The Risk-Based Approach (RBA), mandated by the FATF and implemented in India under the PMLA and RBI guidelines, requires banks to identify, assess, and mitigate ML and TF risks proportionately.

Under this approach, risk is evaluated across four dimensions: Customer, Product, Channel, and Geography. higher-risk exposures demand EDD, senior management oversight, and intensive monitoring to ensure effective mitigation.

The module outlines the framework for risk rating methodologies, transaction monitoring systems, and continuous assessment to detect geographic or behavioral anomalies. It emphasizes timely documentation, escalation of alerts, investigation of suspicious activities, and filing of STRs and CTRs with the FIU-India. Given the dynamic nature of risk, it must be reassessed continuously throughout the customer lifecycle.

The module concludes with practical case studies and scenarios to illustrate real-world applications of the RBA framework.

About the Trainer

Himanshu Vasa

Empaneled Trainer

Himanshu Vasa is Former President & Chief Compliance Officer (CCO) of Kotak Mahindra Bank with over 34 years of strategic and operational leadership in banking, financial services, and consulting. His expertise in corporate governance, regulatory compliance, enterprise risk management, and strategic transformation and ability to resolve regulatory and operational challenges has earned him the Certificate of Recognition of Excellence at the CFO 100 awards function for 7 consecutive years.