Background: PML Rules and Name Change
The Prevention of Money-laundering (Maintenance of Records) Rules, 2005 define what constitutes an officially valid document (OVD) for KYC purposes.
To ease difficulties faced by individuals whose names change after marriage or otherwise, the Government notified the Prevention of Money-laundering (Maintenance of Records) Third Amendment Rules, 2015 (G.S.R. 730(E) dated 22 September 2015).
Explanation inserted in Rule 2(1)(d)
Rule 2(1)(d) of the PML Rules defines “officially valid document” and now carries an explanation on name change.
The inserted explanation reads: “For the purpose of this clause, a document shall be deemed to an ‘officially valid document’ even if there is a change in the name subsequent to its issuance provided it is supported by a marriage certificate issued by the State Government or Gazette notification, indicating such a change of name.”
RBI Circular to Banks and REs
Following this amendment, RBI issued circular RBI/2015-16/213 DBR.AML.BC.No.46/14.01.001/2015‑16 dated 29 October 2015 on “Amendment to PML Rules – Submitting ‘Officially Valid Documents’ – Change in name on account of marriage or otherwise”.
The circular is addressed to all regulated entities, including Scheduled Commercial Banks, RRBs, Local Area Banks, NBFCs, Primary (Urban) Co‑operative Banks, State and Central Co‑operative Banks, payment system providers, system participants, PPI issuers and authorised persons under MTSS.
Practical KYC Relaxation: What Banks Can Accept
Under the RBI circular, regulated entities may accept the following while establishing an account-based relationship or during periodic KYC updation:
- A copy of the marriage certificate issued by the State Government or a Gazette notification indicating the change in name.
- Along with a certified copy of an OVD in the existing (old) name of the customer.
This enables a smooth KYC process even where the customer’s current name differs from the name appearing in the OVD, as long as the change is backed by a State marriage certificate or Gazette notification.
Alignment with Current KYC Directions
RBI’s KYC Master Direction (DBR.AML.BC.No.81/14.01.001/2015‑16, as amended) incorporates this explanation, treating an OVD as valid despite post‑issuance name change when supported by a marriage certificate or Gazette notification.
Banks should ensure that their internal KYC policies, account opening forms and periodic updation procedures clearly reflect this position so that front-line staff handle name-change cases consistently and customer‑friendly.
