In the ongoing discussions around the WazirX restructuring, a recurring question has emerged:

Does Zettai, the Singapore-based entity, need to register with India’s Financial Intelligence Unit (FIU-IND)?

This question gained attention after concerns were raised during the Singapore court proceedings. However, a closer look at Indian law makes the answer quite clear: Zettai is NOT required to register with FIU-IND, and expecting otherwise reflects a misunderstanding of how crypto compliance currently works in India.

India Has No Licensing Regime for Crypto (Yet)

First, it’s important to understand the regulatory environment in India. As of now, India does not have a formal licensing system for crypto exchanges. The only existing compliance obligation comes from a March 2023 notification under the Prevention of Money Laundering Act (PMLA). This notification brought certain Virtual Digital Asset (VDA) service providers under the scope of “reporting entities.”

But what does that actually mean?

It means these entities must conduct KYC checks, file Suspicious Transaction Reports, and maintain transaction records. These requirements are compliance-focused — not licensing-based. FIU-IND registration is meant for entities that deal directly with Indian users and INR transactions, not for every business involved in crypto infrastructure or backend support.

Zettai vs. Zanmai: Who Handles What?

In WazirX’s case, the division of responsibility is crystal clear:

• Zanmai Labs, the India-based entity, handles INR deposits and trading pairs. It is already registered with FIU-IND and complies with all requirements under Indian law.

• Zettai, incorporated in Singapore, does not handle INR, does not manage fiat accounts, and does not onboard Indian users. Its role was limited to backend infrastructure and, now, a one-time crypto distribution as part of a court-approved scheme.

Under current law, Zettai’s activities do not trigger the need for separate FIU registration. The idea that every offshore or supporting entity must register stretches the law far beyond its intended purpose.

This Structure Is the Industry Norm — Not an Exception

Zettai’s role in WazirX isn’t unusual. In fact, this dual-entity model is standard across the crypto industry — especially in jurisdictions like India, where regulation is still evolving.

Consider these examples:

• ZebPay operates with an Indian entity that’s FIU-registered, while its offshore arm manages the crypto backend.
• CoinDCX partners with BitGo, a US-based custodian, to hold assets securely. Their Indian entity handles INR trading and compliance.
• Even Binance, the world’s largest exchange, used global entities to offer services in India. Only after FIU show-cause notices in 2023 did one Binance group entity register — confirming that only one entity typically registers, even when others are involved operationally.

If Zettai was forced to register separately, the same logic would apply to these other platforms too — breaking the current operational norm across the entire crypto sector.

Stretching the Law Doesn’t Help Anyone

The idea of forcing Zettai to register with FIU-IND simply doesn’t align with how the current system works. It would require every backend service, offshore custodian, or infrastructure provider linked to Indian users to register — even if they don’t touch INR or onboard users directly.

That’s not the law, and more importantly, it’s not how FIU operates.

The current framework is built around targeted compliance, focusing on the part of the business that interacts with the Indian financial system. That role is already being fulfilled by Zanmai Labs.

Conclusion: Zettai Is Within the Law

Zettai’s structure is not an exception — it’s in line with both the letter of the law and industry best practices. It doesn’t handle INR or Indian users, and it’s stepping back from operations to avoid legal overlap. With Zanmai Labs registered and managing all India-facing activities, the regulatory requirements are being met properly.

In short, there is no legal basis for demanding that Zettai register separately with FIU-IND.

The major focus should be on supporting lawful, compliant solutions that enable crypto users to move forward, not complicating things with interpretations the law doesn’t call for.

All eyes are now on the upcoming court hearing scheduled for July 15, with July 16 reserved as a backup date. This moment could prove pivotal not just for WazirX users, but for the broader Indian crypto ecosystem. With the operational shift from Zettai to Zanmai Labs — a move that aligns with legal norms and regulatory expectations — WazirX has taken a strategically sound step toward compliance and clarity. The industry is watching closely, and there’s a shared sense of optimism that this restructuring will finally pave the way for resolution and restored trust.