PROJECT SOVEREIGN // DAY 01

Regulatory Corpus

RBI + DPDP Act 2023 + GDPR Art 44-49. Searchable. No hallucinations. Source of truth for all future agents.

RBIRBI-2018Penalty: RBI Audit, License Risk

Storage of Payment System Data - India Only

All data relating to payment systems must be stored in India only. No copy outside India.

Applies to: Payment data, transactions

Allowed: IN

DPDP Act 2023DPDP-16Penalty: Up to 250Cr INR

Cross-border transfer restriction

Govt may notify that personal data cannot be transferred outside India. Transfer needs consent.

Applies to: Aadhaar, PAN, financial data

Allowed: IN, Conditional

GDPRGDPR-44Penalty: 20M EUR or 4% turnover

Adequacy or SCCs required for EU transfer

Transfer outside EU only with adequacy decision or SCCs / BCRs.

Applies to: EU personal data

Allowed: EU, Adequate, With SCCs

RBIRBI-TOKENPenalty: Non-compliance penalty

Tokenisation of card data

No entity other than issuer can store actual card data. Must tokenise.

Applies to: Card data

Allowed: IN Token Vault

DPDP Act 2023DPDP-8Penalty: High

Data fiduciary must ensure safeguards

Data fiduciary must protect personal data and ensure processor has safeguards.

Applies to: All personal data processing

Allowed: IN

GDPRGDPR-5Penalty: 10M EUR

Purpose limitation and data minimisation

Collect only what is necessary for specified purpose.

Applies to: EU data

Allowed: EU

RBIRBI-CYBERPenalty: Audit observation

Cyber Security Framework for Banks

Banks must have audit trail, access logs for all data access.

Applies to: Bank systems

Allowed: IN

DPDP Act 2023DPDP-CONSENTPenalty: 250Cr

Consent must be free, specific, informed

Consent artifact must be maintained, withdrawable.

Applies to: Personal data

Allowed: IN

GDPRGDPR-33Penalty: 10M EUR

Breach notification within 72 hours

Notify DPA within 72 hours of breach awareness.

Applies to: EU data breaches

Allowed: EU

Enterprise RiskERM-MODELPenalty: Model Risk Management finding

AI Model Risk must be logged

All AI models using PII must have model risk register, evals, and approval.

Applies to: AI models in banks

Allowed: Governance Required

Tangible Outcome: 10 curated rules, searchable, deployed. Tomorrow this becomes the knowledge base for our Data Sovereignty Guard agent.