Practice Drills: Designing an AML Program Framework for a Mock Institution

A practice-first course built around one mock institution: a fictional mid-sized NBFC in the RBI Middle Layer that runs gold loans, MSME loans and digital personal loans through lending service providers, and has outgrown the AML program it started with. You play the newly hired Principal Officer and build its program from the ground up. First you map every obligation under the PMLA, the PML (Maintenance of Records) Rules and the RBI KYC Directions into a requirements register. Then you run the institution-wide ML and TF risk assessment, build a customer risk rating model and assess new products and lending partners before launch. You define the Designated Director and Principal Officer mandates, draft the policy skeleton and the escalation paths, design due diligence tiers, beneficial ownership and PEP procedures and periodic KYC updation, and write the first transaction monitoring rule set, sanctions and UAPA Section 51A screening, the FIU-IND reporting calendar and the record retention design. The course closes with role-based training, the independent AML audit and program KPIs, a full AML Program Document for board approval and a response to an RBI inspection finding.