D1 Sanctions
Sanctions is not yet covered for this jurisdiction in this report.
Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.
India's AML/CFT regime rests on the Prevention of Money Laundering Act 2002 (PMLA) and the Unlawful Activities (Prevention) Act 1967, supervised by FIU-IND, RBI, SEBI and the Enforcement Directorate.
Sanctions is not yet covered for this jurisdiction in this report.
Beneficial Ownership is not yet covered for this jurisdiction in this report.
Enabler Jurisdictions is not yet covered for this jurisdiction in this report.
Conflict Finance is not yet covered for this jurisdiction in this report.
India's virtual-asset AML architecture tightened materially this cycle. FIU-IND imposed a penalty of INR 9.27 crore on Bybit Fintech Limited on 31 January 2025 for operating as a Virtual Digital Asset Service Provider without the mandatory FIU-IND registration that has been in force under the Prevention of Money Laundering Act's reporting-entity framework since March 2023. The action was compounded by coordinated website blocking, executed via MeitY under the Information Technology Act, 2000, that removed Bybit's access to Indian users pending registration compliance; Bybit subsequently registered and resumed operations. Read architecturally rather than as an isolated incident, this sequence confirms that FIU-IND registration operates as a functional substitute for a licensing statute India has not enacted: an unregistered virtual-asset service provider faces both a financial penalty and a coordinated technical-access denial, a two-pronged enforcement mechanism combining a financial regulator's punitive power with an internet-infrastructure regulator's blocking power.
The reach of this mechanism now extends beyond domestically incorporated platforms. Secondary reporting indicates that FIU-IND issued show-cause notices in October 2025 to approximately 25 offshore virtual digital asset exchanges — BingX, LBank, CoinW, CEX.IO and Poloniex among them — for serving Indian users without registration. This is the extraterritorial application of the same registration-gate logic used domestically against Bybit, and it signals that FIU-IND does not treat offshore incorporation as a barrier to its enforcement reach. The registered reporting-entity count is reported to have grown from 49 as of FY2024-25 to approximately 54 by mid-2026, though the precise current figure remains contested between sources and should be treated as an approximate range pending reconciliation.
This enforcement architecture sits against a backdrop of standing baseline facts: India's VASP AML gate operates via FIU-IND registration rather than a dedicated licensing statute, and India itself remains outside both the FATF grey list and black list as of the June 2026 Plenary, sitting in the regular follow-up category from its most recent Mutual Evaluation. The three-pillar balance principle is worth applying here: this cycle's signal is overwhelmingly AML-registration enforcement, with no CTF- or CPF-specific development identified for India in the claims available. That is itself worth noting rather than treating as a gap in coverage — the absence of a CTF-specific signal in a cycle otherwise rich in AML enforcement activity is a data point about where India's current enforcement emphasis sits, not an omission by this brief.
Watch for resolution of the roughly 25 offshore show-cause notices issued in October 2025: whether named exchanges register and resume operation, following the pattern Bybit set, or exit the Indian market instead, will be the clearest near-term signal of how this extraterritorial enforcement campaign concludes. The unresolved discrepancy in the registered-VASP count between approximately 49 and approximately 54 is a reconciliation worth monitoring. No change to India's FATF standing is anticipated absent a material shift in its Mutual Evaluation follow-up status.
Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.
AML/CTF Regime is not yet covered for this jurisdiction in this report.
Commercial Activity is not yet covered for this jurisdiction in this report.
The Bybit penalty and blocking action, and the offshore show-cause campaign, confirm that FIU-IND registration functions as a de facto operating gate for VASPs. MLROs at firms with India exposure should treat FIU-IND reporting-entity registration as a hard compliance prerequisite, not a discretionary filing.
Compliance functions overseeing VASP relationships touching India should confirm counterparty registration status against the FIU-IND registry, noting the registrant count is disputed between approximately 49 and 54 pending reconciliation.
No material change for this persona this cycle
Boards overseeing entities with Indian virtual-asset exposure should note that regulatory risk in India currently runs through AML-registration enforcement rather than a conventional licensing regime, which changes the risk-monitoring approach required.
The Bybit case demonstrates that India's enforcement mechanism against unregistered virtual-asset platforms includes technical access denial via MeitY, not solely financial penalties, which is relevant to infrastructure and access-continuity planning for platforms serving Indian users.
Risk functions should treat India's registration-gate enforcement as an escalating, not static, risk vector, given active extension to offshore exchanges via show-cause notices in October 2025.
No material change for this persona this cycle
Audit functions relying on the FIU-IND registry count for control-testing purposes should note this figure is unresolved between sources and should not be treated as a confirmed audit trail data point without further reconciliation.
FIU-IND penalised and blocked an unregistered VASP and extended show-cause enforcement to roughly 25 offshore exchanges this cycle.
India's VASP reporting-entity framework tightened via active enforcement against unregistered domestic and offshore platforms.
No material change this cycle.
India's crypto AML enforcement architecture is escalating without a parallel licensing statute.
FIU-IND paired a financial penalty with coordinated website blocking against an unregistered VASP.
Extraterritorial enforcement against offshore VASPs signals expanding regulatory reach without new legislation.
No material change this cycle.
Registered-VASP count for India is disputed between approximately 49 and 54 registrants.
As an illustrative orientation only: the EU's move from purely national AML supervision toward AMLA direct and indirect supervision of cross-border obliged entities, under the AMLA Regulation (Reg (EU) 2024/1620) alongside the directly-applicable AMLR (Reg (EU) 2024/1624) and per-state 6AMLD transposition, could in principle reshape how EU-domiciled virtual-asset platforms approach registration obligations in non-EEA jurisdictions such as India. A platform accustomed to a harmonising EU-level supervisor might, illustratively, treat a jurisdiction-specific registration gate like FIU-IND's as a lower-priority compliance item relative to its EU-level obligations, creating a possible divergence-driven blind spot. This is architecture-over-incident illustrative framing only, not a prediction and not an observed fact about any specific platform's conduct.
Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.
| Tracker | Status | Note |
|---|---|---|
| T1 · Russian Sanctions-Evasion Architecture | no_change | No India-specific material this cycle. |
| T2 · EU AML Package / AMLA | no_change | Not applicable to India. |
| T3 · FATF Grey List | no_change | India remains in regular follow-up category; progress report due October 2027. |
| T4 · Beneficial-Ownership Register Status | no_change | No India-specific development this cycle. |
| T5 · Crypto & Digital-Asset Integrity | escalating | FIU-IND's Sept 2026 notices to 15 offshore VDASPs continue the enforcement trajectory begun Dec 2023. |
| T6 · Sanctions Regime Divergence | no_change | No India-specific material this cycle. |