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Markets Securities & Exchange Board

SEBI finds ₹125.92 crore shortfall in Modex International Securities Ltd

This is a final order by SEBI regarding Modex International Securities Ltd, a registered stock broker, concerning allegations of misappropriation of client funds and securities, falsification of records, and other regulatory violations.

125.92 CroreThe total shortfall identified by the forensic audit was Rs. 125.92 Crore.

Who it concerns: Modex International Securities Ltd (SEBI Registration No. INZ000211434); Mr. Pawan Kumar Sachdeva (Director/Authorized Representative); Mr. Dharmendra Kumar Arora (former key decision-maker, deceased).

What SEBI found or ordered

  • SEBI found that the company misappropriated client funds and securities, resulting in a shortfall of Rs. 125.92 Crore.
  • SEBI found that the company falsified the Register of Securities of clients and misrepresented its books and accounts.
  • SEBI found that the company made improper periodic payments to clients and engaged in business activities other than stock broking.
  • The Designated Authority recommended cancelling the company's registration as a Stock Broker.
  • A forensic audit conducted by KPMG (appointed by NSE) revealed the misappropriation and shortfalls.
  • The company did not reply to the initial pre-enquiry show cause notice, leading to ex-parte proceedings at that stage.
  • The company was represented in later hearings by Mr. Pawan Kumar Sachdeva, who stated the company is not in operation.

Also in the document

  • The total shortfall identified by the forensic audit was Rs. 125.92 Crore.
  • The company claimed a 'system error' caused the mixing of client ledger balances and unauthorized sales, but SEBI's findings indicate falsification and misappropriation.
  • The company is currently under Corporate Insolvency Resolution Process (CIRP) proceedings, though NCLT set aside an earlier admission order due to lack of jurisdiction over financial service providers.
  • The company claimed to have approximately 13,000 clients in the capital markets segment and 9,720 in the F&O segment.

How this was written

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The original document

Securities & Exchange Board of India (SEBI) — enforcement orders

Regulatory order · 11 Sep 2026

Order 11 Sep 2026 · 0.9 MB Open the document On sebi.gov.in ↗
Read it here

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