Scope of the Role
The A Capital Account Transaction Desk TL, manages cross-border investments, foreign direct investments (FDI), overseas direct investments (ODI), and external commercial borrowings (ECB), ensuring strict compliance with foreign exchange regulations like FEMA and central bank guidelines.
* The role is a specialised banking position responsible for processing, scrutinising, reporting, advising and monitoring capital account transactions under FEMA and RBI guidelines. * The incumbent will be responsible for end-to-end handling, scrutiny, processing, monitoring, advisory support and regulatory reporting of capital account transactions under FEMA and RBI guidelines. * The incumbent shall be the nodal point for capital account transactions within the bank viz, liaison with RBI for the capital account transactions, for, but not limited to, references, clarifications, approval-route matters, reporting, LSF. * The incumbent will act as a bank’s specialised centralised expert and nodal point for customers, business, transactions teams, compliance, audit and regulators, ensuring that all capital account transactions are handled accurately, consistently and in full regulatory compliance. * To add, the guidance is from an AD bank / FEMA processing perspective and does not replace legal, tax, company law or overseas jurisdiction advice.
Job Description
A. Processing of Capital Account Transactions
The incumbent shall be responsible for processing - reviewing and approving eligible capital account transactions routed through the bank, including:
1. Approve capital account transactions, 2. Clear regulatory reporting submissions. 3. Seek additional documents from customers. 4. Reject or hold transactions pending compliance. 5. Escalate deviations and high-risk transactions to Compliance. 6. Recommend RBI / Government approval route. 7. Recommend LSF / compounding treatment.
B.Scrutiny
The role shall involve detailed scrutiny of transactions from a FEMA and RBI compliance perspective, including:
1. Determining whether the transaction is permitted under the automatic route or requires prior RBI / Government approval. 2. Verifying residential status of parties. 3. Checking sectoral caps, entry route and prohibited sectors. 4. Reviewing pricing and valuation compliance. 5. Checking eligibility of investor, investee, borrower, lender or remitter. 6. Verifying end-use restrictions, especially for ECB and financial commitment cases. 7. Reviewing maturity, all-in-cost, repayment and security conditions. 8. Identifying round-tripping, layering, treaty jurisdiction and beneficial ownership concerns. 9. Ensuring compliance with KYC, AML and sanctions requirements. 10. Escalating transactions involving regulatory ambiguity or high-risk features.
C.Reporting
The incumbent shall be responsible for timely and accurate regulatory reporting, including (indicative):
1. FC-GPR. 2. FC-TRS. 3. LLP-I / LLP-II. 4. Downstream investment reporting. 5. Form FC for overseas investment. 6. UIN tracking. 7. APR monitoring. 8. ECB reporting and ECB-2 follow-up. 9. Trade credit reporting. 10. FLA / FLAIR guidance and customer follow-up, where applicable. 11. FETERS / purpose code coordination. 12. Rectification and resubmission of rejected reports. 13. Maintenance of reporting acknowledgements and audit trail.
D.Guidance and Advisory Support
The incumbent shall act as a specialist advisory resource for relationship managers, customers and internal stakeholders. Responsibilities shall include:
1. Providing transaction-specific FEMA guidance. 2. Advising on documentation requirements. 3. Supporting relationship managers on complex customer proposals. 4. Explaining applicable RBI / FEMA requirements to customers. 5. Reviewing complex transaction structures. 6. Providing guidance on approval route cases. 7. Advising on reporting timelines and consequences of delay. 8. Preparing customer communication notes. 9. Developing FAQs and checklists. 10. Conducting trainings for internal stakeholders.
E. Nodal Point Responsibilities
The incumbent shall act as a nodal point for capital account transactions within the bank. This includes:
1. Liaison with RBI for references, clarifications and approval-route matters. 2. Coordination with internal compliance, legal, tax, audit and reporting teams. 3. Handling branch and customer escalations. 4. Responding to RBI inspection queries. 5. Coordinating internal audit and concurrent audit responses. 6. Maintaining repository of RBI approvals, clarifications and circulars. 7. Ensuring uniform interpretation of FEMA guidelines across the bank. 8. Tracking open regulatory issues and ensuring closure. 9. Preparing internal notes for senior management. 10. Escalating high-risk or precedent-setting cases.
F.Monitoring, Control and Risk Management
The incumbent shall maintain strong control over capital account transactions by:
1. Maintaining transaction-wise records and checklists. 2. Tracking pending documents and pending reporting. 3. Monitoring delayed filings and advising on LSF / compounding. 4. Ensuring maker-checker-authoriser controls. 5. Identifying high-risk transactions. 6. Escalating suspicious or unusual transactions to compliance. 7. Ensuring correct purpose code usage. 8. Reconciling transaction data with regulatory reporting. 9. Reviewing old outstanding cases. 10. Maintaining MIS for management review.
G.Policy, SOP and Process Improvement
The incumbent shall contribute to strengthening the bank’s capital account framework by:
1. Drafting and updating SOPs. 2. Preparing product notes and process notes. 3. Designing transaction checklists. 4. Updating process flows based on RBI circulars. 5. Supporting automation of workflows. 6. Improving portal-based tracking. 7. Creating standard customer guidance templates. 8. Developing escalation matrices. 9. Reducing operational errors and reporting delays. 10. Supporting regulatory change implementation.
H. Documentation Responsibilities
The incumbent shall ensure proper scrutiny and retention of documents such as:
1. Form A2 and FEMA declarations. 2. KYC reports. 3. FIRC / inward remittance advice. 4. Valuation certificates. 5. Board resolutions. 6. Share purchase agreements. 7. Loan agreements. 8. Statutory auditor / CA / CS certificates. 9. Foreign entity documents. 10. RBI approvals and acknowledgements. 11. FIRMS / SMF reporting proof. 12. UIN / LRN records. 13. APR and overseas investment records. 14. Tax documents such as Form 15CA / 15CB, wherever applicable. 15. Internal approval notes.
I. Key Internal Stakeholders
The role will require regular interaction with:
1. Relationship managers. 2. Customers 3. Trade finance operations. 4. CCSCs 5. Treasury. 6. Compliance. 7. Legal. 8. Tax team. 9. Regulatory reporting team. 10. Audit team. 11. Technology team. 12. Senior management. 13. RBI / regulators, wherever required.
J. List of Capital Account Transactions (indicative):
1. Foreign investment into India. 2. Overseas investment by Indian residents / entities. 3. External Commercial Borrowings. 4. Transfer of shares between resident and non-resident parties. 5. Remittance of sale proceeds to non-residents. 6. Refund of share application money. 7. Capital contribution into LLPs. 8. Downstream investment-related transactions. 9. BO / LO / PO transactions. 10. Overseas guarantees, pledge, charge and financial commitments. 11. Non-resident account-related capital transactions.
Ideal Candidates
Looking for bankers with a deep understanding of the Foreign Exchange Management Act (FEMA) or equivalent international capital controls. Experience in forex operations, trade finance, FEMA compliance, regulatory reporting, wholesale banking operations
1. Strong knowledge of trade life-cycle, SWIFT messages, and transaction banking platforms. 2 Hands-on exposure to FDI, ODI, ECB, LRS and regulatory reporting preferred. 3. Experience in handling RBI inspection / audit queries would be an advantage. 4. The ideal candidate should be a seasoned banking professional with deep understanding of FEMA capital account regulations and practical experience in handling cross-border investment, borrowing, reporting and remittance transactions. 5. The candidate should be able to balance business facilitation with regulatory discipline, guide customers and branches effectively, identify risk areas early, maintain strong documentation, and act as the bank’s reliable nodal resource for capital account transactions.
Key Skills: The candidate should possess:
1. Strong knowledge of FEMA and RBI guidelines. 2. Good understanding of FDI, ODI, ECB, trade credit and BO / LO / PO regulations. 3. Ability to interpret RBI Master Directions and AP DIR circulars. 4. Strong documentation and scrutiny skills. 5. Good understanding of banking operations. 6. Ability to identify regulatory and AML risks. 7. Strong communication skills. 8. Ability to guide branches and customers. 9. Good drafting skills for regulatory references and internal notes. 10. Strong MIS and follow-up discipline. 11. Attention to detail. 12. Ability to handle complex and high-value transactions. 13. Ability to work with business teams while maintaining regulatory control.