The Ghatal Peoples Co-operative Bank Limited, West Bengal
Penalty Imposed: ₹5.50 Lakh (Rupees Five Lakh Fifty Thousand Only)
Key Details (Violation Summary)
| Inspection Date | March 31, 2024 (Financial Position) |
|---|---|
| Penalty Order Date | September 26, 2025 |
| Violations |
|
Root Cause Analysis (RCA) – Inferred
- Systemic Gaps: Lack of automated processes for risk review and CKYCR uploads, leading to reliance on manual, error-prone workflows.
- Resource/Training Deficit: Insufficient dedicated staff or lack of comprehensive training on the periodicity (six months) of risk categorization review.
- Technical Integration: Inadequate system integration between the core banking solution and the CKYCR portal, causing delays in mandatory data submissions.
Preventive Controls
- Automated CKYCR Process: Implement an automated module to pull new/updated KYC data from the Core Banking System (CBS) and push it to CKYCR daily or weekly.
- Risk Categorisation Engine: Configure the CBS to automatically flag accounts for risk review on a 5-month cycle, allowing a one-month buffer for completion.
- Mandatory Compliance Audits: Introduce monthly internal audits focusing specifically on KYC/AML compliance, CKYCR status, and risk category review completion.
Lessons Learned
- Compliance is not a one-time activity; ongoing system-driven monitoring is mandatory, especially for periodic tasks like risk review.
- Regulatory directives (CKYCR upload timeline) must be mapped to system processes and not left to human memory or manual intervention.
RBI Press Release
The Gopalganj Central Co-operative Bank Limited, Bihar
Penalty Imposed: ₹5.50 Lakh (Rupees Five Lakh Fifty Thousand Only)
Key Details (Violation Summary)
| Inspection Date | March 31, 2024 (Financial Position) |
|---|---|
| Penalty Order Date | September 26, 2025 |
| Violations |
|
Root Cause Analysis (RCA) – Inferred
- NBA Disposal: Lack of a dedicated legal/recovery cell focused on the timely disposal of foreclosed or acquired assets, leading to administrative and legal delays.
- CKYCR Compliance: Similar to other co-operative banks, a lack of automated data transfer and dedicated resources for timely CKYCR data feeding.
Preventive Controls
- NBA Resolution Committee: Establish a high-level committee (Board oversight) to monitor and drive the disposal of all Non-Banking Assets on a strict quarterly timeline.
- NBA Tracking System: Implement a dedicated system to track the legal/sale status of each NBA with mandatory escalation alerts after statutory deadlines are missed.
- CKYCR Integration: Prioritize the technical upgrade/integration to ensure real-time or near real-time upload of KYC data upon account opening/update.
Lessons Learned
- Statutory compliance, especially regarding Non-Banking Asset holding limits, is non-negotiable and requires aggressive, process-driven resolution.
- Operational deficiencies (like CKYCR upload failure) often coexist with financial/asset management deficiencies, indicating a broader governance issue.
RBI Press Release
Ranaghat People’s Co-operative Bank Limited, West Bengal
Penalty Imposed: ₹5.00 Lakh (Rupees Five Lakh Only)
Key Details (Violation Summary)
| Inspection Date | March 31, 2024 (Financial Position) |
|---|---|
| Penalty Order Date | September 24, 2025 |
| Violation | Failure to upload the KYC records of customers onto Central KYC Records Registry (CKYCR). |
Root Cause Analysis (RCA) – Inferred
- Procedural Oversight: Lack of defined Standard Operating Procedures (SOPs) ensuring CKYCR submission is the final step in the account opening process.
- System Availability: Potential issues with CKYCR system downtime or poor network connectivity not being documented and addressed via defined retry mechanisms.
Preventive Controls
- Process Enforceability: Make CKYCR enrollment a hard-stop in the account opening workflow; the account should not be fully operational until CKYC ID is received/logged.
- System Health Monitoring: Implement daily reconciliation reports between the number of new accounts opened and the number of successful CKYCR submissions.
Lessons Learned
- CKYCR is central to the KYC framework; its failure indicates a major lapse in the foundational AML/CFT compliance structure.
- For large monetary penalties, the scale of non-compliance (i.e., volume of customers missed) is often a significant factor.
RBI Press Release
The Begusarai Central Co-operative Bank Limited, Bihar
Penalty Imposed: ₹1.40 Lakh (Rupees One Lakh Forty Thousand Only)
Key Details (Violation Summary)
| Inspection Date | March 31, 2024 (Financial Position – NABARD) |
|---|---|
| Penalty Order Date | September 24, 2025 |
| Violation | Failure to upload the KYC records of customers onto Central KYC Records Registry (CKYCR) within the prescribed timeline. |
Root Cause Analysis (RCA) – Inferred
- Timeline Misunderstanding: Possible misinterpretation of the “prescribed timeline” by operational staff, or failure to communicate urgency from compliance to front-line.
- IT Infrastructure: Challenges in maintaining stable internet connectivity or upgrading legacy systems required for seamless data transmission to CKYCR.
Preventive Controls
- Time-Bound Escrow: Implement a system alert that automatically escalates un-uploaded CKYCR records to the Compliance Officer after 7 days (well within the typical prescribed timeline).
- Refresher Training: Conduct mandatory, recorded annual training for all operations staff covering CKYCR procedures and the regulatory timelines specified by RBI.
Lessons Learned
- The distinction between data collection (KYC) and regulatory submission (CKYCR) must be clearly segregated and managed with separate control checks.
- Timeliness in compliance is as critical as the compliance itself, particularly for data registries.
RBI Press Release
Sahara Housingfina Corporation Limited, West Bengal (NBFC)
Penalty Imposed: ₹50,000/- (Rupees Fifty Thousand Only)
Key Details (Violation Summary)
| Inspection Date | March 31, 2024 (Financial Position – NHB) |
|---|---|
| Penalty Order Date | September 24, 2025 |
| Violation | Failure to upload the KYC records of customers onto Central KYC Records Registry (CKYCR) within the prescribed timeline. |
Root Cause Analysis (RCA) – Inferred
- NBFC-Specific Focus: As an NBFC (Housing Finance Company), compliance focus may have been heavily skewed toward lending norms rather than data compliance like CKYCR.
- Operational Bandwidth: Limited IT/compliance resources compared to full-fledged banks, resulting in delayed back-office functions.
Preventive Controls
- Outsourcing/Third-Party Check: Leverage third-party compliance software or services to manage CKYCR data submission, reducing reliance on internal bandwidth.
- NHB/RBI Checklist: Create a definitive checklist for all RBI/NHB compliance items, ensuring CKYCR is high-priority and not overlooked.
Lessons Learned
- NBFCs must adhere to the same stringent KYC data submission requirements as banks; the regulatory burden is uniform.
- Proactive compliance investments save costs, as the penalty itself exceeds the cost of minimal automation.
RBI Press Release
The Boudh Co-operative Central Bank Limited, Odisha
Penalty Imposed: ₹10,000/- (Rupees Ten Thousand Only)
Key Details (Violation Summary)
| Inspection Date | March 31, 2024 (Financial Position – NABARD) |
|---|---|
| Penalty Order Date | September 26, 2025 |
| Violation | Failure to submit credit information of its customers to three Credit Information Companies (CICs). |
Root Cause Analysis (RCA) – Inferred
- Multi-CIC Oversight: Failure to recognize the regulatory mandate to report to “all” mandatory CICs, potentially reporting to only one or two.
- Data Inconsistencies: Errors in customer data formats that prevent successful data ingestion by multiple CICs, which have slightly different data validation rules.
Preventive Controls
- Reporting Reconciliation: Implement a dedicated daily/monthly process to ensure that the total number of accounts reported to each of the three mandatory CICs is reconciled against the Core Banking System.
- Test Data Submission: Regularly test the data upload process with mock data for all mandated CICs to ensure continuity of reporting infrastructure.
Lessons Learned
- Accurate and timely credit information submission is vital for financial stability and consumer protection; failure impacts the entire credit ecosystem.
- A comprehensive “Report Card” is needed to track successful submissions to every mandated external agency (CICs, CKYCR, etc.).