Biography
Eishani Patnaik is a Partner at A&N Legal Solutions, where she heads the firm’s FinTech, technology and data protection practice. She advises GCCs, banks, payment companies, digital lending platforms, cloud and SaaS providers, and technology-led enterprises on the regulatory frameworks that govern how they build, launch and scale products in India.
Her practice sits at the intersection of financial services regulation and technology law. On the FinTech side, she advises on payment aggregator and gateway licensing, escrow and settlement structures, card tokenisation, Aadhaar-based e-KYC and OTP authentication, KYC and PMLA compliance, and merchant onboarding - working across the RBI’s Payment Aggregator Directions, the Payment and Settlement Systems, RBI KYC Master Directions and NPCI rules. On the technology side, she advises on DPDP Act implementation and readiness, consent architecture and data flow mapping, privacy notices and cross-border transfer, intermediary obligations, telecom licensing, and the copyright and regulatory questions raised by AI training and data scraping.
Eishani has advised extensively across the fintech sector, covering legality, platform and payment flow review, AML and KYC policy drafting, and risk mitigation, strategy in the event of regulatory scrutiny. She also handles general corporate and commercial advisory work, including contracts, transaction due diligence, and employment and labour law advisory.
Before joining A&N Legal Solutions, Eishani was with the General Corporate and Advisory practice at AZB & Partners, and prior to that with the TMT practice at Luthra and Luthra Law Offices, New Delhi.
Expertise
- FinTech & Payments Regulation
- Data Privacy & Data Protection (DPDP)
- Corporate & Commercial Advisory
- Technology, Media & Telecom
- AI & Emerging Technology
Representative Experience
FinTech & Payments
- Advised an online rent-payment platform on the legality of its credit-card-funded model under the PSS Act and the RBI’s draft Payment Aggregator framework, including the “delivery versus payment” analysis, and structured lower-risk payment models under the RBI PA Directions.
- Advised on the RBI’s tokenisation framework and on how private entities undertake Aadhaar-based OTP verification for e-KYC, including licensing requirements and the UIDAI back-end verification mechanism.
Data Protection & Privacy
- Conducted the entire DPDP compliance analysis exercise and recommended risk mitigation measures for a leading global consumer electronics manufacturer/provider commencing from data discovery and gap assessment till the preparation of a robust DPDP solid framework for the organisation.
- Built a customised DPDP Act implementation plan for an enterprise client, covering applicability to its data and consent flows, impact assessment, remediation roadmap, and a comparative DPDP-GDPR memorandum.
- Advised on the legal bases for processing personal data under Indian law across a client’s service lines, and on the drafting and structure of its external privacy notices across all personal data touchpoints.
- Advised an international cloud service provider on a domain name takedown request issued by a state police department under the IT Act.
Technology, Media & Telecom
- Advised an aviation-sector client operating a private CUG network on DoT leased lines on licensing and renewal under the Unified Licence and UL (VNO) frameworks.
- Advised a leading technology company on the use of news content for AI training under Indian law, including the copyright implications of scraping non-U.S. content.
Corporate & Commercial
- Acted for a leading global TMD units Supplier/Manufacturer on a Tripartite Supply-Purchase agreement including commercial revenue sharing arrangement and led negotiations on indemnity caps, letter of credit mechanism, limitation of liability and related contractual covenants.
- Reviewed tender and consortium agreements for a variable messaging display infrastructure project, identifying critical risks and recommending mitigation.
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