Note on Certification Requirement under IFSCA (AML/CTF/KYC) Guidelines, 2022

The International Financial Services Centres Authority (IFSCA) has issued a circular, dated 17 November 2025, bearing reference number e.F. No.IFSCA-DAC/8/2024-AMLCFT (IFSCA Circular) under the IFSCA (AML/CTF/KYC) Guidelines, 2022 (AML Guidelines), mandating all ‘Designated Directors’ and ‘Principal Officers’ of ‘Regulated Entities’ to undergo a customized certification course developed by the National Institute of Securities Market (NISM). The course developed by NISM, namely ‘NISM-IFSCA-01: Certification Course on Anti-Money Laundering and Counter-Terrorist Financing in the IFSC’ (NISM-IFSCA-01: AML Certification) has been developed by NISM in collaboration with the IFSCA Academy and is aligned with the AML Guidelines and was launched on 18 November 2025.
The AML Guidelines define a “Regulated Entity” to mean any unit/entity which has been granted license, recognition, registration or authorisation by IFSCA. This essentially means that any entity set up in GIFT IFSC would be a “Regulated Entity” since it is not possible to set up any entity in GIFT IFSC unless it is regulated by the IFSCA. Therefore, entities such as banks registered with IFSCA under the IFSCA (Banking) Regulations 2019, Fund management entities registered with IFSCA under the IFSCA (Fund Management) Regulations 2025, aircraft leasing companies registered with IFSCA under IFSCA (Finance Company) Regulation 2021, law firms, trusteeship companies, and accounting firms registered with IFSCA under the IFSCA (TechFin and Ancillary Services) Regulations 2025 would all be treated as Regulated Entities.
IFSCA’s AML Guidelines mandate that every “Regulated Entity” should designate an individual as “Designated Director” to ensure overall compliance with its obligations under the AML Guidelines and another individual as “Principal Officer” to be responsible for furnishing information under the AML Guidelines.
The IFSCA Circular requires the ‘Designated Directors’ and ‘Principal Officers’ of ‘Regulated Entities’ to obtain the prescribed certification within 4 (four) months from the date of launch of the NISM-IFSCA-01: AML Certification , i.e. 18 March 2026, or within 4 (four) months from the date of appointment of the relevant Designated Director or Principal Officer, as the case may be.

• On October 17, 2025, IFSCA had released a consultation paper (“Consultation Paper”) proposing various amendments to the IFSCA (Fund Management) Regulations, 2025 (FM Regulations). This Consultation Paper has proposed to modify the qualifications required to be a compliance officer. Currently, a compliance officer is required to have a professional qualification and at least three years of experience in compliance or risk management in a listed company or any entity regulated by a financial service regulator. The Consultation Paper proposes to allow individuals possessing any professional qualification and 3 years of work experience in a financial institution to be appointed as a compliance officer provided, the individual has also obtained a prescribed certification. It is likely that if the Consultation Paper’s proposal with respect to the qualifications required to be a compliance officer is implemented, the ‘NISM-IFSCA-01: AML Certification’ will be prescribed as the applicable certification for a compliance officer employed with a Regulated Entity in GIFT-IFSC.

The IFSCA Circular dated 17 November 2025 can be found here.

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