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title: "India (IN) — Financial-Integrity Intelligence · Sentinel"
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description: "Financial integrity intelligence for India (IN): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings."
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# India (IN) — Financial-Integrity Intelligence · Sentinel

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 &ldquo;Probable&rdquo; until stronger sources are retrieved.

Financial Integrity Monitor

# India IN

Domains covered

8 of 8

Sources

200

Role actions

8

Horizon <90d

0

Jurisdiction profile

FATF status: Largely Compliant Tier: A Risk direction: Increasing Enablement vs enforcement: Mixed

India&#x27;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. More FATF&#x27;s 2024 MER found strong technical compliance and good results on risk understanding, asset deprivation and international cooperation, but flagged prosecution delays, thin DNFBP supervision and an early-stage VASP regime.

Key deficiencies

- DNFBP sectors (real estate, DPMS, lawyers, accountants) largely unsupervised for AML/CFT outside Goa casinos
- Backlog and delay in concluding ML and TF prosecutions and convictions
- Risk-based, non-punitive engagement with the non-profit sector on TF risk not yet implemented
- MCA beneficial ownership registry monitoring and data-accuracy gaps
- VASP/DNFBP AML/CFT implementation still in early stages

Recent developments (18m)

- FATF/APG/EAG Mutual Evaluation Report of India adopted June 2024, published 19 September 2024
- EU 18th sanctions package designated India&#x27;s Nayara Energy (Rosneft 49.13% stake) in July 2025
- US imposed then rescinded a 25% secondary tariff (stacking to 50% total) on Indian goods over Russian oil purchases (Aug 2025-Feb 2026)
- Indian Coast Guard&#x27;s first seizure of three suspected dark-fleet tankers off Mumbai, February 2026
- Gautam Adani/Adani Group settled US DOJ bribery charges, SEC civil fraud suit and an OFAC Iran-sanctions probe for a combined ~$300 million, May 2026
- Record-scale &#x27;digital arrest&#x27; cyber-fraud wave (₹19bn/$212m in 2024) laundered via Tether P2P crypto conversion
- India&#x27;s Vivek Aggarwal selected as incoming FATF Vice-President (term July 2026-June 2027), June 2026 plenary

Brief

## Lead signal

#### Lead Signal

India&#x27;s sanctions-architecture posture this cycle is one of procedural continuity rather than structural change. The Financial Action Task Force closed its October 2026 Plenary in Paris on 30 October 2026 with India remaining off both the grey and black lists, a status that has held since India&#x27;s 2010 accession. India&#x27;s own push to have Pakistan re-listed did not succeed in this round, a diplomatic data point that sits alongside, rather than inside, India&#x27;s own compliance standing. Domestically, the Reserve Bank of India continued its routine implementation of United Nations Security Council sanctions-list maintenance: Circular RBI/2026-27/296 of 19 October 2026 communicated amendments to three entries on the ISIL (Da&#x27;esh) and Al-Qaida Sanctions List under Section 51A of the Unlawful Activities (Prevention) Act, and a follow-on circular numbered 297 of 2026, dated 23 October 2026, recorded the removal of seven entities from the same list. Neither action reflects a new designation episode inside India; both are the mechanical transmission of UNSC list changes into the domestic banking sector&#x27;s screening obligations.

Read full brief

#### Lead Signal

India&#x27;s sanctions-architecture posture this cycle is one of procedural continuity rather than structural change. The Financial Action Task Force closed its October 2026 Plenary in Paris on 30 October 2026 with India remaining off both the grey and black lists, a status that has held since India&#x27;s 2010 accession. India&#x27;s own push to have Pakistan re-listed did not succeed in this round, a diplomatic data point that sits alongside, rather than inside, India&#x27;s own compliance standing. Domestically, the Reserve Bank of India continued its routine implementation of United Nations Security Council sanctions-list maintenance: Circular RBI/2026-27/296 of 19 October 2026 communicated amendments to three entries on the ISIL (Da&#x27;esh) and Al-Qaida Sanctions List under Section 51A of the Unlawful Activities (Prevention) Act, and a follow-on circular numbered 297 of 2026, dated 23 October 2026, recorded the removal of seven entities from the same list. Neither action reflects a new designation episode inside India; both are the mechanical transmission of UNSC list changes into the domestic banking sector&#x27;s screening obligations.

The analytical significance lies in the architecture, not the incident. India&#x27;s sanctions-screening pipeline, running from UNSC list change to RBI circular to reporting-entity action, functioned on schedule and without evident friction this cycle. That is itself a finding: a functioning transmission mechanism is as material to assessing sanctions-evasion exposure as a breakdown would be, because it is the absence of friction that determines whether a jurisdiction&#x27;s screening regime can be relied upon by correspondent counterparties.

#### Other Developments

Grey-list diplomacy produced no change to India&#x27;s own rating. The October Plenary outcome leaves India&#x27;s FATF standing exactly where it was; the attempted re-listing push against Pakistan is a geopolitical signal about India&#x27;s use of the FATF process rather than a finding about India&#x27;s own anti-money-laundering or counter-terrorist-financing framework.

Routine UNSC list maintenance proceeded via two sequential RBI circulars. The 19 October circular addressed amendments to three entries; the 23 October follow-on addressed the removal of seven entities from the same ISIL/Al-Qaida list. The two-step cadence, amendment followed shortly by removal, reflects the pace at which UNSC list changes are being transmitted into the Reserve Bank&#x27;s Section 51A notification practice this cycle, with no indication of a backlog or delay in that transmission.

#### Cross-Monitor Connections

The routine sanctions-list transmission mechanism observed here is the kind of structural plumbing that other monitors rely on when assessing counterparty and correspondent-banking risk in flows touching India; a jurisdiction whose domestic screening updates track UNSC changes without lag reduces one class of exposure that conflict-finance and state-capture-focused monitors would otherwise need to flag independently. No new findings this cycle connect directly to compliance-technology, commodity-flow, or information-operations themes.

#### Outlook

Absent a new FATF plenary cycle or a fresh UNSC designation round, the near-term expectation is continuity: further routine RBI circulars transmitting UNSC list changes, and no change to India&#x27;s own grey/black-list status before the next Plenary. The more significant open question, India&#x27;s standing push on Pakistan&#x27;s FATF status, remains a diplomatic rather than a compliance-architecture matter and will be revisited at the next Plenary cycle.

Earlier periodic briefs (7) 4 Nov 2026 · fim-2026-11-04

#### Lead Signal

India&#x27;s sanctions-architecture posture is one of procedural continuity rather than structural change. The Financial Action Task Force closed its October 2026 Plenary in Paris on 30 October 2026 with India remaining off both the grey and black lists, a status that has held since India&#x27;s 2010 accession. India&#x27;s own push to have Pakistan re-listed did not succeed in this round, a diplomatic data point that sits alongside, rather than inside, India&#x27;s own compliance standing. Domestically, the Reserve Bank of India continued its routine implementation of United Nations Security Council sanctions-list maintenance: Circular RBI/2026-27/296 of 19 October 2026 communicated amendments to three entries on the ISIL (Da&#x27;esh) and Al-Qaida Sanctions List under Section 51A of the Unlawful Activities (Prevention) Act, and a follow-on circular numbered 297 of 2026, dated 23 October 2026, recorded the removal of seven entities from the same list. Neither action reflects a new designation episode inside India; both are the mechanical transmission of UNSC list changes into the domestic banking sector&#x27;s screening obligations.

The analytical significance lies in the architecture, not the incident. India&#x27;s sanctions-screening pipeline, running from UNSC list change to RBI circular to reporting-entity action, functioned on schedule and without evident friction. That is itself a finding: a functioning transmission mechanism is as material to assessing sanctions-evasion exposure as a breakdown would be, because it is the absence of friction that determines whether a jurisdiction&#x27;s screening regime can be relied upon by correspondent counterparties.

#### Other Developments

Grey-list diplomacy produced no change to India&#x27;s own rating. The October Plenary outcome leaves India&#x27;s FATF standing exactly where it was; the attempted re-listing push against Pakistan is a geopolitical signal about India&#x27;s use of the FATF process rather than a finding about India&#x27;s own anti-money-laundering or counter-terrorist-financing framework.

Routine UNSC list maintenance proceeded via two sequential RBI circulars. The 19 October circular addressed amendments to three entries; the 23 October follow-on addressed the removal of seven entities from the same ISIL/Al-Qaida list. The two-step cadence, amendment followed shortly by removal, reflects the pace at which UNSC list changes are being transmitted into the Reserve Bank&#x27;s Section 51A notification practice, with no indication of a backlog or delay in that transmission.

#### Cross-Monitor Connections

The routine sanctions-list transmission mechanism observed here is the kind of structural plumbing that other monitors rely on when assessing counterparty and correspondent-banking risk in flows touching India; a jurisdiction whose domestic screening updates track UNSC changes without lag reduces one class of exposure that conflict-finance and state-capture-focused monitors would otherwise need to flag independently. No new findings connect directly to compliance-technology, commodity-flow, or information-operations themes.

#### Outlook

Absent a new FATF plenary cycle or a fresh UNSC designation round, the near-term expectation is continuity: further routine RBI circulars transmitting UNSC list changes, and no change to India&#x27;s own grey/black-list status before the next Plenary. The more significant open question, India&#x27;s standing push on Pakistan&#x27;s FATF status, remains a diplomatic rather than a compliance-architecture matter and will be revisited at the next Plenary cycle.

3 Nov 2026 · fim-2026-11-03

#### Lead Signal

India&#x27;s sanctions-architecture posture is best read as routine maintenance layered on a stable external standing. The Reserve Bank of India issued two circulars, RBI/2026-27/296 dated 19 October 2026 and a follow-on dated 23 October 2026, communicating amendments to entries on the United Nations Security Council&#x27;s ISIL (Da&#x27;esh) and Al-Qaida Sanctions List under the Section 51A framework of the Unlawful Activities (Prevention) Act. The circulars direct banks, non-banking financial companies and asset reconstruction companies to align sanctions-screening databases to the amended entries, a mechanical but structurally important act of list-maintenance that keeps India&#x27;s domestic screening infrastructure synchronised with the UN consolidated list on an ongoing basis. This sits alongside a quieter but equally relevant signal from the Financial Action Task Force&#x27;s October 2026 Plenary, concluded in Paris on 30 October 2026, at which four jurisdictions were removed from the list of jurisdictions under increased monitoring and none were added. India remains off both the FATF call-for-action list and the increased-monitoring list, a position it has held continuously as a FATF member since 2010.

The juxtaposition is instructive for how the architecture of sanctions compliance actually functions day to day: the headline-grabbing plenary outcome is the removals, but the operationally significant event for Indian obliged entities is the circular traffic that follows any UNSC list amendment, however incremental. Separately, reporting around the Paris plenary noted that India had pressed for Pakistan&#x27;s return to increased monitoring; Pakistan was not relisted and remains outside the grey list, having been removed from increased monitoring in October 2022. That diplomatic push did not alter any list status and carries no compliance consequence for Indian institutions, but it is a useful marker of where India&#x27;s sanctions-related diplomatic energy is currently directed.

#### Other Developments

Routine list-maintenance circulars continue to be the dominant mode of sanctions-related regulatory activity. The two RBI circulars follow a now-familiar pattern: a UNSC amendment is made, India&#x27;s Ministry of External Affairs communicates it, and the RBI issues a circular directing regulated entities to update screening systems accordingly. Neither circular introduces a new obligation beyond the standing Section 51A screening duty; both are maintenance of an existing structural requirement rather than a new structural development.

India&#x27;s standing outside both the FATF call-for-action and increased-monitoring lists remains unchanged. The October 2026 Plenary&#x27;s removals (four jurisdictions, none added) leave India&#x27;s own position untouched. This is worth stating explicitly because the absence of change is itself the finding: India&#x27;s sanctions standing is not under live review at FATF level.

#### Cross-Monitor Connections

The RBI&#x27;s Section 51A screening circulars touch directly on payment-sector obligations tracked elsewhere: the same banks and non-bank financial entities subject to these sanctions-screening updates are also the regulated population for ongoing scheme and licensing developments in the payments space, since sanctions-screening databases and payment-rail onboarding controls are frequently maintained by the same compliance infrastructure within a regulated entity. A sustained pattern of UNSC list amendments flowing through RBI circulars is the kind of structural plumbing that a conflict-finance or illicit-finance reading would want to track for corridor-level implications, though no such corridor-specific finding arises from the evidence.

#### Outlook

Absent a new FATF listing action affecting India directly, the near-term trajectory here is continuation of the current pattern: periodic RBI circulars following UNSC list amendments, with India&#x27;s own standing stable. The marked FATF tracker trajectory of watch reflects the general volatility of the grey-list process at the global level (four jurisdictions moved this plenary) rather than any specific signal of change in India&#x27;s position; it is a watch on the mechanism, not a watch on India.

25 Oct 2026 · fim-2026-10-25

#### Lead Signal

India&#x27;s enforcement architecture against unlicensed online betting moved on two fronts this period, exposing the money-flow mechanics that sit underneath the countrys gambling prohibition rather than any change to the prohibition itself. The Enforcement Directorates Mumbai Zone-II unit searched twenty premises across Mumbai, Pune, Mehsana, Surat and Hyderabad on 13 October 2026, a sweep reported 18 October and conducted under the Prevention of Money Laundering Act, 2002. The probe targets alleged laundering tied to unlicensed betting platforms All Panel Exchange and MGM91, with investigators examining mule bank accounts, trade over-invoicing and cryptocurrency transfers as the specific channels used to move proceeds. Separately, and independently of the central action, Himachal Pradesh police raided a rented house in Birta, Kangra district, on 24 October 2026, detaining six individuals and seizing forty-one phones and seven laptops in connection with an illegal online gaming operation and associated mule accounts.

Read together, these two actions by a central agency and a state police force illustrate a now-familiar enabler pattern: unlicensed betting and gaming operations persist by routing proceeds through domestic banking rails via third-party or mule accounts, obscuring the trail further through trade-based mechanisms such as over-invoicing, and in at least one case extending into crypto-denominated transfers as an off-ramp. The pattern is episodic in its enforcement expression but structural in its underlying mechanics, and it sits squarely at the intersection of enabler-jurisdiction dynamics and digital-asset exposure.

#### Other Developments

Standing FATF position unchanged. India remains outside the FATF grey and black lists, with its 2024 Mutual Evaluation having placed the country in regular follow-up status on the basis of what one source characterised as comprehensive measures against money laundering, terrorist financing and proliferation financing. No development this period altered that standing assessment; it is carried forward as the backdrop against which the periods enforcement actions should be read, not as a new finding.

Crypto enforcement posture steady. The most recent dedicated digital-asset enforcement action, FIU-INDs issuance of non-compliance notices to fifteen offshore virtual-digital-asset service providers, dates to early September 2026 and remains the operative standing action; no new takedown list or Central Board of Direct Taxes crypto notification was dated within this periods window. The absence of a fresh dedicated crypto action does not indicate reduced exposure, given that the crypto dimension surfaced this period instead through its role as one laundering channel within the betting-platform probe rather than through a standalone digital-asset enforcement event.

#### Cross-Monitor Connections

The All Panel Exchange/MGM91 probe sits at a genuine three-way overlap. The underlying activity is unlicensed betting, which is the core subject of gambling-focused monitoring; the laundering mechanics under investigation, mule accounts and crypto transfers, are a payments and digital-asset exposure that a payments-focused monitor would track as a channel risk; and the proceeds-of-crime and reporting-entity dimensions under the Prevention of Money Laundering Act are the direct subject of this monitor&#x27;s own enabler-jurisdiction and AML/CTF tracking. None of these three readings displaces the others: the same facts support a gambling-regulatory reading, a payment-rail reading and a financial-integrity reading simultaneously, and each is best left to its own lens rather than collapsed into one.

#### Outlook

Watch for whether the Enforcement Directorate or the Press Information Bureau issues a primary release on the All Panel Exchange/MGM91 action; the current record rests on tier-three press reporting only, and a primary confirmation (or a formal charge-sheet) would meaningfully firm up the evidentiary basis for this finding. Equally, continued state-level actions of the Himachal Pradesh type, if they recur in other states, would begin to indicate a broader law-enforcement pattern against mule-account banking tied to illegal gaming rather than an isolated local action. On the standing architecture side, no change to India&#x27;s FATF status or its Prevention of Money Laundering Act framework is indicated at this time; any shift would be a materially larger story than either of this periods individual raids.

18 Oct 2026 · fim-2026-10-18

#### Lead Signal

The lead development is the United States decision to waive the near-term secondary-sanctions and tariff teeth of the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 as it would have applied to India. On 16 October 2026, two days before a scheduled 18 October implementation deadline, the President signed an executive order waiving sections 112 and 113 of the Act, suspending a planned 100 percent tariff on the largest buyers of Russian crude and gas, a list that includes India. The waiver rests on a presidential national-interest certification submitted to Congress, which means the suspension is a discretionary and revocable act rather than a structural repeal: the underlying sanctions architecture targeting Russian-oil-buyer counterparties remains in place and could be reactivated without new legislation.

#### Other Developments

Enforcement Directorate crypto-betting action. On 13 October 2026, the Enforcement Directorate searched twenty premises in five cities under the Prevention of Money Laundering Act, 2002, in connection with betting platforms identified as All Panel Exchange and MGM91. Investigators allege that proceeds were layered through shell firms and mule bank accounts before conversion into cryptocurrency and movement offshore, a pattern consistent with established crypto-conversion laundering typologies applied here to betting-fraud proceeds rather than a conventional predicate offence. No primary government publication was retrieved this cycle, so the finding is carried at probable rather than confirmed confidence pending corroboration.

Fintech funding and M&A concentration. India&#x27;s fintech sector raised approximately 2.2 billion dollars across the first nine months of 2026, up 14 percent on the same period in 2025, with a notable concentration pattern: a small number of mega-rounds, and a comparatively modest number of acquisitions, accounted for a disproportionate share of total capital. The period&#x27;s largest disclosed acquisition was Indiabulls Group&#x27;s 110 million dollar purchase of Fintech Cloud. This commercial pattern is presented as market-structure context rather than an integrity finding in itself, though concentration of capital and control in a small number of platforms is a factor worth tracking for beneficial-ownership and governance purposes in future cycles.

Standing AML/CTF architecture. India&#x27;s anti-money-laundering and counter-terrorist-financing regime continues to rest on the Prevention of Money Laundering Act, 2002, with the Financial Intelligence Unit-India as the designated financial intelligence unit and the Reserve Bank of India and the Securities and Exchange Board of India as principal sectoral supervisors. The FATF and Asia Pacific Group mutual evaluation found India compliant or largely compliant with 37 of the 40 FATF Recommendations, with partial compliance recorded on Recommendations 8, 12 and 28, and only moderate effectiveness on supervision and sanctions-implementation outcomes. No instrument-level change to this architecture occurred this cycle.

#### Cross-Monitor Connections

The crypto-conversion dimension of the Enforcement Directorate&#x27;s betting-platform action is directly relevant to the crypto and digital-asset surface that this FIM brief carries under its own D5 domain, and it also intersects with payment-rail and consumer-harm questions that a payments-focused reader would track independently: the same betting-platform conduct that generated laundering proceeds also depended on inducing victims to deposit funds and then denying withdrawals, a consumer-harm vector sitting outside FIM&#x27;s own remit. The sanctions-waiver development sits at the intersection of trade policy and sanctions architecture, and its implications for India&#x27;s broader trade and tariff exposure extend beyond financial-crime integrity into commercial and diplomatic territory that a dedicated trade-policy or payments monitor would be better placed to develop further.

#### Outlook

The sanctions waiver is explicitly revocable and tied to a presidential national-interest determination rather than a permanent carve-out, so the central watch item is whether the underlying tariff and secondary-sanctions provisions are reactivated, extended, or allowed to lapse as the geopolitical situation around Russian energy exports evolves. On the enforcement side, the Enforcement Directorate&#x27;s crypto-betting action remains at probable confidence pending a primary government publication; corroboration in a future cycle would allow the finding to be upgraded, while a long silence would leave it as a dated, single-episode finding rather than evidence of a broader enforcement pattern.

11 Oct 2026 · fim-2026-10-11

#### Lead Signal

India&#x27;s Financial Intelligence Unit has extended an enforcement pattern against offshore virtual digital asset platforms, issuing non-compliance notices under Section 13 of the Prevention of Money Laundering Act, 2002 to fifteen offshore VDA platforms for serving Indian customers without registering as FIU-IND reporting entities. This September 2026 wave continues a trajectory first visible in an October 2025 action against roughly twenty-five platforms, and reflects the structural reality that India has no dedicated crypto licensing regime: registration as a PMLA reporting entity is the only gateway through which an offshore exchange can lawfully serve Indian users, and non-registration is being treated as an AML violation rather than a licensing gap. The pattern is probable rather than confirmed, resting on convergent press reporting without a primary FIU-IND notice retrieved this cycle, but the architecture it describes is now well established: enforcement is substituting for licensing.

Alongside this, the Reserve Bank of India has floated a structurally distinct but thematically connected development: draft Know Your Customer Amendment Directions, 2026, which would let banks place a temporary, amount-limited debit hold of up to sixty days on transactions of one thousand rupees or more flagged by AI-based monitoring as linked to suspected mule-account or cyber-fraud activity. The proposal is at consultation stage, so no commencement date is yet binding, with an expected effective date around January 2027.

#### Other Developments

Fintech capital formation continued at scale. India&#x27;s fintech sector raised over two billion dollars in the first half of 2026, up forty-two percent year on year, led by CRED&#x27;s $900 million Series H and KreditBee&#x27;s $280 million Series E. This figure derives from a single vendor deal-data aggregator and has not been independently corroborated, so it is read as probable rather than confirmed, but the scale and the lead-deal composition point to a capital-formation environment that continues to outpace the regulatory architecture governing some of the sectors receiving that capital, particularly where fintech lending platforms intersect with the same AI-based monitoring and KYC infrastructure the RBI is now proposing to formalise.

FATF status remains unchanged. India sits in FATF&#x27;s regular follow-up category, with its last mutual evaluation in September 2024 and the next possible onsite visit not expected before November 2030. This is a stable, confirmed baseline fact drawn directly from FATF&#x27;s own assessments calendar, and it frames the enforcement activity described above: India is not operating under increased FATF monitoring, so the offshore-platform enforcement wave and the draft KYC rules reflect domestic policy choices rather than externally imposed remediation obligations.

#### Cross-Monitor Connections

The FIU-IND enforcement wave against offshore VDA platforms sits squarely at the intersection of this monitor&#x27;s AML pillar and the digital-asset regulatory perimeter tracked by the crypto-focused monitor; readers following licensing and token-classification questions there will find the same underlying enforcement action read through a different lens. The draft RBI KYC Amendment Directions likewise connect directly to payments-system consumer-protection and fraud-control tracking, since the proposed debit-hold mechanism operates through bank transaction-monitoring infrastructure rather than through AML reporting channels narrowly defined. The fintech funding data, while presented here as a commercial-activity signal, also bears on compliance-technology investment capacity across the sector, since well-capitalised platforms are typically the ones able to absorb new AI-based monitoring obligations fastest, potentially widening a compliance gap with smaller or offshore-domiciled competitors.

#### Outlook

The offshore VDA enforcement pattern is likely to continue on its current trajectory absent a change in India&#x27;s underlying licensing architecture: so long as registration with FIU-IND remains the only compliance pathway, periodic enforcement waves against unregistered platforms are a predictable recurring feature rather than a one-off event. The draft KYC Amendment Directions, if finalised as drafted, would mark a structural addition to India&#x27;s AML/CTF technology stack, introducing a standardised AI-flagging and debit-hold mechanism where current mule-account practice is fragmented across individual banks; the stated expected date of January 2027 should be treated as scheduled rather than confirmed, since the instrument remains at consultation stage. Continued strong fintech capital formation, if sustained through the second half of 2026, will likely increase the population of firms that fall within scope of both the AML registration regime and any finalised KYC amendments, raising the stakes of how clearly RBI and FIU-IND coordinate the two work streams.

28 Sep 2026 · fim-2026-09-28

#### Lead Signal

India&#x27;s financial intelligence unit has intensified enforcement of its virtual-asset AML registration gate this cycle, with FIU-IND imposing a penalty of INR 9.27 crore on Bybit Fintech Limited on 31 January 2025 for operating as an unregistered Virtual Digital Asset Service Provider under the Prevention of Money Laundering Act. The action combined a monetary penalty with coordinated website blocking executed via MeitY under the Information Technology Act, 2000, pending Bybit&#x27;s compliance; Bybit subsequently registered and resumed operations. This is architecture, not incident: it confirms that FIU-IND&#x27;s reporting-entity registration functions as India&#x27;s de facto operating gate for virtual asset service providers, substituting for a dedicated licensing statute that India has not enacted.

#### Other Developments

Offshore VASP show-cause campaign. Secondary reporting indicates FIU-IND issued show-cause notices in October 2025 to roughly 25 offshore virtual digital asset exchanges, including BingX, LBank, CoinW, CEX.IO and Poloniex, for serving Indian users without registration. The reporting-entity registry is reported to have grown from 49 registrants in FY2024-25 to approximately 54 by mid-2026, though the precise current figure is contested between sources and should be treated as an approximate range.

Standing FATF status unchanged. India 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. FATF&#x27;s June 2026 Plenary added Iraq and Bosnia and Herzegovina to, and removed Algeria and Namibia from, the list of jurisdictions under increased monitoring, but these changes do not touch India&#x27;s own standing.

#### Cross-Monitor Connections

The Bybit enforcement action and the offshore show-cause campaign are directly relevant to world-payments&#x27; coverage of payment-services regulation in India, given that VASP registration functions as an AML gate on payment-adjacent digital-asset infrastructure. The same underlying facts inform crypto&#x27;s licensing and cross-border-transfer readings of this cycle&#x27;s developments; this brief foregrounds the AML-architecture reading of those facts rather than the licensing-market reading.

#### Outlook

Expect continued FIU-IND enforcement pressure on unregistered VASPs, both domestic and offshore, as the show-cause campaign against the roughly 25 named offshore exchanges works toward resolution. The unresolved discrepancy between the approximately 49 and approximately 54 registered-provider figures is worth monitoring for an authoritative reconciliation. No change to India&#x27;s FATF standing is expected in the near term absent a material shift in its Mutual Evaluation follow-up status.

5 Sep 2026 · fim-2026-08-21

#### Lead Signal

The Enforcement Directorate&#x27;s provisional attachment order against the Mahadev Online Book network, filed 5 June 2026, newly quantifies India&#x27;s largest domestic money-laundering signal this cycle: proceeds of crime estimated at approximately INR 43,000 crore accumulated over seven years through illegal betting platforms. This is a single tier-three press account of a PMLA filing, not yet corroborated by a primary ED document, and is accordingly assessed rather than confirmed. The scale is amplified by a parallel Directorate General of GST Intelligence track, which estimates roughly INR 70,000 crore routed through approximately 750 shell companies, with GST evasion of approximately INR 19,600 crore linked to the same betting network. Read together, these two tracks evidence a domestic laundering architecture that combines opaque corporate-vehicle layering with cross-border asset flight, most visibly into approximately INR 1,700 crore of attached assets including a Burj Khalifa property connected to Mahadev promoter Sourabh Chandrakar — a claim resting on tier-four sourcing alone and treated with low confidence pending corroboration. The affected-firm-type tagging on this finding spans banks, payment companies and, via the DGGI track, cross-sector corporate structures, reflecting the breadth of the intermediary layer used to move betting proceeds through the formal financial system.

#### Other Developments

Sanctions architecture continues to fragment rather than converge. OFAC extended General Licence 131H, governing the Lukoil International GmbH wind-down, to 22 August 2026, while the EU&#x27;s 21st Russia sanctions package designated 14 Chinese and Hong Kong entities on 24 July 2026; China responded the same day by adding 14 EU-based companies to its own export-control list. This pattern of extension-and-retaliation is now a structural feature of the sanctions environment rather than an episodic event. The correspondent-banking customer typology attached to the OFAC extension underscores that these sanctions-architecture developments are being felt primarily through correspondent relationships rather than direct retail exposure.

India&#x27;s crypto compliance burden continues to tighten without regime liberalisation. Budget 2026 retained the flat 30% virtual-digital-asset transfer-gains tax and 1% TDS structure without loss-offset reform, while new exchange-reporting penalties took effect and OECD Crypto-Asset Reporting Framework alignment is scheduled for 1 April 2027. This is a compliance-cost story, not a licensing or prohibition story: the underlying tax treatment is unchanged, but the reporting and cross-border data-sharing perimeter around VASP counterparties is widening. The customer typology tagged to this development is VASP counterparties specifically, distinguishing this compliance-burden signal from a broader retail-consumer tax story.

India&#x27;s AML/CFT baseline remains internationally well-regarded. India&#x27;s Mutual Evaluation Report, adopted at the FATF Plenary in June 2024, found a high level of technical compliance and placed India in the regular follow-up category, a status shared with only four other G20 countries. Vivek Aggarwal of India was named incoming FATF Vice-President for July 2026 to June 2027 — a reputational marker that does not itself signal a change to India&#x27;s domestic regime.

#### Cross-Monitor Connections

The Mahadev network&#x27;s payment and platform infrastructure is the subject of active advennt (gambling regulatory) coverage of India&#x27;s enforcement posture against illegal betting operators, and the same shell-company layering evidenced by DGGI&#x27;s GST-evasion track intersects with world-payments&#x27; interest in India&#x27;s tightening payment-instrument regulation; both should be read alongside this cycle&#x27;s D2 and D3 findings for the fuller cross-domain picture. The crypto monitor&#x27;s tracking of India&#x27;s VDA tax and reporting regime is the domain-native counterpart to this cycle&#x27;s D5 finding, and the compliance-burden trajectory described there is consistent with, rather than contradictory to, the assessment here.

#### Outlook

Three threads bear watching next cycle. First, whether the Enforcement Directorate&#x27;s PMLA order text becomes available as a primary source, which would move the Mahadev proceeds-of-crime estimate from assessed to a higher-confidence tier and might also clarify the extent of cross-border layering into UAE real estate. Second, whether India&#x27;s OECD CARF alignment, due 1 April 2027, generates any interim implementing guidance that would sharpen the compliance picture for VASP counterparties ahead of that date. Third, the sanctions-regime divergence tracked here — extension on one side, designation and retaliation on the other — bears watching for whether it hardens into a durable bifurcation of correspondent-banking access along US/EU and Chinese lines. Neither of the first two developments is a prediction; both are simply the evidentiary gaps most likely to move next cycle&#x27;s assessment.

Domain intelligence (D1–D8)

#### Sanctions Architecture and Evasion

India&#x27;s sanctions posture this cycle is best read through its screening architecture rather than through any single enforcement episode. The Financial Action Task Force concluded its October 2026 Plenary in Paris on 30 October 2026 with India&#x27;s own status unchanged: India remains off both the grey list and the black list, a position it has held continuously since its 2010 accession to the Task Force. India used the Plenary process to press for Pakistan&#x27;s re-listing on the grey list; that push did not succeed this round. The outcome is notable as a diplomatic data point about how India deploys its FATF standing, but it says nothing about India&#x27;s own compliance architecture, which was not under review in that exchange.

Continue reading The domestic sanctions-screening mechanism continued to function on its routine cadence. The Reserve Bank of India issued Circular RBI/2026-27/296 on 19 October 2026, communicating amendments to three entries on the United Nations Security Council&#x27;s ISIL (Da&#x27;esh) and Al-Qaida Sanctions List, acting under the Section 51A framework of the Unlawful Activities (Prevention) Act. A second circular, numbered 297 of 2026 and dated 23 October 2026, followed within days, recording the removal of seven entities from the same consolidated list. Both circulars are transmission instruments: they carry a UNSC-level list change into the domestic banking sector&#x27;s screening obligations without introducing a new designation of Indian origin.

Architecturally, what stands out is the absence of lag. A sanctions-screening regime&#x27;s reliability is measured less by any single circular than by whether list changes agreed at the UNSC level reach regulated entities promptly and completely. The sequencing observed here, an amendment circular followed within four days by a removal circular addressing the same list, is consistent with a functioning pipeline rather than a backlogged one. Enablement-as-signal logic cuts the other way too: there is no enforcement action to report against any Indian institution in connection with either circular, and that absence should be read as evidence of routine compliance rather than as a gap in the research.

#### Outlook

The near-term trajectory is continuity. Further UNSC list changes will likely generate further RBI circulars on broadly the same cadence observed this cycle, and India&#x27;s own FATF status is not expected to move before the next Plenary cycle. The more consequential open question, whether India&#x27;s campaign to have Pakistan re-listed gains traction at a future Plenary, is a matter of multilateral diplomacy rather than a reflection on India&#x27;s own sanctions-architecture performance, and any assessment of it should be kept analytically separate from India&#x27;s own standing.

#### Beneficial Ownership and Corporate Transparency

India&#x27;s own beneficial-ownership and corporate-transparency exposure surfaced directly this cycle through the Directorate General of GST Intelligence&#x27;s parallel track on the Mahadev illegal-betting network: DGGI estimates approximately INR 70,000 crore routed through roughly 750 shell companies, with associated GST evasion of approximately INR 19,600 crore. This is a domestically-generated corporate-opacity finding, not an import of EU architecture — it evidences a shell-company layering structure used specifically to move betting-derived proceeds through India&#x27;s formal corporate and banking system, running in parallel to the Enforcement Directorate&#x27;s own Prevention of Money Laundering Act track against the same network, which separately estimates approximately INR 43,000 crore in proceeds of crime. Together, these two tracks are the most significant beneficial-ownership-adjacent finding for India this cycle, with obligation implications for banks and payment companies conducting customer due diligence on corporate customers exhibiting these typologies.

Continue reading Globally, the EU AML Package sets the structural direction for beneficial-ownership regulation, though India sits outside its direct perimeter. As standing context: the EU AML Package comprises three distinct instruments — the directly applicable AML Regulation (Regulation (EU) 2024/1624), the sixth AML Directive requiring per-Member-State transposition, and the AMLA Regulation (Regulation (EU) 2024/1620) establishing the Anti-Money Laundering Authority. This cycle saw two convergent EU milestones: AMLA&#x27;s 10 July 2026 deadline to submit approximately 23 technical standards to the European Commission, and the AMLD6 beneficial-ownership-register transposition deadline, both falling within or near this reporting window, while full AMLR application and repeal of the AMLD4/5 predecessor framework remain fixed for 10 July 2027. The AMLA direct/indirect-supervision perimeter is progressively shifting supervision of cross-border obliged entities from purely national authorities toward a hybrid EU-level regime — a durable structural fact rather than a single-cycle development. For India specifically, however, this EU architecture is contextual rather than operative: the directly relevant development this cycle is domestic, arising from DGGI&#x27;s own shell-company findings rather than from any EU transposition step.

The DGGI finding also carries a control-gap signal: the interpreter&#x27;s obligation-reference tagging on this development notes only partial coverage of the shell-company layering typology under existing customer due-diligence obligation frameworks, meaning the customer-typology categories most exposed — corporate entities and money-service-business-adjacent typologies — may not be fully captured by current CDD controls tuned to more conventional shell-company red flags. This cycle&#x27;s beneficial-ownership signal for India does not exist in isolation: the same Mahadev network&#x27;s opaque corporate layering is the plausible upstream predicate for the asset-flight signal captured separately under enabler-jurisdiction analysis, where attached assets connected to a network promoter surfaced in the UAE, even though the two tracks rest on separate source chains and separate confidence tiers.

#### Outlook

Watch for whether the Enforcement Directorate&#x27;s and DGGI&#x27;s parallel tracks against the Mahadev network converge into a single consolidated filing, which would sharpen the corporate-vehicle count and evasion estimate beyond the current tier-three sourcing. On the EU side, watch whether the 10 July 2026 AMLA technical-standards and AMLD6 register-transposition deadlines were met in practice, though this remains contextual backdrop rather than a directly India-relevant development.

#### Enabler Jurisdictions

This periods signal from India centres on the domestic banking and payments mechanisms that allow unlicensed betting operations to persist and move proceeds despite the countrys online money-gaming prohibition. The Enforcement Directorates Mumbai Zone-II unit conducted a search operation across twenty premises in Mumbai, Pune, Mehsana, Surat and Hyderabad on 13 October 2026 (reported 18 October), acting under the Prevention of Money Laundering Act, 2002 against betting platforms All Panel Exchange and MGM91. The specific channels under investigation are mule bank accounts, used to layer proceeds through accounts not obviously connected to the underlying betting operation; trade over-invoicing, which disguises the movement of value as ordinary commercial trade; and cryptocurrency transfers, which provide a further off-ramp once funds have entered the formal or informal banking system. This is a textbook enabler-jurisdiction pattern: the prohibition on the underlying activity does not by itself close off the financial infrastructure that the activity depends on, and enforcement has to separately target the money-movement layer.

Continue reading A second, independent action reinforces the same reading. Himachal Pradesh police raided a rented property in Birta, Kangra district, on 24 October 2026, detaining six individuals and seizing forty-one phones and seven laptops in connection with an illegal online gaming racket and its associated mule accounts. That this action came from a state police cyber-crime unit rather than the central Enforcement Directorate indicates that the mule-account enabling pattern linked to unlicensed online gaming and betting is not confined to one enforcement tier or one geography; it is being independently identified and acted on at both central and state level.

Neither action, on the present record, is confirmed by a primary government release; both rest on tier-three press reporting, and that sourcing limitation should be read alongside the substantive finding rather than treated as resolved. The standing architecture against which these actions sit is otherwise unchanged: India&#x27;s position outside the FATF grey and black lists, following its 2024 Mutual Evaluation and placement in regular follow-up, was not affected by either action and reflects a separately-assessed dimension of the countrys AML/CFT standing.

#### Outlook

The most consequential near-term question for this domain is whether either the All Panel Exchange/MGM91 probe or the Kangra action is followed by a primary regulatory or prosecutorial release, a charge-sheet, or asset-freezing order that would convert the current press-sourced finding into a confirmed enforcement outcome. A recurrence of state-level mule-account actions tied to illegal gaming in other states would also be a notable escalation, suggesting a broader distributed enforcement pattern against this specific enabling mechanism rather than two isolated incidents.

No conflict-finance-specific development identified this cycle.

#### Crypto, Digital Assets, and Financial Innovation

The only digital-asset signal for India this cycle is a single, uncorroborated claim, and it is reported here at the confidence level the Interpreter assigned rather than elevated for narrative convenience. One Tier 4 source asserts that FATF has flagged gaming-adjacent crypto flows and offshore virtual-asset-service-provider exploitation in India as an influence on the enforcement focus of the Promotion and Regulation of Online Gaming Rules 2026 (possible confidence). No primary FATF document was located this cycle to corroborate the claim, and the Interpreter records this explicitly as a gap requiring verification rather than a confirmed regulatory finding. Analytically, the claim, if verified, would connect the domestic payment-blocking architecture already documented in this cycle to an offshore virtual-asset displacement channel, an intuitive extension of the enforcement picture given that mule-account and offshore-URL activity has already been confirmed by domestic authorities this cycle at possible-to-assessed confidence. But intuition is not corroboration, and the Interpreter is correct to withhold confirmation pending a primary source.

Continue reading No other India-specific crypto, virtual-asset, or digital-innovation development met the evidentiary threshold this cycle. This is itself worth stating plainly rather than papering over: the substantial enforcement architecture built this cycle around real-money gaming payments has not yet been matched by any corroborated finding on how, or whether, illicit proceeds are moving through crypto or virtual-asset rails specifically. That absence may reflect a genuine gap in the underlying activity, a gap in this cycle research coverage, or both; the Interpreter coverage notes flag crypto-laundering corroboration for this domain as independently unconfirmed by a primary source this cycle, and that caveat is carried forward rather than resolved.

#### Outlook

The single unverified claim in this domain should be treated as a watch item pending primary-source confirmation, not as an established FATF position. If a primary FATF document or an Indian regulatory statement subsequently corroborates a link between gaming-adjacent crypto flows and enforcement focus, that would represent a material upgrade to this domain and would warrant direct assessment of virtual-asset-service-provider exposure alongside the banking and payment-sector obligations already in force under the Promotion and Regulation of Online Gaming Rules 2026. Until then, this domain remains thin, and the honest position is to flag rather than narrate.

#### Compliance Technology and Active Defence

The Reserve Bank of India has published draft Know Your Customer Amendment Directions, 2026 proposing a new compliance-technology mechanism: banks would be permitted to place a temporary, amount-limited debit hold of up to sixty days on transactions of one thousand rupees or more that are flagged by AI-based transaction monitoring systems as linked to suspected mule-account or cyber-fraud activity. Under the draft, the hold would restrict only the disputed amount rather than the full account, and would depend on an AI-based flagging event as its operative trigger. The proposal is at consultation stage as of early October 2026, with an expected effective date of January 2027, and rests on a single press source, so it is assessed as probable rather than confirmed.

Continue reading This is a proactive compliance-technology development rather than a reactive enforcement action, and it is best read as an attempt to standardise what is currently fragmented practice. At present, individual banks appear to apply differing ad hoc approaches to holding suspected mule-account funds, creating inconsistency in both the speed and scope of intervention across the banking sector. A uniform, RBI-mandated mechanism tied to a quantified AI-flagging threshold and a capped hold period would represent a structural addition to India&#x27;s active-defence toolkit against mule-account-enabled fraud, shifting the locus of control from discretionary bank-level policy to a nationally consistent regulatory standard.

The design detail that the hold applies only to the disputed amount, rather than freezing the full account, reflects an attempt to balance fraud-prevention effectiveness against consumer-protection concerns about overbroad account restrictions — a tension that is characteristic of compliance-technology instruments generally, where the active-defence objective must be weighed against the risk of disproportionate impact on legitimate account holders whose transactions are flagged in error by automated systems.

#### Outlook

As a consultation-stage instrument, the draft directions remain subject to revision before finalisation, and the January 2027 expected effective date should be treated as scheduled rather than settled. If finalised substantially as drafted, the mechanism would mark a notable formalisation of AI-based transaction monitoring within India&#x27;s banking AML/CTF technology stack, moving mule-account detection from a bank-discretionary practice toward a standardised regulatory requirement. The eventual calibration of the AI-flagging threshold and the appeals or reversal process for erroneously held transactions will determine whether the mechanism achieves its stated fraud-prevention objective without generating disproportionate consumer friction; neither detail is resolved in the draft as currently reported.

PMLA 2002, PML Rules 2005, UAPA s.51A and WMD Act s.12A confirmed as the standing AML/CTF regime of record for India, with FIU-IND as central FIU.

Continue reading PMLA standing AML/CTF regime confirmed : PMLA, in force since 1 July 2005, applies to all Reporting Entities with CDD, record-keeping and STR obligations; FIU-IND empowered under s.12A/s.13.

#### Commercial Activity

India&#x27;s fintech sector recorded a strong first half of 2026, raising over two billion dollars in funding, an increase of forty-two percent year on year, led by CRED&#x27;s $900 million Series H round and KreditBee&#x27;s $280 million Series E round. This figure is drawn from a single vendor deal-data aggregator and has not been independently corroborated this cycle, so it is assessed as probable rather than confirmed. Against this funding surge, merchant and acquisition activity appears to have been more selective, with acquisitions reported to have fallen to approximately seven from sixteen the prior year, suggesting that capital is concentrating into fewer, larger late-stage rounds rather than being distributed across a broader set of smaller consolidation transactions.

Continue reading The scale of the CRED round in particular is notable both for its size relative to the broader Indian fintech funding environment and for pointing toward continued investor confidence in India&#x27;s consumer-fintech and credit infrastructure space even as the regulatory environment for adjacent sectors, including virtual digital assets, continues to tighten through enforcement rather than through a settled licensing framework. The divergence between strong capital formation in mainstream fintech lending and credit products on one hand, and enforcement-driven contraction in the unregistered offshore crypto-platform population on the other, illustrates a bifurcated commercial environment: well-capitalised, India-domiciled fintech platforms operating within established regulatory categories continue to attract substantial investment, while platforms operating in regulatory grey zones face escalating pressure.

The decline in acquisition volume, from sixteen to approximately seven year on year, may reflect either a maturing market with fewer distressed-asset consolidation opportunities, or greater acquirer caution amid an uncertain near-term regulatory trajectory across adjacent financial-services categories; the underlying data does not resolve which explanation predominates.

#### Outlook

If the funding pace recorded in the first half of 2026 continues through the remainder of the year, India&#x27;s fintech sector is likely to end 2026 with a materially larger population of well-capitalised platforms than in the prior year, a population that will increasingly fall within scope of tightening compliance-technology and KYC requirements such as the RBI&#x27;s draft mule-account hold mechanism. The lower acquisition count bears watching for whether it reflects a durable shift toward organic growth and late-stage financing over consolidation, or a temporary pause pending greater regulatory clarity across adjacent sectors.

Regulatory horizon

No dated horizon items this cycle. 4 items tracked without a confirmed date.

4 pending date · baseline financial-integrity-2026-07-05

Role action cards

MLRO

### Routine UNSC sanctions-list updates were transmitted via two RBI circulars this cycle.

Section 51A screening lists require updating to reflect the amendments and removals communicated in RBI/2026-27/296 and the follow-on circular 297, affecting ISIL/Al-Qaida list entries.

1 evidence refs

Compliance

### India&#x27;s FATF status remained unchanged following the October 2026 Plenary.

No new jurisdictional risk classification applies to India-linked counterparties as a result of this Plenary cycle.

1 evidence refs

Board

### India&#x27;s sanctions and FATF standing remained stable this cycle.

No elevated reputational or regulatory exposure arises from India&#x27;s sanctions architecture this cycle; routine screening updates proceeded without disruption.

2 evidence refs

Risk

### Sanctions-screening transmission into Indian banking channels continued without evident lag this cycle.

The functioning cadence between UNSC list changes and RBI circular issuance is a relevant input to counterparty and correspondent-banking exposure assessments touching India.

1 evidence refs

Operations

### Two RBI circulars updated UNSC sanctions-list entries this cycle.

Screening lists should reflect the three amended and seven removed entries communicated in RBI/2026-27/296 and the follow-on circular 297.

1 evidence refs

Standing trackers (T1–T6)

Tracker Status Note

T1 · Sanctions Architecture and Evasion no_change

T2 · EU AML Package Transposition no_change

T3 · Beneficial Ownership Registries no_change

T4 · Enabler Jurisdiction Dynamics no_change

T5 · Crypto / VASP Regulatory Framework stable India&#x27;s VASP perimeter runs via PMLA FIU-IND registration and tax law, with no dedicated VASP licensing statute.

T6 · Sanctions Regime Divergence no_change

Registers

### Enforcement actions

- 9 Dec 2025

- 25 Mar 2026

- 15 Mar 2026

- 5 Jun 2026

- 28 Mar 2026

- 1 Aug 2025

- 31 Jan 2025

- 9 Sep 2026

- 13 Oct 2026

- 13 Oct 2026

- The Indian Coast Guard seized three tankers in waters off Mumbai, describing the operation as busting an international oil-smuggling racket involving vessels known to frequently change identity, marking India&#x27;s first domestic enforcement action of its kind against dark-fleet shipping. 6 Feb 2026

- US authorities resolved a multi-year bribery and securities-fraud matter: DOJ moved to drop criminal bribery charges tied to a $250 million solar-contract bribery scheme, the SEC settled its civil fraud suit for roughly $18 million, and OFAC separately settled a probe into Adani Group&#x27;s alleged Iran-sanctions violations for approximately $275 million. 19 May 2026

- Coinbase registered with India&#x27;s Financial Intelligence Unit as a Virtual Asset Service Provider, following the same FIU-IND registration route already used by Binance, Bybit and KuCoin after India&#x27;s late-2023 enforcement sweep against nine unlicensed offshore exchanges. 20 Mar 2025

- The US designated The Resistance Front, the group that initially claimed responsibility for deadly attacks in Kashmir, as a Foreign Terrorist Organization, aligning US CTF designation architecture with India&#x27;s domestic terrorism-financing threat assessment. 18 Jul 2025

### Sanctions changes

- 22 Aug 2026

- 24 Jul 2026

- 19 Jun 2026

- 16 Oct 2026

- The EU&#x27;s 18th Russia sanctions package (adopted 18 July 2025) designated India&#x27;s Nayara Energy Ltd., in which Rosneft holds a 49.13% stake, as part of measures to curb Kremlin energy revenue derived from Russian crude exports to India. 18 Jul 2025

- The US imposed a stacked 25% secondary tariff (on top of an existing 25% reciprocal tariff, totalling 50%) on Indian goods in August 2025 as an IEEPA-based penalty for continued Russian crude and arms purchases; this was not a formal OFAC SDN action but functioned as a sanctions-adjacent secondary-pressure tool targeting India specifically. 6 Aug 2025

- Following a US-India trade agreement, Washington eliminated the extra 25% Russia-related tariff in February 2026 after India represented it would stop directly or indirectly importing Russian oil, purchase US energy products, and expand defence cooperation over the next decade. 6 Feb 2026

- The EU&#x27;s 20th Russia sanctions package (23 April 2026) expanded shadow-fleet vessel listings to 632 vessels, added a significant maritime insurer, listed a third-country port (Karimun, Indonesia) for the first time, and activated the EU&#x27;s anti-circumvention instrument against a third country enabling sanctions evasion, all of which bear on India&#x27;s role as a major destination and transhipment point for sanctioned Russian crude. 23 Apr 2026

### Regulatory horizon (register)

- UK ECCTA 2023 failure-to-prevent-fraud offence

- UK ECCTA 2023 failure-to-prevent-fraud offence

- RBI draft Guidance on Regulatory Principles for Model Risk Management 2026

- Draft RBI KYC Amendment Directions 2026 - mule account hold mechanism

- FATF 5th-round follow-up / Roadmap review for India

- India&#x27;s stalled comprehensive crypto/VDA legislation

- RBI AI/ML supervisory-technology expansion for anomaly detection

- Compliance monitoring of India&#x27;s pledge to halt Russian oil imports

### Active schemes

-

- [CRITICAL] Indian refiner Nayara/dark-fleet Russian crude transit architecture

- [HIGH] Digital-arrest scam proceeds laundered via Tether P2P mule networks

- [HIGH] Hawala and cash-courier financing of ISIL/AQ-linked theatres

- Shell-company and TBML layering via real estate and third-party accounts

Sources

- [MeitY (Government of India)](https://www.meity.gov.in/static/uploads/2025/10/8a7f103cefc68ed8aaa2ebc9a2ed7c13.pdf)

- [SCC Online](https://www.scconline.com/blog/post/2026/04/23/meity-notified-enforcement-of-promotion-regulation-online-gaming-act-2025/)

- [Storyboard18](https://www.storyboard18.com/gaming-news/ed-raids-on-winzo-gameskraft-and-dream11-rattle-gaming-sector-industry-fears-wider-crackdown-in-2026-86631.htm)

- [Whalesbook](https://www.whalesbook.com/news/English/economy/ED-Seizes-indian-rupee1700-Cr-Dubai-Assets-in-Mahadev-Betting-Syndicate-Probe/69c5f9fa63d6db8f4b520903)

- [ICLG](https://iclg.com/practice-areas/gambling-laws-and-regulations/india/)

- [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html)

- [Model Diplomat](https://modeldiplomat.com/story/indias-2026-gaming-rules-banks-face-new-compliance-burden)

- [https://www.business-standard.com/india-news/mahadev-betting-app-probe-ed-estimates-rs-43000-crore-illegal-betting-proceeds-126072800511_1.html](https://www.business-standard.com/india-news/mahadev-betting-app-probe-ed-estimates-rs-43000-crore-illegal-betting-proceeds-126072800511_1.html)

- [https://organiser.org/2026/07/12/369430/bharat/mahadev-betting-app-scam-cbis-major-crackdown-on-a-parallel-financial-empire-exceeding-rs-6000-crore/](https://organiser.org/2026/07/12/369430/bharat/mahadev-betting-app-scam-cbis-major-crackdown-on-a-parallel-financial-empire-exceeding-rs-6000-crore/)

- [https://theindianeye.com/2026/03/28/from-mumbai-to-dubai-india-intensifies-its-crackdown-on-illegal-betting-apps/](https://theindianeye.com/2026/03/28/from-mumbai-to-dubai-india-intensifies-its-crackdown-on-illegal-betting-apps/)

- [https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html)

- [https://www.fatf-gafi.org/en/publications/Mutualevaluations/India-MER-2024.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/India-MER-2024.html)

- [https://financialregulations.eu/blog/eu-aml-package-amla-amlr-guide](https://financialregulations.eu/blog/eu-aml-package-amla-amlr-guide)

- [https://zavia.ai/eu-beneficial-ownership-in-2026-amlr-amld6-amla-explained/](https://zavia.ai/eu-beneficial-ownership-in-2026-amlr-amld6-amla-explained/)

- [https://www.fieldfisher.com/en/services/international-trade/trade-sanctions-blog/uk-eu-and-us-sanctions-on-russia](https://www.fieldfisher.com/en/services/international-trade/trade-sanctions-blog/uk-eu-and-us-sanctions-on-russia)

- [https://www.americanactionforum.org/insight/oil-in-the-shadows-dark-shipping-evades-sanctions/](https://www.americanactionforum.org/insight/oil-in-the-shadows-dark-shipping-evades-sanctions/)

- [https://www.coingabbar.com/en/crypto-blogs-details/india-crypto-regulation-guide-ban-taxes-vda-rules-2026](https://www.coingabbar.com/en/crypto-blogs-details/india-crypto-regulation-guide-ban-taxes-vda-rules-2026)

- [https://www.fatf-gafi.org/en/countries/detail/India.html](https://www.fatf-gafi.org/en/countries/detail/India.html)

- [https://www.businesstoday.in/latest/economy/story/fatf-to-release-indias-mutual-evaluation-report-on-september-19-places-india-in-regular-follow-up-category-445299-2024-09-10](https://www.businesstoday.in/latest/economy/story/fatf-to-release-indias-mutual-evaluation-report-on-september-19-places-india-in-regular-follow-up-category-445299-2024-09-10)

- [https://www.dor.gov.in/fatf-cell](https://www.dor.gov.in/fatf-cell)

- [https://checklynx.com/en/resources/knowledge-base/fatf-grey-list](https://checklynx.com/en/resources/knowledge-base/fatf-grey-list)

- [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html)

- [https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/)

- [https://sigma.world/news/cambodia-anti-gambling-drive-fatf-grey-list/](https://sigma.world/news/cambodia-anti-gambling-drive-fatf-grey-list/)

- [https://www.fincen.gov/system/files/2025-08/FinCEN-Alert-on-Cartel-Oil-Smuggling-Spanish-508C.pdf](https://www.fincen.gov/system/files/2025-08/FinCEN-Alert-on-Cartel-Oil-Smuggling-Spanish-508C.pdf)

- [https://www.fincen.gov/sites/default/files/shared/BCS-Alert-FINAL-508C.pdf](https://www.fincen.gov/sites/default/files/shared/BCS-Alert-FINAL-508C.pdf)

- [https://blog.compliance7.com/2026/06/18/vasp-compliance-india-fiu-registered-firms/](https://blog.compliance7.com/2026/06/18/vasp-compliance-india-fiu-registered-firms/)

- [https://virtualauditor.in/learn/companies-act-amendments-2026/](https://virtualauditor.in/learn/companies-act-amendments-2026/)

- [Press Information Bureau](https://www.pib.gov.in/PressReleaseIframePage.aspx?PRID=2098153&reg=48&lang=2)

- [FATF](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html)

- [Yahoo Finance](https://finance.yahoo.com/news/crypto-oversight-strengthens-india-49-130745613.html)

- [openrate.live](https://openrate.live/blog/fiu-ind-registration-explained)

- [https://the420.in/betting-funds-ai-investments/](https://the420.in/betting-funds-ai-investments/)

- [https://crypto.news/indias-rbi-stays-cautious-on-crypto/](https://crypto.news/indias-rbi-stays-cautious-on-crypto/)

- [https://www.coindesk.com/policy/2026/09/09/india-s-financial-intelligence-unit-flags-15-crypto-platforms-for-aml-lapses](https://www.coindesk.com/policy/2026/09/09/india-s-financial-intelligence-unit-flags-15-crypto-platforms-for-aml-lapses)

- [https://amluae.com/what-are-fatf-blacklist-and-grey-list-countries/](https://amluae.com/what-are-fatf-blacklist-and-grey-list-countries/)

- [https://www.medianama.com/2026/06/223-rbi-ai-guidelines-2026-banks-kill-switch/](https://www.medianama.com/2026/06/223-rbi-ai-guidelines-2026-banks-kill-switch/)

- [https://www.fatf-gafi.org/en/calendars/assessments.html](https://www.fatf-gafi.org/en/calendars/assessments.html)

- [https://varindia.com/news/india-tightens-crypto-rules](https://varindia.com/news/india-tightens-crypto-rules)

- [https://candourlegal.com/fiu-ind-registration-crypto-businesses-india-4/](https://candourlegal.com/fiu-ind-registration-crypto-businesses-india-4/)

- [https://notabene.id/world/india](https://notabene.id/world/india)

- [https://tracxn.com/d/insights/market-reports/india-fintech-semi-annual-funding-report-h1-2026/__KI88fIIv3fr5S2VBcl2e1wyQJn6Vtcx04wbRitnU33o](https://tracxn.com/d/insights/market-reports/india-fintech-semi-annual-funding-report-h1-2026/__KI88fIIv3fr5S2VBcl2e1wyQJn6Vtcx04wbRitnU33o)

- [https://www.bankingfinance.in/regulatory-radar-for-october-2026.html](https://www.bankingfinance.in/regulatory-radar-for-october-2026.html)

- [https://www.cnbc.com/2026/10/17/trump-waives-russia-related-sanctions-tariffs-before-they-take-effect-.html](https://www.cnbc.com/2026/10/17/trump-waives-russia-related-sanctions-tariffs-before-they-take-effect-.html)

- [https://www.dailyexcelsior.com/trump-waives-russia-energy-sanctions-suspends-threat-of-100-pc-tariffs-on-india-china/amp](https://www.dailyexcelsior.com/trump-waives-russia-energy-sanctions-suspends-threat-of-100-pc-tariffs-on-india-china/amp)

- [https://www.cryptotimes.io/2026/10/17/indias-ed-raids-20-locations-in-betting-fraud-probe-involving-crypto-conversions/](https://www.cryptotimes.io/2026/10/17/indias-ed-raids-20-locations-in-betting-fraud-probe-involving-crypto-conversions/)

- [https://www.businessworld.in/article/india-fintech-s-great-squeeze-five-mega-deals-grab-half-the-money-as-seed-funding-crashes-57-628316](https://www.businessworld.in/article/india-fintech-s-great-squeeze-five-mega-deals-grab-half-the-money-as-seed-funding-crashes-57-628316)

- [https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofindia.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofindia.html)

- [https://www.knowyourcountry.com/country-reports/india/](https://www.knowyourcountry.com/country-reports/india/)

- [https://www.newsbytesapp.com/news/business/ed-conducts-raids-in-20-locations-in-betting-fraud-investigation/story](https://www.newsbytesapp.com/news/business/ed-conducts-raids-in-20-locations-in-betting-fraud-investigation/story)

- [https://fincrimecentral.com/fiu-ind-15-crypto-platforms-aml-compliance/](https://fincrimecentral.com/fiu-ind-15-crypto-platforms-aml-compliance/)

- [https://the420.in/kangra-online-gaming-racket-busted-birta-police-raid/](https://the420.in/kangra-online-gaming-racket-busted-birta-police-raid/)

- [https://carajput.com/blog/virtual-digital-assets-legal-aml-framework/](https://carajput.com/blog/virtual-digital-assets-legal-aml-framework/)

- [https://crypto-license-asia.com/crypto-licenses/india/](https://crypto-license-asia.com/crypto-licenses/india/)

- [https://sumsub.com/blog/cryptocurrency-in-india/](https://sumsub.com/blog/cryptocurrency-in-india/)

- [https://www.azbpartners.com/bank/virtual-currency-regulation-review-2025/](https://www.azbpartners.com/bank/virtual-currency-regulation-review-2025/)

- [https://fiuindia.gov.in/pdfs/AML_legislation/AMLCFTguidelines10032023.pdf](https://fiuindia.gov.in/pdfs/AML_legislation/AMLCFTguidelines10032023.pdf)

- [https://fiuindia.gov.in/pdfs/downloads/AML_CFT_Guideline_TCSPs.pdf](https://fiuindia.gov.in/pdfs/downloads/AML_CFT_Guideline_TCSPs.pdf)

- [https://en.wikipedia.org/wiki/Prevention_of_Money_Laundering_Act,_2002](https://en.wikipedia.org/wiki/Prevention_of_Money_Laundering_Act,_2002)

- [https://membercheck.com/aml-cft-legislation-in-india/](https://membercheck.com/aml-cft-legislation-in-india/)

- [https://amlindia.in/aml-laws-and-regulations-india/](https://amlindia.in/aml-laws-and-regulations-india/)

- [India&#x27;s measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/India-MER-2024.html)

- [Mutual Evaluation of India](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofindia.html)

- [MUTUAL EVALUATION REPORT OF INDIA](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/Executive-Summary-MER%20India%202024.pdf.coredownload.inline.pdf)

- [Outcomes FATF Plenary, 26-28 June 2024](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2024.html)

- [India](https://www.fatf-gafi.org/en/countries/detail/India.html)

- [Asia/Pacific Group on Money Laundering (APG)](https://www.fatf-gafi.org/en/countries/global-network/asia-pacific-group-on-money-laundering--apg-.html)

- [September 2024 Anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/India-MER-2024.pdf.coredownload.inline.pdf)

- [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html)

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- [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html)

- ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html)

- [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html)

- [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html)

- [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html)

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- [FATF](https://www.fatf-gafi.org/en/home.html)

- [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html)

- [Search page](https://www.fatf-gafi.org/en/search-page.html)

- [Outcomes FATF Plenary, 17-19 June 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html)

- [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26)

- [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/)

- [Crypto Exchanges Eye India Comeback as Regulators Tease Pivot - Bloomberg](https://www.bloomberg.com/news/newsletters/2025-03-20/crypto-exchanges-eye-india-comeback-as-regulators-tease-pivot)

- [Crypto Has Become a Target of India&#x27;s Dreaded Enforcement Directorate - Bloomberg](https://www.bloomberg.com/opinion/articles/2022-08-10/crypto-has-become-a-target-of-india-s-dreaded-enforcement-directorate)

- [What Is a Darknet Market? Definition, How They Work & Law Enforcement Guide- Chainalysis](https://www.chainalysis.com/glossary/darknet-markets/)

- [Elliptic&#x27;s 2026 regulatory and policy outlook: 5 crypto trends to expect in 2026](https://www.elliptic.co/blog/regulatory-and-policy-crypto-trends-to-except-in-2026)

- [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025)

- [India Imposes Money Laundering Provisions on Crypto Sector - Bloomberg](https://www.bloomberg.com/news/articles/2023-03-08/india-imposes-money-laundering-provisions-on-the-crypto-sector)

- [India: UNODC enhances digital resilience of law enforcement officials strengthen responses to virtual assets and cryptocurrencies](https://www.unodc.org/southasia//frontpage/2023/September/india_-unodc-enhances-digital-resilience-of-law-enforcement-officials-strengthen-responses-to-virtual-assets-and-cryptocurrencies.html)

- [Russia’s Airlines Skirt Sanctions to Keep Boeing, Airbus Jets Flying](https://www.bloomberg.com/graphics/2026-russian-airlines-sanctions/)

- [EU adopts 20th package of sanctions against Russia - Finance](https://finance.ec.europa.eu/news/eu-adopts-20th-package-sanctions-against-russia-2026-04-23_en)

- [Dark Fleet Seeking Russian Protection as US Seizes Oil Tankers - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-14/dark-fleet-seeking-russian-protection-as-us-seizes-oil-tankers)

- [Russia Oil’s Unexpected Staying Power in India Extends Into 2026 - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-27/russia-oil-s-unexpected-staying-power-in-india-extends-into-2026)

- [Captain charged over sanctions breach in Russian shadow oil tanker operation | The Crown Prosecution Service](https://www.cps.gov.uk/cps/news/captain-charged-over-sanctions-breach-russian-shadow-oil-tanker-operation)

- [India Splurges on Russia Oil as Sanctions Threat Begins to Fade - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-10/india-splurges-on-russian-oil-as-sanctions-threat-begins-to-fade)

- [1 Red ALERT Shadow Fleet Sanctions Evasion and Avoidance Network](https://www.nationalcrimeagency.gov.uk/who-we-are/publications/753-red-alert-shadow-fleet-sanctions-evasion-and-avoidance-network/file)

- [India Grabs Three Tankers in First Action Against Dark Fleet - Bloomberg](https://www.bloomberg.com/news/articles/2026-02-10/india-seizes-three-tankers-in-first-action-against-dark-fleet)

- [China Snaps Up Distressed Russian Oil Cargoes Shunned by India - Bloomberg](https://www.bloomberg.com/news/articles/2026-02-20/china-snaps-up-distressed-russian-oil-cargoes-shunned-by-india)

- [India’s Nayara Turns to Dark Fleet and Russian Oil for Survival - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-20/india-s-nayara-turns-to-dark-fleet-and-russian-oil-for-survival)

- [India’s Nayara Cuts Oil Refinery Run Rate After EU Sanctions - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-29/india-s-nayara-trims-crude-processing-rates-after-eu-sanctions)

- [EU Sanctions Against India’s Nayara ‘Unjustified,’ Rosneft Says - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-20/eu-sanctions-against-india-s-nayara-unjustified-rosneft-says)

- [Sanctions Choke Crude Shipments to Indian Refiner Nayara - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-12/sanctions-choke-crude-shipments-to-indian-refiner-nayara)

- [Saudi Arabia, Iraq Stop Oil Shipments to Nayara After Sanctions - Bloomberg](https://www.bloomberg.com/news/articles/2025-09-01/saudi-arabia-iraq-stop-oil-shipments-to-nayara-after-sanctions)

- [Oil Shippers, Traders Avoid EU-Sanctioned Nayara Energy - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-22/oil-shippers-traders-stay-away-from-eu-sanctioned-nayara-energy)

- [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information)

- [Europe Sanctions on India’s Nayara Energy Puts Its Sale at Risk - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-18/europe-sanctions-on-india-s-nayara-energy-puts-its-sale-at-risk)

- [EU-Sanctioned Nayara Energy Set to Receive Iraqi Crude This Week - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-28/eu-sanctioned-nayara-energy-set-to-receive-iraqi-crude-this-week)

- [India’s Sanction-Hit Nayara Delays Oil Refinery Maintenance Work - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-24/india-s-sanction-hit-nayara-delays-oil-refinery-maintenance-work)

- [India’s RBI Eases Some Curbs on Banks’ Forex Market Trades: INR/USD - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-20/india-s-rbi-eases-some-curbs-on-banks-forex-market-trades)

- [Central Repository of Information on Large Credits (CRILC) ...](https://www.unodc.org/documents/corruption/G20-Anti-Corruption-Resources/G20-Step-by-step-guides-on-nternational-cooperation-and-asset-recovery/Asset-Tracing-Country-Profiles/India.pdf)

- [Key Changes in FinCEN’s Proposed Rule to Refocus AML/CFT Programs on](https://www.fincen.gov/system/files/2026-04/Key-Changes-Program-NPRM.pdf)

- [ASIA/PACIFIC GROUP ON MONEY LAUNDERING FINANCIAL ACTION TASK FORCE](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/MER%20India%20full.pdf.coredownload.pdf)

- [FinCEN Proposes Rule to Fundamentally Reform Financial Institution Programs Designed to Fight Illicit Finance | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs)

- [FinCEN Issues Proposed Rule to Postpone Effective Date of Investment Adviser Rule | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-proposed-rule-postpone-effective-date-investment-adviser-rule)

- [Year in Review for Fiscal Year 2025](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf)

- [Digital Arrests: India’s Billion Online IDs Sparked Criminal Scam Bonanza](https://www.bloomberg.com/features/2025-india-digital-scams/)

- [Digital Arrests: Inside India’s Scariest Scam — and How to Stop It - Bloomberg](https://www.bloomberg.com/opinion/features/2025-10-12/digital-arrests-inside-india-s-scariest-scam-and-how-to-stop-it)

- [How Bloomberg Reported India’s New Digital Nightmare - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-05/how-bloomberg-reported-india-s-new-digital-nightmare)

- [India&#x27;s Digital Arrests Signal Scary Future in Scams - Bloomberg](https://www.bloomberg.com/opinion/newsletters/2025-10-18/india-s-digital-arrests-signal-scary-future-in-scams)

- [Inside India&#x27;s Wave of &#x27;Digital Arrests&#x27; — A Graphic Novel](https://www.bloomberg.com/graphics/2025-india-digital-arrest-by-phone-graphic-novel/)

- [Digital arrest scams in India set a record in 2024. - Bloomberg](https://www.bloomberg.com/news/newsletters/2025-12-05/digital-arrest-scams-in-india-set-a-record-in-2024)

- [FATF report highlights evolving terrorist financing risks and warns of gaps in global understanding of the threats](https://www.fatf-gafi.org/en/publications/Methodsandtrends/comprehensive-update-terrorist-financing-risks-2025.html)

- [1 BY OPIATE TRAFFICKERS AND MIGRANT SMUGGLERS The Hawala System](https://www.unodc.org/documents/data-and-analysis/AOTP/Hawala_Digital.pdf)

- [‘No Money for Terror’ Ministerial Conference on Counter-Terrorism Financing](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Raja-kumar-speech.html)

- [US Declares Group Accused of Kashmir Attacks a Terror Outfit - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-18/us-declares-group-accused-of-kashmir-attacks-a-terror-outfit)

- [The role of Hawala and other similar service providers in money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Role-hawalas-in-ml-tf.html)

- [Comprehensive Update on Terrorist Financing Risks FATF REPORT July 2025](https://www.fatf-gafi.org/content/dam/fatf-gafi/publications/Comprehensive-Update-on-Terrorist-Financing-Risks-2025.pdf.coredownload.inline.pdf)

- [Terrorist Financing](https://www.fatf-gafi.org/en/topics/Terrorist-Financing.html)

- [CTED Trends Tracker Evolving Trends in the Financing of Foreign Terrorist](https://www.un.org/securitycouncil/ctc/sites/www.un.org.securitycouncil.ctc/files/cted_trends_tracker_evolving_trends_in_the_financing_of_foreign_terrorist_fighters_activity_2014_-_2024.pdf)

- [Trump Hits India With Additional 25% Tariff Over Russian Oil - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-06/trump-hits-india-with-additional-25-tariff-over-russia-oil-buys)

- [Trump Removes India’s 25% Russia-Related Tariff After Deal - Bloomberg](https://www.bloomberg.com/news/articles/2026-02-06/trump-removes-india-s-25-russia-related-tariff-after-deal)

- [Trump’s India Trade Deal: How Tariffs Have Tested Modi’s US-Russia Balancing Act - Bloomberg](https://www.bloomberg.com/news/articles/2026-02-03/trump-s-india-trade-deal-how-tariffs-have-tested-modi-s-us-russia-balancing-act)

- [Trump Hits India With 25% Tariff, Threatens More Over Russia - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-30/trump-says-he-will-levy-25-tariff-on-india-starting-aug-1)

- [Trump Vows to Ramp Up India Tariffs, Escalating Spat Over Russia - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-04/trump-says-us-to-hike-india-s-tariffs-over-russian-oil-purchases)

- [Trump’s Punitive India Tariff Spoils Modi’s Russian Oil Math - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-07/trump-s-punitive-india-tariff-spoils-modi-s-russian-oil-math)

- [What to Know as Trump Threatens India With Penalties Over Russia Ties - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-31/what-to-know-as-trump-threatens-india-with-penalties-over-russia-ties)

- [Trump Targets India Oil Buying, Shadow Fleet to Pressure Putin - Bloomberg](https://www.bloomberg.com/news/newsletters/2025-08-06/trump-targets-india-oil-buying-shadow-fleet-to-pressure-putin)

- [India Refiners to Trim Russia Oil Buying as Trump Sows Confusion - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-16/indian-refiners-to-take-less-russian-oil-after-trump-comments)

- [India Holds Line on Russian Oil With Trump’s Tariffs in Question](https://www.bloomberg.com/news/articles/2026-02-26/india-holds-line-on-russian-oil-with-trump-s-tariffs-in-question)

- [Binance And Other Crypto Exchanges Restart India Business - Bloomberg](https://www.bloomberg.com/news/articles/2024-08-16/binance-restarts-india-business-after-getting-local-registration)

- [Global Crypto Policy Review & Outlook 2024/2025 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2024-25-report)

- [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/)

- [Introduction to Cryptocurrency Exchange Compliance - Chainalysis](https://www.chainalysis.com/blog/introduction-to-cryptocurrency-exchange-compliance-crypto-businesses-2024/)

- [Regulatory Outlook 2024: How crypto policy and regulation will shape up around the globe](https://www.elliptic.co/blog/regulatory-outlook-2024-how-crypto-policy-and-regulation-will-shape-up-around-the-globe)

- [The readiness of the digital asset ecosystem](https://www.elliptic.co/hubfs/State%20of%20crypto%202025/Elliptic_Report_State_of_Crypto_2025.pdf)

- [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/)

- [Billionaire Adani’s Bid to End Bribery Case Stalls With Strained US-India Ties - Bloomberg](https://www.bloomberg.com/news/articles/2025-09-11/billionaire-adani-s-bid-to-end-bribery-case-stalls-with-strained-us-india-ties)

- [India&#x27;s Adani Group Denies U.S. Bribery Charges, Calls Allegations &#x27;Baseless&#x27; | OCCRP](https://www.occrp.org/en/news/indias-adani-group-denies-us-bribery-charges-calls-allegations-baseless)

- [Adani Hires Top Wall Street Lawyer in Sign SEC Case Will Advance - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-30/adani-hires-top-wall-street-lawyer-in-sign-sec-case-will-advance)

- [SEC Seeks Fresh Pathway to Advance in Stalled Adani ...](https://www.bloomberg.com/news/articles/2026-01-22/sec-seeks-fresh-pathway-to-advance-in-stalled-adani-fraud-case)

- [Adani Camp Meets Trump Officials in Bid to End Bribery Cases - Bloomberg](https://www.bloomberg.com/news/articles/2025-05-05/adani-camp-meets-trump-officials-in-push-to-end-us-bribery-cases)

- [US Authorities Move to End Fraud Cases Against Gautam Adani - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-14/us-authorities-moving-to-end-fraud-cases-against-gautam-adani)

- [Gautam Adani Settles All US cases With $300 Million of Fines - Bloomberg](https://www.bloomberg.com/news/newsletters/2026-05-19/gautam-adani-settles-all-us-cases-with-300-million-of-fines?srnd=ai-jobs-economy)

- [Adani Lawyers Argue SEC Lacks Jurisdiction in US Fraud Suit Over Green Energy - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-07/adani-tells-judge-sec-fraud-suit-against-him-should-be-dismissed)

- [India’s Adani Steps Up Defense In US Bribery Cases, GIFT City Eases Liquor Rules - Bloomberg](https://www.bloomberg.com/news/newsletters/2026-01-30/india-s-adani-steps-up-defense-in-us-bribery-cases-gift-city-eases-liquor-rules)

- [Bank Documents Expose Scale of Secret Investments in Adani Group by Adani Family Associates | OCCRP](https://www.occrp.org/en/investigation/bank-documents-expose-scale-of-secret-investments-in-adani-group-by-adani-family-associates)

- [A Regulatory Governance Framework for AI-Driven Financial Fraud Detection in U.S. Banking: Integrating OCC, SR 11-7, CFPB, and FinCEN Compliance Requirements for Model Development, Validation, and Monitoring Lifecycles](https://arxiv.org/pdf/2605.04076)

- [Generative AI in Financial Institution: A Global Survey of Opportunities, Threats, and Regulation](https://arxiv.org/pdf/2504.21574)

- [A systematic review and future directions for AI-driven detection of fraud patterns in SACCO transactions](https://www.ncbi.nlm.nih.gov/pmc/articles/PMC12901501/)

- [Artificial intelligence in neurology, ethics, recent guideline, and law-an Indian perspective](https://www.ncbi.nlm.nih.gov/pmc/articles/PMC12000087/)

- [Advanced fraud detection using machine learning models: enhancing financial transaction security](https://arxiv.org/pdf/2506.10842)

- [E-Commerce Fraud Detection Model by Computer Artificial Intelligence Data Mining](https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9110132/)

- [Emerging threats in Southeast Asia – Exploitation of AI and automation in the regional cybercrime landscape](https://www.unodc.org/unodc/frontpage/2025/September/emerging-threats-in-southeast-asia--exploitation-of-ai-and-automation-in-the-regional-cybercrime-landscape.html)

- [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en)

- [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en)

- [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en)

- [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en)

- [Commission adds Russia to list of high-risk jurisdictions to strengthen international fight against financial crime](https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2910)

- [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2)

- [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en)

- [Anti-Money Laundering and Terrorist Financing Directive 4 - Finance](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en)

- [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html)

- [Protecting the EU’s financial system - Finance - European Commission](https://finance.ec.europa.eu/news/protecting-eus-financial-system-2025-07-16_en)

- [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2)

- [ECSH31555 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh31555)

- [ECSH64830 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh64830)

- [HM Treasury Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/hm-treasury-advisory-notice-high-risk-third-countries)

- [High-risk third countries](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries)

- [HM Treasury publish updated list of high risk third jurisdictions](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasury-publish-updated-list-of-high-risk-third-jurisdictions)

- [ECSH33336 - High-risk third countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh33336)

- [FATF / APG / EAG (joint mutual evaluation)](https://www.fatf-gafi.org/en/publications/Mutualevaluations/India-MER-2024.html)

- [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2024.html)

- [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html)

- [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html)

- [European Commission](https://finance.ec.europa.eu/news/eu-adopts-20th-package-sanctions-against-russia-2026-04-23_en)

- [European Commission](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en)

- [HM Treasury (UK)](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2)

- [Bloomberg](https://www.bloomberg.com/news/articles/2025-07-20/eu-sanctions-against-india-s-nayara-unjustified-rosneft-says)

- [Bloomberg](https://www.bloomberg.com/news/articles/2025-08-20/india-s-nayara-turns-to-dark-fleet-and-russian-oil-for-survival)

- [Bloomberg](https://www.bloomberg.com/news/articles/2026-02-06/trump-removes-india-s-25-russia-related-tariff-after-deal)

- [Bloomberg](https://www.bloomberg.com/news/articles/2026-02-10/india-seizes-three-tankers-in-first-action-against-dark-fleet)

- [Bloomberg](https://www.bloomberg.com/news/newsletters/2026-05-19/gautam-adani-settles-all-us-cases-with-300-million-of-fines)

- [OCCRP](https://www.occrp.org/en/news/indias-adani-group-denies-us-bribery-charges-calls-allegations-baseless)

- [Bloomberg Businessweek](https://www.bloomberg.com/features/2025-india-digital-scams/)

- [ICIJ](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/)

- [TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2024-25-report)

- [Bloomberg](https://www.bloomberg.com/news/newsletters/2025-03-20/crypto-exchanges-eye-india-comeback-as-regulators-tease-pivot)

- [Bloomberg](https://www.bloomberg.com/news/articles/2025-07-18/us-declares-group-accused-of-kashmir-attacks-a-terror-outfit)

- [FATF](https://www.fatf-gafi.org/en/publications/Methodsandtrends/comprehensive-update-terrorist-financing-risks-2025.html)

- [arXiv preprint (academic survey)](https://arxiv.org/pdf/2504.21574)

Coverage gaps

fim-int-2026-07-11-G001: OGAI has not published its official… fim-int-2026-07-11-G001: OGAI has not published its official determination list of prohibited online money games, leaving financial institutions without a definitive compliance reference this cycle. [resolved]

fim-int-2026-07-11-G002: RBI has not issued a located primar… fim-int-2026-07-11-G002: RBI has not issued a located primary circular implementing the OGAI payment-blocking mandate despite industry requests for guidance and transition time. [resolved]

fim-int-2026-07-11-G003: Tier D jurisdictions Cambodia, Laos… fim-int-2026-07-11-G003: Tier D jurisdictions Cambodia, Laos, Mexico and Colombia were not directly queried this cycle; research effort was concentrated on jurisdiction IN, so their no-change status is a coverage gap rather than a confirmed finding. [resolved]

fim-int-2026-07-11-G004: The claim that FATF has flagged Ind… fim-int-2026-07-11-G004: The claim that FATF has flagged India&#x27;s gaming-adjacent crypto flows and offshore VASP exploitation is uncorroborated by any primary FATF document located this cycle. [resolved]

fim-int-2026-07-11-G005: ED&#x27;s own primary press releases on … fim-int-2026-07-11-G005: ED&#x27;s own primary press releases on the WinZO, Gameskraft, Probo and Pocket52 raids and the Mahadev Dubai attachment were not directly retrieved this cycle; findings rest on Tier 3 secondary reporting only. [resolved]

fim-int-2026-08-20-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-08-20-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): Tier D corridor-specific material (FinCEN alerts, UNODC narco-finance data) for Mexico and Colombia was not retrieved this cycle. [resolved]

fim-int-2026-08-20-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-08-20-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D2&#x27;}): UK ECCTA 2023 failure-to-prevent-fraud implementation status could not be refreshed against a primary FCA/SFO source this cycle. [resolved]

fim-int-2026-08-20-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-08-20-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D2&#x27;}): ED&#x27;s PMLA provisional attachment order text has not been directly retrieved; the ~INR 43,000 crore estimate rests on a single tier-3 press account. [resolved]

fim-int-2026-09-05-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-05-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D1&#x27;}): No India-specific D1 sanctions finding surfaced this cycle. [resolved]

fim-int-2026-09-05-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-05-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D4&#x27;}): Colombia-linked TBML coverage relied on the standing Black Market Peso Exchange typology rather than a fresh 2026 finding; a genuine current-cycle Colombia-specific action was not located. [resolved]

fim-int-2026-09-05-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-05-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D7&#x27;}): 6AMLD transposition status is not applicable to India as a non-EEA autonomous jurisdiction. [resolved]

fim-int-2026-09-28-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-28-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D1&#x27;}): D1 sanctions, D2 beneficial ownership, D3 enabler jurisdictions and D4 conflict finance returned no India-specific material this cycle; not asserted as settled negatives, only logged as not-yet-researched gaps. [resolved]

fim-int-2026-09-28-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-28-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D5&#x27;}): Verified current count of FIU-IND-registered VDASPs as of September 2026 is uncertain; sources conflict between approximately 49 and 54. [resolved]

fim-int-2026-09-28-G003: Tier D watch jurisdictions (Cambodi… fim-int-2026-09-28-G003: Tier D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) are out of scope for this single-JID India dispatch and were not researched here. [resolved]

fim-int-2026-10-04-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-04-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D2&#x27;}): No India-specific beneficial ownership registry development located this cycle. [resolved]

fim-int-2026-10-04-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-04-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D4&#x27;}): No India-specific conflict finance or enabler-jurisdiction development located this cycle beyond the ODI-structuring enforcement finding already captured. [resolved]

fim-int-2026-10-04-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-04-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D5&#x27;}): Exact statutory penalty provision and order date for the Binance FIU-IND PMLA penalty were not located this cycle; primary PIB/FIU-IND notice text for the 15-platform enforcement round was not directly retrieved. [resolved]

fim-int-2026-10-11-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-11-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D2&#x27;}): No dedicated beneficial-ownership-registry search was run for India this cycle; T4 tracker status is awaiting_primary_source, not a confirmed no-change. [resolved]

fim-int-2026-10-11-G002: Tier D watch jurisdictions (Cambodi… fim-int-2026-10-11-G002: Tier D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) were not actively searched this cycle; pooled union search budget was directed at India across all five consumers. [resolved]

fim-int-2026-10-18-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-18-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D1&#x27;}): No OFAC/Treasury/Federal Register primary text for the Russia-sanctions waiver was retrieved this cycle; confidence capped at Probable. [resolved]

fim-int-2026-10-18-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-18-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D5&#x27;}): No gov.in/PIB primary page for the ED enforcement statement was retrieved this cycle; confidence capped at Probable. [resolved]

fim-int-2026-10-18-G003: Mandatory Tier-D jurisdictions (KH,… fim-int-2026-10-18-G003: Mandatory Tier-D jurisdictions (KH, LA, MX, CO) were not actively searched this cycle under the IN-bound dispatch. [resolved]

fim-int-2026-10-25-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-25-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): No ED/PIB/FIU-IND primary release located confirming the All Panel Exchange/MGM91 and Kangra enforcement actions; relies on T3 press only. [resolved]

fim-int-2026-10-25-G002: Tier-D jurisdictions (Cambodia, Lao… fim-int-2026-10-25-G002: Tier-D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not actively re-searched this cycle due to pooled search budget concentrated on India; this is a coverage gap, not an asserted no-change finding. [resolved]

fim-int-2026-11-02-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-11-02-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D5&#x27;}): No dedicated crypto-asset licensing statute exists in India; oversight is distributed across FIU-IND (AML), CBDT (tax) and SEBI (where tokens are securities), with no unified VASP licence. [resolved]

fim-int-2026-11-04-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-11-04-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D5&#x27;}): No dedicated crypto-asset licensing statute exists in India; coverage of SEBI&#x27;s potential securities-law treatment of VDAs is thin. [open]

FIM-GAP-001 (D3): With the exception of casinos operating in… FIM-GAP-001 (D3): With the exception of casinos operating in Goa, India&#x27;s DNFBP sectors (real estate agents, dealers in precious metals and stones, lawyers, accountants, company service providers) are not subject to the PMLA and are not regulated or supervised for AML/CFT purposes.

FIM-GAP-002 (D3): India&#x27;s ML and TF prosecutions and convict… FIM-GAP-002 (D3): India&#x27;s ML and TF prosecutions and convictions face a substantial backlog inconsistent with the risk profile, with a high number of pending cases and accused persons in judicial custody awaiting trial conclusion.

FIM-GAP-003 (D3): India has not fully implemented a risk-bas… FIM-GAP-003 (D3): India has not fully implemented a risk-based, non-disruptive approach to protecting non-profit organisations from terrorist-financing abuse, a deficiency explicitly flagged at both the 2024 MER adoption and the June 2024 plenary outcomes statement.

FIM-GAP-004 (D2): FATF assessors recommended India enhance m… FIM-GAP-004 (D2): FATF assessors recommended India enhance monitoring of the Ministry of Corporate Affairs (MCA) company registry to ensure the availability of adequate, accurate and up-to-date basic and beneficial-ownership information on legal persons.

FIM-GAP-005 (D6): This baseline could not directly retrieve … FIM-GAP-005 (D6): This baseline could not directly retrieve primary Reserve Bank of India, SEBI or Ministry of Corporate Affairs regulatory publications during the research window; findings on RBI SupTech/AI adoption and MCA registry status rely on the FATF MER and secondary/vendor reporting rather than a direct rbi.org.in or mca.gov.in citation.

## Evidence

#### Confidence-tiered claims

Virtual Digital Asset Service Providers are designated reporting entities under PMLA s.2(1)(sa)(vi) and s.2(1)(wa). [[Source 1]](#sec-sources)

Probable · 1 source

PMLA Section 13 non-compliance notices issued to 15 offshore virtual digital asset service providers on 9 September 2026, seeking app/URL takedowns for operating without FIU-IND registration [[Source 1]](#sec-sources)

Probable · 1 source

Investigation into illegal offshore betting syndicates (Parimatch-linked) allegedly laundering over Rs2,000 crore via shell AI/tech Overseas Direct Investment structuring, exploiting the RBI/FEMA ODI route rather than hawala or crypto [[Source 1]](#sec-sources)

Probable · 1 source

RBI Governor reaffirmed cautious posture toward private cryptocurrencies/stablecoins on monetary-sovereignty, singleness-of-money and capital-flow grounds, promoting CBDC/tokenisation instead, 3 October 2026 [[Source 1]](#sec-sources)

Probable · 1 source

India remains off FATF grey/black lists, in regular follow-up category since its 2024 Mutual Evaluation, with a progress report due to the Plenary by October 2027; June 2026 Plenary changes did not affect India [[Source 1]](#sec-sources)

Probable · 1 source

Draft Guidance on Regulatory Principles for Model Risk Management, 2026 (AI &#x27;kill-switch&#x27; rules for banks/NBFCs) remains unfinalised; public comment window closed 24 July 2026, no final guidance issued as of this cycle [[Source 1]](#sec-sources)

Probable · 1 source

15 offshore VDA platforms issued PMLA s.13 non-compliance notices for lacking registration [[Source 1]](#sec-sources)

Probable · 1 source

Raised over $2 billion in H1 2026, up 42% YoY, led by CRED&#x27;s $900M Series H and KreditBee&#x27;s $280M Series E [[Source 1]](#sec-sources)

Probable · 1 source

Regular follow-up category; last evaluation September 2024; next possible onsite November 2030 [[Source 1]](#sec-sources)

Probable · 1 source

Draft KYC Amendment Directions 2026 propose a 60-day amount-limited debit hold on transactions ≥₹1,000 flagged by AI-based monitoring as linked to suspected cyber fraud [[Source 1]](#sec-sources)

Probable · 1 source

US executive order (16 Oct 2026) waives ss.112-113, suspending 100% tariff on top Russian-oil buyers including India, two days before the 18 Oct 2026 deadline [[Source 1]](#sec-sources)

Probable · 1 source

PMLA search of 20 premises alleging ~Rs800 crore laundered via crypto conversion of betting-platform proceeds (All Panel Exchange, MGM91) [[Source 1]](#sec-sources)

Probable · 1 source

Compliant/largely compliant with 37 of 40 Recommendations; partial compliance on R.8, R.12, R.28; moderate effectiveness on IO.3/IO.4/IO.10 [[Source 1]](#sec-sources)

Probable · 1 source

$2.2bn raised across 153 rounds Jan-Sep 2026 (+14% YoY); 11 acquisitions led by Indiabulls Group&#x27;s $110m purchase of Fintech Cloud [[Source 1]](#sec-sources)

Probable · 1 source

stable [[Source 1]](#sec-sources)

Uncertain · 1 source

PMLA search operation across 20 premises in 5 cities against betting platforms All Panel Exchange and MGM91, investigating mule accounts, trade over-invoicing and crypto transfers [[Source 1]](#sec-sources)

Probable · 1 source

Raid on illegal online gaming racket and associated mule bank accounts in Kangra district [[Source 1]](#sec-sources)

Probable · 1 source

Mandatory FIU-IND registration for five categories of VDA activity since 7 March 2023 [[Source 1]](#sec-sources)

Probable · 1 source

No unified VASP licence; AML via FIU-IND, tax via CBDT, securities touchpoint via SEBI only where tokens qualify [[Source 1]](#sec-sources)

Probable · 1 source

PMLA in force since 1 July 2005, binding all Reporting Entities [[Source 1]](#sec-sources)

Probable · 1 source

Targeted financial sanctions screening duty under UAPA s.51A and WMD Act s.12A [[Source 1]](#sec-sources)

Probable · 1 source

PMLA, in force since 1 July 2005, applies to all Reporting Entities, imposing CDD, record-keeping and STR obligations, with FIU-IND empowered to call for information and impose penalties. [[Source 1]](#sec-sources)

Probable · 1 source

Every reporting entity must evolve an internal mechanism for AML/CFT/CPF compliance. [[Source 1]](#sec-sources)

Probable · 1 source

Reporting entities are obliged to screen against UN Security Council-designated persons under UAPA s.51A. [[Source 1]](#sec-sources)

Probable · 1 source

Reporting entities are obliged to screen for counter-proliferation-financing targeted financial sanctions under WMD Act s.12A. [[Source 1]](#sec-sources)

Probable · 1 source

FIU-IND, established 18 November 2004, is the central agency receiving, analysing and disseminating STR/CTR intelligence from Reporting Entities. [[Source 1]](#sec-sources)

Probable · 1 source

Virtual Digital Assets are taxed at a flat 30% rate with no loss set-off, and subject to 1% TDS on transfers under s.194S; crypto regime has no dedicated licensing statute. [[Source 1]](#sec-sources)

Probable · 1 source
