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

 

 

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

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