C.10  ECGC Post-shipment Guarantee Scheme
285. The bank shall, in the interest of export promotion and credit risk mitigation,
consider opting for export credit insurance products offered by ECGC Ltd. The
salient features of the scheme, Export Credit Insurance for Banks (ECIB), may be
obtained directly from ECGC Ltd.
As the post-shipment guarantee mainly benefits the banks, the cost of premium
may be borne by the banks and not passed on to the exporters.
286. However, even where the post-shipment credit is insured under an ECGC
policy, the bank shall not dilute their efforts towards realisation of their dues against
long outstanding export bills.
C.11  Export Credit - DTA to SEZ Units
287. As per the extant Foreign Trade Policy, goods and services going to Special
Economic Zone area (SEZ) from Domestic Tariff Area (DTA) shall be treated as
exports. Accordingly, the supply of goods and services from DTA to Special
Economic Zone area would be eligible for export credit facilities.
D. Deemed Exports - Rupee Export Credit
288. The bank shall extend rupee pre-shipment and post-shipment export credit to
parties against orders for supplies in respect of projects aided / financed by
bilateral or multilateral agencies / funds (including World Bank, IBRD, IDA), as
notified from time to time by Department of Economic Affairs, Ministry of Finance
under the Section "Deemed Exports" in Foreign Trade Policy, which are eligible
for grant of normal export benefits by Government of India.
289. Packing Credit provided shall be adjusted from free foreign exchange
representing payment for the suppliers of goods to these agencies. It shall also be
repaid / prepaid out of balances in Exchange Earners Foreign Currency account
(EEFC A/c), as also from the rupee resources of the exporter to the extent supplies
have actually been made.
290. The bank shall also extend rupee
(1) pre-shipment credit, and
(2) post-supply credit (for a maximum period of 30 days or up to the actual date of
payment by the receiver of goods, whichever is earlier),


for supply of goods specified as 'Deemed Exports' under the same Section of
Foreign Trade Policy from time to time.
E. Interest on Rupee Export Credit
291. The bank shall determine interest rate on rupee export credit (pre-shipment
credit and post-shipment credit) as per the policy approved by their Board, subject
to the regulatory provisions contained in the Reserve Bank of India (Commercial
Banks – Interest Rates on Advances) Directions, 2025.
292. If pre-shipment advances are not liquidated from proceeds of bills on purchase,
discount, etc. on submission of export documents within 360 days from the date
of advance, or as indicated at paragraph 235 of these Directions, the advances
shall not be treated as export credit ab initio.
293. If exports do not materialise at all, the bank shall charge on relative packing
credit domestic lending rate plus penal charges, if any, to be decided by the bank
on the basis of a transparent policy approved by their Board.
F. Pre-shipment Credit in Foreign Currency (PCFC)
F.1
General Provisions
294. With a view to making credit available to exporters at internationally competitive
rates, authorised dealers have been permitted to extend pre-shipment Credit in
Foreign Currency (PCFC) to exporters for domestic and imported inputs of
exported goods at Alternative Reference Rate in the currency concerned.
295. The scheme is an additional window for providing pre-shipment credit to Indian
exporters at internationally competitive rates of interest. It shall be applicable to
only cash exports. The instructions with regard to Rupee Export Credit shall apply
to export credit in Foreign Currency mutatis mutandis, unless otherwise specified.
296. The exporter shall have the following options to avail of export finance:
(1) to avail of pre-shipment credit in rupees and then the post-shipment credit
either in rupees or discounting / rediscounting of export bills under EBR
Scheme mentioned in paragraph 340  to 364 of these Directions.
(2) to avail of pre-shipment credit in foreign currency and discount / rediscounting
of the export bills in foreign currency under EBR Scheme.


(3) to avail of pre-shipment credit in rupees and then convert drawal into PCFC at
the discretion of the bank.
297. Choice of currency
(1) The facility shall be extended in one of the convertible currencies viz. US
Dollars, Pound Sterling, Japanese Yen, Euro, etc.
(2) To enable the exporters to have operational flexibility, it shall be in order for
banks to extend PCFC in one convertible currency in respect of an export order
invoiced in another convertible currency. For example, an exporter can avail of
PCFC in US Dollar against an export order invoiced in Euro. The risk and cost
of cross currency transaction shall be that of the exporter.
(3) The bank shall extend PCFC for exports to ACU countries.
(4) The applicable benefit to the exporters shall accrue only after the realisation of
the export bills or when the resultant export bills are rediscounted on ‘without
recourse’ basis.
F.2
Source of funds for banks
298. The foreign currency balances available with the bank in Exchange Earners
Foreign Currency (EEFC) Accounts, Resident Foreign Currency Accounts RFC(D)
and Foreign Currency (Non-Resident) Accounts (Banks) Scheme may be utilised
for financing the pre-shipment credit in foreign currency.
299. The bank shall also utilise the foreign currency balances available under
Escrow Accounts and Exporters Foreign Currency Accounts for the purpose,
subject to ensuring that the requirements of funds by the account holders for
permissible transactions are met and the limit prescribed for maintaining maximum
balance in the account under broad based facility is not exceeded.
300. Foreign currency borrowings
(1) In addition, the bank may arrange for borrowings from abroad. The bank shall
negotiate lines of credit with overseas banks for the purpose of grant of PCFC
to exporters without the prior approval of the Reserve Bank.
(2) The bank shall avail of lines of credit from other banks in India if they are not in
a position to raise loans from abroad on their own, provided the bank does not
have a branch abroad. The spread between the borrowing and lending bank is
left to the discretion of the banks concerned.


(3) The bank shall draw on the line of credit arranged only to the extent of loans
granted by them to the exporters under the PCFC. However, where the
overseas bank making available the line of credit stipulates a minimum amount
for drawals which shall not be very large, the small unutilised portion shall be
managed by the bank within its foreign exchange position and Aggregate Gap
Limit (AGL). Similarly, any pre-payment by the exporter shall also be taken
within the foreign exchange position and AGL limits.
301. In case the exporters have arranged for the suppliers’ credit for procuring
imported inputs, the PCFC facility shall be extended by the banks only for the
purpose of financing domestic inputs for exports.
302. The bank shall use foreign currency funds borrowed in terms of Notification No.
FEMA.3(R)/2018-RB dated December 17, 2018  as also foreign currency funds
generated through buy-sell swaps in the domestic forex market for granting pre-
shipment credit in Foreign Currency (PCFC) subject to adherence to Aggregate
Gap Limit (AGL) in terms of Master Direction - Risk Management and Inter-Bank
Dealings.
F.3
Interest on Export Credit in Foreign Currency
303. The bank is free to determine interest rates on export credit in foreign currency
using any widely accepted Alternative Reference Rate (ARR) in the currency
concerned, in accordance with their Board-approved policy and subject to the
relevant guidelines contained in the Reserve Bank of India (Commercial Banks –
Interest Rates on Advances) Directions, 2025, or any other applicable direction /
circular.
F.4
Period of credit
304. The PCFC shall be available for a maximum period of 360 days. Any extension
of the credit shall be subject to the same terms and conditions as applicable for
extension of rupee packing credit.
305. Further extension shall be subject to the terms and conditions fixed by the bank
concerned and if no export takes place within 360 days, the PCFC shall be
adjusted at T.T. selling rate for the currency concerned. In such cases, the bank
shall arrange to remit foreign exchange to repay the loan or line of credit raised
abroad and interest without prior permission of the Reserve Bank.


F.5
Export Credit in Foreign Currency to Protect Exporters from Rupee
Fluctuations
306. Banks extend export credit in Indian Rupees as well as in foreign currency,
such as Pre-Shipment Credit in Foreign Currency (PCFC) and Post Shipment
Credit in Foreign Currency (PSCFC), as per their own internal lending policy within
the overall regulatory framework prescribed by the Reserve Bank.
307. The export credit limits are calculated in Indian Rupees and the limit is
apportioned between Rupee and foreign currency components depending upon
the borrowers' requirement. While the overall export credit limits are fixed in Indian
Rupees, the foreign currency component of export credit fluctuates based on the
prevailing exchange rates.
308. It is observed that whenever there is a depreciation of Indian Rupee :
(1) the unavailed foreign currency component of export credit gets reduced;
(2) the foreign currency component of export credit already availed gets revalued
at a higher value in terms of Indian Rupees resulting in the exporter being
asked to reduce their exposure by part payment or where the export credit limit
is not fully disbursed, the available limit for the borrower reduces, depriving
exporter of funds.
309. The bank shall consider denominating export credit facilities in foreign currency
to ensure that exporters are not adversely impacted by Rupee fluctuations.
310. The bank shall compute the overall export credit limits of the borrowers on an
ongoing basis say monthly, based on the prevalent position of current assets,
current liabilities and exchange rates and re-allocate limit towards export credit in
foreign currency, as per the bank's own policy. This may result in increasing or
decreasing the Indian Rupee equivalent of foreign currency component of export
credit.
311. Alternatively, the bank shall denominate foreign currency (FC) component of
export credit in foreign currency only with a view to ensuring that the exporters are
insulated from Rupee fluctuations. The FC component of export credit, sanctioned,
disbursed and outstanding will be maintained and monitored in FC. However, for
translation of FC assets in the banks' book, the bank shall refer to Reserve Bank


of India (Commercial Banks – Financial Statements: Presentation and
Disclosures) Directions, 2025.
F.6
Disbursement of PCFC
312. In case full amount of PCFC or part thereof is utilised to finance domestic input,
the bank shall apply appropriate spot rate for the transaction.
313. As regards the minimum lots of transactions, it is left to the operational
convenience of the bank to stipulate the minimum lots taking into account the
availability of its own resources. However, while fixing the minimum lot, the bank
shall take into account the needs of their small customers also.
314. The bank shall take steps to streamline their procedures so that no separate
sanction is needed for PCFC once the packing credit limit has been authorised
and the disbursement is not delayed at the branches.
F.7
Liquidation of PCFC Account
315. PCFC shall be liquidated out of proceeds of export documents on their
submission for discounting / rediscounting under the EBR Scheme as detailed in
paragraphs 340 to 364 of these Directions or by grant of foreign currency loans
(DP Bills). Subject to mutual agreement between the exporter and the banker, it
shall also be repaid / prepaid out of balances in EEFC A/c as also from rupee
resources of the exporter to the extent exports have actually taken place.
316. Packing credit in excess of F.O.B. value
In certain cases, (viz. agro based products like HPS groundnut, defatted & deoiled
cakes, tobacco, pepper, cardamom, cashew nuts, etc.) where packing credit
required is in excess of FOB value, PCFC shall be available only for exportable
portion of the produce.
317. Substitution of order / commodity
Repayment / liquidation of PCFC shall be with export documents relating to any
other order covering the same or any other commodity exported by the exporter or
amount of balance in the EEFC Account. While allowing substitution of contract in
this way, the bank shall ensure that it is commercially necessary and unavoidable.
The bank shall also satisfy about the valid reasons as to why PCFC extended for
shipment of a particular commodity cannot be liquidated in the normal method. As


far as possible, the substitution of contract shall be allowed if the exporter
maintains account with the same bank or it has the approval of the members of
the consortium, if any.
F.8
Cancellation / non-execution of export order
318. In case of cancellation of the export order for which the PCFC was availed of
by the exporter from the bank, or if the exporter is unable to execute the export
order for any reason, the exporter may repay the loan together with accrued
interest thereon, by purchasing foreign exchange (principal + interest) from
domestic market through the bank.
319. It shall also be in order for the bank to remit the amount to the overseas bank,
provided the PCFC was made available to exporter from the line of credit obtained
from that bank.
320. The bank shall extend PCFC to such exporters subsequently, after ensuring
that the earlier cancellation of PCFC was due to genuine reasons.
F.9
Running Account Facility for all commodities
321. The bank shall extend the ‘Running Account’ facility under the PCFC Scheme
to exporters for all commodities, on the lines of the facility available under rupee
credit, subject to the following conditions:
(1) The facility shall be extended provided the need for ‘Running Account’ facility
has been established by the exporters to the satisfaction of the bank.
(2) The bank shall extend the facility only to those exporters whose track record
has been good.
(3) In all cases, where pre-shipment credit ‘Running Account’ facility has been
extended, the LCs or firm orders shall be produced within a reasonable period
of time.
(4) The PCFC shall be marked-off on the ‘First-in-First-Out’ basis.
(5) PCFC shall also be marked-off with proceeds of export documents against
which no PCFC has been drawn by the exporter.
322. The bank shall closely monitor the production of firm order or LC subsequently
by exporters and also the end-use of funds. It shall be ensured that no diversion
of funds is made for domestic use. In case of non-utilisation of PCFC drawals for


export purposes, the penal provisions stated above shall be made applicable and
the ‘Running Account’ facility shall be withdrawn for the concerned exporter.
323. The bank shall take any prepayment by the exporter under PCFC scheme
within their foreign exchange position and Aggregate Gap Limit (AGL) as indicated
in paragraph 300(3) of these Directions. With the extension of ‘Running Account’
facility, mismatches are likely to occur for a longer period involving cost to the
banks. The bank shall charge the exporters the funding cost, if any, involved in
absorbing mismatches in respect of the prepayment beyond one month period.
F.10  Forward Contracts
324. In terms of paragraph 297 of these Directions, PCFC can be extended in any
of the convertible currencies in respect of an export order invoiced in another
convertible currency. The bank shall also allow an exporter to book forward
contract on the basis of confirmed export order prior to availing of PCFC and
cancel the contract (for portion of drawal used for imported inputs) at prevailing
market rates on availing of PCFC.
325. The bank shall allow customers to seek cover in any permitted currency of their
choice which is actively traded in the market, subject to ensuring that the customer
is exposed to exchange risk in a permitted currency in the underlying transaction.
326. While allowing forward contracts under the scheme, banks shall ensure
compliance of the basic Foreign Exchange Management requirement that the
customer is exposed to an exchange risk in the underlying transaction at different
stages of the export finance.
F.11  Sharing of EPC under PCFC
327. The rupee export packing credit may be shared between an export order holder
and the manufacturer of the goods to be exported. Similarly, the bank shall extend
PCFC also to the manufacturer on the basis of the disclaimer from the export order
holder through its bank.
328. PCFC granted to the manufacturer can be repaid by transfer of foreign currency
from the export order holder by availing of PCFC or by discounting of bills. The
bank shall ensure that no double financing is involved in the transaction and the


total period of packing credit is limited to the actual cycle of production of the
exported goods.
329. The facility shall be extended where the banker or the leader of consortium of
banks is the same for both the export order holder and the manufacturer or, the
banks concerned agree to such an arrangement where the bankers are different
for export order holder and manufacturer. The sharing of export benefits shall be
left to the mutual agreement between the export order holder and the
manufacturer.
F.12  Supplies from One EOU/EPZ/SEZ Unit to another EOU/EPZ/SEZ Unit
330. PCFC shall be made available to both, the supplier EOU / EPZ / SEZ unit and
the receiver EOU / EPZ / SEZ unit.
331. The PCFC for supplier EOU / EPZ / SEZ unit shall be for supply of raw materials
/ components of goods which will be further processed and finally exported by
receiver EOU / EPZ / SEZ unit.
332. The PCFC extended to the supplier EOU / EPZ / SEZ unit shall have to be
liquidated by receipt of foreign exchange from the receiver EOU / EPZ / SEZ unit,
for which purpose, the receiver EOU / EPZ / SEZ unit may avail of PCFC.
333. The stipulation regarding liquidation of PCFC by payment in foreign exchange
shall be met in such cases not by negotiation of export documents but by transfer
of foreign exchange from the banker of the receiver EOU / EPZ / SEZ unit to the
banker of supplier EOU / EPZ / SEZ unit. Thus, there shall not normally be any
post-shipment credit in the transaction from the supplier EOU / EPZ / SEZ unit’s
point of view.
334. In all such cases, it shall be ensured by banks that there is no double financing
for the same transaction. Needless to add, the PCFC to receiver EOU / EPZ / SEZ
unit shall be liquidated by discounting of export bills.
F.13  Deemed Exports
335. PCFC shall be allowed for ‘deemed exports’ only for supplies to projects
financed by multilateral / bilateral agencies / funds. PCFC released for ‘deemed
exports’ shall be liquidated by grant of foreign currency loan at post-supply stage,
for a maximum period of 30 days or up to the date of payment by the project


authorities, whichever is earlier. PCFC shall also be repaid / prepaid out of
balances in EEFC A/c as also from rupee resources of the exporter to the extent
supplies have actually been made.
F.14  Other aspects
336. The applicable benefits such as credit of eligible percentage of export proceeds
to EEFC Account etc. to the exporters shall accrue only after realisation of the
export bills and not at the stage of conversion of pre-shipment credit to post-
shipment credit (except when bills are discounted / rediscounted 'without
recourse').
337. For the purpose of reckoning the bank’s performance in extending export credit,
the rupee equivalent of the PCFC shall be taken into account.
F.15  Diamond Dollar Account (DDA) Scheme
338. In terms of the extant Foreign Trade Policy, firms / companies dealing in
purchase / sale of rough or cut and polished diamonds, diamond studded jewellery,
with good track record of at least two years in import or export of diamonds with
an annual average turnover of ₹3 crore or above during the preceding three
licensing years (from April to March) are permitted to carry out their business
through designated Diamond Dollar Accounts (DDAs).
339. Under the DDA Scheme, the bank shall liquidate PCFC granted to DDA holders
by dollar proceeds from sale of rough, cut and polished diamonds by them to other
DDA holders. (For details regarding the Diamond Dollar Accounts, bank may refer
to Foreign Exchange Management (Foreign currency accounts by a person
resident in India) Regulations, 2015, issued by FED vide Notification No. FEMA 10
(R) /2015-RB dated January 21, 2016, as amended from time to time.
G. Post-shipment Credit in Foreign Currency: Rediscounting of Export Bills
Abroad Scheme (EBR)
340. The bank shall utilise the foreign exchange resources available with it in
Exchange Earners Foreign Currency Accounts (EEFC), Resident Foreign
Currency Accounts (RFC), Foreign Currency (Non-Resident) Accounts (Banks)
Scheme, to discount usance bills and retain them in their portfolio without resorting


to rediscounting. The bank can rediscount export bills abroad at rates linked to
international interest rates at post- shipment stage.
G.1
Scheme
341. It will be comparatively easier to have a facility against bills portfolio (covering
all eligible bills) than to have rediscounting facility abroad on bill-by-bill basis.
There shall, however, be no bar if rediscounting facility on bill-to-bill basis is
arranged by a bank in case of any particular exporter, especially for large value
transactions.
342. The bank shall arrange a "Bankers Acceptance Facility" (BAF) for rediscounting
the export bills without any margin and duly covered by collateralised documents.
343. Each bank can have its own BAF limit(s) fixed with an overseas bank or a
rediscounting agency or an arrangement with any other agency such as factoring
agency (in case of factoring arrangement, it shall be on ‘without recourse’ basis
only).
344. The exporters, on their own, can arrange for themselves a line of credit with an
overseas bank or any other agency (including a factoring agency) for discounting
their export bills direct subject to the following conditions:
(1) Direct discounting of export bills by exporters with overseas bank and / or any
other agency shall be done only through the branch of an authorized dealer
designated by them for this purpose.
(2) Discounting of export bills shall be routed through designated bank / authorized
dealer from whom the packing credit facility has been availed of. In case, these
are routed through any other bank, the latter will first arrange to adjust the
amount outstanding under packing credit with the concerned bank out of the
proceeds of the rediscounted bills.
345. The limits granted to banks by overseas banks / discounting agencies under
BAF shall not be reckoned for the purpose of borrowing limits fixed by Foreign
Exchange Department of the Reserve Bank for them.
G.2
Eligibility criteria
346. The Scheme shall cover mainly export bills with usance period up to 180 days
from the date of shipment (inclusive of normal transit period and grace period, if


any). There is, however, no bar to include demand bills, if overseas institution has
no objection to it.
347. In case borrower is eligible to draw usance bills for periods exceeding 180 days
as per the extant instructions of Foreign Exchange Department, Post-shipment
Credit under the EBR shall be provided beyond 180 days.
348. The facility under the Scheme of Rediscounting shall be offered in any
convertible currency.
349. The bank can extend the EBR facility for exports to ACU countries.
350. For operational convenience, the BAF Scheme shall be centralised at a branch
designated by the bank. There shall, however, be no bar for other branches of the
bank to operate the scheme as per the bank's internal guidelines / instructions.
G.3
Source of On-shore funds
351. In the case of demand bills [subject to paragraph 346 of these Directions], these
shall be routed through the existing post-shipment credit facility or by way of
foreign exchange loans to the exporters out of the foreign currency balances
available with banks in the Schemes ibid.
352. To facilitate the growth of local market for rediscounting export bills,
establishment and development of an active inter-bank market is desirable. It is
possible that the bank holds bills in their own portfolio without rediscounting.
However, in case of need, the bank shall also have access to the local market,
which will enable the country to save foreign exchange to the extent of the cost of
rediscounting. Further, as different banks may be having BAF for varying amounts,
it shall be possible for a bank which has balance available in its limit to offer
rediscounting facility to another bank which may have exhausted its limit or could
not arrange for such a facility.
353. The bank shall avail of lines of credit from other banks in India if they are not in
a position to raise loans from abroad on their own or they do not have branches
abroad
354. The bank shall also use foreign currency funds borrowed in terms of Notification
No. FEMA.3(R)/2018-RB dated December 17, 2018 as also foreign currency funds
generated through buy - sell swaps in the domestic forex market for granting facility


of rediscounting of Export Bills Abroad (EBR) subject to adherence to Aggregate
Gap Limit (AGL) in terms of Master Direction - Risk Management and Inter-Bank
Dealings.
G.4
Facility of Rediscounting 'with recourse' and 'without recourse'
355. It is recognized that it will be difficult to get ‘without recourse’ facility from abroad
under BAF or any other facility. Therefore, the bills may be rediscounted ‘with
recourse’. However, if an AD is in a position to arrange ‘without recourse’ facility
on competitive terms, it shall avail itself of such a facility.
G.5
Accounting aspects
356. The rupee equivalent of the discounted value of the export bills shall be payable
to the exporter and the same shall be utilised to liquidate the outstanding export
packing credit.
357. As the discounting of bills / extension of foreign exchange loans (DP bills) shall
be in actual foreign exchange, the bank shall apply appropriate spot rate for the
transactions.
358. The rupee equivalents of discounted amounts / foreign exchange loan shall be
held in the bank’s books distinct from the existing post-shipment credit accounts.
359. In case of overdue bills, the bank shall charge interest from the due date to the
date of crystallization as per the interest rate policy of the bank.
360. In the event of export bill not being paid, the bank shall remit the amount
equivalent to the value of the bill earlier discounted, to the overseas bank / agency
which had discounted the bill, without the prior approval of the Reserve Bank.
G.6
Restoration of limits and availability of export benefits such as EEFC
Account
361. As stated in paragraph 355 of these Directions, ‘without recourse’ facility may
not generally be available. Thus, the restoration of exporter’s limits and the
availability of export benefits, such as credit to EEFC accounts, in case of ‘with
recourse’ facility, shall be effected only on realisation of export proceeds and not
on the date of discounting / rediscounting of the bills, However, if the bills are
rediscounted ‘without recourse’, the restoration of exporter’s limits and availability
of export benefits shall be given effect immediately on rediscounting.


G.7
ECGC cover
362. In the case of export bills rediscounted ‘with recourse’, there shall not be any
change in the existing system of coverage provided by ECGC Ltd as the liability of
the exporter continues till the relative bill is retired / paid. In other cases, where the
bills are rediscounted ‘without recourse’, the liability of ECGC ceases as soon as
the relative bills are rediscounted.
G.8
Export credit performance
363. Only the bills rediscounted abroad ‘with recourse’ basis and outstanding shall
be taken into account for the purpose of export credit performance. The bills
rediscounted abroad ‘without recourse’ shall not count for the export credit
performance.
364. Bills rediscounted ‘with recourse’ in the domestic market could get reflected
only in the case of the first bank discounting the bills as that bank alone will have
recourse to the exporter and the bank rediscounting shall not reckon the amount
as export credit.
H. Gold Card Scheme for exporters
365. The bank shall lay down the criteria for issuing Gold Cards under the scheme
to creditworthy exporters having good track record, including those in MSME
sector. The bank shall clearly specify the benefits it shall be offering to Gold Card
holders, based on the following salient features of the scheme.
366. All creditworthy exporters, including those in small and medium sectors, with
good track record shall be eligible for issue of Gold Card by the bank as per the
criteria laid down by it.
367. The scheme shall not be applicable for exporters placed in Specific Approval
List (SAL) by ECGC or having overdue bills in excess of 10 per cent of the previous
year’s turnover.
368. Gold Card holder exporters, depending on their track record and credit
worthiness, shall be granted better terms of credit including rates of interest than
those extended to other exporters by the bank.
369. Applications for credit shall be processed at norms simpler and under a process
faster than for other exporters.


370. The bank shall clearly specify the benefits it shall be offering to Gold Card
holders.
371. The charges schedule and fee-structure in respect of services provided by the
bank to exporters under the Scheme shall be relatively lower than those provided
to other exporters.
372. The sanction and renewal of the limits under the Scheme shall be based on a
simplified procedure to be decided by the bank. Taking into account the anticipated
export turnover and track record of the exporter the bank shall determine need-
based finance with a liberal approach.
373. 'In-principle' limits shall be sanctioned for a period of three years with a
provision for automatic renewal subject to fulfilment of the terms and conditions of
sanction.
374. A stand-by limit of not less than 20 per cent of the assessed limit shall be
additionally made available to facilitate urgent credit needs for executing sudden
orders. In the case of exporters of seasonal commodities, the peak and off-peak
levels shall be appropriately specified.
375. In case of unanticipated export orders, norms for inventory shall be relaxed,
taking into account the size and nature of the export order.
376. Requests from card holders shall be processed quickly by the bank within 25
days / 15 days and seven days for fresh applications / renewal of limits and ad hoc
limits, respectively.
377. Gold Card holders shall be given preference in the matter of granting of packing
credit in foreign currency.
378. The bank may consider waiver of collaterals and exemption from the ECGC’s
ECIB schemes on the basis of card holder's creditworthiness and track record.
379. The facility of further value addition to their cards through supplementary
services like ATM, Internet banking, international debit / credit cards may be
decided by the issuing bank.
380. The applicable rate of interest to be charged under the Gold Card Scheme shall
not be more than the general rate for export credit in the respective bank. In
keeping with the spirit of the Scheme, the bank shall endeavour to provide the best


rates possible to Gold Card holders on the basis of their rating and past
performance.
381. Gold Card holders, on the basis of their track record of timely realization of
export bills, shall be considered for issuance of foreign currency credit cards for
meeting urgent payment obligations, etc.
382. The bank shall ensure that the PCFC requirements of the Gold Card holders
are met by giving them priority over non-export borrowers with regard to granting
loans out of their FCNR(B) funds, etc.
383. The bank shall consider granting term loans in foreign currency in deserving
cases out of their FCNR(B), RFC, etc. funds (other than from their overseas
borrowing limits prescribed by FED, RBI).
384.  The instructions relating to the Gold Card Scheme for Exporters shall be strictly
implemented and the branch level functionaries suitably sensitised in this regard.
Further, the bank shall also provide adequate publicity to the Scheme for the
benefit of exporters.
I.
'On line' credit to exporters
385. Banks provide 'Line of Credit' normally for one year which is reviewed annually.
In case of delay in renewal, the sanctioned limits shall be allowed to continue
uninterrupted and urgent requirements of exporters shall be met on ad hoc basis.
386. In case of established exporters having satisfactory track record, the bank shall
consider sanctioning a 'Line of Credit' for a longer period, say, three years, with in-
built flexibility to step-up / step-down the quantum of limits within the overall
assessed outer limits. The step-up limits will become operative on attainment of
pre-determined performance parameters by the exporters. The bank shall obtain
security documents covering the outer limit sanctioned to the exporters for such
longer period.
387. In case of export of seasonal commodities, agro-based products, etc., the bank
shall sanction Peak / Non-peak credit facilities to exporters.
388. The bank shall permit interchangeability of pre-shipment and post- shipment
credit limits.


389. Assessment of export credit limits shall be 'need based' and not directly linked
to the availability of collateral security. As long as the requirement of credit limit is
justified on the basis of the exporter's performance and track record, the credit
shall not be denied merely on the grounds of non-availability of collateral security.
J. Other Provisions
390. Waiver of submission of orders or LCs for availing pre-shipment credit
The bank shall waive, ab initio, submission of order / LC in respect of exporters
with good track record and put in place the system of obtaining periodical
statement of outstanding orders / LCs on hand. The same shall be incorporated in
the sanction proposals as well as in the sanction letters issued to exporters and
appropriately brought to the notice of ECGC. Further, if such waivers are permitted
at a time subsequent to sanction of export credit limits with the approval of the
appropriate authority, the same shall be incorporated in the terms of sanction by
way of amendments and communicated to ECGC.
391. Fast track clearance of export credit
Where feasible, the bank shall set up a 'Credit Committee' at specialized branches
and at administrative offices, for sanctioning working capital facilities to exporters.
The 'Credit Committee' shall have sufficiently higher sanctioning powers.
392. Pre-shipment
credit
to
Diamond
Exporters
-
Conflict
Diamonds -
Implementation of Kimberley Process Certification Scheme (KPCS)
India, among other countries, has adopted a UN mandated new Kimberley
Process Certification Scheme to ensure that no rough diamonds mined and
illegally traded enter the country. Therefore, import of diamonds into India shall be
accompanied by Kimberley Process Certificate (KPC). Similarly, exports from India
shall also be accompanied by the KPC to the effect that no conflict / rough
diamonds have been used in the process. The KPCs shall be verified / validated
in the case of imports / exports by the Gem and Jewellery Export Promotion
Council. In order to ensure the implementation of Kimberley Process Certification
Scheme, the bank shall obtain an undertaking in the format given in Annex - III
from such of the clients who have been extended credit for doing any business
relating to diamonds.


393. Consortium Finance – Sanction of Credit
In the case of consortium finance, once the consortium has approved the
assessment, member banks shall simultaneously initiate their respective sanction
processes.
394. Credit Monitoring Arrangement - Export Credit
(1) The bank shall ensure that the credit requirements of the export sector are
promptly met and, additional credit needs of exporters for implementing export
orders, shall be met in full even if sanction of such additional credit exceeds
MPBF.
(2)  The bank shall take certain steps to ensure timely flow of need-based credit to
their exporter-clients as also to inform us the action taken in this regard besides
monitoring the flow of credit to the export sector as also performance of such
exporter-clients.
(3) The bank shall reach a certain minimum level of export credit, viz., equivalent
to ten per cent of each bank's net credit. Strict enforcement of this may please
be ensured.
(4)  The bank shall ensure that there is a system of monitoring the flow of export
credit as also whether the export credit disbursement is in tune with the export
performance of your exporter-borrowers.
395. Compliance of Foreign Exchange Management Act, 1999
The bank shall adhere to the directions issued under Foreign Exchange
Management Act, 1999 as amended from time to time.
K. Special Measures
396. Trade Relief Measures
To mitigate the burden of debt servicing brought about by trade disruptions caused
by global headwinds and to ensure the continuity of viable businesses, banks
extending export credit finance may provide relief measures to eligible borrowers,
as specified under Reserve Bank of India (Trade Relief Measures) Directions,
2025 dated November 14, 2025. The Directions inter alia include a defined sunset
clause for the measures.


Chapter XVI - Non-Fund Based (NFB) Credit Facilities
Background: Non-fund based (NFB) facilities like guarantees, letters of credit, co-
acceptances etc. facilitate effective credit intermediation and smooth business
transactions. In order to harmonize and consolidate guidelines covering these
facilities and to broaden the funding sources for infrastructure financing, the Reserve
Bank had issued the following guidelines on NFB facilities.
397. Within this Chapter, the term Regulated Entity (RE) or Regulated Entities (REs)
shall refer to:
(1) Commercial Banks (including Regional Rural Banks and Local Area Banks).
(2) Primary (Urban) Co-operative Banks (UCBs) / State Co-operative Banks
(StCBs) / Central Co-operative Banks (CCBs).
(3) All India Financial Institutions (AIFIs).
398. The Directions in this Chapter shall not apply to the derivative exposures of the
bank, other than the general conditions as laid down in this Chapter.
399.
29[*****]
A. General Conditions
400. The credit policy of the bank shall incorporate suitable provisions for issue of
NFB facilities, inter alia, covering aspects relating to type of NFB facilities, limits
granted, credit appraisal, security requirement, fraud prevention, overall
monitoring mechanism including post-sanction monitoring, delegation matrix, audit
and internal controls, compliance to uniform standards issued by standard setting
bodies and other safeguards.
401. The bank shall issue a NFB facility only on behalf of a customer having funded
credit facility from the bank.
Provided that this clause shall not be applicable in respect of:
(1) Derivative contracts entered into by the bank with counterparty.
(2) Partial Credit enhancement facility, as permitted under this Chapter.

29 Deleted with effect from April 1, 2026


(3) NFB facilities issued based on the counter guarantee of another RE, as
permitted under this Chapter.
(4) NFB facilities on behalf of an obligor who has not availed any fund based
facility from any RE in India.
(5) NFB facilities extended by the bank against No Objection Certificate issued by
the RE / REs which has / have provided fund based facility to the obligor.
(6) NFB facilities which are fully secured by eligible financial collateral.
Explanation: The eligible financial collateral specified herein shall be as defined
under Reserve Bank of India (Commercial Banks – Prudential Norms on
Capital Adequacy) Directions, 2025.
402. The bank shall not issue a NFB facility to any entity assuring redemption /
repayment of funds raised by any entity via deposits, issuance of bonds, or in any
other form, unless specifically permitted under any regulatory guidelines /
directions issued by the Reserve Bank.
403. Once a NFB facility devolves and is converted into a fund based facility, then the
prudential norms shall be as applicable to fund based facilities.
B. Guarantees
404. In general, a guarantee (or a counter-guarantee) issued by the bank (guarantor)
shall be irrevocable (i.e., there shall be no clause in the contract that would allow
the guarantor to unilaterally cancel the same), unconditional (i.e. there shall be no
clause in the contract that could prevent the bank from being obliged to pay out in a
timely manner in the event that the original counterparty fails to meet its obligation),
incontrovertible and shall contain a clear mechanism for honouring the same
without demur as and when invoked.
405. The bank shall put in place suitable internal aggregate / individual ceilings for
issuance of guarantees in general and unsecured guarantees in particular.
406. The provisions of the internal policy relating to guarantees shall, inter alia,
address aspects related to invocation and settlement mechanism, claim period,
tenor, fee / commission / applicable charges, timelines for release of security,
renewal, fraud prevention measures etc.


407. A bank shall honour the guarantee issued by it as and when invoked in
accordance with the terms and conditions of the guarantee deed unless there is a
court order restraining the same.
C. Usage of electronic-Guarantee
408. Wherever a bank issues an electronic Guarantee, it shall frame a standard
operating procedure (SOP) aimed at minimization of manual intervention; meeting
system integration requirements; ensuring technological compatibility between the
bank’s interface and the electronic Guarantee platforms, audit and internal controls
etc. The SOP shall, inter alia, consider the aspects mentioned at paragraphs 409
to 413 of these Directions.
409. Policy and SOP for issuance of electronic Guarantees
(1) The bank shall have suitable enabling provisions in its credit policy which shall,
inter alia, envisage the adoption of electronic Guarantees, the risk controls to
be put in place, delegation of authority, the monitoring process, etc.
(2) The bank shall put in place appropriate SOPs for user reference, detailing all
the steps to be followed during the entire electronic Guarantee lifecycle.
Electronic Guarantees shall not be issued without ensuring that the underlying
transaction has been duly reflected in the Core Banking System (CBS)/ Trade
Finance System (TFS).
410. Integration of the systems with regard to issuance of electronic Guarantees
(1) The bank shall have a strong control environment covering the policies,
processes and systems; sound internal controls; and appropriate risk
mitigation strategies for all operations pertaining to electronic Guarantees.
(2) The bank shall ensure that all features relating to the entire lifecycle events of
electronic Guarantees such as issuance, amendment, invocation, cancellation
etc. shall be available on its platform through suitable integration with the
electronic Guarantee service provider.
(3) The CBS / TFS shall be integrated with the APIs and other related messaging
platforms offered by the electronic Guarantee service provider, in Straight
Through Processing (STP) mode, without any manual intervention.
411. User Roles for issuance of electronic Guarantees


(1) The bank shall have an efficient system of ‘Maker, Checker and Authorizer’ for
issuance and monitoring of electronic Guarantees, while ensuring strict access
control and an effective segregation of the role and accountability.
(2) No role involved in electronic Guarantee issuance lifecycle shall violate
principle of segregation of duties, four / six eye principle and no employee shall
be allocated roles / privileges across systems, applications that are conflicting
in nature or in violation of four/ six eye principle.
(3) The system access shall be provided only to specified users, and access
through generic user IDs shall not be permitted. User review shall be
continuous, at defined periodicity and identifiable at any point of time with
respective rights and privileges. The user privileges shall be decided on "need
to know/ need to do" basis.
412. Control Measures for issuance of electronic Guarantees
(1) The bank shall have in place a system of periodical review and reconciliation
of all the electronic Guarantees issued / modified / cancelled, during the
specified period.
(2) The issuance of electronic Guarantees shall be mandatorily covered within the
scope of concurrent audit and RBIA of the bank.
413. Other aspects pertaining to issuance of electronic Guarantees
(1) The robustness of the electronic Guarantee systems shall be part of the
Vulnerability Assessment / Penetration Testing (VA / PT), Information Systems
Audit.
(2) Dependence on the vendors for day-to-day transactions shall be avoided.
Access to production systems shall be provided to vendors only in a controlled
environment, and audit trail shall be maintained.
(3)  Security Incident and Event Management (SIEM) tool shall be integrated with
the concerned servers and consoles / PCs connected to electronic Guarantee
related critical systems directly in its VLAN to generate automatic alerts.
(4)  The bank shall integrate electronic Guarantee systems with Privileged User
Management Systems / Identity and Access Management systems. The logs of
the same shall be monitored through Security Operation Centre (SOC) setup.


(5) Business Continuity Measures and contingency plans for system failures, shall
be put in place by the bank.
D. Guarantee favouring another RE
414. The bank shall not provide a guarantee favouring another RE to enable it to
provide any fund based credit facility to an obligor, unless specifically permitted by
RBI.
Provided that this clause shall not be applicable in case of credit facilities extended
against guarantees pertaining to trade related transactions.
415. However, the bank may provide a guarantee favouring another RE for a NFB
facility extended by the latter. Such guarantee issued by a RE shall be treated as
an exposure on the obligor on whose behalf the guarantee has been issued by it,
for all purposes including for the calculation of capital adequacy. The exposure of
the RE extending credit facility against a guarantee shall be treated as a claim /
exposure on the RE which is providing the counter guarantee.
E. Co-acceptances
416. Only genuine trade bills shall be co-accepted, and it shall be ensured that the
goods covered by bills co-accepted are actually received in the stock accounts of
the borrowers.
417. Proper records of the bills co-accepted for each customer shall be maintained,
so that the commitments for each customer and the total commitments at a branch
can be readily ascertained, and these shall be part of internal audit.
418. The bank shall not co-accept bills drawn by another lender or where the buyer
/ seller has received funding for the underlying trade transaction from any lender.
F. Guarantee and related business involving overseas current or capital
account transaction
419. Banks permitted as Authorized Dealer (AD) may extend NFB facilities as
permitted under the extant regulations / Directions issued under Foreign Exchange
Management Act, 1999, for bonafide current or capital account transaction,
including guarantees in respect of debt or other liability incurred by an exporter on
account of exports from India.


420. AD banks are also permitted to issue guarantee to or on behalf of a foreign
entity, or any of its step-down subsidiary in which an Indian entity has acquired
control through the foreign entity, which is backed by a counter-guarantee or
collateral by the Indian entity or its group company.
Provided that such guarantees shall not be issued by banks, including overseas
branches/ subsidiaries of Indian banks, for the purpose of raising loans/ advances
of any kind by the foreign entity except in connection with the ordinary course of
business overseas. Further while extending such guarantees, banks shall ensure
effective monitoring of the end use of such facilities and its conformity with the
business needs of such entities.
G. Guarantees on behalf of Stock / Commodity Brokers
421. Only Scheduled Commercial Banks (SCBs) may issue guarantees on behalf of
stock/ commodity brokers in favour of stock/ commodity exchanges in lieu of
security deposit to the extent it is acceptable in the form of bank guarantee as laid
down by exchanges. SCBs may also issue guarantees in lieu of margin
requirements as per exchange regulations read along with other instructions
issued by Reserve Bank in this regard from time to time.
H. Partial Credit Enhancement – Salient Features
422. The bank may provide Partial Credit Enhancement (PCE) to bonds issued by
corporates / special purpose vehicles (SPVs) for funding all types of projects and
to bonds issued by Non-deposit taking NBFCs with asset size of ₹1,000 crore and
above registered with RBI (including HFCs). PCE may also be provided to bonds
issued by Municipal Corporations subject to adherence to, inter alia, paragraph 134
of these Directions. The objective behind allowing banks to extend PCE is to enhance
the credit rating of the bonds issued so as to enable corporates to access the funds
from the bond market on better terms.
423. The credit policy of the bank shall incorporate suitable provisions for issue of
PCE, covering issues such as quantum of PCE, underwriting standards,
assessment of risk, pricing, setting limits, etc.
424. PCE shall be a subordinated facility provided in the form of an irrevocable
contingent line of credit which will be drawn in case of shortfall in cash flows for
servicing the bonds and thereby may improve the credit rating of the bond issue.


The contingent facility may, at the discretion of the PCE providing bank, be made
available as a revolving facility.
425. A clear agreement documenting all aspects of this arrangement shall be signed
between the promoter (bond issuer), the PCE providing bank, the bondholders
(through the Trustee) and all other lenders to the project. The agreement to this
effect shall be in the nature of a legally binding contract. The documentation for the
facility shall clearly define the circumstances under which the facility would be
drawn upon.
426. The PCE exposure limit by a single bank shall be 50 per cent of the bond issue
size. The aggregate exposure limit of all PCE providers towards the PCE for a given
bond issue has also been capped at 50 per cent of the bond issue size.
427. The PCE facility shall be provided at the time of the bond issue and shall be
irrevocable. PCE cannot be provided by way of guarantee.
428. As the purpose of PCE by bank is to enable wide investor participation in the
corporate bond market, bank shall not invest in corporate bonds which are credit
enhanced by any RE of the Reserve Bank. They may, however, provide other need
based credit facilities (funded and / or non-funded) to the corporate / SPV.
429. Bank may offer PCE only in respect of bonds whose pre-enhanced rating are
not lower than “BBB” minus as issued by accredited External Credit Assessment
Institutions (ECAI).
430. To be eligible for PCE, corporate bonds shall be rated by a minimum of two ECAI
at all times.
431. The rating reports, both initial and subsequent, shall disclose both standalone
credit rating (i.e., rating without taking into account the effect of PCE) as well as the
enhanced credit rating (taking into account the effect of PCE).
432. So long as the exposure of the bank to a project loan is classified as standard
and the borrower is not in any financial distress (Refer to Reserve Bank of India
(Commercial Banks – Resolution of Stressed Assets) Directions, 2025 for
indicative list of signs of financial difficulty), providing a commercially priced PCE
to enhance the rating of a bond issue, whose proceeds replace, in whole or in part,
the bank’s project loan, would not amount to restructuring.


433. The PCE shall be available only for servicing the bond and not for any other
purpose (such as funding acquisition of additional assets by the corporate, meeting
part of the project cost or meeting recurring expenses of the corporate or servicing
other lenders / creditors to the project etc.), irrespective of the seniority of claims
of other creditors in relation to the bond holders.
434. In case the PCE facility is partly drawn and interest accrues on the same, the
unpaid accrued interest shall be excluded from the calculation of the remaining
amount available for drawing.
435. In a waterfall mechanism, Credit Enhancement (CE) gets drawn only in a
contingent situation of cash flow shortfall for servicing a debt / bond etc., and not in
the normal course of business. Hence, such an event is indicative of financial
distress of the project. Keeping this aspect in view, a drawn tranche of the
contingent PCE facility shall be required to be repaid within 30 days from the date
of its drawal (due date). The facility shall be treated as NPA if it remains
outstanding for 90 days or more from the due date and provided for as per the
usual asset classification and provisioning norms. In that event, the bank’s other
facilities to the borrower shall also be classified as NPA as per extant guidelines.
436. The PCE providing bank shall observe the following exposure limits:
(1) PCE exposure by the bank to a single counterparty or group of counterparties
shall be within the overall regulatory exposure limits applicable to the bank.
(2) The aggregate PCE exposure of the bank shall not exceed 20 per cent of its Tier
1 capital.
I.
Additional conditions for providing PCE to bonds of NBFCs and HFCs
437. The tenor of the bond issued by NBFCs / HFCs for which PCE is provided shall
not be less than three years.
438. The proceeds from the bonds backed by PCE from banks shall only be utilized
for refinancing the existing debt of the NBFCs / HFCs. The bank shall introduce
appropriate mechanisms to monitor and ensure that the end-use condition is met.
439. The exposure of a bank by way of PCEs to bonds issued by each such NBFC
/ HFC shall be restricted to one per cent of capital funds of the RE within the extant
single / group borrower exposure limits.


J. Other Aspects of PCE
440. The effect of the PCE on the bond rating shall be disclosed in the bond offer
document i.e., the rating of the bond without and with the PCE shall be disclosed.
441. The bank shall ensure that the project assets, created out of the bond issue for
which PCE has been provided by them, and the cash flows from the project are
ring fenced through an escrow account mechanism administered under a bond
trustee arrangement. The manner in which security interest in the project assets
would be shared by the lenders to the project, bond holders and banks providing
the PCE and the manner in which the project cash flows would be shared for
servicing loans, if any, and the bonds and PCE, shall be decided and agreed upon
before the issue of bonds and shall be properly documented.
442. The project shall have a robust and viable financial structure even before the
credit enhancement is taken into account. Nevertheless, while providing PCE, the
bank shall exercise necessary due diligence and credit appraisal, including making
their own internal credit analysis/ rating.
443. The bank shall honour the full PCE commitment irrespective of the asset
classification of the concerned borrower’s credit facilities.
444. All extant regulatory prescriptions for credit and investment exposures by the
banks, unless specified otherwise in this Chapter, shall continue to apply.
445. For disclosure of the details of NFB credit facilities, the bank shall be guided
by Reserve Bank of India (Commercial Banks – Financial Statements:
Presentation and Disclosures) Directions, 2025.
446. The Directions in this Chapter have been issued without prejudice to Directions
under Foreign Exchange Management Act (FEMA), 1999; Foreign Exchange
Management (Guarantees) Regulations, 2000, notified vide Notification No. FEMA
8/2000-RB dated May 03, 2000; as amended from time to time.
447. Notwithstanding paragraph 446 above, bank shall comply with all the related
regulatory norms including Reserve Bank of India (Commercial Banks –
Concentration Risk Management) Directions, 2025.


Chapter XVII - Miscellaneous Provisions
A. Bank finance to Government owned entities
448. While extending finance to Government owned entities, banks shall specifically
ensure adherence with paragraphs 96, 134, 138 and 450 of these Directions, and
ensure that bank finance is not in lieu of or a substitute for budgetary resources
envisaged for a project, and that finance is not extended against receivables from
Governments.
B. Loans and advances to Micro, Small & Medium Enterprises (MSMEs)
449. Lending to MSMEs by the bank shall be guided by Master Direction - Lending
to Micro, Small & Medium Enterprises (MSME) Sector.
C. Bridge Loans against Receivable from Government
450. The bank shall not extend bridge loans against amounts receivable from
Central / State Governments by way of subsidies, refunds, reimbursements,
capital contributions, etc. The following exemptions are, however, made:
(1) The bank is permitted to finance subsidy receivable under current fertilizer
subsidy schemes of the Government of India that are akin to the erstwhile
Retention Price Scheme (RPS) for periods up to 60 days in case of fertilizer
industry. It is clarified that the facility is being allowed as a purely temporary
measure and the fertilizer companies should strengthen their financial position
gradually so that they do not depend on the banks for finance against subsidy.
No other subsidy receivables such as, those in respect of claims raised by units
on the basis of expected revision in retention price because of escalation in
costs of inputs and in respect of freight, etc., shall be financed by the bank.
(2) The bank may continue to grant finance against receivables from Government
by exporters (viz. Duty Draw Back and IPRS) to the extent covered by the
existing instructions.


Chapter XVIII - Repeal and other provisions
A. Repeal and saving
451. With the issue of these Directions, the existing Directions, instructions, and
guidelines relating to Credit Facilities as applicable to commercial banks stand
repealed, as communicated vide circular DOR.RRC.REC.302/33-01-010/2025-26
dated November 28, 2025. The Directions, instructions and guidelines already
repealed shall continue to remain repealed.
452. Notwithstanding such repeal, any action taken or purported to have been taken,
or initiated under the repealed Directions, instructions, or guidelines shall continue
to be governed by the provisions thereof. All approvals or acknowledgments
granted under these repealed lists shall be deemed as governed by these
Directions. Further, the repeal of these Directions, instructions, or guidelines shall
not in any way prejudicially affect:
(1) any right, obligation or liability acquired, accrued, or incurred thereunder;
(2) any, penalty, forfeiture, or punishment incurred in respect of any contravention
committed thereunder;
(3) any investigation, legal proceeding, or remedy in respect of any such right,
privilege, obligation, liability, penalty, forfeiture, or punishment as aforesaid;
and any such investigation, legal proceedings or remedy may be instituted,
continued, or enforced and any such penalty, forfeiture or punishment may be
imposed as if those directions, instructions, or guidelines had not been
repealed.
B. Application of other laws not barred
453. The provisions of these Directions shall be in addition to, and not in derogation
of the provisions of any other laws, rules, regulations, or directions, for the time
being in force.
C. Interpretations
454. For the purpose of giving effect to the provisions of these Directions or in order
to remove any difficulties in the application or interpretation of the provisions of
these Directions, the RBI may, if it considers necessary, issue necessary