Photo of Janak Panicker

Associate in the corporate and financial regulatory practice at the Mumbai office of Cyril Amarchand Mangaldas. Janak has represented various Indian and multinational fintech, and emerging technology companies on transactional, enforcement and regulatory matters. His transactional practice focus is on public & private M&A, commercial agreements and regulatory matters. He can be reached at janak.panicker@cyrilshroff.com

FIG Papers No. 6 - Series–2 RBI Payment Regulations – 2009 to 2021 - Bank ‘nodals’ to PA PG licenses Blog

Introduction:

In our previous FIG Paper, we shared key learnings from our experience in connection with the payment aggregator and payment gateway guidelines (“PA/PG Guidelines”) issued by the Reserve Bank of India (“RBI”) on March 17, 2020. Based on representations received from various industry associations and payment intermediaries, the RBI has formalised the clarifications (initially issued on September 17, 2020) relating to the PA/PG Guidelines on March 31, 2021 (“Clarifications”).
Continue Reading FIG Papers (No. 6: Series–2) RBI Payment Regulations – 2009 to 2021: Bank ‘nodals’ to PA/PG licenses!

RBI Payment Regulations - 2009 to 2021 - Bank nodals to PA PG licenses

Introduction:

In early March 2020, a regulatory moratorium imposed on a private bank in India froze the country’s digital payments ecosystem. Many payment aggregators (“PA”) and payment gateways (“PG”) had set up nodal accounts with this bank, including others, and it raised a question on whether the customer funds pooled in those accounts were bankruptcy ‘remote’. Within 10 days, the Reserve Bank of India (“RBI”) issued the payment aggregator and gateway guidelines (“PA/PG Guidelines”) on March 17, 2020, under the Payment and Settlement Systems Act, 2007 (“PSSA”), to regulate PAs and prescribe baseline technology standards for PAs and PGs.
Continue Reading FIG Papers (No. 5 : Series -1) : RBI Payment Regulations – 2009 to 2021: Bank ‘nodals’ to PA/PG licenses!