Who is the regulatory authority in India?

In India, the supervision of compliance with the Prevention of Money Laundering Act (PMLA) by Virtual Asset Service Providers (VASPs) is carried out by the Financial Intelligence Unit-India (FIU-IND). The FIU-IND operates under the Department of Revenue in the Ministry of Finance. The FIU-IND ensures that VASPs comply with the reporting obligations and other requirements as stipulated under the PMLA to prevent money laundering and related financial crimes.

What is the minimum threshold for the Crypto Travel Rule in India?

No threshold applies. In India, the full scope of required information must be provided for every transaction, regardless of the amount.

What personally identifiable information must VASPs collect and share for the Crypto Travel Rule in India?

The rules establish that originator VASPs must obtain and hold originator and  beneficiary information and submit it to beneficiary VASPs immediately and securely.

The originator information that needs to be collected and transmitted is as follows:

Are there differences in customer PII requirements for cross-border transfers versus transfers within India?

No. The customer PII requirements are the same for both cross-border and domestic transfers.

What are the non-custodial or self-hosted wallet requirements in India?

The approach to self-hosted wallet transactions in India is not prescriptive. Local regulations mention that transactions with self-hosted wallets are high risk and therefore additional limitations or controls may be put in place for those transactions.

PARA. 11.2.2., P. 26

VDA transfers to / from unhosted wallets are categorised as high risk since either the originating or beneficiary wallet may not be hosted at an SP that is an obliged entity.This also covers P2P transfers where one of the wallets is not hosted.In case where the VDA transfer is between two wallets where at least one of them is a hosted wallet, the onus of compliance would be on the obliged entity where the wallet is hosted.
In addition, additional limitations or controls may be put in place on such transfers with unhosted wallets.

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Why choose Notabene for crypto Travel Rule Compliance in India?

Choosing Notabene for crypto Travel Rule compliance in India offers several compelling advantages, making it a leading solution for VASPs. Notabene provides a comprehensive compliance platform designed to help VASPs adhere to the FIU-IND’s implementation of the FATF crypto Travel Rule.

Key features include:

• Automated real-time decision-making
• VASP due diligence
• Counterparty sanctions screening
• Identification of self-hosted wallets
• Seamless rollout of Travel Rule compliance in line with global and local regulations

Notabene’s SafeTransact, the only pre-transaction decision-making platform in the crypto industry, allows VASPs to identify and stop illicit activities before they occur, enhancing security and compliance. This robust system ensures that VASPs can operate confidently within the regulatory framework, minimizing risks and maintaining trust with regulators and customers alike.

By choosing Notabene, VASPs in India can ensure comprehensive compliance, robust security measures, and efficient transaction processing.