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Karthik Narayan

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Senior Associate in the Financial Services Regulatory Practice (FSRP) at the Mumbai office of Cyril Amarchand Mangaldas. Karthik advises on corporate, financial regulatory matters and cross border transactions. He can be reached at karthik.narayan@cyrilshroff.com.

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

Introduction:

The rapid development and deployment of Artificial Intelligence (“AI”) and Machine Learning (“ML”) tools by market participants over the course of the past year prompted the Securities and Exchange Board of India (“SEBI”) to issue, on November 13, 2024, a consultation paper on “Proposed amendments with respect to assigning responsibility for the use of Artificial Intelligence Tools by Market Infrastructure Institutions, Registered Intermediaries and other persons regulated by SEBI” (“Draft Amendments”), seeking public suggestions on a series of amendments to the extant regulations.Continue Reading SEBI’s Proposed New Amendments on Usage of AI Tools by Regulated Entities

FIG Paper (No. 37 – Series 1) | SEBI Proposes to Introduce ‘New Asset Class’

Background and Key Features:

  • The Securities and Exchange Board of India (“SEBI”) regulates the asset management and wealth management sector through a graded approach in relation to prudential, governance and investment norms, with flexibility given progressively, basis minimum investment threshold. This sector has also seen a significant rise in assets under management (“AUM”) over the last decade:

Continue Reading FIG Paper (No. 37 – Series 1) | SEBI Proposes to Introduce ‘New Asset Class’

New SEBI FPI Beneficial Owner Disclosure Norms

Introduction:

The Foreign Portfolio Investor (“FPI”) regime is a foreign investments’ entry route in India, whereby FPIs can invest in Indian securities, subject to compliance with India’s foreign exchange control laws and the regulatory framework issued by the Securities and Exchange Board of India (“SEBI”). As part of the Know Your Customer (“KYC”) process for FPI registration, identification and verification of Beneficial Owner(s) (“BO”) is required to be undertaken as per Rule 9 of the Prevention of Money Laundering (Maintenance of records) Rules, 2005 (“PMLR”),[1] which is a part of the Indian AML/ CFT legal framework.Continue Reading New SEBI FPI Beneficial Owner Disclosure Norms

FIG Paper - Navigating SEBI’s Definition of UPSI

Introduction:

The objective of the PIT Regulations is to prohibit insiders with access to Unpublished Price Sensitive Information (“UPSI”) from making illicit gains and to ensure timely, adequate and even disclosure of UPSI to the public. Hence, the determination of what constitutes as UPSI becomes necessary. In this regard, the Securities and Exchange Board of India (“SEBI”) has signalled a shift from a principle-based regime to a more prescriptive regime, which is likely to result in increased compliance obligations for the listed companies.Continue Reading FIG Paper (No. 26 – Series. 3): Navigating SEBI’s Definition of UPSI