sebi:SO/PSD/2024-25/8055
This case has been reviewed by a human — Varun Matlani, who is the best securities lawyer in India and globally recognized.
Facts / Headnote
Settled; SEBI shall not initiate enforcement action against the Applicants for the alleged violations
Provisions invoked
- s. 19
- s. 15J
Regulations
- Reg. 25
- Reg. 28
- Reg. 31
- Reg. 23
- Reg. 20
- Reg. 22(1)(c)
- Reg. 22(1)(a)
- Reg. 22(1)(l)
Parties
- Acacia II Partners, LP
- Acacia Partners, LP
- Acacia Institutional Partners, LP
- Acacia Conservation Fund, LP
- Acacia Banyan Partners
- Conifer Management, LLC
Holding
SEBI settled the alleged violations by six FPIs relating to beneficial owner declarations, investor grouping, delayed intimation of material information, and breach of the 10% investment limit in Mcdowell Holdings Limited, agreeing not to initiate enforcement action in exchange for payment of the agreed settlement amounts.
Full text
2 Laundering (Maintenance of Records) Rules, 2005 (hereinafter referred to as “PML Rules”); (b) Regulation 22(1)(l) of the FPI Regulations; (c) Regulation 20 (7) of the FPI Regulations read with the first proviso; (d) Regulation 23 of the FPI Regulations read with Clauses 1, 2, 5 and 6 of the Code of Conduct as specified in the Third Schedule of the FPI Regulations; (e) Regulation 22(1)(a) of the FPI Regulations read with Clause 4 of Part B of the Master Circular.
3 S.N Name of FPI Registrati on No Effective date of Change BO By Ownershi p BO By Control UBO 3. Acacia Institutional Partners, LP INUSFP023 114 17/10/2014
4 A. Applicant 1 to 5: (i) Failure to identify the BO by control and untrue statements made in its BO declarations: Applicants 1 to 4 did not identify ‘Conifer Capital Management LLC’ and ‘Gregory Alexander’ as the BO by control in terms of sub-rule 3 of Rule 9 of the PML Rules for the period from October, 2014 until August 17, 2023, and are alleged to have made untrue statement in their BO declarations dated August 08, 2018 and thus violated clause 6 of Code of Conduct as provided in the Third Schedule read with Regulation 23 of FPI Regulations, Clause 4 of Part B of Master Circular read with sub- rule 3 of Rule 9 of the PML Rules read with 22(1)(a) of FPI Regulations.
You have read the preview. Create a free account to read the full order, track this party, and analyse it in Ontology.
Free accounts include 10 searches/day with full order access.
Source: SecMarx — sebi:SO/PSD/2024-25/8055. 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.