SEBI alleges 6,782 missing PANs in research analyst's client records

This order details SEBI's adjudication proceedings against registered Research Analyst Vineet Ashwinikumar Chawla for alleged violations of SEBI regulations regarding client records, trading restrictions, disclosures, and compliance with KYC and advertisement codes during the period of April 2024 to November 2025.

Who it concerns: Vineet Ashwinikumar Chawla (PAN: AYRPC6869L, SEBI Registration No.: INH000008190)

What SEBI found or ordered

• SEBI alleged violations of 8 specific regulatory provisions, including incomplete client records (missing PANs for 6,782 out of 7,909 entries), trading in recommended securities during restricted periods, and failure to disclose material information in research reports.
• SEBI alleged non-compliance with KYC requirements, including failure to register with a KYC Registration Agency (KRA) and Central KYC Registry (CKYC), and failure to incorporate Most Important Terms and Conditions (MITC) in client agreements.
• SEBI alleged failure to maintain a grievance register, failure to register with the Financial Intelligence Unit (FIU) as a Principal Officer, and non-compliance with advertisement codes including lack of prior exchange approval.
• The Noticee responded that direct B2C operations were discontinued in March 2025, shifting to aggregator platforms, and that historical data was inaccessible due to website discontinuation but records for FY 2025-26 are maintained.
• The Noticee acknowledged trading in 100 shares during restricted periods but claimed no undue benefit was intended, and accepted that advertisement records were not maintained for FY 2024-25.

Also in the document

• The inspection period covered April 1, 2024, to November 30, 2025.
• The Noticee claimed that the figure of 7,909 represented transaction entries rather than unique clients.
• The Noticee stated that FIU registration was completed as a corrective measure after the inspection began.