360 One Private Equity Fund, Manager and KMP settle case with Sebi for Rs 14.62 lakh

The Securities and Exchange Board of India (Sebi) has settled enforcement proceedings against 360 One Private Equity Fund, its manager 360 One Alternates Asset Management Limited, and key managerial personnel (KMP) Saksham Kohli after they jointly paid a settlement amount of Rs 14.62 lakh.

The case pertained to violations of the Alternative Investment Funds (AIF) Regulations, 2012. Sebi observed that 360 One Private Equity Fund, through its scheme 360 One Seed Ventures Fund 1, had simultaneously accepted investments from other AIFs while also investing in units of AIFs. This breached Regulation 15(1)(da) of the AIF Regulations. The fund manager and Kohli were also held liable for additional violations under Regulations 20(1), 20(5) and clauses of the code of conduct.

The matter came to light in June 2023 when the scheme’s filings disclosed investments of Rs 54.19 crore in AIFs, despite having an AIF investor within the scheme. The non-compliance was later corrected on October 30, 2024, but Sebi initiated an examination and found grounds for enforcement action.

On December 23, 2024, Sebi issued a Notice of Summary Settlement to the Fund, its manager, and Kohli, followed by a Supplementary Notice on March 20, 2025. The regulator offered settlement upon payment of Rs 14.62 lakh jointly and severally, in line with the Sebi (Settlement Proceedings) Regulations, 2018.