sebi:QJA/MN/IMD/IMD-SEC-4/32418/2026-27
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Provisions invoked
- s. 11B
- s. 11
- s. 15H
- s. 15J
- s. 15F
Regulations
- Reg. 2(1)(c)
- Reg. 4(2)
- Reg. 200
- Reg. 21
- Reg. 4(2)(k)
- Reg. 202
- Reg. 4(2)(s)
- Reg. 24(10)
- Reg. 22(10)
Parties
- First Global Finance Private Limited (Portfolio Manager)
Holding
On Issue A, the order finds that FGF invested client funds based on advice of another entity by including Mr. Achin Agarwal of Algo One as a decision-making member of its Investment Committee that approved the Model Portfolio, and that basket-file generation involved investment-related discretion, in violation of the outsourcing prohibition.
Full text
Order in the matter of inspection of First Global Finance Private Limited (Portfolio Manager) Page 2 of 88 2. Considering the seriousness and complexity of the observations, SEBI approved a forensic inspection, and Chokshi and Chokshi LLP (hereinafter referred to as “Chokshi / Auditor”) was appointed as forensic auditor vide letter dated January 30, 2024. Chokshi submitted the Forensic Audit Report (hereinafter referred to as “FAR”) on August 21, 2024. The period of the said inspection was April 01, 2021 to December 31, 2023 (hereinafter referred to as “Inspection Period”/ “IP”).
Order in the matter of inspection of First Global Finance Private Limited (Portfolio Manager) Page 3 of 88 Show Cause Notice:
Order in the matter of inspection of First Global Finance Private Limited (Portfolio Manager) Page 4 of 88 Replies: 6. The submissions of the Noticees made vide replies dated March 13, 2026, April 15, 2026 and May 06, 2026 are summarized as below:
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Source: SecMarx — sebi:QJA/MN/IMD/IMD-SEC-4/32418/2026-27. 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.