360 One Private Equity Fund, Fund Manager and KMP Pay Rs14.62 Lakh to Settle Case with SEBI
Moneylife Digital Team 29 August 2025
360 One Private Equity Fund, its manager, 360 One Alternates Asset Management Ltd and key managerial personnel (KMP) Saksham Kohli have settled enforcement proceedings with market regulator Securities and Exchange Board of India (SEBI) after jointly paying a settlement amount of Rs 14.62 lakh.
 
The case stemmed from SEBI examination of investments in 360 One Seed Ventures Fund 1, during which it was observed that the Fund had accepted investments from other alternative investment funds (AIFs) while also investing in units of AIFs itself. 
 
This dual position amounted to a violation of Regulation 15(1)(da) of the SEBI AIF Regulations, 2012. Further lapses were noted against the Fund’s manager and KMP under Regulations 15(1)(da), 20(1), and 20(5) read with the code of conduct.
 
According to SEBI’s findings, the scheme reported in its June 2023 filings that it had invested Rs54.19 crore in AIFs while simultaneously having an AIF as an investor in the same scheme. Although the non-compliance was rectified on 30 October 2024, SEBI proceeded to issue a notice of summary settlement in December 2024, followed by a supplementary notice in March 2025, highlighting the violations.
 
Under the SEBI Settlement Proceedings Regulations, 2018, the Fund, its manager and KMP offered to settle the matter by applying for a settlement order and remitting the proposed settlement amount. The applicants accepted the offer and jointly paid Rs14.62 lakh within the stipulated timeline.
 
The applicants opted for settlement and remitted the required amount. SEBI confirmed receipt and, through its order dated 28 August 2025, concluded the matter.
 
As per the order, SEBI will not pursue enforcement action for the violations already covered under the settlement. However, the regulator has retained the right to reopen proceedings if it finds that the applicants made untrue representations, violated settlement undertakings, or if discrepancies emerge in the settlement terms.
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