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

 

 

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.

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

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

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

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