Description

User manual for trading members to submit FATF declarations identifying clients from jurisdictions specified by SEBI, with mandatory template upload requirements.

Summary

BSE has issued a user manual for trading members to comply with FATF (Financial Action Task Force) declaration requirements following the October 2025 Plenary. Trading members must identify clients belonging to jurisdictions specified by SEBI and submit declarations through the BEFS portal. The SEBI template must be uploaded compulsorily by all members, irrespective of whether they have clients in the specified countries.

Key Points

  • Trading members must identify clients belonging to jurisdictions specified by SEBI from time to time
  • Appropriate due diligence must be conducted on existing clients
  • Proper alert mechanisms must be in place to identify business relationships and transactions with specified jurisdictions
  • SEBI template upload is mandatory for all members regardless of client presence in listed countries
  • Template must be on company letterhead, signed/stamped by MD/Compliance Officer or digitally signed
  • CSV file with client details (UCC code and name) required if clients from specified countries exist
  • Declarations submitted through BEFS portal at https://befs.bseindia.com/login.aspx
  • Acknowledgement email sent upon successful submission

Regulatory Changes

No new regulatory changes introduced. This circular provides procedural guidance for existing FATF compliance obligations where SEBI releases lists of jurisdictions requiring enhanced monitoring.

Compliance Requirements

For All Trading Members:

  1. Access BEFS portal and navigate to FATF Declaration – Declaration Form
  2. Select the relevant period
  3. Check whether clients belong to SEBI-specified countries
  4. Download and fill SEBI template (provided in Word format)
  5. Convert template to PDF
  6. Print on company letterhead and obtain MD/Compliance Officer signature and stamp, OR digitally sign the PDF
  7. Upload signed PDF to BEFS portal (mandatory regardless of client presence)
  8. Click confirmation tab and submit

Additional Requirements if Clients Exist in Specified Countries:

  • Upload CSV file containing:
    • Unique Client Code (UCC)
    • Client Name

Ongoing Requirements:

  • Maintain proper alert mechanisms to identify business relationships and transactions with specified jurisdictions
  • Conduct appropriate due diligence on existing clients

Important Dates

No specific deadlines mentioned. Members must submit declarations for periods as specified in the BEFS portal dropdown.

Impact Assessment

Operational Impact: High - All trading members must implement this compliance process regardless of their client base composition. Requires system checks, manual verification, document preparation, and portal submission.

Risk Management Impact: Enhanced AML/CFT controls through systematic identification of clients from high-risk jurisdictions as identified by FATF and SEBI.

Compliance Burden: Moderate to High - Mandatory template submission for all members, with additional CSV upload requirements for members with clients in specified jurisdictions. Requires coordination between compliance officers and authorized signatories.

Market Impact: Minimal direct market impact, but strengthens overall market integrity through enhanced monitoring of transactions with jurisdictions under FATF scrutiny.

Impact Justification

Mandatory compliance requirement for all trading members to identify and report clients from FATF-specified jurisdictions, with compulsory template submission regardless of client presence