Online Gaming & AML - Recent Developments

A couple of days back an interesting news article made a headline, that India is pushing FATF to adopt stringent AML norms for Online Gaming Companies. The news report further quoted unnamed sources from Indian authorities stating that they wish to highlight the risks posed by the recent violations by online gaming apps like Mahadev App and is analyzing various options to bring online gaming within the ambit of strict AML KYC Norms and stringent reporting of suspicious transactions to the agencien.

In this article of “Quest to Learn (QTL)”, I try to unpack different aspects of what it means for the Online Gaming Industry (“OGI”) in India.

We are aware that through different industry bodies, the OGI has been making various efforts to get recognised and regulated. The OGI is also struggling with various allegations of tax evasion, uncontrolled expansion, lack of transparency etc. and lastly OGI has also been wary of over-regulation and has expressed that over-regulation may stifle innovation and negatively impact the growth prospects of the otherwise booming industry. 

So before we get into, the “impact” and “how” parts of this discussion let us try and understand a few basic details about FATF and its functions.

The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes policies to protect the global financial system against money laundering and terrorist  financing. Recommendations issued by FATF define criminal justice and regulatory measures that should be implemented by countries to counter the problems of money laundering and terrorist financing. FATF recommendations are recognised as the global anti-money laundering (AML) and counter-terrorist-financing (CTF) standard.

India was admitted as the 34th Country Member of FATF on 25th June 2010. India is also a member of the Asia/Pacific Group on Money Laundering (APG) and the Eurasian Group (EAG), which means that over the years India has consistently been making efforts to strengthen its internal laws, policies and practices against AML and CFT. India has also worked a great deal towards increasing cooperation on information sharing on these issues including taxation with multiple countries by becoming signatory of treaties under Foreign Accounts Tax Compliance Act (FATCA) with the United States of America and Multilateral Competent Authority Agreement (MCAA) on Common Reporting Standard (CRS). 

What all this has meant for the India from a legal and regulatory standpoint is as follows:

1. Amend existing laws to create a framework for:

1. Clear identification of Reporting Entities;

2. Prescribe requirements around

1. KYC Norms

2. Mandatory collection of information and documents; and

3. Reporting of information

2. Form a specialized body which is responsible for

1. Collection of reports from reporting entities

2. Monitor and seek information from entities; and

3. Cooperate with international bodies to fulfill reporting obligations under different treaties.

3. Keep upgrading the reporting entities list based on current global and internal developments.

As a result of all these efforts Financial Intelligence Unit – India (FIU-IND) was set by the Government of India vide O.M. dated 18th November 2004 as the central national agency responsible for receiving, processing, analyzing and disseminating information relating to suspect financial transactions. FIU-IND is also responsible for coordinating and strengthening efforts of national and international intelligence, investigation and enforcement agencies in pursuing the global efforts against money laundering and financing of terrorism. FIU-IND is an independent body reporting directly to the Economic Intelligence Council (EIC) headed by the Finance Minister.

India further introduced a two tear (statutory and regulatory) mechanism to introduce certain provisions under the Prevention of Money Laundering Act, 2002 (PMLA) and the Rules framed under the PMLA. Also, the guidelines prescribed by various sectoral regulators like Reserve Bank of India (RBI), Insurance Regulatory and Development Authority of India (IRDAI), PF Regulatory and Development Authority of India (PFRDA) etc. have prescribed various KYC guidelines for the entities regulated under their aegis.    

The provisions of PMLA introduced the concept of Reporting Entity (RE) and also introduced the requirements for maintaining certain records, monitoring of transactions and reporting of suspicious and cash transactions (as prescribed) by these reporting entities to FIU on a regular basis. The Act also introduced the concept of Principal Officer (PO) and Designated Officer (DO) known as Money Laundering Reporting Officer (MLRO) globally.

Under PMLA, every reporting entity (banking company, financial institution, intermediary or person carrying on designated business and profession) is required to appoint a Principal Officer and a Designated Director and communicate their names, designations and addresses to FIU-IND. The reporting entity is also obligated to client due diligence, maintain record of specified transactions for the prescribed period and furnish report of the prescribed transactions to FIU-IND.

Reporting Entities:

Following entities have been recognised as reporting entities under the PMLA:

1. Banking Companies

2. Nationalized banks  State Bank of India and its Associates

3. Private Indian Banks and Private Foreign Banks 

4. Primary District and State Co-operative Banks  

5. Regional Rural Banks

Financial Institutions

•  Financial I institutions as defined in Section 45-1 of the RBI Act

•  Insurance Companies

•  Hire-Purchase Companies

•  Chit Fund Companies

•  Housing Finance Companies

•  Non-Banking Financial Companies

•  Payment System Operators (Credit Cards)

•  Authorized persons (Money changers)

•  India Post

Intermediaries

• All entities registered under section 12 of the SEBI Act including:

•  Stock Brokers and Sub-brokers

•  Share Transfer Agents and Registrars to issue

• Bankers to an Issue and Merchant Bankers

• Underwriters

• Trustees to Trust Deed

• Portfolio Managers and Investment

• Advisers

• Depositories and Depository Participants

• Custodians of Securities

• Foreign Institutional Investors

• Credit Rating Agencies

• Venture Capital Funds

• Collective Investment Schemes including Mutual Funds

• Intermediaries regulated by Forward Market

• Commission (FMC)

• Intermediaries regulated by Pension Fund Regulatory and Development Authority (PFRDA)

Maintenance of records and furnishing of reports to FIU: 

The following transactions have been specified under the PML Rules for which records have to be maintained and reports are to be furnished to FIU-IND: 

1. All cash transactions of the value of more than rupees 10 lakh or its equivalent in foreign currency. 

2. All series of cash transactions integrally connected to each other which have been individually valued below rupees ten lakhs or its equivalent in foreign currency where such series of transactions have taken place within a month and the monthly aggregate exceeds an amount of ten lakh rupees or its equivalent in foreign currency; 

3. All transactions involving receipts by non - profit organizations of value more than rupees ten lakh, or its equivalent in foreign currency; 

4. All cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine or where any forgery of a valuable security or a document has taken place facilitating the transactions; 

5. All suspicious transactions, whether or not made in cash, including attempted transactions. 

6. All cross border wire transfers of the value of more than five lakh rupees or its equivalent in foreign currency where either the origin or destination of fund is in India; 

7. All purchase and sale by any person of immovable property valued at fifty lakh rupees or more that is registered by the reporting entity. 

Reporting Timelines:

The Suspicious Transaction Report mentioned at para (e) above should be furnished within seven working days on being satisfied that the transaction is suspicious. The information in respect of immovable property transactions referred to in (g) above should be furnished to FIU-IND every quarter by the 15th day of the month succeeding the quarter. All other reports need to be furnished on a monthly basis by the 15th day of the succeeding month. 

Suspicious Transaction: 

Suspicious Transaction means a transaction (including an attempted transaction) whether or not made in cash which, to a person acting in good faith:

1. gives rise to a reasonable ground of suspicion that it may involve the proceeds of crime; or 

2. appears to be made in circumstances of unusual or unjustified complexity; or 

3. appears to have no economic rationale or bona fide purpose; or 

4. gives rise to a reasonable ground of suspicion that it may involve financing of activities relating to terrorism.

Based on the above provisions various sectoral regulators like RBI have prescribed detailed master directions for KYC and the entities falling within these regulators have to put in place the systems for (a) Customer Identification Procedure (CIP) (b) Customer Due Diligence Procedure (CDD) (C) On-going Due Diligence; and (d) Advanced and simplified due diligence. It is important to note that these procedures are prescribed for natural as well as artificial persons independently.

These directions typically need the RE to do the following:

1. Carry out customer identification by:

1. Collect self declared information from the customer [name, age, address, etc]

2. Collect supporting documents for the above info

3. Verify the documents submitted

4. Run checks on the individuals, entities based on various sanction lists and OFAC list

2. Carry out enhanced due diligence on certain specified entities/individuals such as Politically Exposed Persons

3. Monitor transactions carried out by individuals and entities on regular basis and create suspicious transaction reports and cash transaction reports

4. File reports with the FIU and the sectoral regulator

5. Engage and provide additional information as may be required by FIU

While there are other amendments under Income Tax Act, which are introduced under different treaties that we discussed above (FATCA and CRS), but since the focus of those is more on tax evasion related information sharing, I am not discussing those here.

Where does the issue relating to AML/KYC norms for OGI, stand as of today ?

 

Admittedly, the OGI lacks any standard or in fact lacks even a basic level of CIP or CDD implementation. It certainly does not have any statutory requirement to do any KYC, CIP, CDD and thus there isn’t any question of monitoring and reporting of transactions.

In the past 3-4 years, however, the Indian Government (GoI) has made it apparent that it strongly feels the need to bring an appropriate AML/KYC regime for the online gaming industry. Several industry interactions, arguments extended by the counsels in various gaming matters before different High Courts, views expressed in different forums and industry interactions and views expressed by certain Online Gaming Authorities like TNOGA have time and again indicated that Government feels the dire need to bring in AML/KYC Guidelines for the OGI. 

The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 were the first piece of subordinate legislation which introduced the requirement of KYC for users as per RBI prescribed norms.

(12) An online gaming intermediary shall, before accepting any deposit in cash or kind from any user for a permissible online real money game, identify such user and verify his identity: 

Provided that the procedure required to be followed by an entity regulated by the Reserve Bank of India for identification and verification of a customer at the commencement of an account-based relationship shall apply, mutatis mutandis, in identification and verification of the users of such online gaming intermediary.

While these discussions were still on, the public policy enthusiasts, the GoI and the online gaming industry were still debating the larger issue of regulation of the industry as a whole and AML/KYC compliance was just a smaller subset of a much larger bucket of issues involving legality, governance, social impact, taxation etc. 

It however, appears that the GoI has been keenly considering various options to not only bring in the OGI under the strict AML/KYC regime, it also has started discussing the issue at a global level to bring focus on AML risks that the OGI industry poses globally necessitating the need to have international cooperation on standard AML/KYC norms, reporting requirements and sharing of information across jurisdiction. 

This positioning of the GoI seems to have stemmed from certain online betting and money laundering frauds like Mahadev App where law enforcement agencies in the absence of information and data faced various challenges in investigating and bringing culprits to book. 

It however, appears that the GoI in its effort to rein in on illegal businesses like Online Betting and Gambling, is pursuing OGI, which stands differentiated from the illegal betting and gambling operators. 

Does that mean that the OGI has a case for being excluded from the discussions about bringing in AML/KYC norms? 

In my opinion, the OGI may not have a very strong case to be fully excluded from any proposal to bring in stringent AML/KYC compliances for the OGI as a whole including betting and gambling. As per various hearsay the key issues enforcement and investigating agencies have quoted the following issues necessitating the AML/KYC compliances: 

1. Massive scale at which OGI operates (millions of users) 

2. Billions of small transactions increasing the possibility of large hoards of money slipping without being tracked or monitored

3. No user standard identification and diligence protocols increasing the risks of misuse of OGI platforms  

In this scenario, it appears that the GoI will continue to use the examples of Online Betting/Gambling to push the agenda for the entire OGI. It also works well internationally as unlike India, various other jurisdictions do not differentiate OGI and Online Betting/Gambling as two separate classes of businesses.

What does it mean for OGI to be considered and brought under strict KYC requirements?

If the OGI were to be brought under the FATF’s AML/KYC regime globally, then the same may inter alia have following implications:

1. The platforms will have to undergo changes in terms of how a new user is onboarded and how and what information gets collected will have to improve

2. Integration of platforms with third party AML tools for OFAC checks etc will have to be put in place 

3. Appoint PO and DO/MLRO

4. Platforms will have to put monitoring mechanisms in place and start preparing report

5. Start submitting reports to FIU and sectoral regulator (if deputed)

6. Get a CIP and CDD done for existing users in a time bound manner 

 

What is the way forward:

To my mind, so far the OGI has been avoiding any open discussions on this issue. The reasons for this seem to be twofold:

• It fears that these norms will negatively impact the user onboarding and hence the growth of the business will stagnate or be negative.

• It fears extremely high costs of compliances and putting the systems in place.

• For an industry reeling under several tax disputes, this may be a wrong time to have added complication of AML/KYC compliance burden.

• A general resistance to change emanating out of a fear of the unknown.

But to my mind it’s time for the industry to start openly engaging with the GoI on the issue of AML/KYC for OGI and start making suggestions revolving around the following unique key issues:

 

• Risks posed by betting and gambling are different as traceability is the key issue there

• For OGI traceability isn’t an issue as it only allows online transactions which originate from REs

• Average Ticket size for casual, fantasy and similar games is too small to be used as a bridge to launder money

• The flow of money in OGI is through three key steps (1) participation (2) winning (3) disbursal of winning. Since, the ultimate receipt of money is contingent on “winning” its not a sure way to launder money and hence reduces the risk of OGI being used as a bridge to launder.

• Most OGIs have upfront platform fees going as high as 25% and for a typical launderer it may not be a lucrative option

I am sure, enough education and engagement will help clear a lot of doubts for GoI to take appropriate and differentiated actions for different classes of online games. 

The OGI as a whole (all federations) will have to come to a common ground on this issue and have an active engagement on the issue with the GoI. This is the only way forward. Avoiding the discussion will result in GoI moving forward with its agenda at FATF and the same may not yield good results and will be even more difficult to reverse once implemented at FATF level.

I will be happy to engage in discussions with anyone interested in the subject. Do write into me on amol.apte@lawknit.co for any queries, suggestions, feedback on the note and/or this important subject as a whole.

Amol Apte  

26.09.2024

Deepfake- Are Indian laws prepared to handle the challenge?

With the advent of Artificial intelligence, Machine Learning, Deep Learning and such other technologies, the world, in the last couple of years, has been witnessing a rapid growth in products and services which are making human lives simpler by the day. But at the same time, the rampant growth of these technologies has created a sense of fear in several intellectuals who think that misuse of these technologies can be really harmful/dangerous for mankind and the effects of the same can be devastating and in some cases even irreversible.     

Since the last month or so, the issue of DeepFake in India has taken a front seat in most of the newshour debates. We have seen news items relating to some of the prominent Hindi movie celebrities expressing their displeasure and fear over how Deepfake was used to show them in bad light on the social media platforms like Instagram and Facebook. We even heard the Hon’ble Prime Minister of India giving an example (in the lighter vein) of how Deepfake was used to create a video of him playing garba during the Navratri festivities and then expressing his concerns over the dangers of how misuse of this technology can create havoc in the society. The Hon’ble Prime Minister also expressed the need for creating an appropriate framework around the subject of Deepfakes, to make sure its orderly use for subjects relevant and important for humanity and not for some illegal objectives.

There have further been news about the Central Government and the Ministry of Information Technology notifying the social media platforms like Instagram and Facebook to make sure they duly comply with the extant provisions of the Information Technology Act, 2000, (IT Act) Rules framed thereunder and the Intermediary Guidelines, applicable to the platforms. 

There are also talks and news in addition to public statements made by Hon’ble ministers and officials about the work that's underway to bring Digital India Act, which will presumably be an all encompassing Act dealing with everything digital in India.

While all this is under works, the use and/or misuse of the technology has already started gaining momentum and till such time we have a comprehensive piece of legislation we will have to look at what do we already have and how we can make good use of the existing legislations to make sure that the misuse of technology does not go undetected and unabated.       

In this article we will try and understand what does Deepfake means, what are its potential dangers and how capable the existing Indian legal and regulatory system [focus being the Information Technology Act, 2000 and the Intermediary Guidelines issued under the same] is to deal with the down sides that the misuse of technology may bring along. 

Let us first try and understand what this term Deepfake really means. As is evident from the term, it is made up of two words “Deep” and “Fake”. The word “Deep” is derived from the term “Deep Learning” which in layman terms refers to a method in Artificial Intelligence (AI), which basically teaches computers to process certain data. It is interesting to note that these methods of data processing are inspired by how a human brain would ordinarily process the data. As per an article by Betül Çolak on Institute for Internet and Just Society: 

“there are three essential techniques to create Deepfake contents: face swap, expression swap, Generative Adversarial Networks (“GAN”). Regardless of which technique is used, the process  has generally the same steps that are extraction, training and creation. Also, there is no need for massive data sets anymore. Today, even one single photo of a source is enough to create deepfake contents.”

It is assumed that the term deepfake was coined sometime in the year 2018 by a Reditt user who apparently created a dedicated forum on the platform for using deep learning and machine techniques to swap female celebrity stars faces on the pornographic content.

Since then the technology has only evolved with time. There are several off-the-shelf Apps available, which can be used to take images from the social media platforms or any other public platforms and swap the faces with faces that the user may want to use for creating deepfakes. 

In April 2023, Kyland Young, a star from the popular reality TV show Big Brother, brought a right of publicity claim against NeoCortext, Inc., the developer of a deepfake software called Reface. See Young v. NeoCortext, Inc., 2:23-cv-02486 (C.D.CA filed Apr. 3, 2023). Young claimed that NeoCortext’s Reface, “which uses an artificial intelligence algorithm to allow users to swap faces with actors, musicians, athletes, celebrities, and/or other well-known individuals in images and videos,” violates California’s right of publicity law. Young’s case, which is still pending in the U.S. District Court for the Central District of California, raises important questions about deepfakes and their intersection with the law as it pertains to famous figures.

While there are several intellectual property rights related issues such as personality rights, right to publicity and copyright, there are some more critical issues surrounding the subject such as human rights issues, privacy issues, political issues and data protection issues etc. WIPO in its Draft issues paper on intellectual property policy and artificial intelligence has recognised this issue that deepfake is more of privacy, human rights and data issue than a copyright issue, but, at the same time it has suggested that when it comes to copyright the same should belong to the inventor of the deepfake technology.

Recently in India too, we have seen a couple of controversies involving deepfake technology. One of which was around an issue where a popular actor’s image was used to be superimposed onto the face of an Indian origin British social media influencer. Within a few days of this incident, we saw Hon’ble Prime Minister of India speaking in a public forum about deepfake being used to create his fake videos. Subsequent to this the Ministry of Information Technology and Electronics ordered the social media platforms, especially the ones falling within the category of “Significant Social Media intermediary” to take down the deepfake content from their website within 36 hours of it being reported to be deepfake. It also directed the platforms to make sure they comply with all the provisions of the IT Act and the Intermediary Guidelines framed thereunder.  

With the above background, in my opinion there are following 5 critical issues that emerge from the rampant use of the deepfake technology:

1. Impersonation Cheating, forgery etc. by use of fake images/videos: There have been news about how technology has been used to place calls on unsuspecting people with the deepfake voice or video call, impersonating one of their close family members and luring/forcing them into paying money to the fraudsters. 

2. Personality rights violation: [moral rights as well as copyrights]

Creating videos, voice clips or images using two different people’s images and videos etc. without taking approvals from either the person whose image/video is used or from the person who owns the rights in the images/videos used.  

3. Obscenity and Pornography connected with impersonation:

The matter relating to Hindi film industry actresses, mentioned hereinabove may be an example of this category where the faces/persona of popular artists are superimposed to create obscene and/or pornographic content and circulated on the internet. 

4. Hate speech, misinformation, fake news, interference in national matters:

We are already seeing a flood of fake social media clips and videos showing certain political figures in certain situations and or making statements which they in reality have not been into or spoken about. This is probably one of the most dangerous misuse of the technology as it may create internal unrest, interfere with political situations or electoral processes etc. 

5. Criminal Defamation:

One of the offshoots of all the above could be defaming someone with a criminal intent and damaging goodwill of a person in public. There are high chances that people may form an opinion about a certain person, which is based purely on fake content that they have heard or seen on social media or any other technological platforms and that may damage the reputation or goodwill of the person irreparably. 

The above being the risks, the next question that comes to our mind is whether the IT Act, 2000 and the Rules made thereunder are adequate to handle these matters? If yes then what are the relevant provisions that may come handy for the Law Enforcement Agencies (LEA).

If we carefully look at the provisions of Section 66A-66E of the Information Technology (Amendment) Act, 2008, the provisions therein deal with the following issues in a nutshell:

S. No.	Section	Brief Content	Remarks
1	66 A	Electronic transmission of information which is offensive, false, causing annoyance or inconvenience	Can come handy while dealing with issues relating to fake news, defamation, deepfake creating false narratives
2	66 B	Dishonestly receiving or retaining a stolen computer resource or communication device	Since the term resource includes software construct, fake images or images/videos obtained without consent may attract this provision
3	66 C	Fraudulent use of electronic signature or unique identity feature of any person	While primarily this deals with misuse of e-signature, the rationale can be extended to personality/persona because the section also applies with respect to unique identity feature
4	66 D	Cheating by personation using computer resource or communication device	Deepfake is all about impersonation or creating images and videos using two or more personas.
5	66 E	Publishing image of a private area of a person without consent [Private Are- refers to human body parts]	Pornography, obscene content under deepfake will attract this subsection.
6	66 F	Threatening unity and integrity of India	Fake news, creating political deepfake content with an intent to disrupt peace and harmony or disturbing the electoral process may attract this subsection.
7	67	Electronic publishing of lascivious content	All three sections deal with publication of obscene, pornographic and child pornography content.
8	67A	Publication of sexually explicit content
9	67B	Publication of child pornography

All the above provisions prescribe imprisonment of up to 7 years and/or penalty of upto 10 lakh rupees and should be able to effectively handle the offences related and connected to deepfakes as mentioned in the article above. 

The provisions of Section 79 of the Information Technology Act, 2000 carve out an exception for the intermediaries and exempts them (subject to conditions prescribed) from applicability of these sections with respect to any third party material uploaded on their platform. 

Recently, The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 have prescribed stricter norms for the intermediaries in terms of due diligence to be carried out by them on the users, the content, the IT Security, data protection, Data deletion requests, grievance redressal measures, communication of policies, procedures and rules to the users and such other measures required to bring in higher level of responsibility and accountability for the platforms/intermediaries.

With all these measures already in place, it would appear that there should be no difficulty for the LEAs to deal with the instances of deepfakes. However, in the modern day and time of borderless commerce and platforms, a lot of times LEAs struggle to gather relevant information, material, and evidence to bring home the charges under relevant provisions of the IT Act. 

Recently in the matter relating to the deepfake of an actor the news reports suggested that the platforms have not been very forthcoming in providing the relevant information to the LEAs and that had hindered the pace of investigation. it was then that the central government through the ministry of Information and Technology issued advisory and then a warning to the social media platforms to ensure due compliance with the relevant provisions of the Intermediary Guidelines.

Considering all the above, it seems that our laws are adequately equipped effectively combat the ill effects of deepfake and such other technology misuse, however the following measures will have to be taken at different levels by different stakeholders to make sure that the rule of law is adhered to and implemented:

1. User education and awareness is the first step towards a safer internet and, therefore, platforms, government, consumer groups etc need to ramp up the programs that educate the common users and make them aware of these issues and ways to better tackle them.

2. LEA training and education is also a must. The agencies who have to enforce these provisions have to be up to date with the developments in technologies, so that they are adequately equipped to handle these modern challenges. 

3. Effective grievance handling at platforms’ level is the need of the hour. Platforms need to be proactive in categorising user grievances in different categories from moderate to severe to grave and then addressing them on priority and the category each one of them belong to. 

4. While the Intermediary Guidelines, 2021 did prescribe stricter norms for platforms, there still is scope for the implementation to be stricter;

5. Since the lines between publishers and intermediaries are blurring by the day, carve outs for platforms need to be based on clear, objective and evidence based demonstration of facts by the platforms who wish to take shelter of these carve outs.

6. With the government announcing the Digital India Act to be the single piece of legislation dealing with all things digital, we can expect some stronger, more effective tools to deal with more modern challenges at hand.  

References

Dcruze, D. C. (2023, November 17). 'I saw a video in which I was doing garba': PM Modi addresses threat of deepfakes in India. Business Today. https://www.businesstoday.in/technology/news/story/i-saw-a-video-in-which-i-was-doing-garba-pm-modi-addresses-threat-of-deepfakes-in-india-406089-2023-11-17

Govt issues advisory to platforms on countering deepfakes. (2023, November 7). Mint. https://www.livemint.com/news/deepfakes-major-violation-of-it-law-harm-women-in-particular-rajeev-chandrasekhar-11699358904728.html

Legal Issues of Deepfakes, B. C. (2021, January 19). Institute for Internet and the Just Society. Institute for Internet and the Just Society. Retrieved December 16, 2023, from https://www.internetjustsociety.org/legal-issues-of-deepfakes

Penning, N. (2023, July 25). The Legal Issues Surrounding Deepfakes: Law Firm, Attorneys, Lawyers - Honigman. Honigman LLP. Retrieved December 16, 2023, from https://www.honigman.com/the-matrix/the-legal-issues-surrounding-deepfakes

Sinha, S. (2023, November 24). Meta not cooperating in Rashmika Mandhana deepfake probe: Delhi Police sources. India Today. https://www.indiatoday.in/india/story/rashmika-mandhana-deepfake-video-delhi-police-investigation-facebook-meta-2467137-2023-11-24

THE STATE OF DEEPFAKES. (2019, October 8). THE STATE OF DEEPFAKES. Retrieved December 16, 2023, from https://regmedia.co.uk/2019/10/08/deepfake_report.pdf

WIPO Secretariat. (2023, October 30). Draft issues paper on intellectual property policy and artificial intelligence. WIPO.in. Retrieved December 16, 2023, from https://www.wipo.int/export/sites/www/about-ip/en/artificial_intelligence/call_for_comments/pdf/ind_lacasa.pdf