Description

User manual for BSE trading members to comply with FATF declarations through BEFS portal for identifying clients from specified jurisdictions as per SEBI 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. SEBI periodically releases lists of jurisdictions requiring enhanced due diligence. Trading members must identify clients from these jurisdictions through the BEFS portal and submit declarations, irrespective of whether they have such clients.

Key Points

  • Trading members must identify clients belonging to FATF-specified jurisdictions
  • Declarations must be submitted through BEFS portal (https://befs.bseindia.com/login.aspx)
  • SEBI template upload is compulsory for all members regardless of client presence in specified countries
  • If members have clients from specified jurisdictions, a CSV file with Unique Client Code and Client Name must be uploaded
  • SEBI template must be printed on company letterhead, signed/stamped by MD/Compliance Officer, or digitally signed
  • Acknowledgement email sent upon successful submission
  • Members must maintain proper alert mechanisms for ongoing monitoring of client relationships with specified jurisdictions

Regulatory Changes

This circular provides procedural guidance for implementing existing SEBI requirements related to FATF public statements. Trading members are required to conduct appropriate due diligence on existing clients and establish alert mechanisms to identify business relationships and transactions with jurisdictions identified by SEBI from time to time.

Compliance Requirements

Step 1: Access BEFS Portal

Step 2: Select Period

  • Select appropriate period and save

Step 3: Client Verification and Upload

  • Check if clients belong to SEBI-specified countries
  • If yes, upload CSV file containing Unique Client Code and Client Name
  • Compulsorily upload SEBI template (converted to PDF)
  • Template must be on company letterhead with MD/Compliance Officer signature/stamp, or digitally signed

Step 4: Final Submission

  • Click Save after uploads
  • Click Confirmation tab and submit

Mandatory Requirements:

  1. SEBI template upload is compulsory for all members
  2. Template must be properly signed/stamped or digitally signed
  3. CSV file required only if clients from specified countries exist
  4. Proper due diligence on existing clients
  5. Alert mechanisms for ongoing monitoring

Important Dates

No specific deadlines mentioned. Declaration to be submitted for each period as specified in the BEFS portal.

Impact Assessment

Operational Impact: High - All trading members must implement the FATF declaration process through BEFS portal, requiring system integration and periodic compliance monitoring.

Compliance Impact: High - Mandatory requirement with potential regulatory consequences for non-compliance. Members must establish robust client screening and monitoring systems.

Resource Impact: Medium - Requires dedicated compliance resources for client identification, documentation, and periodic submissions.

Risk Mitigation: This process helps trading members comply with anti-money laundering (AML) obligations and manage risks associated with clients from high-risk jurisdictions identified by FATF.

Impact Justification

Mandatory compliance requirement for all trading members related to FATF jurisdictions and AML obligations with strict reporting requirements through BEFS portal