SEBI issues final order against First Global Finance over alleged outsourcing of investment decisions

This is a final order by SEBI regarding an inspection of First Global Finance Private Limited (a Portfolio Manager) and two individuals, examining allegations that the firm outsourced core investment decisions to a third party and made misleading performance claims.

Who it concerns: First Global Finance Private Limited, Ms. Devina Mehra, Mr. Neeraj Khanna

What SEBI found or ordered

• SEBI conducted an on-site inspection from December 5 to 9, 2022, and a forensic audit covering the period from April 1, 2021, to December 31, 2023.
• SEBI found that First Global Finance Private Limited (FGF) allegedly outsourced core portfolio management activities to Algo One AI Private Limited and invested client funds based on advice from Algo One personnel, specifically Mr. Achin Agarwal.
• SEBI found that FGF disseminated misleading and exaggerated marketing claims and used inconsistent methodologies for performance disclosures.
• The order cites violations of Regulation 24(10) of the SEBI (Portfolio Managers) Regulations, 2020, and the SEBI Master Circular for Portfolio Managers.
• A Show Cause Notice was issued on January 28, 2026, proposing directions to cease outsourcing, remove misleading advertisements, and restrict accepting new business.
• The noticees filed replies on March 13, 2026, April 15, 2026, and May 6, 2026, and appeared for a personal hearing on April 16, 2026.

Also in the document

• The order is a Final Order, indicating the conclusion of the inquiry process described in the text.
• The inspection period covered approximately two and a half years (April 2021 to December 2023).
• The noticees argued that their relationship with Algo One was limited to technology consulting and that investment decisions remained with FGF's internal Investment Committee.