Description

SEBI adjudication order against research analyst Amit Guruh Sachdeva for violations of record maintenance, audit requirements, and code of conduct provisions.

Summary

SEBI has issued an adjudication order against research analyst Amit Guruh Sachdeva (Registration No. INH100005190) following an inspection conducted for the period April 01, 2022 to February 29, 2024. The order addresses multiple violations related to record maintenance, annual audit requirements, and code of conduct provisions under the Research Analysts Regulations.

Key Points

  • Research analyst Amit Guruh Sachdeva (PAN: BIJPS0406C) found in violation of multiple regulatory requirements
  • Inspection period covered April 01, 2022 to February 29, 2024
  • Show Cause Notice issued on October 31, 2024
  • New Adjudicating Officer appointed on May 02, 2025 due to superannuation of previous officer
  • Multiple regulatory violations alleged across record maintenance and conduct standards

Regulatory Changes

No new regulatory changes introduced. This order enforces existing provisions under:

  • Securities and Exchange Board of India (Research Analysts) Regulations, 2014
  • SEBI Circular No. SEBI/HO/IMD/IMD-II CIS/P/2021/0685 dated December 13, 2021
  • SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD-2/P/CIR/2023/52 dated April 06, 2023

Compliance Requirements

Research analysts must maintain:

  • Copy of annual audit reports
  • Research reports duly signed and dated
  • Research recommendations provided to clients
  • Rationale for arriving at research recommendations
  • Client Master records for all clients
  • Compliance with Code of Conduct provisions in Third Schedule of RA Regulations

Important Dates

  • Inspection Period: April 01, 2022 to February 29, 2024
  • Inspection Conducted: March 14-15, 2024
  • Inspection Findings Communicated: June 27, 2024
  • Noticee Response: June 29, 2024
  • Show Cause Notice Issued: October 31, 2024
  • New AO Appointed: May 02, 2025

Impact Assessment

This enforcement action reinforces SEBI’s focus on ensuring research analysts maintain proper records and comply with regulatory standards. The violations primarily relate to administrative and record-keeping requirements rather than market manipulation or client harm, limiting broader market impact. The order serves as a reminder to all research analysts about the importance of maintaining comprehensive documentation and adhering to audit requirements.

Impact Justification

Individual research analyst penalty with limited market-wide impact but important for regulatory compliance standards