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Showing posts from April, 2025

Analysis of RBI’s Master Direction on Compounding of Contraventions under FEMA, 1999 (April 22, 2025)

 Analysis of RBI’s Master Direction on Compounding of Contraventions under FEMA, 1999 (April 22, 2025)       1. Overview   The Reserve Bank of India (RBI) issued Master Direction No. 04/2025-26 on April 22, 2025, consolidating and updating the framework for compounding contraventions under the Foreign Exchange Management Act (FEMA), 1999. This replaces the earlier Foreign Exchange (Compounding Proceedings) Rules, 2000, with the new Compounding Rules, 2024, notified by the Government of India on September 12, 2024.       2. Key Amendments and Updates       A. Structural Changes   - Consolidation of Rules: The Master Direction integrates all prior circulars and notifications, including:     - A.P. (DIR Series) Circular No. 17 (October 1, 2024)     - A.P. (DIR Series) Circular No. 02 (April 22, 2025) (which deleted the 50% penalty enhancement clause for rep...

Relaxation in Filing of Changes in PPM Through Merchant Banker

Subject: Detailed Note on SEBI Circular Dated April 29, 2024 – Relaxation in Filing of Changes in PPM Through Merchant Banker Dear All, As you are aware, the Financial Year 2024–25 has concluded. In accordance with the SEBI (Alternative Investment Funds) Regulations, 2012, Alternative Investment Funds (AIFs) are required to file changes in the Private Placement Memorandum (PPM) with SEBI. As per paragraph 2.5.3 of the SEBI Master Circular (SEBI/HO/AFD/PoD1/P/CIR/2023/130) dated July 31, 2023, any change in the terms of the PPM must be intimated to SEBI through a Merchant Banker, along with a due diligence certificate in the prescribed format. However, SEBI has now issued a new circular (SEBI/HO/AFD/PoD/CIR/2024/028) dated April 29, 2024 , to ease compliance and reduce the regulatory burden on AIFs. This circular brings the following relaxations , effective immediately: Key Highlights of the SEBI Circular: Direct Filing Allowed for Certain Changes: SEBI has identified specifi...