No real funds, custody or blockchain transfers.
TRADEBuild compliance first.
Enable live trading last.
This workspace maps the operational controls required before ChatOnYou can consider real VDA exchange, transfer or custody services.
AML/CFT VDA Guidelines updated 08 January 2026 are the readiness baseline. This is not FIU registration.
Compliance, security and legal review must pass first.
Six control systems before live.
Each workstream needs documented ownership, tested technology and evidence that can be demonstrated to FIU-IND.
Entity & governance
FIU-IND registration, an India-based Principal Officer and a separate Designated Director must be in place.
- ✓FINGate application and RE-ID
- ✓Board-approved AML/CFT/CPF policy
- ✓Annual risk assessment and independent audit
Client due diligence
Live onboarding will require verified identity, contact, financial and device-level evidence.
- ✓PAN plus accepted identity document
- ✓Liveness selfie, IP and geolocation
- ✓OTP contact checks and bank penny-drop
Transaction monitoring
Every live transfer must be continuously monitored and reconstructable from its source to destination.
- ✓Blockchain analytics and wallet screening
- ✓Alert review and STR escalation
- ✓Five-year tamper-resistant records
Travel Rule
Originator and beneficiary information must travel securely before or with every applicable VDA transfer.
- ✓PAN, identity and verified address
- ✓Names and wallet/account addresses
- ✓No post-facto information submission
Sanctions controls
Screening must run during onboarding, KYC changes, list changes and every live VDA transaction.
- ✓UNSC, UAPA and WMDA screening
- ✓Hold transfer until screening clears
- ✓Re-screen when sanctions lists change
Cybersecurity & records
A CERT-In empanelled audit must cover the complete environment used for notified VDA services.
- ✓Wallet, API and cryptographic controls
- ✓Incident detection and reporting readiness
- ✓Backup, recovery and complete audit trails
Guidelines added now. Registration follows separately.
Risk-based customer due diligence, beneficial-owner identification, enhanced checks and ongoing KYC updates.
Customer and transaction risk assessment, continuous monitoring, alert review and documented escalation.
Secure originator and beneficiary information sharing, transaction traceability and five-year record retention.
STR reporting, sanctions screening, Principal Officer oversight, staff training, audit and policy governance.
Operating model review in progress.
Internal scope is documented below. It is not an independent legal, tax, custody or financial-control opinion.
Customer-funds boundary
ChatOnYou does not accept, hold, pool or transfer customer money.
- ✓No deposits or withdrawals
- ✓No pooled settlement account
- ✓No production payment rail
Custody boundary
ChatOnYou does not custody VDAs, hosted wallets, seed phrases or customer private keys.
- ✓No hosted wallet service
- ✓No withdrawal signing capability
- ✓Testnet credentials remain user-scoped
Execution boundary
Execution is limited to paper trading and Binance Spot Testnet virtual assets.
- ✓Real-money execution locked
- ✓No leverage or futures
- ✓Owner approval cannot bypass compliance gates
Ledger and reconciliation
Any future money or asset flow needs segregated ledgers, daily reconciliation and maker-checker controls.
- ✓Customer and corporate funds separation
- ✓Exception and suspense-account workflow
- ✓Independent balance verification
Tax operating model
GST registration is recorded, but product-specific GST, fee, VDA and withholding treatment needs professional confirmation.
- ✓Fee invoice and GST mapping
- ✓TDS and transaction-reporting design
- ✓Period-end tax reconciliation
Incidents and redressal
Complaints, freezes, refunds, disputes and incident actions need approved ownership and immutable audit records.
- ✓Customer grievance workflow
- ✓Freeze and release authorisation
- ✓Incident evidence and retention
Live stays locked until every gate clears.
Confirm which proposed services are notified VDA activities under PMLA.
Complete documents, in-person systems demonstration and obtain formal RE-ID.
Complete CERT-In cybersecurity audit and independent AML control review.
Test KYC, monitoring, Travel Rule, sanctions and incident response end to end.
PRODUCT BOUNDARY
What ChatOnYou can do now.
- ✓Virtual ₹10,000 paper balance
- ✓Illustrative AI decisions and risk checks
- ✓Saved simulated orders and analytics
WHAT REMAINS BLOCKED
What waits for formal readiness.
- ×Real deposits, withdrawals or custody
- ×Live exchange order execution
- ×Hosted-wallet VDA transfers