1. Freeze the facts
Record the entity, security or product, transaction, decision-maker, counterparty, amount and event date.
Finin2min Summary — in 2 Minutes
Decision: Apply Regulation 4’s prohibition, presumptions and available defences to the facts and decision-maker.
Legal owner and source control
How to apply this control
2. Locate the provision
Open the official consolidated Regulation and identify the exact numbered provision, proviso, explanation and Schedule.
3. Add subordinate implementation
Map the current Master Circular, later circular, exchange/depository specification and filing format without treating them as the Regulation itself.
4. Preserve evidence
Trade records, decision chronology, information-access logs and defence evidence.
Evidence checklist
- Applicable legal version and amendment date.
- Named business and compliance owner.
- Approval, filing, acknowledgement and communication trail.
- Maker-checker, exception and escalation evidence.
- Post-event reconciliation and breach assessment.
Common failure
Avoid: Relying on stated intent when possession and surrounding evidence indicate otherwise.
Finin2min Q&A
Is this page the legal text?
No. It is an implementation guide. Use the official SEBI consolidated Regulation for the exact wording and numbering.
Does a successful exchange or portal filing prove compliance?
No. Acceptance proves a system transaction; it does not cure wrong applicability, approvals, disclosures, timing or evidence.
What should be checked after an amendment?
Effective date, saved actions, forms, policies, system rules, open transactions, board approvals and investor/client communications.