Mirae Asset Venture Opportunity Trust, Manager and Six Officials Pay ₹12.75 Lakh to Settle SEBI Case

Mirae Asset Venture Opportunity Trust, its investment manager Mirae Asset Venture Investments (India) Private Limited, and six key managerial personnel (KMPs) have settled regulatory proceedings initiated by the Securities and Exchange Board of India (SEBI) by paying a consolidated settlement amount of ₹12.75 lakh.

The regulatory action pertained to alleged breaches of portfolio concentration limits applicable to Category-II Alternative Investment Funds (AIFs) under SEBI's regulatory framework.

Key Officials Named in Settlement

The six key managerial personnel who participated in the settlement alongside the trust and the asset management entity are:

• Puneet Kumar
• Shikha Pareek
• Ashish Saini
• Purva Kaurani
• Gaurav Matta
• Arpit Kumar

Nature of the Regulatory Violation

The matter originated from an audit examination of the Private Placement Memorandum (PPM) of the Mirae Asset Late Stage Opportunities Fund—a scheme under the Mirae Asset Venture Opportunity Trust—for the financial year 2023–24, along with written submissions provided by the fund.

During the review, SEBI observed that the investment manager had deployed ₹128.18 crore of the scheme’s capital into a single portfolio entity, Supermarket Grocery Supplies Private Limited.

Under Regulation 15(1)(c) of the SEBI (Alternative Investment Funds) Regulations, 2012, Category-I and Category-II AIFs are statutorily restricted from investing more than 25% of their investable funds into a single investee company. However, regulatory checks revealed the following exposure trajectory:

• Quarter ended March 31, 2023: The investment stood at 25.11% of the scheme's investable funds, marginally above the permissible boundary.
• Quarter ended June 30, 2023: The allocation reached ₹128.18 crore, accounting for 38.35% of the total investable corpus of ₹334.28 crore, significantly overshooting the 25% legal threshold.
• Quarter ended September 30, 2023: The scheme brought the exposure back into compliance, with the holding declining to 24.44% of investable funds.

Consequently, SEBI arrived at a prima facie conclusion that the fund and its manager were non-compliant from January 1, 2023, to September 30, 2023.

Statutory Provisions Invoked

SEBI held that the excess concentration breached Regulation 15(1)(c) of the AIF Regulations and Clause 1(e) of the Code of Conduct under the Fourth Schedule. Additionally, the manager and the six KMPs faced proceedings under Regulation 20(1) read with Clauses 2(a) and 2(c) of the Code of Conduct, which govern managerial diligence, risk oversight, and compliance responsibilities.

Following the issuance of regulatory notices, the entities filed a settlement application under the SEBI (Settlement Proceedings) Regulations, proposing to settle the adjudication proceedings without admitting or denying the findings. The High Powered Advisory Committee (HPAC) recommended the settlement terms upon the remittance of ₹12.75 lakh, which was subsequently approved by SEBI's panel of Whole-Time Members.

Implications for Indian Private Markets

The resolution comes at a time when institutional and high-net-worth capital flowing into Indian private equity and venture capital funds has expanded substantially. SEBI has progressively tightened compliance parameters around alternative assets, including mandatory PPM audits, direct reporting of concentration caps, and accountability of individual fund managers and compliance personnel. The enforcement serves as a clear signal that the regulator is actively auditing asset allocations and enforcing single-borrower or single-company caps to protect investor portfolios from excessive downside concentration.

Tags: Mirae Asset SEBI Alternative Investment Funds Supermarket Grocery Supplies Venture Capital Capital Markets