Photo of Anu Tiwari

Anu Tiwari

Head – Fintech & Financial Service Regulatory & Senior Director at the Singapore office of 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

 

 

FIG Paper No. 62 (VDA Series 12): Regulating Virtual Digital Assets: Global Trends and India’s Emergent Supervisory Architecture

Summary: India’s approach to regulating virtual digital assets (VDA) is evolving from fragmented enforcement towards a structured supervisory framework. This aligns with global trends in the US, UK and EU, of adopting activity-based regimes focused on governance, disclosure, consumer protection and stablecoin oversight. In India, parliamentary consultations, enhanced tax reporting, and increased enforcement actions signal a maturing regulatory outlook. The FIG Paper provides guidance to VDA businesses on navigating India’s current supervisory and enforcement developments whilst preparing for future regulation.

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FIG Paper No. 61: RBI’s Draft Data Governance Guidance: An Overview

Summary: The RBI has released the Draft Guidance on Regulatory Expectations for Data Governance, proposing a comprehensive enterprise-wide framework applicable across banks, NBFCs, payment banks, co-operative banks, CICs, and other regulated entities. The Draft Guidance emphasises board oversight, defined data governance roles, lifecycle-based controls, SSOT architecture, metadata and lineage management, data classification, data quality processes…

FIG Paper No. 60 - COMPARATIVE ANALYSIS – Comparative Analysis – Master Direction On Prepaid Payment Instrument, 2021, And Draft Directions On Prepaid Payment Instrument, 2026

Summary: Continuing the overhaul exercise, RBI has released the draft master directions on PPI which proposes a significant change to the existing framework, aimed at simplifying classification, strengthening regulatory oversight, and curbing misuse of prepaid instruments. These reforms signal RBI’s intent to align the PPI ecosystem with evolving risk considerations while promoting a more streamlined framework.

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FIG Paper No 59 – AI in Indian Financial Services: Balancing Innovation with Accountability and Regulation

Summary: As artificial intelligence reshapes the contours of India’s financial landscape, regulated entities find themselves navigating a delicate balance between harnessing transformative innovation and managing its inherent risks spanning algorithmic bias, model opacity, and systemic concentration. The RBI’s establishment of the FREE-AI committee signals a decisive regulatory commitment to responsible AI governance, anchored in principles of accountability, fairness, and explainability. The paper ultimately calls upon regulated entities to embed these imperatives at the very foundation of their AI frameworks, underpinned by robust data governance and a culture of institutional vigilance.

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FIG Paper No 58: RBI Issues Operating Framework for Facilitating Outward Remittance Services by Non-Bank Entities

Introduction

The Foreign Exchange Department, Reserve Bank of India (“RBI”), on May 13, 2026, issued a circular titled ‘Operating framework for facilitating Outward Remittance services by non-bank entities through Authorized Dealer (Category I) Banks (“AD Banks”) in India’ (“Outward Remittance Circular”), which:

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FIG Paper No. 57 (VDA Series 11): India Digital Assets Round-Up: Recent Regulatory and Market Developments

Summary: This FIG Paper examines recent global regulatory and market developments in digital assets, including Hong Kong’s first stablecoin licences, countries finalising their digital assets regulatory frameworks, and BIS warnings on stablecoin-driven dollarisation. It then analyses India’s evolving response through the revised FIU-IND registration regime, tightening tax reporting and enforcement trends, and the RBI’s evolving regulatory response to stablecoins.

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UPI Goes Global: The Regulatory Reckoning Ahead

Summary: India’s push to internationalise UPI promises faster, cheaper, and more seamless cross-border payments, while also exposing deep regulatory and legal issues. This article explains why real-time payment speed is outpacing compliance frameworks across spanning foreign exchange rules, AML/KYC obligations, data localisation, and supervisory oversight and why resolving these tensions is critical for UPI’s global scalability. For regulators and financial institutions, it highlights what must evolve for cross-border digital payments to succeed.

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Payments Vision 2028: Way Forward

Summary: The Payments Vision 2028 themed “Shaping India’s Payment Frontier” lays out the strategic direction for payments regulation till December 2028. The regulator’s focus is on strengthening accountability among regulated entities, building customer trust, and enhancing the resilience of payment systems. Key proposals include a cyber risk monitoring regime for non-bank PSOs, a Payments Switching Service enabling customers to redirect payments across bank accounts, and interoperability mandates for card networks and TReDS platforms, amongst others.

Continue Reading FIG Paper No. 56 : Payments Vision 2028: Way Forward
FIG Paper No. 55 (VDA Series 10): India’s First Asset Tokenisation Bill: What It Means for the Digital Assets Space

Summary: The Asset Tokenisation (Regulation) Bill, 2026, introduced in the Rajya Sabha on March 14, 2026, is India’s first dedicated legislative proposal for regulating and licensing tokenised real-world assets. Significantly, it proposes a novel multi-regulator model in light of global standards and provides a pathway for regulating tokenised assets, including stablecoins. 

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FIG Paper No. 54 (VDA Series 9): Recent Delhi High Court Rulings: Learnings for Digital Asset Players

This FIG paper examines in detail the recent Delhi High Court rulings, which have clarified the scope of judicial remedies available for cryptocurrency exchange users in India and distils important lessons for virtual digital asset (“VDA”) industry players.

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