRDA Master Circular on KYC, AML and CFT Guidelines, updated on 25 September 2025, is the central rulebook, read with its amendment on KYC for NRI and OCI onboarding to the NPS, the officially valid documents circular, and the PFRDA frequently asked questions, all under the PFRDA Act, 2013.
The National Pension System is a long-term, contribution-based product with a lock-in and restricted withdrawals, which lowers the money laundering risk relative to a trading account. The risk that remains sits in subscriber onboarding at volume, in NRI and OCI onboarding, in the source of large or irregular contributions, and in nominee and claimant details at exit, so reliable subscriber KYC and screening are the core controls.
Suspicious transaction reports of any value, cash transaction reports where cash above Rupees 10 lakh is involved, non-profit organisation receipt reports and counterfeit currency reports. Cash and related reports are filed monthly by the 15th of the succeeding month, and suspicious transaction reports promptly once the Principal Officer is satisfied, through FINnet 2.0.
Yes. The screening duties under Section 51A of the UAPA and Section 12A of the WMD Act apply to every PFRDA-registered pension intermediary. It screens subscribers and their beneficial owners against the United Nations and domestic designated lists and reports and acts on any match without delay.
Official sources and review
Last reviewed: July 2026. This guide is grounded in the following primary official sources, linked to their official source where available.
This guide covers money laundering law and compliance, a sensitive area where the rules change; confirm the current position for your firm with a qualified professional before acting.
Why work with AML India
AML India helps PFRDA-regulated pension intermediaries meet their PMLA and PFRDA obligations, from risk assessment and policy and procedure to subscriber due diligence, screening, monitoring, reporting, training and independent review.
Industries we serve: Pension Intermediaries, Points of Presence, Central Record- keeping Agencies, Pension Funds, Custodians, Mutual Funds and other Securities Intermediaries, Banks, NBFCs, Insurers, DNFBPs and IFSC and GIFT City entities.
Want to confirm what the PFRDA framework means for your firm?
AML India can walk you through the PFRDA KYC, AML and CFT Master Circular and build a proportionate subscriber due diligence and monitoring programme for your role in the NPS.
About the Author
Pathik Shah
FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)
Pathik is a Chartered Accountant with more than 26 years of experience in governance, risk, and compliance. He helps companies with end-to-end AML compliance services, from conducting Enterprise- Wide Risk Assessments to implementing the robust AML Compliance framework. He has played a pivotal role as a functional expert in developing and implementing RegTech solutions for streamlined compliance.
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