RBI Regulatory Sandbox · Cross-Border Payments Cohort · Proposal

Money shouldn’t cross a border for value to move across it.

A pre-funding-free remittance rail between the UAE and India — settled in e‑Rupee and a regulated AED token, bound by atomic payment-versus-payment. Opposing flows fund each other locally; only the net imbalance ever needs to settle.

Corridor AED ↔ INR Settlement e-Rupee · AEDZ Indicative ~USD 300m / month Novel ask one netting permission

Discussion draft — counterparties, volumes and regulatory characterisations are indicative and subject to confirmation.

UAE INDIA AEDZ POOL recirculates locally collects inbound AED pays outbound AED e-RUPEE POOL locus of netting collects inbound INR pays outbound INR ATOMIC PvP LINK VALUE NEVER CROSSES THE BORDER Matched opposing flows fund each other locally. Either both legs settle, or both refund.
~6%
global average cost of a $200 remittance (World Bank) — against a 3% SDG target
1–3 days
typical settlement time across correspondent chains
100%
of payout value pre-funded in nostro accounts under the status quo
1
novel regulatory permission this proposal requires
What exists today

The constraint isn’t messaging. It’s trapped capital.

Cross-border retail payments are slow and expensive not because messages travel slowly, but because providers must lock working capital in destination accounts before value has arrived. Faster messaging — or swapping fiat for stablecoins — changes the instrument, not the requirement.

Today — the pre-funded chain
SenderAED UAE bankSWIFT msg NOSTROpre-funded INRidle capital BeneficiaryINR · T+1–3 Every corridor, every provider: capital parked ahead of every payout, scaling with gross volume
  • Nostro capital scales with gross volume — the more you move, the more you trap
  • Settlement risk managed by delay: batches, cut-offs, T+1–3
  • FX margin + fees stack across 3–5 intermediaries
  • Stablecoin “workarounds” still pay out from pre-funded local liquidity
Proposed — netted local loops
AED staysin the UAE INR staysin India ATOMIC PvP Matched flows fund each other in minutes; only the net imbalance settles separately
  • Capital scales with the net imbalance and timing variance — not gross volume
  • Settlement risk removed by construction: both legs settle or both refund
  • One firm quote inside an IBR-anchored band — no slippage, no stacked margins
  • 24/7 settlement in central-bank money on the India leg from day one
How it works

Five steps. All-or-nothing. No oracle on the safety path.

Each matched pair settles through an asymmetric atomic PvP: a native hashlock on the public-chain AEDZ leg, an emulated conditional hold on the e-Rupee leg at a regulated settlement-node bank. The regulated party always moves first. Click through the lifecycle:

Order & match

A sender’s order enters as a marketable limit order, priced within a volatility-elastic band anchored to the interbank reference rate. A multilateral netting cycle (~5 minutes, dynamic) pairs opposing AED→INR and INR→AED flows, with partial and divisible fills to maximise the match ratio.

Rate certainty for the consumer; no AMM, no slippage, no front-running.

Node-first revelation. The regulated settlement node acts first and publishes the secret; the trustless AEDZ leg follows deterministically. No oracle sits on the safety-critical path.
T_A > T_e + finality margin. The public-chain claim stays replayable until T_A, so a deep reorg cannot strand the node. Residual risk is parameter calibration, not structure.
Segregated, bankruptcy-remote wallet. e-Rupee under hold is ring-fenced, CCIL-style. A node insolvency triggers the atomic abort; both legs refund in full.
Atomic by construction. Either both beneficiaries are paid, or both legs refund. There is no state in which one side loses principal.
The liquidity case

Capital scales with the net — not the gross.

Move the sliders. The model is illustrative, but the structure is the point: under correspondent banking, working capital is a multiple of daily gross flow; under netted PvP it collapses to the unmatched residual plus a marginal timing buffer.

Indicative v1 scope is ~USD 300m / month across both directions.
Share of flow that finds an opposing flow inside a netting cycle. UAE→India is lopsided; v2 multi-corridor netting raises this.
Days of gross flow typically parked ahead of payouts across the chain.
Correspondent model — pre-funded nostro$30.0m
This rail — residual + timing buffer$6.5m
−78%
working capital locked against the corridor
Honest definition: “pre-funding-free” means free of the structural, gross-volume-scaled nostro. A marginal LP-provided buffer is always required by design, and the unmatched residual is reset periodically over a licensed wholesale settlement rail.
Regulatory architecture

Built inside existing frameworks. One new permission.

Every gross leg rides a framework RBI already supervises — RDA or MTSS for inbound personal remittances, LRS via an AD-II for outbound. Money already does not cross the border under these schemes. The rail changes how the legs are funded, not how they comply.

THE SINGLE NOVEL ASK

Permission to net an independently-compliant inbound e-Rupee leg against an independently-compliant outbound e-Rupee leg. Each gross leg stays scheme-compliant; only liquidity is netted — and programmability gives the regulator a per-leg audit trail that no correspondent chain can offer.

RDA / MTSSinbound personal remittances
LRS via AD-IIoutbound, current-account purposes
CCIL-grade nettingno CCP, no novation, no default fund
Privacy-preserving audithashed KYC/AML commitment on-ledger, never PII
Tax & fees out of remitTCS, levies, PSP fees stay with originators
DimensionCorrespondent / SWIFT todayThis rail (v1 sandbox)
Working capitalPre-funded nostro, scales with gross volumeNet imbalance + marginal timing buffer
Settlement riskManaged by delay and exposure limitsEliminated by construction (atomic PvP)
SpeedT+1–3, batch cut-offs, business hoursNear-real-time, 24/7 netting cycles
AuditabilityFragmented across intermediariesPer-leg, on-ledger, purpose-coded
Consumer rateMargins stack across the chainOne firm quote in an IBR-anchored band
Compliance perimeterEstablished, well understoodUnchanged — same schemes, same originator obligations
Why now

Central-bank research already points here.

The building blocks are individually proven in BIS Innovation Hub work. What has never been done is joining them on a live retail corridor — with a regulator-grade liquidity answer. India’s e-Rupee pilot makes the AED–INR corridor the first place this can exist in production.

BIS Project RialtoFX settlement joining wholesale CBDC with instant retail payments — validates the settlement core this rail adapts.
BIS Project NexusConnecting instant payment systems multilaterally — validates the many-originators, few-nodes network shape.
Mariana · Meridian · Jasper–UbinAtomic PvP and cross-ledger settlement repeatedly proven in central-bank experiments — never yet productised on a retail corridor.
Scope discipline

A narrow v1. A committed path beyond it.

The sandbox application is deliberately bounded to what must be proven. The network properties the infrastructure unlocks are claimed openly — and committed as post-sandbox extensions, not smuggled into v1.

v1 — in the sandbox

Bounded & provable
  • AED ↔ INR, personal remittances only, two-way
  • e-Rupee + AEDZ settlement; atomic PvP with multilateral netting cycles
  • One settlement-node bank (a participating e-Rupee pilot bank), one AD-II outbound originator
  • Marginal LP-provided buffer; residual reset over a licensed wholesale rail
  • Success = demonstrable netting of compliant legs, zero principal loss, full auditability
Who is proposing this

Saber Money

Saber builds cross-border payments infrastructure and operates regulated money movement at scale today. The rail proposed here is not a whitepaper exercise — it is the next architecture for flows we already run.

FIU-IND registered Licensed MSB — Canada Exclusive BFI partner, INR payouts — Circle Payments Network $3B+ cross-border volume 40+ countries

Let’s build the first pre-funding-free corridor.

The full concept note, technical annex and legal comparison note are available on request. We’d welcome a working session with your team.

edul@mudrex.com