Author: Archana Balasubramanian Foreign Portfolio Investors (FPIs) appear to be sending mixed signals to Indian markets: while secondary market withdrawals crossed INR 25,000 crore recently, anchor investment in IPOs has risen sharply, with over INR 26,000 crore deployed in recent months. This apparent contradiction reveals a sophisticated investment strategy that transcends simple market sentiment. FPIs... Continue Reading →
Long-Lag Compliance and Diligence: A Conversation with Archana Balasubramanian
BACKGROUND Recently the Enforcement Directorate (ED) has issued show-cause notices totalling INR 1,654 crore to Myntra Designs Pvt Ltd and its affiliate Vector E-Commerce Pvt Ltd. The investigation focuses on structuring decisions dating back to 2010, when the company, then an early-stage, foreign-funded online apparel platform, created multiple group entities so that a marketplace front-end... Continue Reading →
What the Myntra ED Probe Says About Long-Lag Regulatory Investigations
BY NITIN JAIN It's not often that a regulatory case opens a 10+ year window into past compliance decisions. But that's what the Enforcement Directorate's INR 1,654 crore FEMA case against Myntra is doing. The alleged violations (from 2010–2015) involve multi-brand retail structuring using affiliate sellers. The ED claims that Vector E-Commerce, an entity related... Continue Reading →
How MoA Language Affects Investor Due Diligence
By Archana Balasubramanian A mid-growth SaaS company, fresh off their first term sheet for a ₹40 crore infusion, found themselves in a surprising delay. Everything was aligned: due diligence done, traction numbers strong, founder chemistry perfect. Then the investor’s compliance team flagged one line in the Memorandum of Association (MOA). The company, focused on AI-led... Continue Reading →
Regulatory ‘Gotchas’ in Cross-Border SaaS Billing Models
By Archana Balasubramanian Software-as-a-Service (SaaS) companies in India that serve global clients often assume their billing models are “just tech contracts”. But once money starts crossing borders, the rules shift and so does regulatory exposure. What looks like a seamless Stripe or Razorpay integration can raise red flags across the Reserve Bank of India (RBI),... Continue Reading →
Catching The CSCRF Wave- A Compliance Imperative For Merchant Bankers
Introduction As key players in the Indian capital markets, Merchant Bankers perform essential functions like issue management, underwriting, portfolio management, and loan syndication. Their work as intermediaries give them privileged access to immensely valuable and sensitive information of varied entities. Given their access to sensitive data including personal and financial information, merchant bankers carry an... Continue Reading →

