Module: General Practice
Q20: With reference to the Amendment Directions dated December 29, 2025, regarding the reliance on Central KYC Records Registry (CKYCR), consider the following statements:
The Regulated Entity (RE) that uploads or updates the customer’s KYC records in CKYCR is responsible for verifying the identity and address of the customer.
An RE downloading KYC records from CKYCR is fully exempted from all Customer Due Diligence (CDD) responsibilities, including transaction monitoring.
An RE downloading records from CKYCR is not required to re-verify the identity or address of the customer, provided the records are current and valid.
Select the correct combination:
An RE downloading KYC records from CKYCR is fully exempted from all Customer Due Diligence (CDD) responsibilities, including transaction monitoring.
An RE downloading records from CKYCR is not required to re-verify the identity or address of the customer, provided the records are current and valid.
Select the correct combination:
✅ Correct Answer: B
The Legislation: The RBI (Commercial Banks – KYC) Amendment Directions, 2025 (Dec 29, 2025) clarified the liability matrix for CKYCR.
Analysis of Statements: Statement 1 is Correct: The "Explanation" added to Paragraph 65 explicitly states that the RE uploading or updating the record is responsible for the core verification of identity/address.
Statement 2 is Incorrect: The downloading RE is NOT exempted from all CDD.
The direction states: "The bank downloading… shall remain responsible for all aspects of CDD procedure… except verification of identity and/or address." This means they must still perform risk categorization, transaction monitoring, and other due diligence.
Statement 3 is Correct: The downloading RE is relieved specifically from the burden of re-verifying the identity/address if the downloaded CKYCR data is current and compliant.
Analysis of Statements: Statement 1 is Correct: The "Explanation" added to Paragraph 65 explicitly states that the RE uploading or updating the record is responsible for the core verification of identity/address.
Statement 2 is Incorrect: The downloading RE is NOT exempted from all CDD.
The direction states: "The bank downloading… shall remain responsible for all aspects of CDD procedure… except verification of identity and/or address." This means they must still perform risk categorization, transaction monitoring, and other due diligence.
Statement 3 is Correct: The downloading RE is relieved specifically from the burden of re-verifying the identity/address if the downloaded CKYCR data is current and compliant.