Concurrent audit is a broader term which is covered in depth in the RBI circular dated 16 July 2015. The regulator defines concurrent audit as follows:
“Concurrent audit is an examination which is contemporaneous with the occurrence of transactions or is carried out as near thereto as possible. This audit is essentially a management process integral to the establishment of sound internal accounting functions and effective controls and setting the tone for a vigilant internal audit to preclude the incidence of serious errors and fraudulent manipulations. A concurrent auditor may not sit in judgement of the decisions taken by a branch manager or an authorised official. This is beyond the scope of concurrent audit. However, the audit will necessarily have to see whether the transactions or decisions are within the policy parameters laid down by the Head Office, they do not violate the instructions or policy prescriptions of the RBI, and that they are within the delegated authority.”
Furthermore, in the revision shared by RBI on 18 September 2019 (Annex) covers the remit of the auditor for concurrent audits which includes KYC/AML as “Adherence to KYC / AML guidelines including monitoring of transactions in accounts …”
Therefore, the interpretation of concurrent audit should be that of thorough examination of the Video KYC process, continuous audits and best practices laid down by the Regulated Entity in line with the V-CIP regulations set out by RBI.