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  • What Fintechs Must Know About Grievance Redressal, Impersonation, and Digital Compliance

    What Fintechs Must Know About Grievance Redressal, Impersonation, and Digital Compliance

    India’s fintech ecosystem (lending apps, stock broking apps, wealth management and PMS businesses- “regulated entities”), operates at the intersection of technology, finance, and regulation.

    While innovation and widespread digitization have accelerated access to credit, payments, investments, and digital banking, it has also expanded the attack surface for fraudsters.

    Fake customer-support numbers, social media, WhatsApp, Telegram presence, clone websites, impersonated mobile apps, and misleading advertisements have become routine tools for financial crime.

    Recognising these risks, Indian regulators and lawmakers have strengthened the legal framework governing online platforms, intermediaries, and digital content.

    The Information Technology Act, 2000 (IT Act) and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 now play a direct role in how fintechs protect customers, manage brand misuse, and demonstrate compliance.

    For regulated financial entities, these laws are no longer abstract “platform regulations”. They are deeply connected to consumer protection, fraud prevention, grievance handling, and supervisory expectations from RBI, SEBI, and other regulators.

    From the IT Act, 2000, to the 2021 Intermediary Rules

    The IT Act, 200,0 laid the foundation for India’s digital economy by recognising electronic records, digital signatures, and cyber offences.

    Of particular importance to fintechs is Section 79, which introduced intermediary liability and the concept of safe harbour.

    However, the scale and sophistication of digital fraud have increased dramatically since 2000.

    Financial scams today rely heavily on:

    • Impersonation of key stakeholders
    • Misuse of brand names and logos
    • Fake customer care presence
    • Fake apps and phishing websites
    • Fraudulent ads and social media posts
    To address this, the government notified the Intermediary Guidelines and Digital Media Ethics Code Rules, 2021, which significantly tightened due-diligence, grievance-redressal, and content-takedown obligations.
    For fintechs, the practical implication is clear: digital fraud and impersonation risks now intersect directly with statutory compliance obligations.

    Who Is an “Intermediary” and Why It Matters to Fintechs

    Broad Definition, Real Impact

    Under the IT Act, an intermediary includes any entity that receives, stores, transmits, or provides services related to electronic records on behalf of another person.

    This includes:

    • App stores hosting fintech applications
    • Search engines displaying fintech ads and links
    • Social media platforms where brands communicate with users
    • Marketplaces and aggregators distributing financial products

    Messaging platforms are used for customer communication

    While fintechs themselves may not always be intermediaries, their digital presence is entirely dependent on intermediaries. Any impersonation or misuse occurring on these platforms directly affects fintech customers and brand trust.

    Conditional Safe Harbour

    Intermediaries enjoy safe-harbour protection under Section 79 only if they comply with prescribed due-diligence obligations.

    This protection is conditional on:

    • Publishing clear content policies
    • Acting on complaints and lawful notices
    • Removing or disabling access to unlawful content promptly
    If intermediaries fail to act, regulators increasingly expect regulated financial entities to demonstrate that they took reasonable steps to flag and mitigate the risk.

    Rule 3 of the IT Rules, 2021: Due Diligence and Fintech Risk

    Rule 3 sets out detailed due-diligence requirements that have direct relevance for fintech-related fraud.

    Mandatory Policies and User Communication

    Intermediaries must publish rules, privacy policies, and user agreements that prohibit hosting or sharing unlawful content.

    Importantly, these policies must clearly cover content that:

    • Is patently false or misleading
    • Impersonates another person or entity
    • Facilitates fraud, cheating, or deception

    This explicitly covers many common fintech scam vectors, including fake loan offers, fraudulent investment guarantees, and impersonated customer-support channels.

    Impersonation and Fraud A Core Compliance Risk for Fintechs

    Impersonation and Fraud: A Core Compliance Risk for Fintechs

    Rule 3 and Impersonation Content

    Rule 3(1)(b) specifically identifies impersonation and misleading information as prohibited categories. Once notified, intermediaries are required to restrict such content.

    For fintechs, this means:

    • Fake apps using similar names or logos
    • Look-alike websites mimicking login pages
    • Social media accounts posing as official handles
    • Ads falsely claiming association with regulated entities

    All these fall squarely within the scope of Rule 3 violations.

    Section 66D of the IT Act: Cheating by Personation

    Section 66D criminalises cheating by personation using computer resources.

    This provision is frequently invoked in cases involving:

    • Phishing attacks targeting fintech users
    • Fraudulent KYC update messages
    • Impersonated investment advisors or trading platforms

    Such conduct is also recognised under corresponding provisions of the Bharatiya Nyaya Sanhita, reinforcing its seriousness as a criminal offence.

    From a regulatory perspective, fintechs are expected to detect, document, and escalate such incidents, not merely react after customer losses occur.

    Grievance Redressal: Timelines Fintechs Cannot Ignore

    One of the most operationally significant aspects of the 2021 Rules is the formalisation of grievance redressal.

    Grievance Officer Requirements

    Every intermediary must appoint a Grievance Officer in India and publish their contact details. This creates a defined escalation channel for victims of impersonation and fraud.

    Statutory Timelines

    The Rules mandate:

    • Acknowledgement of complaints within 24 hours
    • Resolution within 15 days, including takedown decisions

    For fintech brands dealing with multiple impersonation incidents across platforms, meeting these timelines consistently requires structured evidence, precise legal framing, and follow-ups.

    Significant Social Media Intermediaries and Financial Fraud

    Platforms classified as Significant Social Media Intermediaries (SSMIs) face additional obligations, including:

    • Appointment of a Chief Compliance Officer
    • Appointment of a Resident Grievance Officer
    • Appointment of a nodal contact for law enforcement

    They must also publish monthly compliance reports detailing complaints and content removals. This transparency increases scrutiny on how impersonation and financial fraud complaints are handled.

    For fintechs, this means that well-documented, rule-aligned complaints are far more likely to result in swift takedowns.

    Digital Media, Ads, and Financial Misinformation

    Financial misinformation is not limited to social media. Fake news portals, sponsored articles, and misleading OTT advertisements can also misrepresent financial products.

    Under the IT Rules, digital publishers must follow a three-tier grievance redressal mechanism, appoint grievance officers, and resolve complaints within defined timelines. This provides fintechs with a regulatory pathway to challenge misleading content that damages brand credibility or misleads consumers.

    Why AiPlex ORM Can be Your Trusted Compliance Partner

    Why AiPlex ORM Can be Your Trusted Compliance Partner

    The regulatory framework makes one thing clear: fintechs must demonstrate proactive digital risk management, not just reactive incident handling.

    AiPlex ORM supports fintechs and financial institutions across three critical compliance dimensions:

    24/7 Real-Time Monitoring & Identification of Impersonation and Fraud Risks

    AiPlex ORM helps fintechs and regulated entities:

    • Detect fake websites, apps, and domains
    • Identify impersonated social media handles and ads
    • Monitor misuse of brand names, logos, and executive identities in messaging platforms such as WhatsApp and Telegram.
    This early detection is critical to prevent consumer harm and regulatory escalation.

    Compliance-Aligned Grievance and Takedown Execution

    AiPlex ORM prepares platform-specific, legally structured complaints by:

    • Mapping violations to Rule 3 provisions
    • Referencing the relevant IT Act and fraud sections
    • Submitting evidence-ready notices that meet platform and statutory expectations

    This enables intermediaries’ Grievance Officers to comply with the 24-hour and 15-day statutory timelines.

    Evidence Support for Cyber-Crime and Regulatory Reporting

    In cases involving Section 66D and organised fraud, AiPlex ORM provides:

    • Consolidated evidence bundles
    • Documentation suitable for cybercrime portals and law-enforcement escalation
    • Audit-ready records demonstrating reasonable efforts at consumer protection

    Why This Matters to Regulators and Boards

    Regulators increasingly evaluate fintechs on their ability to manage third-party and digital ecosystem risks.

    Persistent impersonation and unchecked online fraud can raise questions around:

    • Consumer protection controls
    • Operational risk management
    • Board-level oversight of digital risk
    A structured brand-protection and takedown program aligned with the IT Act and Intermediary Rules helps fintechs demonstrate regulatory maturity and governance readiness.

    Compliance Is No Longer Optional in Digital Brand Protection

    The IT Act and Intermediary Guidelines, 2021, have fundamentally changed how online fraud, impersonation, and grievance redressal are regulated in India. For fintechs and financial institutions, these are not peripheral laws, but they directly influence compliance posture, customer trust, and regulatory outcomes.

    By working with a compliance-aligned partner like AiPlex ORM, fintechs can move from reactive takedowns to systematic digital risk governance, ensuring faster response times, stronger evidence trails, and measurable compliance outcomes.

    In an environment of rising digital fraud and regulatory scrutiny, proactive brand protection is no longer a marketing function. It is a core compliance responsibility.

    References

    • Information Technology Act, 2000
    • Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
    • MeitY notifications on grievance redressal timelines.
  • SEBI Circulars on Investor Protection, Cybercrime, Online Fraud and Impersonation

    SEBI Circulars on Investor Protection, Cybercrime, Online Fraud and Impersonation

    How Market Regulators are Strengthening Safeguards and Why Compliance Partners like AiPlex Matter

    There has been a rapid and unprecedented digitization of the financial ecosystem, from digitized bank services, online trading platforms, payment apps, algorithmic advisory services and a lot more.

    While this innovation has expanded access to markets and made financial transaction just a matter of few clicks, unfortunately, it has also created a fertile ground for cybercrime, fraud, miscommunication, and impersonation at scale.

    The Securities and Exchange Board of India (SEBI), India’s apex regulator of India’s securities markets, has responded with multiple circulars, advisories, and frameworks aimed at protecting investors from these evolving threats.

    These regulatory measures not only protect investor interests but also impose compliance requirements on regulated entities and intermediaries operating in the digital space.

    We will very briefly explore and understand:

    • Key SEBI circulars and advisories on investor protection
    • Cybercrime and online fraud prevention directives
    • Guidelines on fraud communication and impersonation
    • Implications for intermediaries and brands
    • How compliance partners like AiPlex can help protect brands, intermediaries, and investors

    SEBI’s Mandate on Investor Protection

    What SEBI Aims to Protect

    SEBI’s statutory mandate is to promote investor protection, ensure fair and transparent markets, and foster confidence among participants in India’s capital markets.

    Investor protection under SEBI covers:

    • Preventing unauthorized or fraudulent investment schemes
    • Guarding against cyber-enabled financial fraud
    • Ensuring accurate, verifiable communications
    • Minimizing identity impersonation and misrepresentation
    • Strengthening complaint redressal and market surveillance

    Through circulars and public releases, SEBI provides a regulatory roadmap for intermediaries and investors to identify and mitigate financial fraud risks.

    SEBI Circulars Addressing Cybercrime

    Cybercrime threats against financial institutions, intermediaries, and investors have substantially increased as markets and communications move online.

    SEBI has responded with a consolidated cybersecurity framework:

    Cybersecurity and Cyber Resilience Framework (CSCRF)

    Circular: SEBI/HO/ITD-1/ITD_CSC_EXT/P/CIR/2024/113 dated August 20, 2024
    Purpose: To establish a comprehensive cybersecurity and resilience framework for all SEBI-regulated entities (REs).
    Coverage: Stockbrokers, depositories, mutual funds, AMCs, portfolio managers, investment advisors, research analysts, custodians, AIFs, RTAs, and more.

    Securities and Exchange Board of India

    Key Requirements under CSCRF:

    • Governance structures, including the appointment of a Chief Information Security Officer (CISO)
    • Risk identification and threat monitoring
    • Protection mechanisms, including access control, encryption, and patch management
    • Detection systems and continuous monitoring
    • Incident response and disaster recovery processes
    • Periodic cyber audits and compliance reporting

    The CSCRF framework is structured to ensure that regulated entities are prepared to anticipate, withstand, contain, recover from and evolve with cyber threats. Ascentium

    Implementation and Clarifications:
    SEBI has also issued clarification circulars on CSCRF compliance (e.g. April 30, 2025, and subsequent technical clarifications) to help entities interpret CSCRF requirements, categorize entities, and formulate and align compliance practices.

    MSEI

    Why This Matters:

    • Standardizing cybersecurity across financial institutions reduces systemic risk
    • Clear expectations for incident response help limit investor impact
    • Mandated audit and reporting improve transparency

    For intermediaries, robust cyber posture is no longer optional; it is a regulatory requirement, and falling short can expose entities to enforcement actions and reputational damage.

    SEBI Guidance on Online Fraud Impersonation and Miscommunication min

    SEBI’s Guidance on Online Fraud, Impersonation and Miscommunication

    While the CSCRF covers internal cybersecurity measures, SEBI has also issued public advisories and warnings directed at investors, focusing on scams that originate outside traditional regulated channels.

    Fraudulent Social Media Activities

    SEBI has repeatedly cautioned the public against fraudulent activities on social media platforms, including YouTube, WhatsApp, Telegram, Facebook, Instagram, and X (formerly Twitter).

    Fraudsters use these platforms to:

    • Disseminate misleading education sessions that eventually sell high-risk or fake investment schemes
    • Promote unverified trading tips and guaranteed return claims
    • Impersonate registered intermediaries to build false credibility and defraud customers
    • Advertise fake trading apps or advisory services

    SEBI urges investors to only engage with SEBI-registered intermediaries and verified trading applications. Unregistered entities are not eligible for investor protection or grievance redressal under SEBI’s mechanisms such as the SCORES portal. ETLegalWorld.com

    Impersonation of SEBI and Intermediaries

    Fraudsters have been known to impersonate:

    • SEBI officials, using fake letterheads and forged certificates
    • Registered intermediaries and brokers
    • Official communication channels demanding payments

    SEBI has issued specific cautions about fake SEBI communications that request compliance payments or penalty settlements via unofficial channels. Genuine SEBI notices are always posted on SEBI’s official website, and payments, if any, are processed through SEBI’s secure portals and gateways (e.g., designated SEBI payment portal). The Times of India+1

    Tips from SEBI’s Advice to Investors

    SEBI’s advisories consistently emphasize the following to prevent fraud and miscommunication:

    • Verify registration: Anyone claiming to be a SEBI-registered advisor must provide a valid registration number, and investors should verify it on SEBI’s official website. Business Standard
    • Use only official communication channels: Investors should interact with SEBI only through official emails (@sebi.gov.in), websites, or portals. The Times of India
    • Recognize official call numbering: Registered intermediaries are instructed to use dedicated phone series (e.g., ‘1600’ series) to prevent fraudulent phone calls. 1-Comply
    • Report fraudulent activities: Investors are expected to report suspicious communication via SEBI’s Market Intelligence Portal, enforcement portal, or cybercrime reporting tools. ETLegalWorld.com
    • Engage only with trusted applications and platforms: Fake trading apps or unvalidated software can capture login credentials and facilitate identity theft or fund diversion. ETLegalWorld.com

    These advisories aim to empower investors with awareness while also clarifying where regulatory boundaries lie.

    Enforcement Actions and Investor Redressal Mechanisms

    SEBI has established investor grievance mechanisms like SCORES (SEBI Complaints Redress System), which allow investors to log complaints against intermediaries or platforms. Investors can escalate fraud issues here, although redressal depends on whether the intermediary is registered and compliant. Investors engaging with unregistered entities may not receive relief under SEBI’s aegis. ETLegalWorld.com

    Further, SEBI publishes enforcement actions and issues public alerts for unauthorized investment schemes. These enforcement disclosures reinforce registered intermediaries’ obligation to maintain compliance and internal controls and serve as warnings to the wider investing community.

    Implications for Intermediaries and Market Participants

    Compliance Is Central

    For SEBI-regulated entities, compliance with investor protection obligations and cybersecurity requirements is mandatory.

    This includes:

    • Implementing robust cyber controls per CSCRF
    • Maintaining clear, authenticated communication channels
    • Monitoring online platforms for fraudulent impersonation
    • Acting promptly on investor complaints and risk reports

    Failing to address fraud vectors or miscommunication risks can result in regulatory action, financial penalties, and reputational damage.

    Online Presence Monitoring

    Given how fraudsters mirror legitimate brands and intermediaries online through fake websites, clone apps, social media channels, messaging groups, and contact numbers, the regulated entities must proactively monitor their digital footprint and online presence. This brand monitoring is essential to protect investors who may mistake fraudulent channels for official ones.

    How AiPlex can be your Compliance Partner

    How AiPlex can be your Compliance Partner

    At AiPlex ORM, we understand that regulatory compliance and brand integrity are intertwined.

    In the context of SEBI’s investor protection and cybercrime directives, intermediary firms and financial brands face the dual challenge of:

    • Ensuring compliance with SEBI cybersecurity and communication standards.
    • Mitigating external fraud risks that exploit their brand, misleading investors.

    Our Compliance Assurance Suite Includes:

    Brand Monitoring and Protection

    • Detection and removal of fake websites and domain clones
    • Identification and takedown of fraudulent mobile apps and search listings
    • Monitoring and deletion of messaging groups (WhatsApp, Telegram) using brand names
    • Detection and deletion of false customer care numbers impersonating brands

    These efforts directly counter the kinds of impersonation and fraud SEBI warns against.

    Regulatory Compliance Support

    • Mapping cybersecurity and communication obligations under SEBI circulars
    • Assisting in risk assessment and mitigation planning aligned with CSCRF standards
    • Monitoring digital channels for compliance breaches

    Rapid Takedown and Enforcement

    • Filing formal DMCA and legal takedown requests
    • Engaging with platform enforcement teams to remove unauthorized content
    • Liaising with authorities and intermediaries to manage fraud incidents

    Real-Time Alerts and Intelligence

    • Continuous surveillance of digital ecosystems for emerging threats
    • Incident reports and dashboards tailored for compliance and legal teams

    A Proactive Compliance and Protection Strategy

    SEBI’s investor protection circulars and cybersecurity frameworks reflect the regulator’s focus on combating the multifaceted challenges of fraud, cybercrime, and impersonation in a digitized market. From public advisories to comprehensive cyber resilience requirements, these measures aim to preserve investor trust and market integrity.

    For regulated entities and intermediaries, compliance is more than a checklist. It is a strategic necessity to mitigate reputational risk, protect investors, and uphold the credibility of India’s financial markets.

    AiPlexORM stands ready to be your compliance partner, helping financial brands navigate regulatory expectations while proactively defending against brand abuse, online fraud, and digital impersonation.

     Through robust monitoring, enforcement, and risk mitigation services, we ensure your brand remains protected, and investors stay confident.

    For detailed service engagement and compliance solutions tailored to your business, connect with us at https://aiplexorm.com/contact-us

  • RBI Master Direction-Digital Payment Security Controls

    RBI Master Direction-Digital Payment Security Controls

    RBI’s Master Direction on Digital Payment Security Controls (DPSC) is no longer a “pure tech” document.  It is a board‑level governance and conduct‑risk instrument.

    Why RBI Cares About Digital Payment Security

    Digital Payments are the Most Widely Used Mode of Retail Payment in India.

    RBI explicitly states that the “pre‑eminent role” of these systems makes the security of digital payment channels a key supervisory priority. The DPSC directions were issued vide RBI/2020‑21/74 DoS.CO.CSITE.SEC. No.1852/31.01.015/2020‑21; dated February 18, 2021, to ensure regulated entities (REs) implement a robust governance structure and common minimum standards of security controls across internet banking, mobile banking, card payments and other digital payment products.​

    Digital payments can no longer be treated as a pure IT project or channel initiative; they are a regulated activity with clearly laid-out expectations on Board oversight, risk management and customer protection.

    The direction is technology‑agnostic but outcome‑specific: secure, resilient, complaint‑light digital payments that do not expose customers or the institutions to avoidable fraud losses or reputational damage.​

    To whom is it applicable?

    The DPSC directions apply to scheduled commercial banks (excluding regional rural banks), small finance banks, payment banks and credit‑card issuing NBFCs. In practice, these entities also act as anchors for payment gateways, aggregators, UPI apps and wallets, meaning DPSC considerations ripple through the entire digital‑payments ecosystem.​

    The channels covered include:

    • Internet banking platforms used by customers to initiate transactions and manage accounts
    • Mobile banking apps and mobile‑based payment applications
    • Card payment systems (card‑present and card‑not‑present)
    • Other digital payment products and services that rely on bank infrastructure, directly or via third parties​

    The direction mandates risk assessments that cover “the complete payment ecosystem as well”, third‑party apps, payment partners and even customer‑facing communication surfaces should be brought into the digital payment risk perimeter.

    This is exactly where phishing sites, fake apps and social‑media impersonation begin to intersect with DPSC expectations.​

    Governance: What are the Board, CCO and CRO’s responsibilities?

    Chapter II of the Direction mandates that regulated entities formulate a digital payment products and services policy with Board Approval. This policy must explicitly discuss payment‑security requirements from functionality, security and performance (FSP) perspectives, including confidentiality, integrity of data and processes, and security of the applications supporting digital products.​

    From a governance standpoint, the Direction expects Regulated Entities to:

    • Integrate digital payment risk into the overall risk management programme, covering compliance risk, fraud risk, operational risk, business continuity and cyber risk.​
    • Define roles and responsibilities for Board, Senior Management and the CISO for overseeing digital‑payment security.​
    • Approve risk appetite and quantitative benchmarks for digital payment security and periodically compare actual performance against these benchmarks to detect adverse trends.​

    For CCO and CRO, the practical implication is that DPSC compliance cannot be delegated solely to IT or InfoSec; non‑compliance or weak implementation is a Board‑level risk that can draw supervisory scrutiny, including through thematic reviews or incident‑driven inspections.​

    Risk Management

    The DPSC Directions require regulated entities to incorporate appropriate processes into their governance and risk management programs for identifying, analysing, monitoring and managing the specific risks, including compliance risk and fraud risk, associated with the portfolio of digital payment products and services.

    This risk assessment must:​

    • Evaluate payment‑data protection, fraud patterns, customer behaviour and potential abuse vectors for each digital product.​
    • Cover operational risk, fraud risk, business continuity, compliance with extant cybersecurity requirements, and compatibility considerations.​
    • Explicitly cover the “surrounding ecosystem”, meaning partners, vendors and customer‑facing channels that influence transaction initiation and authentication.​

    Banks and financial institutions increasingly face incidents where social‑engineering and impersonation occur outside the bank’s core systems, e.g., fake UPI collection requests, cloned/fake apps using the bank’s brand, or phishing pages that mimic the internet‑banking login but sit on unrelated domains. While these assets are technically “outside the perimeter,” the resulting losses, complaints and reputational damage clearly sit within the regulated entities’ risk metrics and regulatory narrative.​

    Fraud Risk Management and Customer Protection

    Security Control Guidelines

    The Direction lays down generic security controls that regulated entities must implement across digital payment channels, including secure communication protocols, appropriate cryptographic standards, robust server‑side security and secure session management. It also requires application security life‑cycle (ASLC) practices, such as secure coding standards, threat modelling and rigorous pre‑production testing for web and mobile applications.​

    Channel‑specific requirements include:

    • Internet banking and mobile banking
      • Strong customer authentication, typically multi‑factor, and, where relevant, device binding or contextual risk‑based checks.​
      • Defence against common web and mobile vulnerabilities (e.g., injection, XSS, insecure direct object references, improper session handling), aligned with frameworks such as OWASP.​
    • Card payments
      • Adherence to PCI card‑security standards for storage, processing and transmission of card data.​
      • Controls for EMV, tokenisation, and secure card‑not‑present flows, including 3‑D Secure and risk‑based authentication.​

    These requirements intersect directly with the CISO’s domain but require CCO/CRO oversight because security control failures translate into reportable incidents, customer disputes and potential supervisory actions.​

    Fraud Risk Management and Customer Protection

    The Direction devotes significant attention to fraud risk management, reconciliation mechanisms, customer protection and grievance redressal related to digital payments.

    The regulated entities are expected to:​

    • Implement real‑time or near‑real‑time fraud monitoring systems, including behavioural analytics and anomaly detection for digital transactions.​
    • Maintain robust reconciliation processes to identify discrepancies and potential fraud patterns across digital channels.​
    • Establish clear policies for sharing liability between the bank and the customer in fraud cases, aligned with RBI’s existing customer liability circulars.​

    Customer awareness and grievance redressal expectations include:

    • Periodic security advisories, alerts and education campaigns on safe digital payment usage.​
    • Effective and time‑bound complaint handling for digital payment issues, with transparent escalation channels and disclosure of turnaround times.​

    For Legal and Compliance teams, these provisions must be embedded into customer‑facing terms and disclosures, internal SOPs, and complaint‑handling frameworks, ensuring that actual practice matches policy and regulatory expectations.​

    RBI Master Directions for Non‑Bank Payment System Operators

    In July 2024, RBI issued the Reserve Bank of India (Cyber Resilience and Digital Payment Security Controls for non‑bank PSOs) Master Directions, 2024, to strengthen the safety and security of payment systems operated by authorised non‑bank payment system operators. These Directions apply to all authorised non‑bank PSOs and seek to enhance overall information‑security preparedness and operational resilience.​

    Key requirements for PSOs include:

    • Board‑approved policies for cyber resilience and digital‑payment security, including risk management of linkages with unregulated entities such as payment gateways and third‑party service providers.​
    • Baseline security measures ensuring system resilience, continuous migration to updated security standards, and alignment of existing card, PPI and mobile‑banking security measures with the new Directions.​

    For regulated entities that rely heavily on PSOs for payment processing, this creates an additional layer of third‑party risk that must be evaluated within the DPSC‑mandated governance and risk‑assessment framework. CCOs and CROs should ensure that outsourcing arrangements, SLAs and due diligence questionnaires reflect both the RE’s and PSO’s regulatory obligations.​

    Brand protection and takedown enforcement

    Why brand‑protection, brand right enforcement and takedown capabilities?

    The DPSC Directions implicitly assume a threat landscape that spans beyond core banking systems, into the broader digital presence where customers interact with the bank’s brand.

    Common patterns now include:​

    • Phishing domains and websites mimicking the bank’s internet banking or UPI interface
    • Fake mobile apps in third‑party app stores using the bank’s name and logo
    • Rogue payment pages and fake offers circulated through social media or messaging apps
    • Impersonation of bank relationship managers or customer‑support handles soliciting credentials or OTPs

    While these fraudulent assets may sit on infrastructure not owned by the regulated entities (banks and financial institutions), the consequences may include fraudulent transactions, customer complaints, negative media and potential regulatory notices seeking an explanation.  The onus is on the financial institutions.

    AiPlex-Your Critical Compliance Partner

    This is where a specialised techno‑legal brand‑protection partner, such as AiPle,x can provide critical support to DPSC compliance.​

    This is how AiPlex can help:

    • Attack‑surface and brand‑abuse monitoring
      • Continuous scanning of domains, app stores, social platforms and marketplaces for use of the bank’s brand, trademarks and payment interfaces.​
      • Prioritisation based on risk signals (e.g., active credential capture, real‑time fraud reports, traffic patterns).
    • Evidence‑grade investigation and documentation
      • Packaging URLs, screenshots, WHOIS data, hosting information and incident summaries in formats suitable for internal fraud teams, law‑enforcement agencies and regulators.
      • Mapping each incident to relevant regulatory expectations (e.g., DPSC fraud‑risk management, customer protection, grievance redressal obligations) to support internal reporting.
    • Takedown execution and follow‑through
      • Coordinating with registrars, hosting providers, app stores and social‑media platforms to remove phishing sites, fake apps and impersonation accounts.​
      • Providing closure documentation (takedown confirmations, timelines) to feed into DPSC compliance reporting, Board‑level MIS and risk‑committee dashboards.

    The value proposition that AiPlex brings to the table is the ability to demonstrate to RBI that the regulated entity (banks & financial institutions) has a structured, proactive programme to detect and neutralise digital threats that exploit the bank’s brand and payment interfaces, even when those threats sit on third‑party infrastructure.

    An Action Plan to Stay Compliant with RBI Master Direction

    To translate DPSC requirements into a defensible, auditable programme, CCOs, CROs, and the Legal teams of the financial institutions (regulated entities) can consider the following steps:

    Update the Board‑approved digital payment policy

    • Ensure it explicitly references the DPSC Directions, ecosystem risk, and the role of third‑party providers (including PSOs and brand‑protection partners).​
    • Embed clear responsibilities for Compliance, Risk, InfoSec and Business for ongoing adherence.

    Integrate DPSC metrics into risk and compliance dashboards

    • Track digital‑fraud events, attempted phishing/impersonation incidents, complaint volumes and resolution times for digital‑payment issues.​
    • Link brand‑abuse takedown statistics (sites identified, sites removed, time‑to‑takedown) with fraud‑loss and complaint metrics.

    Align outsourcing and vendor‑risk frameworks

    • Incorporate DPSC and PSO Master Directions into vendor due diligence, including requirements for cyber resilience, incident reporting and external threat monitoring across unregulated entities in the payment chain.​
    • For specialised providers handling brand‑abuse detection and takedowns, ensure NDAs, data‑handling clauses and reporting obligations meet RBI’s expectations on outsourcing and confidentiality.

    Strengthen legal and grievance documentation

    • Update customer‑facing terms, privacy notices and disclaimers to reflect digital‑payment risks, liability allocation and official communication channels.​
    • Ensure internal grievance‑redressal SOPs explicitly cover frauds involving impersonation, phishing or fake apps, with clear triggers for engaging external takedown partners and, where appropriate, law enforcement.

    Prepare for supervisory review and incident‑driven scrutiny

    • Maintain audit‑ready documentation showing how DPSC requirements are implemented, including minutes from risk‑committee meetings, Board updates and incident post‑mortems.​
    • For major phishing or impersonation incidents, retain full case files combining technical, legal and customer‑impact analysis to support any RBI queries.
    Staying Compliant with RBI Master Directions

    Staying Compliant with RBI Master Directions is a competitive advantage

    Compliance is not just a defensive exercise; when executed well, it becomes a differentiator in an environment where customers and regulators are acutely sensitive to digital‑fraud risk.

    Institutions that can demonstrate strong governance, ecosystem‑wide risk management and proactive deletion of brand‑abuse and impersonation threats will enjoy more regulatory trust and higher customer confidence.​

    For CCOs, CROs and Heads of Legal, partnering with a specialised techno‑legal brand‑protection provider like AiPlex offers a pragmatic way to extend DPSC‑grade controls into the broader digital landscape where fraudsters operate.

    This combination of internal governance and external enforcement muscle creates exactly what the Master Direction envisages: a secure, resilient and trusted digital‑payments environment for customers and regulators alike.​

  • The Future of Online Reputation Management in India

    The Future of Online Reputation Management in India

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    Trends to Watch

    In a world where online perception can make or break a brand, reputation management has become more than just a reactive strategy—it’s a proactive necessity. As India’s digital landscape evolves, so does the approach businesses take to maintain their online credibility. Here are the key trends shaping the future of Online Reputation Management (ORM) in India.

    AI-Powered Reputation Intelligence

    The integration of AI in ORM (Online Reputation Management) is transforming how brands handle their online presence. AI-powered tools now analyse sentiment, track brand mentions, and even predict potential reputation crises before they blow out. Machine learning algorithms can detect patterns in customer feedback, allowing businesses to refine their engagement strategies and deliver

    personalized responses at scale.

    Social Media Taking Centre Stage

    Social media platforms have become the primary battleground for reputation management. Brands are leveraging advanced monitoring tools to track brand sentiment, detect early signs of PR crises, and engage with customers in real time.

    Online Reviews Shaping Consumer Behaviour

    Customer reviews continue to wield immense influence over purchase decisions. According to recent studies, over 90% of consumers check online reviews before making a purchase. ORM strategies are now prioritizing review management—encouraging satisfied customers to leave positive feedback while efficiently addressing negative ones to prevent reputational damage.

     

    Proactive Crisis Management

    Gone are the days when brands only reacted to negative press. Leading businesses are now investing in proactive crisis management strategies. By preparing contingency plans, training spokespersons, and having a structured response framework in place, brands can mitigate risks before they spiral out of control.

    The Rise of Ethical ORM Practices

    As search engines and social platforms tighten their regulations, ethical ORM practices are becoming non-negotiable. Transparency, authenticity, and responsible content management are now key factors influencing how brands maintain their reputation in the digital age.

     

    Leveraging ORM Tools

    Platforms like AiPlex Bridge, Brand24, and Sprinklr help brands track, analyse, and respond to customer queries, mentions, grievances, and online reviews efficiently.   They also provide brands with actionable brand insights.

    Influencer and Community Building

    Partnering with influencers and thought leaders helps brands build credibility. However, authenticity is crucial; consumers can easily detect inauthentic promotions. Collaborating with industry-relevant micro-influencers can have a stronger impact than working with celebrities who lack audience alignment.

    Final Thoughts

    Online reputation management in India is evolving rapidly, and brands must adapt to stay ahead. Whether through AI-driven insights, proactive review handling, or strategic social media engagement, companies that prioritize their digital reputation will have the upper hand in an increasingly competitive landscape. The key is not just to react but to anticipate, engage, and shape public perception before it shapes you.[/et_pb_text][/et_pb_column][/et_pb_row][/et_pb_section]

  • The Real Cost of a Bad Online Reputation for Indian Brands

    The Real Cost of a Bad Online Reputation for Indian Brands

    The Silent Brand Killer

    A brand’s online reputation could make or break a business. YES, it does!

    Over 1 billion internet users in India rely on Google, social media, and multiple review platforms to make purchasing decisions. A single negative review, viral complaint, or PR crisis can lead to lost revenue, eroded trust, and damaged brand perception.

    How much does a bad online reputation cost Indian brands? Let’s break it down.

    Loss of Trust & therefore, Loss of Revenue

    According to a Bright Local survey, 94% of consumers say negative reviews make them less likely to use a business. In India, where word-of-mouth and trust play a crucial role, a bad reputation does not augur well for any business.

    Case Study: A well-known food delivery platform in India (Yep, both brands have had their share of reputation challenges) faced a backlash over a viral customer complaint. A boycott hashtag trended online, followed by the apps being uninstalled; the social media engagement turned largely negative.

    The company had to invest heavily in damage control, including influencer partnerships and media placements, to regain trust. A tarnished online image impacts both trust and revenues big time.

    Increases Customer Acquisition Costs

    A strong positive brand reputation brings organic leads, but a negative online reputation forces businesses to spend heavily on paid marketing. A brand with poor online sentiment might need to spend 2- 3x more on digital ads, influencer collaborations, and public relations to counter negative perception. Unfortunately, higher advertising spends don’t always fix the issue—if customer sentiment remains negative, even increased marketing spends won’t drive growth.

    Drop in Stock Prices and Investor Confidence

    For publicly traded companies, brand reputation influences stock performance. A negative PR event or social media crisis often leads to an immediate stock price drop.

    Recent Example: When a major Indian airline mishandled a passenger complaint that went viral, its stock price fell 6% within days, wiping out crores in market value.

    Investors perceive reputation risks as financial risks—a company struggling with customer sentiment may find it harder to attract funding or maintain stock stability.

    positive brand reputation

    Hiring Challenges & Employee Morale

    A bad reputation doesn’t just affect customers—it also impacts hiring and employee retention.  Negative reviews on Glassdoor, LinkedIn, or Indeed can reduce job applications by up to 50%, making it harder for brands to attract top talent. Companies with poor employer branding often need to offer higher salaries to offset reputation concerns.

    A leading hospitality chain in India faced online backlash over toxic work culture. Result? Mass resignations, recruitment slowdowns, and increased HR expenses in damage control.

    Prospective employees are more likely to trust peer reviews than corporate PR—a bad employer reputation can hinder growth from within.

    Crisis Management & Legal Spends

    Managing a brand crisis isn’t cheap.

    Brands end up spending on:

    • Legal teams to handle defamation claims and court cases.
    • Crisis PR firms to manage media fallout.
    • Reputation management services.

    Real-World Data: On average, companies dealing with an online reputation crisis spend quite a sum in legal and PR fees alone. Investing in proactive Online Reputation Management (ORM) saves brands from expensive clean-ups later.

    Negative Perception on Search

    Google’s algorithm prioritizes recent and relevant content—if negative articles, bad reviews, or complaints dominate search results, a brand’s perception on search takes a hit.

    Example: A fintech brand saw its organic website traffic drop by 40% after bad press about customer data leaks dominated the first page of Google results.

    Reputation is an Asset, Not an Afterthought

    A poor online reputation doesn’t just affect branding—it has direct financial consequences. Investing in Online Reputation Management (ORM) isn’t just about cleaning up bad reviews—it’s about building long-term trust and ensuring sustainable business growth.

    Want to protect your brand’s reputation before it costs you? Get in touch with our ORM team today!

  • AI-Powered Online Reputation Management (ORM)

    AI-Powered Online Reputation Management (ORM)

    Right Off the Bat

    Whether you’re a household brand, a startup, an OTT platform, a sports streaming service, a gaming company, or a content rights holder, how your audience perceives you online can directly impact revenue, partnerships, and market positioning.

    With social media, review platforms, and digital news, brand perception can shift within hours—sometimes minutes. A single viral controversy, negative review, or fake news story can erode years of trust.

    This is where AI-powered Online Reputation Management (ORM) could be a game-changer.

    Conventionally, ORM relied on manual monitoring, PR teams, and crisis response strategies. While effective to an extent, these methods were slow, reactive, and unable to process the sheer volume of data generated in real time.

    On the contrary, AI can help brands to proactively monitor sentiment, identify potential reputational crisis situations and assist brands in mitigating those situations before they blowout, and assist with automated responses to customer queries and grievances and a lot more.

    We will delve deeper into how AI-driven ORM solutions are helping brands safeguard their online reputation and credibility.

    AI Reshaping ORM strategies

    AI-Powered Sentiment Analysis

    Knowing What the Internet Thinks of You: Imagine you’re an OTT platform launching a new show. Reviews start pouring in across Twitter, Reddit, Facebook, YouTube comments, and online forums. Some are positive, others are scathing. How do you sift through thousands of mentions to understand the overall sentiment? AI-driven Natural Language Processing (NLP) algorithms can scan, analyse, and categorize vast amounts of text from multiple platforms within seconds.

    These AI systems can:

    • Detect emotions in online conversations (anger, excitement, disappointment, enthusiasm).
    • Identify key topics being discussed (is it the storyline, the cast, or a pricing complaint that’s making noise?).
    • Predict sentiment trends—whether public perception is improving or worsening.

    For example, Netflix uses AI-based sentiment analysis to understand audience reactions before a situation escalates into a full-blown PR crisis.

    Real-Time Brand Monitoring

    Spotting Threats Before They Go Viral:  For a gaming company launching a new title, a single negative Reddit post or a YouTube influencer’s bad review can spiral into widespread backlash.  AI-powered ORM tools continuously scan the dark web, forums, blogs, social media, and news websites to detect potential threats.

    They provide:

    • Real-time alerts for emerging controversies.
    • Competitor benchmarking to compare your reputation against rivals.
    • Fake news and misinformation detection to prevent brand damage.

    For example, when EA Sports faced criticism over microtransactions in their FIFA franchise, AI-based ORM tools helped them analyse feedback trends and adjust their messaging to defuse the controversy.

    AI-Powered Online Reputation Management Sentiment Analysis

    AI-Driven Crisis Management: Controlling the Narrative Before It’s Too Late

    When a crisis hits, time is of the essence. AI helps brands:

    • Predict potential PR disasters before they explode.
    • Recommend optimal response strategies based on past crisis data.
    • Automate initial responses via AI chatbots and auto-generated PR messages.

    A major sports streaming portal faced backlash when a high-profile match suffered streaming failures. AI-powered ORM identified negative sentiment spikes, prioritized influencer complaints, and suggested a proactive response strategy that included real-time service updates and compensation offers—preventing further brand damage.

    Post-Crisis Trust Rebuilding

    Once damage is done, AI helps brands strategically rebuild trust through:

    • Targeted audience engagement—prioritizing influential customers for personalized responses.
    • Search engine reputation management (SERM)—ensuring positive content ranks higher than negative articles.
    • Predictive analysis—forecasting whether an apology campaign, influencer endorsement, or product change will best restore public confidence.

    For example, an OTT giant used AI-powered ORM to recover from negative publicity surrounding controversial content by promoting positive audience-generated content that shifted the narrative.

    Case Study: How AI Saved an OTT Platform from a Reputation Meltdown

    A leading Indian OTT platform launched a highly anticipated web series. Within hours, social media exploded with claims that the show offended cultural sentiments. Hashtags calling for a boycott began trending on Twitter.

    AI Steps In

    • Sentiment analysis detected a sudden surge in negative comments within minutes.
    • AI scanned 3 million+ tweets, Reddit posts, and news articles to identify the main concerns.
    • Predictive analytics modelled past controversies to recommend an optimal response strategy.
    • The company swiftly released a clarification video and statement—proactively controlling the narrative.

    Within 48 hours, the backlash subsided, and positive conversations regained traction, preventing major reputational damage.

    Future of AI-Powered ORM for Content Owners

    AI in ORM is evolving rapidly. Some exciting developments include:

    • Deepfake detection to combat manipulated videos harming brand reputation.
    • AI-driven legal action against defamatory content.
    • Blockchain-based ORM for verifiable content authenticity.

    As content consumption skyrockets, content owners, OTT platforms, and gaming companies must invest in AI-powered ORM to stay ahead of potential reputation risks.

    AI-driven ORM offers:

    • Real-time monitoring to detect threats instantly.
    • Sentiment analysis to understand audience perception.
    • Automated crisis management to prevent PR disasters.
    • Reputation repair strategies to rebuild trust.

    If you’re looking for the Best ORM Agency in India, make sure they leverage cutting-edge AI solutions to protect and enhance your brand’s online reputation.

    Connect with the AI-Powered Online Reputation Management Agency India today.  Protect your brand and protect your business.

  • Search Engine Reputation Management (SERM)

    Search Engine Reputation Management (SERM)

    Have you ever Googled your business and were taken aback?

    Digital trust is critical for any business. A single negative search result can impact customer, investor, or stakeholder decisions.

    A survey by Local Circles found that 65% of Indians research brands online before making purchases.

    Why Should You Google Yourself?

    When was the last time you searched for yourself or your business on Google?

    Online reputation significantly impacts business credibility and ignoring search results can be risky.

    According to Bright Local, 87% of consumers read online reviews before engaging with a brand.

    Search Engine Reputation Management (SERM)

    How to manage Search Engine Reputation:

    Social Listening and Alerts – Use Google Alerts and Efficient ORM tools to track mentions of your brand.

    Publish Good Content – Financial firms like Zerodha and Groww publish educational content to dominate search rankings.

    Remove Fake Listings & Reviews – Enforce your brand rights. We can do this for you.

    Encourage Positive Feedback – Request satisfied customers to share their experiences online to build credibility.

    Leverage SEO & PR Strategies – Optimize content for relevant keywords to ensure your brand appears in a positive light.

    These Search Engine Reputation Management (SERM) strategies can help your brand maintain a pristine online reputation.

    Don’t let negative search results impact your business. Protect Your Online Reputation Today!

  • Online Reputation Management for NGOs

    Online Reputation Management for NGOs

    NGOs in India rely on public trust for fundraising and advocacy. They bank on crowdfunding, donations, and grants to fund many of their activities.  However, fraudulent donation websites and fake social media accounts tarnish their reputation.

    According to the India Philanthropy Report by Bain & Company, 40% of online donors hesitate due to fraud concerns.

    Online Reputation Management for NGOs

    Why is ORM is important for NGOs?

    Protect Against Fake Donation Sites – Many scams impersonate trusted charities like Goonj and CRY, deceiving donors into contributing to fraudulent accounts.

    Monitor Public Perception – NGOs should track social media mentions and news reports to counter misinformation.

    Respond To Negative Press Quickly – Addressing controversies early can prevent a PR crisis.

    Showcase Positive Impact – Sharing real beneficiary stories, verified testimonials and impact reports boosts credibility.

    Enhance Security Measures – NGOs must secure donation platforms and educate donors about official payment channels.

    With the right ORM strategies, Indian NGOs can build credibility and continue their good work.

  • Email Marketing for Online Reputation Management

    Email Marketing for Online Reputation Management

    Email marketing is a great tool to build a positive online reputation, yes email marketing.  It remains one of the most effective ways to build trust and manage online reputation.

    According to a 2023 KPMG study, 75% of Indian consumers trust emails from verified businesses over other digital channels.

    Leveraging emails to enhance your online reputation

    Here’s how you can use emails to enhance your online reputation:

    • Seeking Reviews – EdTech companies like UpGrad and Simplilearn send post-course emails requesting students to review their programs.
    • Addressing Complaints Promptly – Providing a direct line for customer grievances and queries and addressing those promptly prevents negative experiences from escalating on social media or public review forums.
    • Educating Your Audience – Financial institutions use email newsletters to warn customers about phishing scams and fake investment schemes.
    • Alert Customer about Fake Accounts & Fraudulent Apps – Alert subscribers about scams impersonating your brand and guide them on verifying authenticity.
    • Build Trust Through Transparency – Share company updates, testimonials, and security enhancements to reinforce credibility.

    Leveraging emails to enhance your online reputation:

    With the right email marketing strategy, businesses can foster trust, build positive perceptions, pre-empt and mitigate reputational issues, and strengthen their online presence.

    Start enhancing your online reputation today! Contact us now for a customized email marketing strategy. 🚀 Get Started