Photo of Anu Tiwari

Anu Tiwari

Partner (Head - Fintech and FSRP) at Cyril Amarchand Mangaldas. Anu represents Indian and multinational banking, broker-dealer, exchange, asset management, speciality finance, fintech and information/ emerging technology companies on transactional, enforcement and regulatory matters. His transactional practice focus is on public & private M&A, capital raising, commercial agreements and activism matters. Anu advises financial services clients on matters before the Reserve Bank of India (RBI), Securities and Exchange Board of India (SEBI), Ministry of Finance, Enforcement Directorate and appellate tribunals. He can be reached at anu.tiwari@cyrilshroff.com

 

 

FIU-IND’s Annual Report 2024-25: Trends and Takeaways for India’s Digital Assets Industry

Introduction

The Financial-Intelligence Unit – India (“FIU-IND”), India’s nodal enforcement agency for anti-money laundering and combatting the financing of terrorism (“AML/CFT”), has released its Annual Report (“Report”) for FY 2024-25.[1] The Report signals two clear trends: one, the continued expansion of India’s digital assets industry, with a focus on bringing offshore virtual digital asset service providers (“VDASP”) within the regulatory ambit; and two, the FIU-IND’s emphasis on data-driven information sharing for enforcement. This FIG Paper explores key areas of the FIU-IND’s focus in the previous year and offers insights into the future of digital assets regulation in the new year.Continue Reading FIG Paper No. 53 (VDA Series 8) FIU-IND’s Annual Report 2024-25: Trends and Takeaways for India’s Digital Assets Industry

FIG Paper (No. 52): RBI Directions on Lending Against Gold and Silver Collateral: A Harmonised Regulatory Framework

Summary: The Reserve Bank of India (Lending Against Gold and Silver Collateral) Directions, 2025, notified on June 6, 2025, establishes a unified regulatory framework for lending against gold and silver collateral by all regulated entities and prescribes a deadline of April 1, 2026, for implementation. These directions provide a single principle-based regulation, addressing systemic issues in the gold loan sector whilst introducing enhanced customer protection measures, standardised assaying protocols, and transparent collateral management processes to create a more robust and customer-centric ecosystem. As regulated entities gear up to adopt the necessary changes by the prescribed deadline, this paper summarises the key changes and compliances laid down by the directions while specifying the important aspects that lenders need to focus on.Continue Reading FIG Paper (No. 52): RBI Directions on Lending Against Gold and Silver Collateral: A Harmonised Regulatory Framework

FIG Paper No. [51] (VDA Series 7): Stablecoins: Recent Indian and Global Regulatory Trends

Introduction

The global stablecoin market capitalisation has crossed USD 230 billion in 2025, representing a growth trajectory that can position stablecoins as critical financial instruments that enterprises can leverage in emerging digital payment corridors and enhance operational competitiveness in global markets.Continue Reading FIG Paper No. 51 (VDA Series 7): Stablecoins: Recent Indian and Global Regulatory Trends

FIG Paper No. 50: Recent SEBI Changes – Implications for Intermediaries

Summary: SEBI has recently approved various rule changes for intermediaries such as stock-brokers, REITs/ InvITs, IAs, RAs, FPIs, and angel funds, with a view to ease entry norms and compliance obligations, provide flexibility and to attract more retail and foreign investments. This paper summarises the key changes and their implications for intermediaries.Continue Reading FIG Paper No. 50: Recent SEBI Changes – Implications for Intermediaries

FIG Paper no. 48: Change in Control & Learnings in FIG space

Mergers and acquisitions (M&A) in the banking, financial services, and insurance (BFSI) sector constituted approximately 10% of all M&A activity in India in 2024, exceeding USD 12.1 billion[1] in value, making it the second highest among all sectors. Infrastructure and BFSI are expected to continue driving M&A deal activity in India. Recently, India is seeing several large M&A transactions involving complex structuring, regulatory approvals on account of change in control, bespoke due diligence and documentation considerations and nuanced approach to regulatory interface before and after deal signing to obviate deal failure risks. Basis our recent experience, and change in control provisions applicable to banks, non-banks, payment system operators (PSOs), mutual funds and insurance players, this paper provides an overview of the specific deal and change in control linked regulatory approvals and learnings / considerations relevant from a transaction structuring and deal execution perspective, across each of the BFSI verticals.Continue Reading FIG Paper no. 48: Change in Control & Learnings in FIG space

FIG Paper No. 47 (VDA Series 6) – Exploring Synergies between Traditional Finance and Decentralised Finance for India

Introduction

A decade after the emergence of cryptocurrencies, regulatory outlooks from the traditional finance sector (“TradFi”) toward banking activities in the digital assets sector (“DeFi”) have evolved significantly. This shift signifies growing institutional acceptance of digital assets as legitimate financial instruments.Continue Reading FIG Paper No. 47 (VDA Series 6) – Exploring Synergies between Traditional Finance and Decentralised Finance for India

Introduction:

Technology has fundamentally transformed the financial services industry, with many contemporary financial institutions (“FI”) adopting a digital-first or exclusively online business model. With third-party technology service providers handling critical functions for FIs, as outsourced partners, regulators such as the Reserve Bank of India (“RBI”), Securities and Exchange Board of India (“SEBI”) and the Insurance Regulatory and Development Authority of India (“IRDAI”) have issued their respective guidelines on outsourcing/ adoption of cloud services.[i] Additionally, FIs are also required to comply with general data protection laws.[ii]Continue Reading FIG Paper (No. 46 – Series 3): Contracting Considerations for Financial Institutions

FIG Paper (No. 45 - Series 3) – SEBI Mulls Relaxation of FPI Norms for Investment in Government Bonds

Background

The Foreign Portfolio Investor (“FPI”) regime is a key entry route for foreign investors seeking to invest in Indian stocks and bonds. Currently, FPIs are subject to various know your customer (“KYC”) obligations, including disclosure of group companies and beneficial ownership and stringent monitoring of equity investment limits. Breaches of these trigger penalties and additional disclosure requirements. Our detailed analysis is available here.Continue Reading FIG Paper (No. 45 – Series 3) – SEBI Mulls Relaxation of FPI Norms for Investment in Government Bonds

FIG Paper (No. 44 - Series 3): RBI Consolidates Directions on Digital Lending: Implications for REs & LSPs

Background:

The Reserve Bank of India (“RBI”) on May 8, 2025, issued the Reserve Bank of India (Digital Lending) Directions, 2025 (“DL Directions”).

The idea of these new directions was to consolidate the various directions and circulars on digital lending by Regulated Entities (“RE”), previously issued by the RBI[1], provide greater clarity on consumer/ customer centric rights from a customer protection point of view and create a repository with the RBI of all digital lending apps/ platforms (“DLA”) provided by REs/ lending service providers (“LSP”).Continue Reading FIG Paper (No. 44 – Series 3): RBI Consolidates Directions on Digital Lending: Implications for REs & LSPs

FIG Paper (No. 43 – VDA Series 5) India’s Stablecoin Industry – Reacting to Global Regulations & Market Trends

Stablecoins, which are virtual digital assets (“VDA”) typically pegged to stable assets like fiat currencies, are being recognised as the cornerstone of digital finance revolution, delivering a blend of traditional currency stability and decentralised innovation. As their global adoption accelerates — from everyday retail transactions/ cross-border remittances to institutional treasury operations — governments worldwide are realising that clear, forward-thinking regulation can foster innovation and help their economies stay ahead of the pack.Continue Reading FIG Paper (No. 43 – VDA Series 5) India’s Stablecoin Industry – Reacting to Global Regulations & Market Trends