Summary: This article is the second part of a two-part series, examining the implications of India’s Digital Personal Data Protection Rules, 2025, on internal investigations conducted by organisations and their legal counsel. While Part I addressed the foundational framework and the applicability of exemptions under the DPDP Act, particularly Section 17(1)(c); Part II focuses on the practical compliance obligations that Data Fiduciaries must navigate during internal investigations, including security requirements, breach notification protocols, data retention and erasure mandates, and cross-border transfer complexities.Continue Reading Implications Of The Digital Personal Data Protection Rules, 2025: Stoking Internal Investigations – Part II
Sahil Kanuga
Partner in the Dispute Resolution Practice at the Mumbai office of Cyril Amarchand Mangaldas. Sahil focuses on internal investigations, white-collar crimes and disputes and has about 20 years of experience. He regularly advises foreign and domestic clients on internal investigations into compliance violations and in matters pertaining to whistle-blower complaints, for corporations and financial institutions, ABAC compliance and regulatory compliance. He also has considerable expertise in advising on corporate governance, cross border disputes, financial crimes, fraud related issues, regulatory and governance issues. He can be reached at sahil.kanuga@cyrilshroff.com
Implications Of The Digital Personal Data Protection Rules, 2025: Stoking Internal Investigations – Part I

Summary: India’s Digital Personal Data Protection Rules, 2025, effective November 13, 2025, have fundamentally transformed the regulatory landscape for internal investigations. This analysis is the first part in a two-part series examining the critical compliance challenges facing organisations and law firms navigating data-sensitive proceedings under the new regime.Continue Reading Implications Of The Digital Personal Data Protection Rules, 2025: Stoking Internal Investigations – Part I
Navigating the MSME Minefield: When Party Autonomy Meets Statutory Reality

Summary: The recent decision in GEA Westfalia highlights the importance of an exclusive jurisdiction clause in contracts involving MSMEs, particularly for determining the court with the jurisdiction to hear challenges to awards passed as part of the mandatory statutory arbitration under the MSMED Act.Continue Reading Navigating the MSME Minefield: When Party Autonomy Meets Statutory Reality
Absence of Due Diligence Not Money Laundering

Summary: The article highlights the powers of statutory auditors following the recent judgment, clarifying that statutory auditors cannot be held liable for money laundering solely because of lack of due diligence or negligence. The article also emphasises that criminal liability under PMLA requires clear evidence of collusion and that auditors are not expected to probe beyond their professional auditing role.Continue Reading Absence of Due Diligence Not Money Laundering
Emergence of the EU sanctions regime and their wide-reaching cross-border impact

Summary: This blog examines the increased compliance challenges faced by Indian companies due to the introduction of EU sanctions. European financial institutions and trading partners strictly enforce these measures, often adopting a zero-tolerance approach to secondary exposure. Consequently, Indian businesses with links to European markets must conduct rigorous due diligence as they face the risk of being cut off from euro-denominated transactions or even delisted from European stock exchanges.Continue Reading Emergence of the EU sanctions regime and their wide-reaching cross-border impact
When Delay Defeats Justice

Summary: This blog aims to highlight the need for litigants seeking timely remedies to avoid protracted and stale litigation. It also focusses on adopting Alternative Dispute Resolution as an effective mechanism, wherever appropriate, for achieving faster and more effective remedies.Continue Reading When Delay Defeats Justice
Global, India implications of US DOJ resuming scaled-back enforcement against foreign bribery

The present US administration signed an Executive Order (“EO 14209”) in February, halting the enforcement of the Foreign Corrupt Practices Act (FCPA), pending new guidance to prosecutors. On June 10, 2025, the US Department of Justice (DOJ) issued new guidelines (“Guidelines”) on the enforcement of the FCPA, marking a significant shift in its approach to combating foreign bribery. These changes are a part of a broader strategy to recalibrate US anti-corruption efforts in line with national security interests and economic competitiveness.Continue Reading Global, India implications of US DOJ resuming scaled-back enforcement against foreign bribery
Changing Landscape of Arrest Under the PMLA – Decoding Section 19 Through Jurisprudence

The Prevention of Money Laundering Act, 2002 (“PMLA”), places proceeds of crime at the core of the offence of money laundering. Before delving into this article, it is imperative to understand the definition of proceeds of crime, which Section 2 (1) (u) of the PMLA[1] defines as “any property derived or obtained by any person, as a result of criminal activity relating to a scheduled offence”.Continue Reading Changing Landscape of Arrest Under the PMLA – Decoding Section 19 Through Jurisprudence