sebi:SO/AN/EFD2/2023-24/6960
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Facts / Headnote
Settled
Provisions invoked
- s. 19
- s. 15J
Regulations
- Reg. 25
- Reg. 28
- Reg. 23
- Reg. 24(a)
- Reg. 18(a)
- Reg. 18
Parties
- Rajgopalan Santhanam
- M S Sundararajan
- Unifi Capital Private Limited
- Sarath Chandra Reddy Kakani
- Sandeep Nadigadda Reddy
- Krishnamurthy Narendranath
- Govindasamy Maran
- Christopher Vinod
Holding
Any proceedings that may be initiated against the Applicant for the violations of Regulations 18(a), 18(c) and 24(a) of the AIF Regulations read with SEBI Circular CIR/OIAE/1/2014 are settled on joint and several payment of Rs. 49,40,000, with no enforcement action subject to Regulation 28.
Full text
Page 2 of 5 investee companies or derivatives or complex or structured products. However, as per the investment conditions contained in Regulation 18(a) of the AIF Regulations, an AIF is not allowed to invest in mutual funds categorized as Large Capital Funds. Hence, the Applicant sought to settle the violation under Regulation 18(a) of the AIF Regulations.
Page 3 of 5 Sr. No. Name PAN 1. Rajgopalan Santhanam AHDPS1429F 2. M S Sundararajan AAFPM4934N 3. Unifi Capital Private Limited AAACU5196J
Page 4 of 5 April 12, 2023. The Applicant and the aforesaid 8 entities informed about the remittance of the aforesaid settlement amount on April 20, 2023 and SEBI has confirmed credit of the same. Further the Applicant and the aforesaid 8 entities, vide email dated May 18, 2023 confirmed that the settlement amount was not paid out of investor funds and vide letter dated June 02, 2023 have undertaken and declared that the “officers-in-default” shall collectively bear the settlement amount. Subsequently, it was observed that certain parameters ought to have been applied that should have resulted in a settlement amount of Rs. 49,40,000/- instead of Rs. 38,00,000/- in terms of the Settlement Regulations. Accordingly, the Applicant and the aforesaid 8 entities were informed of the same and a Notice of Demand for the remaining amount of Rs. 11,40,000/- was issued to the Applicant and the aforesaid 8 entities vide email dated October 20, 2023. Thereafter, the Applicant and the aforesaid 8 entities remitted the differential amount on November 08, 2023 and informed SEBI of the same. SEBI has confirmed credit of the same.
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Source: SecMarx — sebi:SO/AN/EFD2/2023-24/6960. 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.