Legal & Compliance Manager

Job Summary:

The Legal & Compliance Manager will be responsible for ensuring compliance with regulations governing both Account Aggregators (AA) and Payment Aggregators (PA) as outlined by the Reserve Bank of India (RBI) and other relevant regulatory bodies. The role involves managing data privacy, customer consent, payment processing standards, and legal agreements while mitigating operational and regulatory risks. The manager will also be the point of contact for all legal and regulatory matters, ensuring smooth operations in both data sharing and payment aggregation services

Key Responsibilities:

1. Compliance with RBI Regulations:

• Ensure compliance with RBI's Master Directions for both Account Aggregators (AA) and Payment Aggregators (PA), ensuring alignment with guidelines for licensing, reporting, and operational practices.
• Monitor changes in regulatory policies, update compliance procedures accordingly, and ensure implementation across both business models.
• Oversee the filing of regulatory reports for both AAs and PAs, including timely submissions of periodic returns, incident reports, and audit findings to RBI and other regulatory authorities.

2. Legal & Regulatory Advisory:

• Provide legal advice and interpretation of laws relevant to both AAs and PAs, including RBI regulations, Information Technology Act, Data Protection Laws, Payment and Settlement Systems Act, and Consumer Protection Laws.
• Draft and review legal documentation such as master service agreements, merchant contracts, data-sharing agreements, and other related documents for AAs and PAs.
• Advise internal stakeholders on consumer consent frameworks, especially for AAs, ensuring compliance with RBIs guidelines for data sharing and customer privacy.

3. Data Privacy and Security Compliance:

• Ensure both the Account Aggregator and Payment Aggregator comply with data protection laws like PDPB (Personal Data Protection Bill), GDPR, and RBI cybersecurity guidelines.
• Monitor and enforce the organization's compliance with PCI DSS (Payment Card Industry Data Security Standard) and ISO 27001 standards for secure handling of financial data.
• Oversee implementation of a secure consent management system for AAs, ensuring that customers' financial data is shared only with their explicit consent, as per RBI's Account Aggregator regulations.

4. Risk Management:

• Identify, assess, and manage regulatory risks related to both payment facilitation and data aggregation. Implement risk mitigation strategies to minimize exposure to compliance failures.
• Ensure that fraud detection, anti-money laundering (AML), and KYC (Know Your Customer) processes are robust for PAs, and implement data integrity and privacy safeguards for AAs.
• Work closely with IT and security teams to ensure that appropriate cybersecurity measures are in place for both platforms, minimizing risks of data breaches and fraud.

5. Contract and Agreement Management:

• Draft, review, and negotiate contracts with merchants, Financial Information Providers (FIPs), Financial Information Users (FIUs), and third-party service providers, ensuring these agreements comply with legal and regulatory standards.
• Manage and oversee the companys standard operating terms with merchants and partners, ensuring compliance with RBIs PA guidelines, including merchant onboarding and transaction processing.

6. Internal Compliance Audits:

• Conduct periodic compliance audits for both AA and PA operations to assess adherence to internal policies and external regulations.
• Regularly update the compliance framework and manuals based on new regulations or changes in RBI guidelines, ensuring ongoing compliance in both business lines.

7. Liaison with Regulators:

• Serve as the primary liaison for all regulatory bodies, including RBI and Data Protection Authorities, for both AAs and PAs, ensuring clear communication during audits, inspections, and regulatory inquiries.
• Respond to regulatory queries, handle regulatory inspections, and provide timely and accurate reports to RBI and other regulatory bodies.

8. Legal Dispute Resolution:

• Handle disputes or litigations arising from both data-sharing agreements (AA) and payment processing (PA), including customer disputes, privacy complaints, and merchant chargeback issues.
• Coordinate with external legal counsel for more complex disputes, especially those involving regulatory authorities or legal claims related to data privacy breaches or payment fraud.

9. Training and Compliance Awareness:

• Organize training programs for internal teams, including legal, compliance, and operational teams, on regulatory updates, compliance policies, and best practices for managing compliance risks in both AA and PA domains.
• Create awareness of evolving compliance requirements, particularly around data privacy, cybersecurity, fraud detection, and AML/KYC compliance.

Qualifications and Skills:

Educational Qualification:

• Bachelor's or Master’s degree in Law (LLB), Finance, or Compliance.
• Certifications in Data Privacy, Financial Compliance, or Cybersecurity (e.g., CIPP, PCI DSS, ISO 27001) are a plus.

Experience:

• 5-8 years of experience in a legal or compliance role, ideally in the financial services, fintech, or payments industry.
• Hands-on experience dealing with RBI regulations for Account Aggregators and Payment Aggregators is required.

Skills:

• Strong knowledge of RBI regulations, data protection laws, and payment system compliance.
• Expertise in managing legal documentation, contracts, and regulatory filings.
• Excellent problem-solving and analytical skills, with the ability to identify legal and compliance risks and provide solutions.
• Strong communication and negotiation skills for managing relationships with regulators, merchants, and financial institutions.
• Ability to manage multiple regulatory frameworks simultaneously for different financial products (Account Aggregators and Payment Aggregators).

Additional Requirements:

• Knowledge of Technology & Financial Services: Understanding of digital financial platforms, API-driven services, and the implications of emerging technologies on compliance frameworks.
• Experience with cybersecurity compliance, data privacy laws, and risk management in digital ecosystems.
• Willingness to travel for audits, compliance meetings, and discussions with regulators as needed.