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On 25 September 2026, at UN Headquarters in New York, External Affairs Minister S. Jaishankar signed the United Nations Convention against Cybercrime on the sidelines of the 81st session of the UN General Assembly, calling it a step that "strengthens international cooperation for a safer digital future."

 The signature places India among the growing list of nations joining what is officially the first comprehensive global treaty dedicated to cybercrime. What Jaishankar's brief statement did not mention is that this same treaty has spent the better part of three years drawing sustained, detailed criticism from human rights organisations, technology companies, and digital rights groups, who argue it risks becoming a tool for surveillance rather than a tool against crime.

A Conversation CyberPeace Has Been Having for Years

For CyberPeace, India’s signature is not an isolated development but the latest chapter in a conversation the organisation has been following since the Convention was still being negotiated.

In December 2024, CyberPeace published its analysis of the emerging UN Convention against Cybercrime, examining its objectives, proposed offences, mechanisms for international cooperation, electronic evidence and its relationship with the Budapest Convention. The analysis also highlighted an important principle embedded in the emerging framework: that stronger cybercrime enforcement must operate alongside due process, privacy and human-rights safeguards.

That conversation continued in October 2025, when CyberPeace published The Digital Leviathan: The UN Cybercrime Treaty and the Future of Global Governance. The piece examined the Convention not merely as a cybercrime instrument, but as part of a larger evolution in global digital governance, particularly around cross-border evidence, international cooperation and the changing architecture of cyber sovereignty.

And in August 2026, CyberPeace returned to the question from the operational side in The World Is Rewriting the Rules Against Cyber-Enabled Transnational Crime. The analysis placed the Convention alongside the wider international response to transnational cyber-enabled crime, including scam networks, financial fraud and increasingly sophisticated criminal ecosystems that operate across multiple jurisdictions.

What the Convention actually is

The treaty's full, formal title is unusually descriptive for a UN instrument: the United Nations Convention against Cybercrime, Strengthening International Cooperation for Combating Certain Crimes Committed by Means of Information and Communications Technology Systems and for the Sharing of Evidence in Electronic Form of Serious Crimes. The UN General Assembly adopted it unanimously on 24 December 2024, following three years of negotiation, and it opened for signature at a ceremony in Hanoi, Vietnam, in October 2025. It will remain open for signature at UN Headquarters through 31 December 2026, and comes into force ninety days after the fortieth country ratifies it.

At its core, the Convention gives signatory states a shared legal framework for two things: preventing and prosecuting offences committed through digital systems, and cooperating across borders when evidence, offenders, or victims of a crime are scattered across multiple jurisdictions, a structural problem that has long frustrated cybercrime investigations. It also includes provisions specifically addressing the recovery of criminal proceeds, adding a financial dimension that lets states cooperate not just on prosecuting offenders but on tracing and reclaiming stolen money that has moved across borders, often through mule accounts and shell transactions designed to outrun any single country's jurisdiction.

Why India signed, in its own words

Jaishankar's public reasoning was concise. Cybercrime, in the government's framing, does not respect national boundaries, and India's own cybercrime caseload, spanning cross-border financial fraud, romance scams, and organised online extortion networks often operating from outside India's borders, has repeatedly run into exactly the jurisdictional walls this Convention is designed to lower. Prof. Triveni Singh, a well known cybercrime expert and former IPS officer, put the practical case plainly: "Cybercrime does not stop at national borders. Criminals can operate from one country and target victims in another. This convention can help countries share evidence and work together faster. For India, stronger international cooperation can make it easier to investigate cross-border cyber fraud and trace stolen money." 

The part the announcement leaves out

Here is where the story gets considerably more complicated than a signing ceremony photo suggests. Since before the Convention's text was even finalised, a wide coalition of digital rights organisations, including the Electronic Frontier Foundation, Human Rights Watch, the Global Network Initiative, and Privacy International, has warned that the treaty's language is dangerously broad, and that its safeguards against misuse are considerably weaker than they need to be.

Cisco, one of the few major technology companies to comment publicly, stated the Convention does not do enough to "sufficiently protect basic human rights." UN Secretary-General António Guterres, notably, has himself urged countries to sign and ratify the Convention while simultaneously calling for its implementation to be "rooted in human rights," a somewhat unusual dual message from the very institution that produced the text, and one that implicitly acknowledges the concerns raised against it.

Where this leaves India

None of this means India's signature was unwarranted. The jurisdictional friction Prof. Triveni Singh described is real and well documented, and a shared international framework for evidence sharing genuinely could accelerate investigations that currently stall for months while agencies wait on slow, bilateral mutual legal assistance requests. India's existing domestic cybercrime coordination architecture is already substantial, spanning I4C, the National Cybercrime Reporting Portal, and newer mechanisms like the Citizen Financial Cyber Fraud Reporting and Management System and the Sahyog platform, and a global treaty that maps onto this existing infrastructure could genuinely close gaps that purely domestic tools cannot reach, particularly in cases where the perpetrator, the server, and the victim all sit in different countries, a pattern that has become close to the default in organised online financial fraud rather than the exception.

But the criticisms levelled at the Convention are not fringe objections; they come from some of the most established digital rights organisations in the world, and they focus specifically on the treaty's most powerful surveillance and cross-border cooperation provisions, the very mechanisms India will now need to operationalise domestically. Signing the Convention is also only the first procedural step; India's obligations under it will not take practical effect until the instrument is ratified domestically, a process that typically allows room for a signatory state to clarify how broadly or narrowly it intends to apply the treaty's more expansive provisions. How India chooses to implement those provisions, whether through the kind of judicial oversight and narrow, offence-specific application human rights groups have called for, or through the broader interpretation the treaty's text technically permits, will likely determine whether this Convention becomes a genuine tool against fraud and organised cybercrime, or a broader instrument whose reach eventually extends well past the digital offences it was signed to address.

References

• The420.in, "India Signs UN Cybercrime Convention to Strengthen Global Fight Against Digital Crime." ANI, "EAM Jaishankar signs UN Convention against Cybercrime on UNGA sidelines." https://aninews.in/news/world/us/eam-jaishankar-signs-un-convention-against-cybercrime-on-unga-sidelines20260926063207/
• Ministry of Cyber Affairs, "India signs UN Convention against Cybercrime at UNGA 81." https://ministryofcyberaffairs.com/news/india-signs-un-convention-against-cybercrime-at-unga-81-95b7e43b-7e29-4722-a4a7-304bca55b71c
•  Electronic Frontier Foundation, "UN Cybercrime Convention Negotiations Enter Final Phase With Troubling Surveillance Powers Still on the Table."  https://www.eff.org/deeplinks/2023/08/un-cybercrime-convention-negotiations-enter-final-phase-troubling-surveillance
• Electronic Frontier Foundation, "First Draft of UN Cybercrime Convention Drops Troubling Provisions, But Dangerous And Open-Ended Cross Border Surveillance Powers Are Still on the Table."
• https://www.eff.org/deeplinks/2023/07/first-draft-un-cybercrime-treaty-drops-troubling-provisions-dangerous-and-open
• Global Network Initiative, "GNI Calls on Member States Not to Support the UN Cybercrime Convention." https://globalnetworkinitiative.org/gni-statement-on-uncc/
• Just Security, "The UN Cybercrime Convention: Analyzing the Risks to Human Rights and Global Privacy." https://www.justsecurity.org/98738/cybercrime-convention-human-rights/
• TechRadar Pro, "UN cybercrime convention inadequate, says Human Rights Watch." https://techradar.com/pro/un-cybercrime-convention-inadequate-says-human-rights-watch
• Digital Watch Observatory, "Comparative analysis: the Budapest Convention vs the UN Convention Against Cybercrime." https://dig.watch/updates/comparative-analysis-the-budapest-convention-vs-the-un-convention-against-cybercrime
• epicenter.works, "Cybercrime Convention: Cross-Border Human Rights Violations." https://epicenter.works/en/content/cybercrime-convention-cross-border-human-rights-violations
• UN Press, "Secretary-General Urges All Countries to Sign, Ratify New UN Convention against Cybercrime, Calls for Solutions Rooted in Human Rights." https://press.un.org/en/2025/sgsm22961.doc.htm
• https://cyberpeace.org/resources/blogs/the-digital-leviathan-the-un-cybercrime-treaty-and-the-future-of-global-governance 
• https://cyberpeace.org/resources/blogs/the-world-is-rewriting-the-rules-against-cyber-enabled-transnational-crime 

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In Delhi there is a bank branch where a lot of money was stolen from people over the country. This bank branch is where all the money disappeared. The people who did this did not wear masks. Break in at midnight. They just used a passbook a rubber stamp and a form that nobody checked carefully. This is the truth that the people who investigate cybercrime keep finding. The way that cybercriminals get away with the money is not by using a computer it is by using a bank account. The police in Delhi who investigate cybercrime have found that a lot of accounts were opened at bank branches. These accounts were opened using identity documents that were borrowed bought or stolen. Then these accounts were rented out to groups of criminals. One bank branch keeps coming up in complaints. This is not bad luck it is a sign of a bigger problem with how banks check who is opening an account.

These fake accounts, which are called " accounts" are controlled by criminal groups, not the people whose names are on the accounts. These accounts are a part of the cybercrime problem in India. The mistakes that bank branches make which allow these accounts to be opened raise a lot of questions. These questions are about how banks check who is opening an account how they prevent money laundering and how they work with groups to stop cybercrime. The bank accounts are the way that cybercriminals in India get away with the money they steal from people. The cybercrime investigators keep finding bank accounts like the ones at the bank branch, in Delhi, where the money was stolen.

The Anatomy of a Mule Account Network

The pattern is now familiar to investigators. A fraud complaint on the National Cyber Crime Reporting Portal traces a victim's stolen money to a beneficiary account. When police pull the account-opening file, the person named on the KYC documents often denies ever visiting the branch or signing the forms; signature verification frequently shows a mismatch. In one recent Delhi case, a cooperative bank's deputy manager was arrested after a single account he had helped open surfaced in 159 separate cyber fraud complaints from across the country, with transactions worth nearly Rs 68 crore routed through it before detection. Similar investigations have uncovered supply gangs that procure dozens of accounts at a time using POS machines, stacks of ATM cards, and cheque books belonging to different people and rent them out to fraudsters as ready-made conduits for stolen money.

What makes a single branch or a small cluster of accounts significant is what it reveals about entry-point failure. Investigators do not describe these as sophisticated hacking operations; they describe them as verification failures as are accounts opened without the mandatory in-person checks, video KYC, or document authentication that RBI rules require. When 96, or 700, or 8.5 lakh mule accounts are traced back through a handful of branches and intermediaries, the story is not really about the fraudsters at the far end of the chain. It is about the choke point where honest oversight should have stopped the account from ever existing.

Where the KYC Framework Is Breaking Down

The RBI's Know Your Customer Master Direction requires banks to establish customer identity, verify a genuine business relationship, and apply risk-based due diligence before allowing an account to operate. In practice, investigators have repeatedly found accounts opened through complicit or negligent bank staff, business correspondents, and third-party agents who bypass these checks entirely. Analysts note that mule accounts systematically exploit gaps in customer onboarding, KYC verification, transaction monitoring, and dormant-account surveillance, with criminals using forged or stolen identity documents and layering funds across multiple accounts to escape detection. Economically vulnerable individuals who are daily-wage workers, students, the unemployed are frequently paid a small commission to hand over their documents or existing accounts, often without understanding that they could face criminal liability for transactions they never authorised.

This is compounded by a financial-inclusion paradox that regulators themselves acknowledge: India has expanded banking access faster than it has expanded financial and digital literacy, leaving a population that is easy to recruit knowingly or unknowingly  into mule networks. The result is a KYC regime that looks robust on paper but is only as strong as its weakest branch-level implementation, and weak implementation has proved trivially easy for organised networks to locate and exploit at scale.

The Regulatory and Institutional Response

RBI: From Static Compliance to Active Detection

The Reserve Bank of India has moved beyond periodic KYC audits toward technology-driven detection. It has directed banks to tighten onboarding controls, strengthen transaction monitoring, and report suspicious activity more proactively, and it has proposed additional safeguards, including limits on aggregate credits into accounts where a satisfactory business relationship has not yet been established. Its most significant intervention is MuleHunter.ai, an AI and machine-learning system built to flag suspected mule accounts from transaction-behaviour patterns rather than static KYC data alone; the platform is already operational across roughly two dozen banks and is being expanded. The RBI Innovation Hub has also begun working directly with the Indian Cyber Crime Coordination Centre (I4C) to share fraud-risk intelligence and coordinate detection in near real time.

FIU-IND and the PMLA Framework

The Prevention of Money Laundering Act, 2002 (PMLA) is the backbone of India's AML architecture. It mandates KYC verification, Customer Due Diligence, record maintenance, and timely reporting of suspicious transactions to the Financial Intelligence Unit–India (FIU-IND). Banks are required to file Suspicious Transaction Reports (STRs) and Cash Transaction Reports with FIU-IND, which in turn analyses financial intelligence and shares it with law enforcement and regulators. On paper, this creates a feedback loop between banks, the RBI, and enforcement agencies; in practice, the sheer volume of mule-linked transactions are hundreds of thousands of accounts flagged nationally  has strained the capacity of this reporting chain to generate timely, actionable freezes before funds are withdrawn or converted to cryptocurrency.

The IT Act, CERT-In, and Cyber Enforcement

The Information Technology Act, 2000, together with provisions of the Bharatiya Nyaya Sanhita, provides the criminal-law basis for prosecuting mule account operators, aggregators, and the fraudsters who direct them. CERT-In's role sits slightly upstream of the banking layer: it issues advisories on phishing, fake payment gateways, and compromised digital infrastructure that fraud syndicates use to recruit mule account holders and move money. The Ministry of Home Affairs' I4C coordinates the National Cyber Crime Reporting Portal and the 1930 helpline, which allow victims to report fraud and trigger a limited window for freezing beneficiary accounts. I4C has also issued direct public alerts against illegal payment gateways built on mule accounts, warning citizens not to rent or sell their bank credentials to intermediaries.

The Coordination Gap

None of these institutions is short of legal authority. The gap is operational: banks, the RBI, FIU-IND, state police cyber cells, the CBI, and I4C each hold a piece of the picture, but no single agency has a real-time, end-to-end view of an account from opening to fraud to freeze. A mule account can be flagged by one bank's internal monitoring, reported through a completely different victim's complaint in another state, and investigated by a third jurisdiction's cyber police with each step introducing delay. The Indian Banks' Association has publicly pushed for the RBI to be given clearer power to directly freeze accounts flagged as mule accounts, rather than requiring each bank to act unilaterally or wait for a police request, precisely because this fragmentation lets fraudsters withdraw or launder funds within hours of a transaction.

Policy Recommendations

1. Mandatory video-KYC and biometric re-verification for all new accounts opened through business correspondents and third-party agents, with personal liability for verifying bank officials found complicit.

2. A statutory, RBI-backed mechanism allowing banks to freeze accounts flagged by MuleHunter.ai-type systems or FIU-IND intelligence within hours, rather than only after a formal police complaint.

3. A unified, interoperable case database linking the National Cyber Crime Reporting Portal, FIU-IND's STR system, and state cyber cells, so that an account flagged once is visible to every agency instantly.

4. Stronger due-diligence audits of banking correspondents and cooperative banks, which recur disproportionately in mule account cases relative to their share of total accounts.

5. Public financial-literacy campaigns targeted at the economically vulnerable groups most often recruited as unwitting mule account holders, paired with clear legal guidance distinguishing victims from willing participants.

Conclusion

The branch-level mule account cases surfacing across Delhi and other cities are not isolated policing stories; they are a live audit of India's AML and KYC architecture. The RBI, FIU-IND, CERT-In, and law enforcement agencies each have credible tools and legal mandates like MuleHunter.ai, PMLA reporting, IT Act prosecutions, and I4C's coordination portal chief among them but fraud syndicates continue to outpace the system by exploiting the seams between institutions rather than any single point of failure. Closing that gap requires less new law and more operational integration: faster account freezes, verified accountability at the point of account opening, and a shared, real-time picture of mule networks across every agency involved. Until banks, regulators, and investigators can act as one system rather than several disconnected ones, every dismantled racket will simply be replaced by the next.

References

1. https://aninews.in/news/national/general-news/delhi-police-arrests-bank-deputy-manager-in-83776792-crore-mule-account-case-linked-to-159-cyber-fraud-complaints20260610130737/
2. https://the420.in/delhi-bank-manager-mule-account-cyber-fraud-case/
3. https://www.business-standard.com/finance/news/what-are-mule-accounts-cybercrime-banking-layer-india-fraud-rbi-126062400855_1.html
4. https://www.business-standard.com/india-news/centre-freezes-450-000-mule-bank-accounts-used-in-cyber-fraud-schemes-124111200320_1.html
5. https://www.medianama.com/2025/04/223-iba-rbi-cyber-fraud-measures-freeze-bank-accounts-cybercrime/
6. https://www.deccanherald.com/amp/story/india%2Fcentre-warns-of-illegal-payment-gateways-and-mule-accounts-3252723
7. https://www.deccanherald.com/india/over-85-lakh-mule-accounts-in-700-bank-branches-used-by-cyber-criminals-cbi-3604229
8. https://website.rbi.org.in/en/web/rbi/-/notifications/master-direction-know-your-customer-kyc-direction-2016-updated-as-on-may-04-2023-lt-span-gt-11566
9. https://www.indiacode.nic.in/bitstream/123456789/15402/1/moneylaunderingact2002.pdf
10. https://www.indiacode.nic.in/bitstream/123456789/13116/1/it_act_2000_updated.pdf
11. https://www.mha.gov.in/en/division_of_mha/cyber-and-information-security-cis-division/Details-about-Indian-Cybercrime-Coordination-Centre-I4C-Scheme

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Introduction

Cyber slavery has emerged as a serious menace. Offenders target innocent individuals, luring them with false promises of employment, only to capture them and subject them to horrific torture and forced labour. According to reports, hundreds of Indians have been imprisoned in 'Cyber Slavery' in certain Southeast Asian countries. Indians who have travelled to South Asian nations such as Cambodia in the hopes of finding work and establishing themselves have fallen victim to the illusion of internet slavery. According to reports, 30,000 Indians who travelled to this region on tourist visas between 2022 and 2024 did not return. India Today’s coverage demonstrated how survivors of cyber slavery who have somehow escaped and returned to India have talked about the terrifying experiences they had while being coerced into engaging in cyber slavery.

Tricked by a Job Offer, Trapped in Cyber Slavery

India Today aired testimonials of cyber slavery victims who described how they were trapped. One individual shared that he had applied for a well-paying job as an electrician in Cambodia through an agent in Delhi. However, upon arriving in Cambodia, he was offered a job with a Chinese company where he was forced to participate in cyber scam operations and online fraudulent activities.

He revealed that a personal system and mobile phone were provided, and they were compelled to cheat Indian individuals using these devices and commit cyber fraud. They were forced to work 12-hour shifts. After working there for several months, he repeatedly requested his agent to help him escape. In response, the Chinese group violently loaded him into a truck, assaulted him, and left him for dead on the side of the road. Despite this, he managed to survive. He contacted locals and eventually got in touch with his brother in India, and somehow, he managed to return home.

This case highlights how cyber-criminal groups deceive innocent individuals with the false promise of employment and then coerce them into committing cyber fraud against their own country. According to the Ministry of Home Affairs' Indian Cyber Crime Coordination Center (I4C), there has been a significant rise in cybercrimes targeting Indians, with approximately 45% of these cases originating from Southeast Asia.

CyberPeace Recommendations

Cyber slavery has developed as a serious problem, beginning with digital deception and progressing to physical torture and violent actions to commit fraudulent online acts. It is a serious issue that also violates human rights. The government has already taken note of the situation, and the Indian Cyber Crime Coordination Centre (I4C) is taking proactive steps to address it. It is important for netizens to exercise due care and caution, as awareness is the first line of defence. By remaining vigilant, they can oppose and detect the digital deceit of phony job opportunities in foreign nations and the manipulative techniques of scammers. Netizens can protect themselves from significant threats that could harm their lives by staying watchful and double-checking information from reliable sources.

References

1. CyberPeace Highlights Cyber Slavery: A Serious Concern https://www.cyberpeace.org/resources/blogs/cyber-slavery-a-serious-concern
2. https://www.indiatoday.in/india/story/india-today-operation-cyber-slaves-stories-of-golden-triangle-network-of-fake-job-offers-2642498-2024-11-29
3. https://www.indiatoday.in/india/video/cyber-slavery-survivors-narrate-harrowing-accounts-of-torture-2642540-2024-11-29?utm_source=washare

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