SEBI settles case with 360 One PE Fund, manager for ₹14.6 lakh

India’s market regulator has settled proceedings with 360 One Private Equity Fund, its manager 360 One Alternates Asset Management, and key managerial personnel Saksham Kohli after they jointly paid ₹14.62 lakh, according to a Securities and Exchange Board of India (SEBI) order on Thursday.The case pertained to violations of the Alternative Investment Funds (AIF) Regulations, 2012. AIFs are privately pooled investment vehicles that collect funds from investors, whether Indian or foreign, to invest in accordance with a defined policy. SEBI found that 360 One Private Equity Fund, through its scheme 360 One Seed Ventures Fund 1, had simultaneously accepted investments from other AIFs while also deploying capital into units of AIFs.

SEBI stated that the fund had “accepted investments from Alternative Investment Funds (AIFs), while at the same time having invested in units of other AIFs, thereby resulting in violation of 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 provisions of the code of conduct.The issue surfaced in June 2023 when the scheme’s filings showed investments of ₹54.19 crore in AIFs, despite having an AIF investor within the scheme. Although the non-compliance was corrected by October 30, 2024, SEBI’s review flagged grounds for enforcement.

On December 23, 2024, the regulator issued a Notice of Summary Settlement to the fund, its manager and Kohli, followed by a Supplementary Notice in March 2025. A settlement was offered against a joint payment of ₹14.62 lakh under the SEBI (Settlement Proceedings) Regulations, 2018.

“In terms of Regulation 23 of the Settlement Regulations, it is hereby ordered that the specified proceedings in respect of which the Notice and Supplementary Notice was issued are hereby settled in respect of the Applicants,” the order said.

SEBI said it will not take further action against the applicants for these violations, but noted the settlement does not prevent it from acting later if any statements turn out to be false or if the settlement conditions are breached.