sebi:WTM/KV/MIRSD/MIRSD-SEC-1/31521/2025-26

SEBI · SEBI · 2024-11-29 · Kamlesh C. Varshney, Whole Time Member

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Facts / Headnote

Noticee found to have violated most of the provisions alleged in the Enquiry Report; DA's recommendation of regulatory censure rejected as not commensurate with violations; no penalty imposed in this order (adjudication penalty already paid separately)

Provisions invoked

Regulations

Parties

Holding

The WTM held that Rikhav Securities Ltd violated most of the provisions alleged in the Enquiry Report, including stock reconciliation, stock mismatch alerts, monthly/quarterly settlement of funds, margin reporting, client registration, weekly holding statement verification, UCC verification, and cyber security/STQC certification requirements, but did not violate provisions relating to UCC trading, net worth verification, and certain other allegations. The WTM rejected the DA's recommendation to issue a regulatory censure, finding it not commensurate with the violations committed.

Full text

Page 2 of 59 E.3. ALLEGATIONS WITH RESPECT TO MONTHLY/QUARTERLY SETTLEMENT OF FUNDS ............................................................................................................................................. 24 E.4.

Page 3 of 59 A. BACKGROUND 1. The present proceedings have emanated from an Enquiry Report dated November 29, 2024 (hereinafter referred to as the “Enquiry Report”), submitted in terms of regulation 26 of the Securities and Exchange Board of India (Intermediaries) Regulations, 2008 (hereinafter referred to as “Intermediaries Regulations”) with respect to Rikhav Securities Ltd (hereinafter referred to as “Noticee”) who is a stock broker registered with Securities and Exchange Board of India (hereinafter referred to as “SEBI”) since March 14, 2007 having Registration no. INZ000157737.

Page 4 of 59 Sr. No. Alleged violations pertaining to Regulatory provisions violated (i) Stock reconciliation Clause 2.3 of SEBI Circular MRD/DoP/SE/Cir- 11/2008 dated April 17, 2008. (ii) Stock mismatch alerts Sub-clause (j) of clause 6.1.1 and clause 7.1.2 of SEBI Circular SEBI/HO/MIRSD/MIRSD2/CIR/ P/2016/95 dated September 26, 2016. (iii) Monthly/Quarterly settlement of funds Sub-clause (e) of clause 12 of Annexure-A of SEBI Circular SEBI/MIRSD/SE/Cir-19/2009 dated December 03, 2009 read with Clause 8.1 of Annexure of SEBI Circular SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/95 dated September 26, 2016 and Clause no. 5.4. of SEBI circular SEBI/HO/MIRSD/DOP/P/CIR/2021/577 dated June 16, 2021. (iv) Reporting and short collection of Margin SEBI Circular No. CIR/DNPD/7/2011 dated August 10, 2011 read with Clause (iii) of Annexure to SEBI Circular No. SEBI/HO/MRD2/DCAP/ CIR/P/2020/127 dated July 20, 2020. (v) Client registration process SEBI Circular CIR/MIRSD/16/2011 dated August 22, 2011 and SEBI circular CIR/HO/MIRSD/DOP/CIR/P/2019/75 dated June 20, 2019; Sub-clauses (b) and (c) of Clause 13 of Annexure 6 of SEBI Circular CIR/MIRSD/16/2011 dated August 22, 2011 read with SEBI circular CIR/HO/MIRSD/DOP/CIR/P/2019/75 dated June 20, 2019; BSE Circular Notice No. 20210727-6 dated July 27, 2021 read with Sub-clause (5) of Clause A in Schedule II (Code of Conduct for Stock Brokers) of the SEBI (Stock Brokers) Regulations, 1992.

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Source: SecMarx — sebi:WTM/KV/MIRSD/MIRSD-SEC-1/31521/2025-26. 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.