A. For Debit to SNRR A/c (for onward credit domestically)

In case of receipt of Export proceeds by an Indian party by debit to SNRR account of the overseas buyer:

• As in case of any inward remittance received for export payment, the AD bank handling the export documents shall ensure compliance with all export related rules/regulation/ guidelines prescribed under FEMA.

• The AD bank maintaining SNRR account shall be responsible for performing due diligence of the overseas client and related FEMA compliances. Further, it shall, while transferring the funds to the AD bank of the Indian exporter (beneficiary’s bank), provide complete KYC details of the account holder (Name, address, country etc.), purpose of remittance, currency and amount of remittance, name and account number of the beneficiary etc. so as to enable the latter to close the entries in EDPMS with the respective remittance.

B. For Credit to SNRR A/c (received from a domestic account)

In case of payment for Imports by an Indian party by credit to the SNRR account of the overseas seller:

• As in case of any outward remittance sent for import payment, the AD bank handling import documents and remitting funds (Importer’s Bank) shall ensure compliance with all related import rules/regulations/guidelines prescribed under FEMA.

• It shall also communicate all details related to the importer as required by the AD bank maintaining the SNRR account of the overseas client.

C. Similarly, in case of ECB, Trade credits, foreign investments, etc., the designated AD bank maintaining the resident customer’s A/c will be responsible for ensuring compliance with FEMA provisions, including issuance of FIRC, wherever applicable, on the same lines as it would have done in case of money received in freely convertible currency through an inward remittance. Further, the banks involved in the transaction shall be responsible for sharing of the details of the transactions on similar lines as above.

Ans. Sellers, buyers and financiers are the participants on a TReDS platform.

Yes. Foreign nationals resident in India can open and maintain resident Rupee account in India.

Answer: The settlement through Indian Rupees (INR) is an additional arrangement to the existing system that uses freely convertible currencies and will work as a complimentary system. This will reduce dependence on hard (freely convertible) currency.

No. Model Education Loan Scheme, 2021 is currently applicable to Scheduled Commercial Banks (SCBs) only. The list of SCBs is available here.

Ans. The directions require assessment of income and indebtedness at household level. There is no requirement of treating all members of the household as applicants/ borrowers of a loan which can be provided to an individual member. Board-approved policies of REs may include the methodologies/ operational frameworks to assess income and indebtedness of all members of the household.

Answer: An authorised person is an entity authorised by the Reserve Bank of India to deal in forex. It can be an authorised dealer, money changer, off-shore banking unit or any other person for the time being authorised under Sub-Section (1) of Section 10 of FEMA. The list of authorised persons is available here.

The age-limit in para 2.4 of the aforesaid circular was given with the objective of ensuring that the responsibilities associated with CCO are treated as a specialised and core function. Keeping in view the above principle, if a person identified as CCO is above the age of 55 years, however, she/he has had continuous association with the compliance function either as CCO or otherwise, the age limit of 55 years may be taken as the date from when the continuous association with the compliance function started for the identified CCO. Illustratively, if a person identified for CCO role has age more than 55 years but she/he has been continuously associated with the compliance function prior to completing the age of 55 years, the person would be eligible for such appointment.

The entire payment data shall be stored in systems located only in India, except in cases clarified herein.

Ans. NBFC- Factor means a non-banking financial company fulfilling the Principal business criteria i.e. whose financial assets in the factoring business constitute at least 75 percent of its total assets and income derived from factoring business is not less than 75 percent of its gross income, has Net Owned Funds of Rs. 5 crore and has been granted a certificate of registration by RBI under section 3 of the Factoring Regulation Act, 2011.