Business Email Compromise in the Age of AI: The Threat of WormGPT

Introduction

In the multifaceted world of international trade and finance, cross-border transactions constitute the heart of economic relationships that span the globe. The threads that intertwine forming the fabric of global commerce are ceaselessly dynamic and exhibit an intricate pattern of complexity especially when it comes to the regulated movement of capital. It's a domain where economies connect, where businesses engage in sublime commerce, and where technology and regulation intersect at critical juncture. These guidelines will play a critical role in the regulation of capital, fortification of financial integrity, and transparency of regulatory and cross-border payments. The key highlights of this regulation include strict pre-authorization for non-bank entities, mandating specific accounts for import and export PA-CBs and a transaction ceiling of 25,00,000 Rupees.

The Vigilance of RBI 

The Reserve Bank of India (RBI), ever vigilant in its shepherding role over the nation's financial stability and integrity, has taken decisive strides to dispel the haze that once clouded this critical sector. With the issuance of a revelatory circular dated October 31, 2023, the RBI has unveiled a groundbreaking framework that redefines the terrain for these pivotal financial entities, aptly christened as Payment Aggregators – Cross Border (PA-CB). In deploying this comprehensive array of regulations, the RBI demonstrates a robust commitment to harmonizing and synchronizing the oversight of payments within the country's financial fabric, extending its meticulous regulatory weave from domestic Payment Aggregators (PAs) to the PA-CBs, a sector previously undistinguished in formal oversight.

The prescriptive measures announced by the RBI are nothing short of a regulatory beacon that cuts through the fog of uncertainty, illuminating a clear path forward for entities dedicated to facilitating cross-border payment transactions pertaining to the import and export of permissible goods and services in India through online modes. Inclusiveness is a hallmark of the RBI’s directive, encompassing a diverse cadre of financial actors, ranging from Authorized Dealer (AD) banks and conventional Payment Aggregators (PAs), to the emergent breed of PA-CBs actively engaged in processing these critical international payment transactions.

Key Aspects of Regulation

One of the most striking aspects of this new regulatory regime is the RBI's insistence on pre-authorization. All non-bank entities providing PA-CB services are impelled to apply to the apex bank for authorisation by April 30, 2024. This is far from a perfunctory gesture; it represents a profound departure from the bygone era when these entities functioned under a patchwork of provisional guidelines and ad-hoc circulars. Indeed, with this resolute move, the RBI signals its intention to embrace these entities within its direct regulatory gambit, an acknowledgement of the shifting tides and progressive intricacies characteristic of cross-border payments.

The tapestry of new rules is complex, setting forth an array of prerequisites for entities aspiring for authorization. For instance, non-bank PA-CBs are obliged to register with the Financial Intelligence Unit-India (FIU-IND) as a preliminary step before commencing the application process. Moreover, the financial benchmarks set are notably rigorous. Non-banks must boast a minimum net worth of ₹15 crores at the time of the application—a figure that escalates to a robust ₹25 crores by the fiscal deadline of March 31, 2026.

Way Forward

As if these requirements weren't indicative enough of the RBI’s penchant for detail and precision, the guidelines become yet more granular when addressing specific types of PA-CBs. Import-only PA-CBs are mandatorily obliged to maintain an Import Collection Account (ICA) with an AD Category-I scheduled commercial bank, while export-only PA-CBs are instructed to maintain an Export Collection Account (ECA), which can be maintained in Indian Rupees (INR) or any permissible foreign currency. The nuance here is palpable; payments for import transactions must be received in a meticulously managed escrow account of the PA, prior to being funneled into the ICA for smooth settlement with overseas merchants.

Conversely, export-only PA-CBs' proceeds from international sales must be swiftly credited to the relevant currency ECA. This meticulous accounting ensures that the flow of funds is both transparent and traceable, adhering to the utmost standards of financial probity.

Yet, perhaps the most emphatic of the RBI's pronouncements is the establishment of a transaction ceiling. PA-CBs have their per-transaction limit capped at ₹25,00,000 for each unit of goods or services exchanged. This calculated move is transparent in its objective to mitigate risk—a crucial aspect when one considers the potential implications of these transactions on the country’s fiscal health and the integrity of its financial systems.

It is no exaggeration to declare that with these guidelines, the RBI is effectuating a seismic shift in the regulation of cross-border payment transactions. There's a fundamental transformation taking place—a metamorphosis—from a loosely defined existence of PA-CBs to one of distinct clarity, under the direct and unswerving supervisory gaze of the regulator. The compliance burden, indeed, has become heavier, yet the return is a compass that points decisively towards secure harbours.

As we embark upon the fresh horizons that these rules bring into view, it is imperative to acknowledge that the RBI's regulatory innovations represent far more than a mere codification of dos and don'ts. They embody a visionary stride towards safeguarding and fortifying the architecture of international payments, a critical component of India's burgeoning presence on the world economic stage.

Conclusion 

The journey ahead, as we navigate these newly charted waters with the RBI's guidelines as our steadfast North Star, will no doubt be replete with challenges, adaptations and learning curves for the array of operational entities. But it is with confidence we can say, the path is set; the map is clear. The complex labyrinth of cross-border financial transactions is now demystified, and the RBI's clarion call beckons us towards a future marked by regulation, security, and above all else, reliability in the cosmopolitan tapestry of global trade. RBI’s guidelines provide a comprehensive framework for standardizing cross-border financial transactions in India. This decision is a monumental step towards maintaining cyber peace in cyberspace. 

References:

• https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12561&Mode=0
• https://www2.deloitte.com/in/en/pages/tax/articles/tax-alert-Regulation-of-payment-aggregator-cross-border-pa-cb.html
• https://www.jsalaw.com/newsletters-and-updates/rbis-new-guidelines-to-govern-payment-aggregators-in-cross-border-transactions/ 

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In the rich history of humanity, the advent of artificial intelligence (AI) has added a new, delicate aspect. The aspect of promising technological advancement has the potential to either enrich the nest of our society or destroy it entirely. The latest straw in this complex nest is generative AI, a frontier teeming with both potential and perils. It is a realm where the ethereal concepts of cyber peace and resilience are not just theoretical constructs but tangible necessities.

The spectre of generative AI looms large over the digital landscape, casting a long shadow on the sanctity of data privacy and the integrity of political processes. The seeds of this threat were sown in the fertile soil of the Cambridge Analytica scandal of 2018, a watershed moment that unveiled the extent to which personal data could be harvested and utilized to influence electoral outcomes. However despite the indignation, the scandal resulted in meagre alterations to modus operandi of digital platforms.

Fast forward to the present day, and the spectre has only grown more ominous. A recent report by Human Rights Watch has shed light on the continued exploitation of data-driven campaigning in Hungary's re-election of Viktor Orbán. The report paints a chilling picture of political parties leveraging voter databases for targeted social media advertising, with the ruling Fidesz party even resorting to the unethical use of public service data to bolster its voter database.

The Looming Threat of Disinformation

As we stand on the precipice of 2024, a year that will witness over 50 countries holding elections, the advancements in generative AI could exponentially amplify the ability of political campaigns to manipulate electoral outcomes. This is particularly concerning in countries where information disparities are stark, providing fertile ground for the seeds of disinformation to take root and flourish.

The media, the traditional watchdog of democracy, has already begun to sound the alarm about the potential threats posed by deepfakes and manipulative content in the upcoming elections. The limited use of generative AI in disinformation campaigns has raised concerns about the enforcement of policies against generating targeted political materials, such as those designed to sway specific demographic groups towards a particular candidate.

Yet, while the threat of bad actors using AI to generate and disseminate disinformation is real and present, there is another dimension that has largely remained unexplored: the intimate interactions with chatbots. These digital interlocutors, when armed with advanced generative AI, have the potential to manipulate individuals without any intermediaries. The more data they have about a person, the better they can tailor their manipulations.

Root of the Cause 

To fully grasp the potential risks, we must journey back 30 years to the birth of online banner ads. The success of the first-ever banner ad for AT&T, which boasted an astounding 44% click rate, birthed a new era of digital advertising. This was followed by the advent of mobile advertising in the early 2000s. Since then, companies have been engaged in a perpetual quest to harness technology for manipulation, blurring the lines between commercial and political advertising in cyberspace.

Regrettably, the safeguards currently in place are woefully inadequate to prevent the rise of manipulative chatbots. Consider the case of Snapchat's My AI generative chatbot, which ostensibly assists users with trivia questions and gift suggestions. Unbeknownst to most users, their interactions with the chatbot are algorithmically harvested for targeted advertising. While this may not seem harmful in its current form, the profit motive could drive it towards more manipulative purposes.

If companies deploying chatbots like My AI face pressure to increase profitability, they may be tempted to subtly steer conversations to extract more user information, providing more fuel for advertising and higher earnings. This kind of nudging is not clearly illegal in the U.S. or the EU, even after the AI Act comes into effect. The market size of AI in India is projected to touch US$4.11bn in 2023. 

Taking this further, chatbots may be inclined to guide users towards purchasing specific products or even influencing significant life decisions, such as religious conversions or voting choices. The legal boundaries here remain unclear, especially when manipulation is not detectable by the user. 

The Crucial Dos/Dont's 

It is crucial to set rules and safeguards in order to manage the possible threats related to manipulative chatbots in the context of the general election in 2024.

First and foremost, candor and transparency are essential. Chatbots, particularly when employed for political or electoral matters, ought to make it clear to users what they are for and why they are automated. By being transparent, people are guaranteed to be aware that they are interacting with automated processes.

Second, getting user consent is crucial. Before collecting user data for any reason, including advertising or political profiling, users should be asked for their informed consent. Giving consumers easy ways to opt-in and opt-out gives them control over their data.

Furthermore, moral use is essential. It's crucial to create an ethics code for chatbot interactions that forbids manipulation, disseminating false information, and trying to sway users' political opinions. This guarantees that chatbots follow moral guidelines.

In order to preserve transparency and accountability, independent audits need to be carried out. Users might feel more confident knowing that chatbot behavior and data collecting procedures are regularly audited by impartial third parties to ensure compliance with legal and ethical norms.

Important "don'ts" to take into account. Coercion and manipulation ought to be outlawed completely. Chatbots should refrain from using misleading or manipulative approaches to sway users' political opinions or religious convictions.

Another hazard to watch out for is unlawful data collecting. Businesses must obtain consumers' express agreement before collecting personal information, and they must not sell or share this information for political reasons.

At all costs, one should steer clear of fake identities. Impersonating people or political figures is not something chatbots should do because it can result in manipulation and false information.

It is essential to be impartial. Bots shouldn't advocate for or take part in political activities that give preference to one political party over another. In encounters, impartiality and equity are crucial.

Finally, one should refrain from using invasive advertising techniques. Chatbots should ensure that advertising tactics comply with legal norms by refraining from displaying political advertisements or messaging without explicit user agreement.

Present Scenario

As we approach the critical 2024 elections and generative AI tools proliferate faster than regulatory measures can keep pace, companies must take an active role in building user trust, transparency, and accountability. This includes comprehensive disclosure about a chatbot's programmed business goals in conversations, ensuring users are fully aware of the chatbot's intended purposes.

To address the regulatory gap, stronger laws are needed. Both the EU AI Act and analogous laws across jurisdictions should be expanded to address the potential for manipulation in various forms. This effort should be driven by public demand, as the interests of lawmakers have been influenced by intensive Big Tech lobbying campaigns.

At present, India doesn’t have any specific laws pertaining to AI regulation. Ministry of Electronics and Information Technology (MEITY), is the executive body responsible for AI strategies and is constantly working towards a policy framework for AI. The Niti Ayog has presented seven principles for responsible AI which includes equality , inclusivity, safety, privacy, transparency, accountability, dependability and protection of positive human values.

Conclusion 

We are at a pivotal juncture in history. As generative AI gains more power, we must proactively establish effective strategies to protect our privacy, rights and democracy. The public's waning confidence in Big Tech and the lessons learned from the techlash underscore the need for stronger regulations that hold tech companies accountable. Let's ensure that the power of generative AI is harnessed for the betterment of society and not exploited for manipulation.

Reference

McCallum, B. S. (2022, December 23). Meta settles Cambridge Analytica scandal case for $725m. BBC News. https://www.bbc.com/news/technology-64075067

Hungary: Data misused for political campaigns. (2022, December 1). Human Rights Watch. https://www.hrw.org/news/2022/12/01/hungary-data-misused-political-campaigns

Statista. (n.d.). Artificial Intelligence - India | Statista Market forecast. https://www.statista.com/outlook/tmo/artificial-intelligence/india

Introduction

The Ministry of Electronics and Information Technology (MeitY) recently issued the “Email Policy of Government of India, 2024.” It is an updated email policy for central government employees, requiring the exclusive use of official government emails managed by the National Informatics Centre (NIC) for public duties. The policy replaces 2015 guidelines and prohibits government employees, contractors, and consultants from using their official email addresses on social media or other websites unless authorised for official functions. The policy aims to reinforce cybersecurity measures and protocols, maintain secure communications, and ensure compliance across departments. It is not legally binding, but its gazette notification ensures compliance and maintains cyber resilience in communications. The updated policy is also aligned with the newly enacted Digital Personal Data Protection Act, 2023.

Brief Highlights of Email Policy of Government of India, 2024

• The Email Policy of the Government of India, 2024 is divided into three parts namely, Part I: Introduction, Part II: Terms of Use, Part III: Functions, duties and Responsibilities, and with an annexe attached to it defining the meaning of certain organisation types in relation to this policy.
• The policy direct to not use NICeMail address for registering on any social media or other websites or mobile applications, save for the performance of official duties or with due authorisation from the authority competent.
• Under this new policy, “core use organisations” (central government departments and other government-controlled entities that do not provide goods or services on commercial terms) and its users shall use only NICeMail for official purposes. 

• However, where the Core Use Organisation has an office or establishment outside India, to ensure availability of local communication channels under exigent circumstances may use alternative email services hosted outside India with all due approval.
• Core Use Organisations, including those dealing with national security, have their own independent email servers and can continue operating their independent email servers provided the servers are hosted in India. They should also consider migrating their email services to NICeMail Services for security and uniform policy enforcement.
• The policy also requires departments that currently use @gov.in or @nic.in to instead migrate to @departmentname.gov.in mail domains so that information sanctity and integrity can be maintained when officials are transferred from one department/ministry to another, and so that the ministry/department doesn’t lose access to the official communication. For this, the department or ministry in question must register the domain name with NIC. For instance, MeitY has registered the mail domain @meity.gov.in. The policy gives government departments six months time period complete this migration.
• The policy also makes distinction between (1) Organisation-linked email addresses and (2) Service-linked email addresses. The policy in respect of “organisation-linked email addresses” is laid down in paragraphs 5.3.2(a) and 5.4 to 5.6.3. And the policy in respect of “service-linked email addresses” is laid down in paragraphs 5.3.2(b) and 5.7 to 5.7.2 under the official document of said policy. 

• Further, the new policy includes specific directives on separating the email addresses of regular government employees from those of contractors or consultants to improve operational clarity.

CyberPeace Policy Outlook 

The revised Email Policy of the Government of India reflects the government’s proactive response to countering the evolving cybersecurity challenges and aims to maintain cyber resilience across the government department’s email communications. The policy represents a significant step towards securing inter government and intra-government communications. We as a cybersecurity expert organisation emphasise the importance of protecting sensitive data against cyber threats, particularly in a world increasingly targeted by sophisticated phishing and malware attacks, and we advocate for safe and secure online communication and information exchange. Email communications hold sensitive information and therefore require robust policies and mechanisms in place to safeguard the communications and ensure that sensitive data is shielded through regulated and secure email usage with technical capabilities for safe use. The proactive step taken by MeitY is commendable and aligned with securing governmental communication channels.

References:

1. https://www.meity.gov.in/writereaddata/files/Email-policy-30-10-2024.pdf-(Official document for Email Policy of Government of India, 2024.
2. https://www.hindustantimes.com/india-news/dont-use-govt-email-ids-for-social-media-central-govt-policy-for-employees-101730312997936.html#:~:text=Government%20employees%20must%20not%20use,email%20policy%20issued%20on%20Wednesday
3. https://bwpeople.in/article/new-email-policy-issued-for-central-govt-employees-to-strengthen-cybersecurity-measures-537805
4. https://www.thehindu.com/news/national/centre-notifies-email-policy-for-ministries-central-departments/article68815537.ece

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