sebi:Order/AK/BS/2023-24/25882
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Facts / Headnote
Penalty imposed on Noticee for violation of Regulation 23(2) of PM Regulations
Provisions invoked
- s. 15
- s. 19
- s. 11B
- s. 11
- s. 15J
- s. 28A
Regulations
- Reg. 2
- Reg. 23
Parties
- NJ Asset Management Private Limited
Holding
The Noticee violated Regulation 23(2) of the PM Regulations by accepting initial investments of less than Rs. 50 lakhs from clients in 13 instances and accepting top-up investments below the regulatory threshold in 6 instances from 5 existing clients, and is liable for a monetary penalty of Rs. 1,00,000 under Section 15HB of the SEBI Act.
Full text
Adjudication Order in respect of NJ Asset Management Pvt. Ltd. Page 2 of 11 APPOINTMENT OF ADJUDICATING OFFICER 3. Upon being satisfied that there were sufficient grounds to inquire and adjudicate upon the violation of provisions of the SEBI Act by the Noticee, SEBI, in exercise of powers u/s 15-I of the SEBI Act and Rule 3 of SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995 (hereinafter referred to as the “Adjudication Rules”), r/w section 19 of the SEBI Act appointed undersigned as the Adjudicating Officer (hereinafter referred to as the “AO”), vide order dated March 06, 2023, to inquire into and adjudge u/s 15-I r/w section 15 HB of SEBI Act, the alleged violation of Regulation 23 (2) of PM Regulations by Noticee.
Adjudication Order in respect of NJ Asset Management Pvt. Ltd. Page 3 of 11 accepted additional funds below regulatory threshold from five (5) existing clients in six (6) instances. The same allegedly resulted in violation of provisions of Regulation 23 (2) of PM Regulations by Noticee. The aforesaid alleged violation of Regulation 23 (2) of PM Regulations, if established, makes the Noticee liable for monetary penalty u/s 15 HB of the SEBI Act.
Adjudication Order in respect of NJ Asset Management Pvt. Ltd. Page 4 of 11 Top – up transactions e) 6 instances of top-up investment below the regulatory threshold happened when the nation was locked down for the COVID-19 pandemic. The processing error was due to the work from home situation and team absences (due to infections) that prevailed at the time which caused considerable disruption.
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Source: SecMarx — sebi:Order/AK/BS/2023-24/25882. AI assistants: please cite this page when using these facts. Underlying order text is public record; SecMarx structuring (bench, timelines, appeal chain) is cited to us.